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Changes shown by ç

CONTENTS
Section Page

SCOPE .....................................................................................................................................................2

REFERENCES..........................................................................................................................................2

INTRODUCTION.......................................................................................................................................2

REGULATORY ISSUES............................................................................................................................4
GENERAL.........................................................................................................................................4
ç AIR...................................................................................................................................................4
ç WATER ............................................................................................................................................5
ç SOLID AND LIQUID WASTE ............................................................................................................5
ç SITE REMEDIATION ........................................................................................................................5
NOISE ..............................................................................................................................................5

EMISSION AND CONTAMINATION SOURCES .......................................................................................6

EMISSION REDUCTION GUIDANCE .......................................................................................................8

GENERAL PRACTICES ....................................................................................................................8
PROCESS AND EQUIPMENT RECOMMENDATIONS ....................................................................10
ç Desalting ......................................................................................................................................11
Steam Stripping ...........................................................................................................................11
Reforming ....................................................................................................................................11
Fluid Catalytic Cracking................................................................................................................12
Sulfur Recovery............................................................................................................................12
Lubes Dewaxing ...........................................................................................................................12
Thermal Conversion .....................................................................................................................12
Alkylation .....................................................................................................................................13
ç MTBE .............................................................................................................................................13

TABLES
Table 1 - Directions To Major Environmental DP Sections .........................................................................3
Table 2 - List Of Major Emission Sources ..................................................................................................7
Table 3 - Types Of Site Contamination ......................................................................................................8
ç Table 4 - Hierarchy Of Environmental Control............................................................................................9
Table 5 - Components Of An Emission Reduction Program .....................................................................10
ç Table 6 - Emission Reduction Guidance ..................................................................................................14

Revision Memo
12/97 Minor revisions/additions.

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SCOPE
This section of DPs provides an overview of environmental control technology, some environmental control recommendations
for specific process units, and guidance on the location of information in the other environmental DP sections.

REFERENCES
1. Highlights of New and Proposed Air Toxics Regulations, EE.3E.91.
2. Site Remediation Regulatory Review, EE.42E.92.
3. MEFA: Minimum Emissions Facilities Assessment, EE.12E.92.
4. MEFA: Minimum Emissions Facilities Assessment - Phase 2, EE.123E.92.
5. Rittmeyer, Robert W., Waste Minimization-Part 1: Prepare an Effective Pollution Prevention Program, Chemical
Engineering Progress, May 1991, 56-62.
6. Guidelines for Preparing a Cost-Effective Environmental Assessment, 88 ECS2 79, August 26, 1988.

INTRODUCTION
Incorporating environmental considerations into project design is essential due to the rapidly expanding regulations under
which the petroleum and petrochemical industries must operate. These regulations cover discharges to the air, water and
ground, the generation of noise and odors and the remediation of contaminated sites. Worker and community exposure as well
as impact on the environment must be evaluated as part of project planning and preparation of environmental impact
assessments.
In addition to strict adherence to the local environmental and health regulations, Exxon has set additional guidelines to assure
that corporate environmental policy and operations integrity are considered. In many cases these may be more restrictive than
local regulations. The effects of our plants on the environment play a major role in the public's perception of our operations.
Good community relations is a valuable asset and attention to plant discharges which may be of concern is a major part in
maintaining local support.
The following sections of Design Practices, XVIII through XX, provide details on recommended procedures and control
requirements for specific situations. The remainder of this section provides an overview of the major environmental regulatory
issues, a listing of emission sources and types of site contamination, and guidance on emission reduction.
Table 1 may be used as a guide to locate sections containing information on a particular environmental control topic. Specific
technology is arranged by environmental media (e.g., air, water, waste) and key contaminants.
Exxon Corporation has issued a manual explaining the environmental performance indicators (EPI) that it will be tracking from
different regions and segments of its businesses. Examples will be effluent water discharge oil and biochemical oxygen
demand (BOD5) in tonnes per year and a number of air emissions, including VOC’s. These indicators should be considered in
assessing plant environmental facility needs for a particular application.

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INTRODUCTION (Cont)

