Addressing Stationary Source Emission Estimation and Inventories by the Global Oil & Gas Industry

1. Addressing Stationary Source Emission Estimation and Inventories by the Global Oil & Gas Industry Derek Swick and Karin Ritter Regulatory and Scientific Affairs, API, Washington DC Jeffrey Siegell ExxonMobil Research and Engineering, Fairfax, VA Clay Freeberg Chevron Corporation, San Ramon, CA Miriam Lev-On The LEVON Group, LLC, Thousand Oaks, CA EPA 2008 TRI National Training Conference, 12-14 February 2008, Washington DC

2. Outline • Industry Operations • Data Quality • API Emission Studies • TRI Data Variability • Emission Factors Compilation Study • Next steps 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

3. Industry Operations • Global Oil & Gas Industry encounters unique operational and business environments; • Companies range from vertically integrated multinational companies to independent producers, refiners and marketers of petroleum products; • Technical resources and availability of site specific information varies by location and size of operations 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

4. Call for Data Consistency • The Oil&Gas Industry is subject to multiple regulations at the federal, state and local levels • The industry desires robust data for developing emission inventories while complying with a variety of emission reporting mandates • Companies strive towards consistent, reliable, and credible methodologies to derive emission estimates to meet specific emission reporting requirements 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

5. API’s Stationary Source Emissions Task Force • Convened in the early 1990s to coordinate all air related emissions studies at API • Scope is limited to stationary sources • Led and facilitated by member company experts who oversee field and laboratory data collection and analysis for each of the approved projects • Primary Goals: • Publish technical reports containing new emissions data • Inform membership about new emissions data availability, • Provide data to the U.S. EPA for inclusion in AP-42 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

6. Examples of Emission Studies: Combustion Emissions • Fine Particulates • Evaluation of different PM2.5 stack testing methods and the way condensable matter or aerosols are taken into account • Development of test plans and field tests to illustrate these differences • Trace Metals • Explore use of PM test results to confirm / update factors for trace metals from combustion • Compare PM combustion study with existing emission factors available from the Western States Petroleum Association (WSPA), API & EPA • Sulfuric Acid • Develop improved EFs for estimating emissions of sulfuric acid (H2SO4), and sulfur trioxide (SO3), from gas-fired refinery heaters, boilers and FCCUs • Publish guidance for estimating H2SO4 emissions from combustion sources and work on including the results in EPA’s AP-42 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

7. Examples of Emission Studies: Fugitive Emissions • Components in Heavy Liquids (HL) Service • Review previous test data collected by industry and provided to the U.S. EPA • Work with the U.S. EPA to ensure acceptance of new HL emission factors that are based on previously submitted data • Polycyclic Aromatic Hydrocarbons (PAHs) • Determine appropriateness of including PAH species in HL fugitive emissions • Assess relative contribution of specific PAH species to HL fugitive emissions 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

8. Examples of Emission Studies: Loading & Storage Emissions • Tank Cleaning • Develop methodology for estimating emissions from cleaning atmospheric storage tanks • Non-Freely Vented Internal Floating Roof Tanks • Develop methodology for estimating emissions from non-freely vented internal floating roof storage tanks • Surface Temperature • Develop improved methodology for determining the impact of surface temperature on storage tank emissions estimating methodology • Marine Vessel Loading & Transit Emissions • Confirm or improve old emission factors and methods for marine vessel loading and transit emissions • Determine average methane fraction in crude oil loading and off-loading 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

9. TRI Reporting Considerations • TRI requires estimating quantities of chemicals released, discharged, or otherwise managed as waste • Facilities are instructed to use the best “readily available data” • When such data are not available, “reasonable estimates”, are deemed sufficient to fulfill reporting requirements • EPA's TRI Instructions refer to four basic methods that may be used to develop such estimates • Monitoring Data or Direct Measurement; • Mass Balance; • Emission Factors; • Other approaches, such as • Engineering Calculations, or • Best Engineering Judgment 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

10. Highlights of API TRI Variability Review • The flexible approach allowed for TRI emission estimating has led – in some cases - to wide variability in the estimated and reported emissions • API has reviewed refineries TRI data for 2000-2005 to try and understand the roots of the variability • API reviewed data for all of SIC 2911 • Not all reporting refineries are API members • The review focused on air releases, as they make up over 80% of total releases from facilities for most chemicals 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