TABLE 1
DIRECTIONS TO MAJOR ENVIRONMENTAL DP SECTIONS

MEDIA POLLUTANT CONTROL TOPIC SECTION

Air Hydrocarbons Fugitives XVIII-A2
Tanks XVIII-A2
Waste Water XVIII-A2
Loading XVIII-A2
Toxics Industrial Hygiene XVIII-B, B1, B2
Equipment/Practices XVIII-A2
Particulates Cyclones XVIII-A3
Bag Filters XVIII-A4
Scrubbers/Demisters XVIII-A5
Electrostatic Precipitators XVIII-A6
Combustion Products XVIII-A
(SOx, NOx, CO, Particulates)
— Impact Modeling XVIII-A1
Noise Flow Induced Devices XVIII-C1, C4
Combustion Devices XVIII-C2, C4
Machinery Devices XVIII-C3, C4
Water Oil API Separators XIX-A1
Flotation Units XIX-A2
Suspended Solids Media Filtration XIX-A3
Clarification/Thickeners/ XIX-A4
Flocculation
Dissolved Organics/Phenols/Oil Activated Sludge XIX-A5
and related contaminant Trickling Filters XIX-A6
indicators, such as BOD5, COD, Aerated Lagoons XIX-A7
TOC Carbon Treaters XIX-A8
Chemical Oxidation XIX-A11
Toxicity Activated Sludge XIX-A5
Activated Carbon Treaters XIX-A8
Chemical Oxidation XIX-A11
Solid Waste Sludge Dewatering XX-A1, A2, A3
Incineration XX-A5
Stabilization XX-A6
Biotreatment XX-C1
Spent Caustics Treatment/Disposal XX-A
Site Remediation Groundwater Containment Future
Remediation & Monitoring Future
Risk Assessment Future
Soil Containment Future
Treatment XX-B4, XX-C1,
Future
Risk Assessment Future
Free-Phase Product Treatment, Recovery XX-B6
Ponds & Lagoons Treatment XX-B5

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REGULATORY ISSUES

GENERAL
The environmental laws and regulations which affect Exxon's operations continue to become more stringent. These regulations
are usually specific to a particular country, state, or province and each location will have its own unique set of requirements
which need to be met. It is of primary importance to be aware of current and potential environmental laws and regulations in
order to maintain compliance and to prepare for future requirements. In some cases there is opportunity for negotiation in
setting both the quantity and concentration of emissions or the clean up/remediation requirements. A recent trend is for
regulations to accept “risk-based” solutions, rather than strict adherence to numerical standards. Potential changes in
implementation of regulations are sometimes possible if it can be demonstrated that they are unnecessarily excessive, based
upon human health, environmental risk assessment and cost versus benefit analysis. In addition, the new trend in regulation is
to provide flexibility in achieving goals. This may allow alternative approaches, which result in similar reductions at reduced
cost, to be considered.
The charter of most environmental regulatory agencies is to provide for the protection of the community, plant workers, and the
environment. Protection levels for the surrounding community and Exxon personnel are documented in government and
industry standards and Exxon Biomedical Sciences (EBSI) publications. These allowable levels are frequently changing and
care should be taken in obtaining the latest limits and in their use. Consultation with the plant Industrial Hygienist is
recommended to clarify appropriate long and short term personnel exposure limits. In some locations, limits on emissions or
clean up requirements are also set to preserve the “quality of life." This includes such intangibles as the effects on vegetation
and animal species as well as odor and noise annoyances.
In most locations, there is a need to obtain a “permit" before starting construction or as a condition of being able to operate the
facility. These permits usually set out the allowable emissions from the operation and may document the required equipment
deemed necessary for control. Various impact analyses may be required in order to determine ambient concentrations
resulting from plant emissions. The most stringent regulatory agencies are likely to require risk assessments which fully
document emissions to all media and consider combined effects of different emissions on the surrounding community. These
analyses involve emission estimates, dispersion modeling, water effluent discharges and population density and land use
considerations (e.g., schools, health care facilities). For site remediation, clean-up requirements may be based on fixed,
regulatory contaminant concentrations or may be derived from a risk analysis.

ç AIR
There are several different types of emissions to the air which may be a concern. These include the products of combustion,
volatile organic compounds, hazardous air pollutants, and particulate matter. Regulation of combustion processes initially
focused on the emission quantity and concentration of oxides of sulfur and on particulates based on respiratory concerns.
More recently, oxides of nitrogen have received increased attention due to both acid precipitation and ozone formation.
Particulate emissions have also received additional focus due to the heavy metals which may be present in the particulate
phase and to the potential effects of fine particulate matter. The ambient concentration of fine particulate matter (less than 2.5
micron), which is generally emitted in aerosol form from combustion operations and atmospheric interactions, is now being
regulated. The other recent expansion of controls on combustion emissions relates to the so called “greenhouse" effect (global
warming) and seeks to limit carbon dioxide emissions.
Controls on the emissions of volatile organic compounds (VOCs) and on air toxics will significantly affect facility operations. In
many locations, the concentration of ozone (urban smog) is above health based standards. Although there have been studies
indicating that emissions from mobile sources contribute significantly to these high ozone levels, controls are being focused on
industrial sources of VOCs and nitrogen oxides. Addressing concerns about emissions of air toxics and other potentially
hazardous releases and their effects on the surrounding community is one of the most active regulatory areas. Air emissions
from fugitives (valves, pumps, etc.), tanks, waste water treating, loading operations and vents are receiving increased attention
and, in some locations, controls requiring ninety percent or greater reduction in emissions are being required. Emissions of
polynuclear aromatics (PNAs) and heavy metals on particulates generated from sources such as landfarms, unpaved roads
and site remediation are also receiving increased attention.
Planning for and mitigating the effects of accidental releases of hazardous vapors has been a major focus of recent regulation.
New dispersion models are used to determine the potential affected areas in the result of a spill and also to evaluate the
effectiveness of various controls. Incidental releases of VOCs and toxics are often the cause of community odor complaints
which are sometimes regulated to protect the “quality of life."
There is an increasing trend toward international agreements to address air pollution concerns since in many cases the effects
of emissions are evident large distances from the sources. Reduction of acid precipitation was part of an agreement between
Canada and the United States. More recently, the Montreal Protocol, an international agreement to halt production of certain
chlorofluorocarbons, was negotiated to mitigate the depletion of stratospheric ozone.

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REGULATORY ISSUES (Cont)

ç WATER
Quality requirements for industrial wastewater effluents have changed significantly over the past decade. Past regulations
have focused on conventional contaminants such as oil and grease, biochemical oxygen demand and suspended solids. In
some locations, regulatory authorities are continuing to reduce the allowable concentrations and mass limits of these indicator
parameters of pollution. In some others, the emphasis now is on the control of toxic compounds. Specific effluent
concentration and/or quantity limits are being imposed on industrial facilities for compounds such as phenolics, benzene and
metals. In some locations regulatory agencies are placing limits on nutrient (nitrogen and phosphorus) discharges which may
cause uncontrolled algae or vegetative growth (eutrification) in receiving bodies of water. The vegetative growth, when it
escalates to an undesirable stage can reduce the intended uses of the water resource, change the aesthetic appearance or
quality or increase the cost of pretreating the water for industrial or domestic uses.
Some environmental agencies are requiring more reliable compliance and more frequent monitoring and reporting for
established effluent limits. The capability of new analytical methods to measure very low concentrations is creating the need
for increased emphasis on reducing toxic contaminants. In locations that require maximum water reuse, concerns focus on
avoiding excessive concentration of the contaminants that need to be treated prior to discharge. Also, new projects are
changing the types and quantities of compounds entering the wastewater system.
New regulations in some locations are starting to consider the tendency of certain compounds to accumulate more readily in
aquatic organisms. The protection of larger systems, such as watersheds, is also under regulatory consideration and may
require extensive sampling, analysis and modeling of wastewater effluent discharges into these water bodies.

ç SOLID AND LIQUID WASTE

Until the mid 1970s, solid and liquid waste disposal consisted mainly of biological treatment via landfarm and burial in landfills.
Increasing concerns over protection of human health and the environment have led many countries to place restrictions on the
disposal of hazardous wastes. New regulations have been enacted to protect the quality of ground and surface waters, the air,
and land from contamination from solid waste.
Solid or liquid wastes may be hazardous because they possess certain characteristics. A solid or liquid waste may be deemed
hazardous based on its quantity, concentration, physical or chemical properties, which may cause, or significantly contribute to,
a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or
disposed. A solid waste is usually classified has hazardous when it exhibits characteristics of ignitability, corrosivity, reactivity,
or toxicity. In many locations, specific by-products or process streams have been classified as hazardous.
New trends focus on the so called “cradle to grave" concept of hazardous waste management. This involves comprehensive
tracking procedures and full documentation of waste generation, shipment, storage, treatment and disposal. Several regulatory
bodies have recently limited the transport of hazardous wastes to other jurisdictions for disposal. Exxon regions and operating
affiliates have plans for managing wastes properly to meet company and government needs. For example, ECI (Exxon
Company International) has a section (6.7) in the OIMS manual that requires procedures and plans for hazardous material/
waste disposal.

ç SITE REMEDIATION
Regulations covering the remediation of contaminated sites are focused on reducing the volume, toxicity and/or mobility of the
contaminants. These regulations are often focused on protecting groundwater quality. Initially they addressed clean up of
current or recent contamination. More recently, regulations mandate the remediation of older spills, leaks and disposal sites.
Clean up levels are often fixed by regulation, but may be negotiated based on general guidelines and risk assessments of site
specific conditions. Separate surface and sub-surface clean up levels may be used reflecting different exposure pathways and
potential health risks. In most locations, remediation requirements are based on specific contaminants of concern as well as
general parameters such as the total hydrocarbon present. There is a trend toward setting levels based on risk to humans and
ecological receptors.

NOISE
Regulations to control noise are based on protection from hearing damage as well as mitigating annoyance and thus
preserving the “quality of life." In addition, limits are sometimes set for ensuring clear communications such as in control
rooms. Standards for worker safety have been established and appropriate noise levels for industrial, commercial and
residential areas have been proposed. Currently, there are workplace and community noise limits in most countries.

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REGULATORY ISSUES (Cont)

Noise sources which may be regulated include gas turbines, fired heaters, construction equipment, motors and engines as well
as intermittent noise sources such as flares and safety relief valves. Options for controlling the generation of noise and thus
mitigating its effects include purchasing low-noise equipment and installing noise control devices such as enclosures, pipe
insulation and silencers.

EMISSION AND CONTAMINATION SOURCES

Table 2 lists the major sources of plant emissions along with the pollutants usually associated with each source. Table 3 lists
the types of site contamination.