11. Total Releases & Transfers per Capacity • TRI Data Source • EPA TRI public data flat file, “basic pull” format, • As provided by EPA 8/16/2007 • Operable Capacity Data • Energy Information Administration (EIA) Refinery Capacity Reports, 2001 – 2006 • Atmospheric Crude Distillation, barrels per stream day 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

12. Variability of Air Releases Reported to TRI by Petroleum Refineries • Reported air release data vary widely among facilities, even when normalized by total operating capacity • Example: Sulfuric Acid • Data based on “Releases to air on site” • Total of Form R Part II Sections 5.1 (fugitive) and 5.2 (stack) • For each year evaluated minimum, maximum, 1st and 3rd quartiles, median, mean, number of reporting facilities • Documented also the number of facilities whose reported releases seem to be outliers 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

13. Normalized Sulfuric Acid Releases to Air • Maximum reported release • Consistently about 60 lbs/1,000 bbl from 2000 – 2004, • Decreased about 5-fold between 2004 and 2005 to 12 lbs/1,000 bbl, • The maximum in each year is about 9 – 35 times the median. • 1 – 5 % of reporting facilities are outliers in each year • Overall • 74 facilities reported releases from 2000 – 2005, • 3 of which were outliers in at least one year. 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

14. Sulfuric Acid Releases to AirNormalized by Total Operable Capacity 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

15. Findings from the API TRI Variability Review • The wide disparity in reported releases normalized by capacity suggests estimation methods may contribute to the variability • While these results were for normalized data, similar results are found for non-normalized release data • Reported releases from a relatively few facilities can significantly ‘bias’ the total emissions reported by the petroleum refining sector 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

16. Data Quality Observations • EPA’s Guidance on Systematic Planning Using the Data Quality Objectives (DQO) Process (EPA QA/G-4, 2006), • Provides a standard working tool to develop DQOs in support of EPA’s Quality System agency-wide • Ensures that the quantity, and quality of data are of the appropriate type for their intended use • The methodological flexibility and associated variability of TRI data is a case in point for data being taken out of its original design parameters, • The primary goal of TRI is to increase public awareness to the presence, releases and transfers of listed chemicals, • It was not designed to have the rigor needed for quantitative exposure estimates, • It was not intended to be the basis for regulatory decision-making 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

17. Rationale for TRI Emission Factors Project • The use of potentially unrepresentative emissions factors in petroleum industry operations has the potential to leading to reporting errors, • For example: BP initially reported for RY2004 – 1,938,362 lbs of Formaldehyde • Following site specific sample data the revised amount was 102,156 lbs • The error was due to selecting the wrong emission factor • Industry reputation is at stake due to the use of potentially unrepresentative emission factors • A more cooperative sector-wide guidance approach on best available emissions factors is desired to improve consistency and comparability of reported data. 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

18. Compilation of Emission Estimation Methods for TRI Reporting • Guidance document designed to provide quick reference look-up tables for methods that are available for estimating emissions for reporting under the U.S. EPA TRI • Focuses on sources and operations that are prevalent in the petroleum industry, and its operating segments, that are subject to TRI reporting • Table format with appropriate methods for each air release source categories • Direct links from the compilation table where the methods are described to the authoritative references provided elaborating on the methods 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

19. Excerpt Methods Compilation Tables: Combustion Devices 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

20. Excerpt Methods Compilation Tables: Fugitive Emissions 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

21. Benefit of Emission Factors Compilation Study • The Compilation contains emission factors that are relevant to the petroleum industry • The Compilation has the potential to benefit other reporting programs, beyond TRI, as many of the chemicals are also on the hazardous air pollutants (HAPs) list • Improved emission factors and estimation methods should contribute to enhanced reporting accuracy under various Air regulations • Accurately – and credibly - characterizing emissions from industry facilities will contribute to improved public perception and community relations for industry facilities 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

22. Next Steps • API is continuing to conduct emissions studies and is publishing results in peer reviewed journals and technical reports • Relevant data are provided to API Standards department for inclusion in updates of standards • Data are provided to the U.S. EPA for inclusion in AP-42 • The Emission Factors Compilation study is moving to its next phase to generate specific examples on how to calculate air releases from key industry sources • New studies are being proposed during the yearly budget cycle and are considered for implementation 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org

23. Contact InformationDerek D. Swick, MPPRegulatory and Scientific AffairsAmerican Petroleum Institute1220 L Street, NWWashington, D.C. 20005(202) 682-8341swickd@api.org 1220 L Street, NW • Washington, DC 20005-4070 • www.api.org