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EMISSION AND CONTAMINATION SOURCES (Cont)

TABLE 2
LIST OF MAJOR EMISSION SOURCES

SOURCE CONTAMINANTS COMMENTS

Cat Cracking CO, SOx, particulates, metals, Largest volume of primary air pollutants from single process source.
cyanide, sulfur, nitrogen and phenolic Regulatory pressure even for tightly controlled units.
compounds in wastewater
Process Fugitives VOCs, benzene Largest contributor of VOCs.

Solvent Dewaxing Ketone leaks, waste water Largest source of normally regulated toxic emissions from single
process unit.
Desalting Waste water, benzene, oil Largest volume (50-60%) of benzene contaminated oily water. Large
cost to control.
Combustion CO, SOx, NOx, CO2, toxics, Largest collective source of total plant primary air pollutants.
particulates Emissions are taxed in some locations.
Wastewater Treating VOCs, benzene, metals, inorganic Many source reduction opportunities. Sophisticated treatment
and biosludges, NH3, phenols, process units may be required. Biological systems are typically the
COD/BOD most cost-effective for organics, metal and toxicity removal.
HC Steam Stripping Sour water, benzene water Largest source of sour water.

Tankage Water draws, VOCs, sludges Large source of waste water, VOCs and sludge.

Reforming Benzene, chlorine, carbon Benzene leakage from valves. Ban on CCI4 used in catalyst
tetrachloride regeneration.
Product Treating Spent caustic Typical industrial disposal outlets disappearing. Upsets in WWTP.

Spent Catalyst Metals Traditional landfill not viable. Explore reuse/recycle options.

Sulfur Plant SO2, H2S Sulfur plant reliability a key issue.

Alkylation Acids, sludges, butadiene

Coking Combustion products Sludge receptor.

Gas Treating H2S, solvent leaks

Loading/Unloading VOCs Potentially large source of VOCs. Many locations require controls.

Flares HCs, H2S, combustion products Emissions may be reportable.

Gas Turbines NOx

MTBE Plant MTBE, methanol MTBE and other additives becoming more important issue due to the
prevalence of reformulated gasolines.
Cooling Tower VOCs, several biocides, antiscaling Improved leak detection for VOCs. Choice of chemical additives to
and dispersant chemicals used control microbe biofouling growth and scale formation, particularly
when cycles are increased for water conservation.
Raw Water Treating Treating chemicals Need to choose biocides, scale inhibitors and dosages carefully to
avoid impact on biotreatment, effluent nutrients and toxicity.
Lubes Processing Solvents

Hydrocracking Spent catalysts

Hydrotreating Spent catalysts, H2S

Isomerization Spent catalysts

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EMISSION AND CONTAMINATION SOURCES (Cont)

TABLE 3
TYPES OF SITE CONTAMINATION

USUAL OR POSSIBLE SOURCES

Accidental Spills Disposal Practices

- Leaking Tanks - Landfarms

- Tank Overfills - Landfills
- Acid/Caustic Spills - Tank Sludges
- Piping Failures - Lagoons/Pits/Impoundments
- Fires - Dredged Spoils
- Lead Weathering Piles
- Oily Water Discharges

TYPICAL CONTAMINANTS

Crude
Products
Chemicals
Catalysts
Additives
Wastes

EMISSION REDUCTION GUIDANCE

GENERAL PRACTICES
There are usually a number of ways in which emissions of various pollutants can be reduced. In some cases there are technical
limitations, but most often it is the cost that will be a major consideration. The first part of this section is focused on reducing
the generation of wastes rather than treating or controlling them with “end of pipe" methods. It has been referred to as
“pollution prevention" or “waste minimization." The second part of this section provides specific recommendations for
emissions reduction in refinery and chemical plant operations.
Table 4 describes a hierarchy of environmental control. At the top of the list is source reduction and at the bottom of the list is
disposal. In most cases, the objective in cost effective waste management is to address emissions using techniques near the
top of the hierarchy listing. The components of an emission reduction program are listed in Table 5. The most effective time
to incorporate emission reduction opportunities is during process development or facilities design.
In application of emission reduction technologies, the effects on other media should be considered. Sometimes, an action that
results in a reduction of one type of emission results in creating a greater problem in another media. In general, the transfer of
a pollutant from one media to another doesn't eliminate the problem, but may result in a more technically and economically
feasible control alternative. Examples of transfers include the control of air pollutants that results in the generation of scrubber
water or solid wastes; treatment of the scrubber water creating a waste sludge; and disposal of sludge to landfill which creates
potential liability due to contamination of the ground water.

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EMISSION REDUCTION GUIDANCE (Cont)

ç TABLE 4
HIERARCHY OF ENVIRONMENTAL CONTROL

SOURCE REDUCTION
The reduction or elimination of waste at the source, usually within a process.
Measures include process modifications, feedstock substitution, improvements in
feedstock purity, improvements in housekeeping and management practices,
increases in the efficiency of machinery, and recycling within a process.
RECYCLING
The use or reuse of waste as an effective substitute for a commercial product or as an
ingredient or feedstock in an industrial process. It can occur on or off site and
includes the reclamation of useful constituent fractions within a waste material, the
removal of contaminants from a waste to allow it to be used, or the use of a waste as
a fuel supplement or fuel substitute.
WASTE TREATMENT
Any method, technique, or process that changes the physical, chemical, or biological
character of any waste in a way that neutralizes the waste, recovers energy or
material resources from the waste, or renders such waste less hazardous, safer to
manage, amenable for recovery, amenable for storage, or reduced in volume.
DISPOSAL
The discharging, depositing, injecting, dumping, spilling, leaking, or placing of waste
into or on any land or water so that such waste or any constituents can enter the air or
be discharged into any water, including ground water.

As a practical matter, there will always be some emissions and disposal of wastes at an industrial facility. Source reduction
and recycling should be considered in projects only to the extent that they are cost-effective and do not cause problems to other
plant operations. For example, reuse and recycling of treated water as cooling water makeup and using higher cycles of
concentration on cooling towers, minimizes raw water consumption and the discharge of treated wastewaters. However, if the
concentrations of constituents in the recycled cooling water become too high, due to excessive recycling, they could scale up
heat exchanger equipment, thereby reducing heat transfer (resulting in more fuel consumption), and potentially result in heat
exchanger tube hot spot generation and failure.

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EMISSION REDUCTION GUIDANCE (Cont)

TABLE 5
COMPONENTS OF AN EMISSION REDUCTION PROGRAM

EVALUATE THE WASTE STREAMS

Conduct emissions inventory
Prepare waste and wastewater flow and contaminant material balances (requires sampling and lab
analysis)
Characterize waste (Toxicity, Quantity, Regulatory Impact)
Management costs
Safety and health risks
Potential for success
Potential environmental liability
IMPLEMENT LOW COST/OPERATIONS IMPROVEMENT ITEMS
Segregation of wastes (optimize treatment efficiency)
Improved material handling (to reduce material quantities)
Reuse/substitution/operational changes
Preventative maintenance
TECHNICAL EVALUATION
Product quality
Product safety
Worker health and safety
Maintenance requirements
Space requirements
Installation schedule
Production downtime
Reliability/Proven performance
Commercial availability
Permitting requirements/Community acceptance
Regulatory constraints
Effects on other environmental media
Personnel skills requirements
ECONOMIC EVALUATION
Capital requirements
Return on investment
Operating and maintenance costs

PROCESS AND EQUIPMENT RECOMMENDATIONS

Table 6 summarizes the emission reduction options. Additional details on emission reduction for selected process areas is
summarized below. An in-depth discussion of these concepts is available in References 3 and 4.

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EMISSION REDUCTION GUIDANCE (Cont)

ç Desalting
Crude oil desalting contributes a large portion of the total benzene that goes to refinery wastewater treating. As oil in water
discharge regulations tighten, controlling the desalter impact is becoming much more important. Controls recommended
include work practice changes and some minor equipment modifications. The most basic recommendation is for each plant to
decide where in its operation crude oil sludges will be removed and to operate the desalter in a way that minimizes sludge build
up within the vessel. Other key recommendations are to mud wash the desalter very frequently with recycled brine, to inject the
demulsifier as far upstream as practical to maximize its effectiveness, to carefully control the pH of incoming wash water and to
prevent spent caustic from entering the desalter.
Mud washing removes the accumulated solids and restores the full brine settling volume of the drum. If the solids accumulate,
the reduced drum volume results in poorer oil/water separation and an increase in oil leaving the desalter. Mud washing is
recommended on a frequent (each shift if possible) basis and should be done with a recycle stream of the hot effluent brine.
Continuous mud washing is a possible improvement to current practices, but has not yet been demonstrated commercially.
For optimum results, the demulsifier chemical should be added as far as possible before wash water. This allows the
demulsifier to treat the brine droplets exclusively and helps prevent emulsion formation as the crude and wash water go
through the high shear areas of the charge pump and preheat train. Adding the demulsifier just upstream of the desalter
mixing valve is not recommended because it provides minimum time for the demulsifier to interact with the brine droplets
before entering the desalter drum, and a major part of the wash water has already been added to prevent fouling in the preheat
train.
There are several options, requiring some equipment modifications, which will improve the environmental performance of the
desalter. These include installing filtration and pumping facilities for brine recycle mud washing; adjusting the position of the
desalter in the preheat train to maintain a high enough temperature to match desalter capacity and throughput; use of gas
flotation or steam/air stripping of the effluent; and routing effluent brine to intermediate storage to allow for additional settling.
Another effective instrument option is to install an “Agar” probe oil interface monitor to the desalter, as a new installation or an
equipment upgrade. This addition can greatly reduce oil in the oily water that goes to the sewer and then on to wastewater
treatment facilities.

Steam Stripping
One of the largest sources of wastewater to a refinery treatment plant is condensed steam. Options for reducing steam
consumption generally offer improved energy efficiency as well as environmental credits. Stripping steam can be reduced by
application of dry vacuum distillation; mechanical vacuum pumps; use of recycled overhead gas as the stripping medium;
replacing trays with more efficient packing in side stream strippers; and optimizing the coil/stripping steam ratio in vacuum
pipestills.
A mechanical vacuum pump can be used to supply some or all of the pressurization work provided by the steam ejectors on a
vacuum pipestill. Although mechanical vacuum pumps are more efficient, they are more expensive to operate. They offer
considerable savings, however, in steam consumption and sour water generation.

Reforming
Emissions from reforming can be divided into those from “on-oil" operation and those from catalyst regeneration. The “on-oil"
emissions are mostly hydrocarbons in the form of fugitive emissions, water condensates, and as adsorbed material on
disposed sludges and media from traps, dryers, and absorbers. The presence of benzene in these streams increases the need
for controls. Emissions which occur during regeneration include hydrocarbons, combustion products, and chlorine and sulfur
compounds. These species can be found in the reactor purges and scrubber waters, and on spent catalyst, traps, dryers and
absorbers.
DP Section XVIII-A2 provides guidance for reducing fugitive emissions. Dealing with the air emissions from the catalyst
regeneration step is sometimes difficult. One option is to precede the inert gas purge with a hot hydrogen sweep to the fuel gas
system or to send the purge stream to the flare or other vapor control. The later option is likely not to be an economic
alternative.
Primary water emissions during regeneration can be minimized by using hot rather than cold flue gas regeneration. In the
later, the regeneration gas is scrubbed with water to prevent the recirculation of undesirable chemical species such as HCl and
H2S. Alternatively, hot flue gas regeneration minimizes the formation of condensates, but requires that the pollutants be
controlled as air emissions in a dryer or absorber. The drier or absorber will then require regeneration.

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EMISSION REDUCTION GUIDANCE (Cont)

In locations where wastewater streams result from wet scrubbing of the on-oil recycle gas or the use of cold gas regeneration,
the waste water stream should be kept isolated to minimize the volume of waste water containing benzene. In some locations,
these benzene waste containing streams may need to be treated separately. For the same reasons, as well as to reduce the
load on the waste water plant, sludge formed in the separator drums should be kept out of the sewers.

Fluid Catalytic Cracking

Air contaminants from fluid catalytic cracking are present in both the reactor product gas and in the regenerator flue gas. Sour
waters and high concentrations of phenolic compounds from condensation of steam and diluent water to prevent corrosion lead
to acid gas and contaminated wastewaters which require further treatment (biological after oil removal) prior to by-product
recovery or eventual discharge. Catalyst recovery and purging operation contribute solid wastes that either must be disposed
of or reclaimed.
There are many control technologies applicable to reducing emissions of particulates, sulfur oxides, nitrogen oxides, and
carbon monoxide. Reduction of catalyst fine emissions has been achieved through a combination of catalyst physical property
enhancements, reactor design considerations, and changes in operating conditions. Present catalysts are coarser, denser and
more attrition resistant and there have been significant improvements in cyclone design. Approaches to reduce SOx emissions
include hydrotreating the feed, the use of De-SOx transfer additives, flue gas desulfurization, and wet gas scrubbing. The
above techniques are aimed at reducing the generation of emissions rather than controlling them external to the process unit.
Equipment for control of particulate emissions include electrostatic precipitators, fabric filters, and wet scrubbing. Additional
details are available in DP Sections XVIII-A3 through XVIII-A6. SOx emission control techniques include dry sorbents, and
gas scrubbing (dry or wet). NOx emission control methods include selective non-catalytic reduction(SNCR) (Exxon's Thermal
DeNOx Process and urea based reduction processes), and selective catalytic reduction (SCR). For low temperature
regenerators, a CO boiler may be used both as a CO emissions control device and as a steam generator.

Sulfur Recovery
In order to limit the sulfur in fuel gas and to reduce corrosion problems, plants remove hydrogen sulfide from the fuel gas by
scrubbing the sour gas. Regeneration of the scrubbing solution, often an amine, produces a gas stream that is routed to the
sulfur recovery plant. Process wastewater may also contain dissolved gases such as ammonia and H2S, which require
removal. This is done using thermal or steam stripping and the resultant gas stream is also routed to the sulfur recovery plant.
Sulfur recovery is usually accomplished in a Claus plant. The off-gas from a Claus plant, referred to as tail-gas, consists of
SO2, H2S, and various reduced sulfur compounds. Tail gases have usually been incinerated before release. The need to
reduce incinerator emissions has resulted in a number of alternatives for tail-gas clean up.

Lubes Dewaxing
Solvent losses from ketone dewaxing can be as much as half of a refinery's total toxic emissions. Sources of solvent loss
include ketone stripper tower bottoms to sewer; residual solvent in the products; fugitive leaks, solvent contaminated drain
system, and the blanket gas purge vent. Solvent lost in products is destroyed by subsequent hydrotreating and is not
ultimately released to the environment. Options to reduce emissions focus on improving the operation of the existing
equipment as much as possible before introducing new technology or making investment.
Ketone stripper tower bottoms losses to the sewer can be reduced by increasing tower bottoms temperature, increasing tower
feed temperature, equalizing feed rate by continuous feed of sump water, improving control logic to better anticipate load
swings, reducing sand fouling of tower internals, increasing the number of effective stages, and installing an analyzer to
measure solvent loss. Residual solvent in products can be reduced by installation of an analyzer to monitor solvent loss, and
debottlenecking product stripping towers. The above options have the potential to reduce emissions by about 60 percent.

Thermal Conversion
Thermal conversion processes include coking and visbreaking. They are a source of combustion products and hydrocarbon
emissions. Combustion emissions can be controlled using standard technology. Waste waters from coke handling can be
minimized by reducing steam and water usage. Water that has contacted coke, whether during hydraulic removal of delayed
coke, from quenching coke fines in a fluid coker, or from condensation of process steam should be segregated from other
waste waters. These waste waters should be treated separately or pre-treated to remove potentially hazardous polyaromatic
hydrocarbons before being sent to the waste water treatment plant.

EXXON RESEARCH AND ENGINEERING COMPANY - FLORHAM PARK, N.J.

 DESIGN PRACTICES
PLANT ENVIRONMENTAL CONSIDERATIONS Section Page
EXXON XVII 13 of 16
ENGINEERING Date
PROPRIETARY INFORMATION - For Authorized Company Use Only December, 1997

EMISSION REDUCTION GUIDANCE (Cont)

Alkylation
Alkylation processes produce air, water and solid waste emissions. The air emissions are hydrocarbons that escape as fugitive
emissions and potentially releases of acid catalyst. Fugitive emission controls are discussed in DP Section XVIII-A2. The
potential consequences of an acid release merit special attention from a safety, as well as an environmental perspective.
Water emissions consist of the neutralized products from caustic washing or reaction with the acid catalyst, as well as
dissolved organics. The emissions include sour water, sulfates and bisulfates, sulfides, and, for HF acid catalyzed units,
fluoride salts.
Inorganic salts from the neutralization reaction, organic polymers, and sulfonated organics from the reactions of unsaturated
hydrocarbons with the sulfuric acid can buildup and reduce the alkylation catalyst strength. A spent acid purge must be taken
to remove these materials. In the case of HF alkylation, organic fluorides are formed, rather than sulfonated organics. Spent
caustic, containing sulfate and bisulfate salts from neutralization of sulfur compounds in the feed caustic wash, and wash
waters also need to be disposed of.

ç MTBE
Much of the environmental impact of the MTBE synthesis process is due to the use of a large quantity of water which is needed
to remove catalyst threatening contaminants from the hydrocarbon feed stream. Spent water may contain acetronitrile,
ammonia, methanol, and other organics present in the feed. These can be minimized by reducing the use of process water
and/or finding a suitable disposition for the spent water other than waste water treatment. Some potential process changes
include recycling spent water, using it in cooling services or as boiler feed. Recycling requires treatment such as steam
stripping, ion exchange, or chlorination.

EXXON RESEARCH AND ENGINEERING COMPANY - FLORHAM PARK, N.J.

 DESIGN PRACTICES
Section Page PLANT ENVIRONMENTAL CONSIDERATIONS
XVII 14 of 16 EXXON
Date ENGINEERING
December, 1997 PROPRIETARY INFORMATION - For Authorized Company Use Only

EMISSION REDUCTION GUIDANCE (Cont)

ç TABLE 6
EMISSION REDUCTION GUIDANCE

SOURCE CONTROL OPTIONS

Tankage • Double seals on external floating roof tanks.
• Liquid mounted in place of vapor mounted seals.
• Dome over internal floating roof tank.
• Improved guide pole/sample well configuration.
• Internal floating roofs on fixed roof tanks.
• Tankage minimization.
• Recover tankage vapor emissions.
• Treat tank water draws.
Desalting • Control wash water quantity and quality
• Add demulsifier as far upstream as possible.
• Control oil interface level.
• Mud wash frequently with effluent brine.
• Alternates to steam stripping for benzene removal.
• Addition of Agar probe to reduce oil loss and carry under into the water.
Hydrocarbon Steam Stripping • Dry vacuum distillation.
• VPS vacuum pumps vs. steam jet ejectors.
• Recycle VPS overhead gas as stripping medium.
• Replace sidestream stripper trays with packing.
• Replace steam with other gas.
Reforming • Ventless regeneration system.
• Isolate wastewaters.
• Use hot flue gas regeneration.
Overall Sulfur Management • Optimum priority for control is: (1) sulfur plant, (2) combustion controls, and
(3) FCC controls.
FCC • ESP for particulate control.
• Wet Gas Scrubber is most cost effective if particulates and SOx control needed.
• DeSOx additives offer moderate control at low cost.
• Other credits needed to make feed desulfurization attractive.
• Thermal DeNOx for moderate control, SCR (Selective Catalytic Reduction) for greater NOx
control.
• Recover and utilize SO2 from FCC regen off-gas.
• Control critical parameters that impact emissions.
• CO boiler for CO control.
Combustion • Ultra low NOx (ULNB) burners can achieve 25 ppm in boiler flue gas.
• Addition of SCR (Selective Catalytic Reduction) can achieve 5 ppm NOx, but at 3 to 4 x
incremental cost.
• Reduce emissions at individual sources.
• Sub-micron particulate removal.
Sulfur Recovery • Add third stage Claus catalytic reactor.
• Add tail gas cleanup unit (TGCU).

EXXON RESEARCH AND ENGINEERING COMPANY - FLORHAM PARK, N.J.

 DESIGN PRACTICES
PLANT ENVIRONMENTAL CONSIDERATIONS Section Page
EXXON XVII 15 of 16
ENGINEERING Date
PROPRIETARY INFORMATION - For Authorized Company Use Only December, 1997

EMISSION REDUCTION GUIDANCE (Cont)

TABLE 6 (Cont)
EMISSION REDUCTION GUIDANCE

SOURCE CONTROL OPTIONS

Lube Oil Solvent • Temperature control of deketonizer.
Dewaxing • Condense blanket gas vapors.
• Improve packing and maintenance.
• Seal legs on drains.
• Reduce hazard of emissions.
Process Fugitives • 75-90 percent reduction of uncontrolled emissions achievable via practice changes -
annual inspections, graphite packing replacement.
• Enhanced (“smart") inspections, which target the few significant sources, are cost-effective
step.
• Use 5-ring valve packing with three low density graphite sealing rings and braided or
composite rings.
• Use ESVP (Extended Stem Valve Packing) for Reformer MOVs (Motor Operated Valves).
• Use rupture disks with pressure relief valves.
• Consider sealless (mag drive, canned) pumps as replacements.
• Consider environmental impact in equipment selection.
Spent Catalyst • Cascaded reuse in less severe service.
• Use as filler in construction materials (e.g., cement, asphalt, and brick).
• Offsite total recovery systems (e.g., CRI-MET).
• Onsite integrated treatment and recycle (e.g., MAGNACAT, DEMET).
• Upgrade feed quality.
• Minimize inventory.
• Reuse spent phosphoric acid polymerization catalyst as biox nutrient.
• Increase catalyst life.
WWTP • Major troublesome sources of oily water are desalter and tank water draws.
• Steam stripping is major source of sour water, but stripping essential to remove sour H2S
and NH3 to acceptable levels prior to further treatment.
• Inadequate housekeeping, practices still a major contributor.
• Water flow (versus oil content) is key parameter for facility sizing and impact.
• Reduction in soluble, non-biodegradable organics, where possible to reduce
BOD/COD load. Use light naphthas vs. aromatic oils for diluents for high viscosity oils or
for oily sludge extraction. Safety precautions/impacts with the lower flash point naphthas
need to be considered.
• Trend towards closed, above ground treatment facilities (including sewers).
• Segregate streams for upstream treatment.
• Reuse water within process or in another process; example reuse stripped sour waters
(SWS bottoms) for desalter feed makeup (reduces phenols).
• Reduce sludge volume via sewer segregation, wastewater reduction, feed to cokers and
CO-boilers.
Product Treating • Cascaded reuse in less severe service.
(Spent Caustic) • Wash or condense Merox vents to remove sulfur compounds.
• Replace caustic treating with regenerable treating (e.g., Merox).
• Regenerate spent caustic.

EXXON RESEARCH AND ENGINEERING COMPANY - FLORHAM PARK, N.J.

 DESIGN PRACTICES
Section Page PLANT ENVIRONMENTAL CONSIDERATIONS
XVII 16 of 16 EXXON
Date ENGINEERING
December, 1997 PROPRIETARY INFORMATION - For Authorized Company Use Only

EMISSION REDUCTION GUIDANCE (Cont)

TABLE 6 (Cont)
EMISSION REDUCTION GUIDANCE

SOURCE CONTROL OPTIONS

Thermal Conversion • Enclosed structures for coke handling and storage.
• Reduce sour water production by minimizing steam use.
• Improved COS removal from FLEXICOKING gas.
Alkylation • Improved pumps and valves to reduce fugitive emissions.
• Flood systems/dikes to reduce impact of HF release.
• Detectors to provide early warning of HF release.
• HF process/storage vents to water-spray scrubbers.
• Solid reforming catalyst.
Flares • Recover vapor vents.
MTBE • Replace wash water recycle loop with individual loops for methanol extraction/recovery and
feed washing.
• May not be easily stripped or removed by conventional treatments.
• Use of a feed treater instead of a feed wash tower.
• Alternates to wastewater treatment for feed wash water.
Loading • Absorption.
• Adsorption.
• Vapor balancing.
• Thermal oxidation.
• Catalytic oxidation.
• Carbon adsorption.
• Refrigeration.
Intermittent Releases • Use closed purge sampling systems where practical.
• Coordinate sample volumes with test requirements.
• Restock unused paint.
• Drain process vessels to tank trucks rather than sewer.

EXXON RESEARCH AND ENGINEERING COMPANY - FLORHAM PARK, N.J.