2 category 2: petroleum industry, the production of
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2-1
2 CATEGORY 2: PETROLEUM INDUSTRY, THE PRODUCTION OF
GASEOUS AND LIQUID FUELS AS WELL AS
PETROCHEMICALS FROM CRUDE OIL, COAL, GAS OR
BIOMASS
This section covers combustion processes, handling and storage of fuel products and
industrial fuel oil recyclers that are associated with the petroleum industry or the
production of gaseous and liquid fuels from crude oil, coal, natural gas or biomass. It
does not include production of solid fuels (e.g. char from carbonization) and coal
gasification.
For processes involving:
• Carbonization and coal gasification; refer to Category 3. Note that coal
gasification may precede the processes in Category 2.
The synthetic production of liquid and gas fuels can be split into 3 main processes:
• Gas-to-liquids;
• Liquid-to-gas; and
• Solid-to-gas.
These fuels are made up of organic molecules. Gas molecules are typically short
carbon chain molecules (e.g. methane – CH4, propane – C3H8), liquids are made up of
longer molecules (e.g. hexane – C6H14, octane – C8H18) and solids consist of even longer
chain molecules (e.g. Icosane C20H42). Gas-to-liquid processes mostly go about by
combining the shorter, lighter molecules of the gas into longer, heavier molecules which
tend to have higher boiling points. These reactions typically rely on catalysts, such as
the Fischer-Tropsch reaction. The raw material feed to the Fischer-Tropsch process is a
mixture of carbon monoxide (CO) and hydrogen (H2), called “syngas”. It may contain
some methane (CH4). Depending on the source of the syngas it will require a certain
degree of conditioning, or cleaning, as it may contain impurities that could foul or react
with the catalyst (usually sulphur, in which case the Claus process can be used for
sulphur recovery).
Where natural gas is the raw material, the natural gas is mixed with steam and these
react to form a syngas.
H2O + CH4 → CO + 3 H2
(Steam + methane react to form syngas [i.e. carbon monoxide + hydrogen gas])
The syngas is then passed through the Fischer-Tropsch process to form a variety of
organic molecules some of which are liquid. Syngas may also be used directly as a fuel.
In this case it is combusted to provide heat for other processes.
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Where coal, wood or other carbonaceous solids, are the raw material, the solids are first
gassified and then cleaned and passed to the Fischer-Tropsch process. To convert coal
to gas it is mixed with super-heated steam and in some cases a limited amount of
oxygen. This is commonly referred to as gasification, and may be applied to liquids as
well. The resultant gas is syngas.
H2O + C → CO + H2
(Steam + carbon react to form syngas [i.e. carbon monoxide + hydrogen gas])
Conversion of solids is sometimes (but not necessarily) undertaken by combusting the
material with a limited supply of oxygen, this results in incomplete combustion, (i.e.
generating CO instead of CO2). This is also commonly referred to as gasification.
Note that a solid-to-liquid conversion is typically made up of two steps: solid-to-gas
(gasification) followed by gas-to-liquid (typically Fischer-Tropsch process).
The APPA scheduled activities that are covered in this category are:
14. Hydrocarbon Refining Processes;
18. Benzene Processes;
25. Acid Sludge Processes; and
33. Producer Gas Processes.
2.1-1
2.1 SUB-CATEGORY 2.1: COMBUSTION INSTALLATIONS
2.1.1 APPLICABILITY
Combustion processes not used primarily for steam raising or electricity generation
All combustion installations (except test or experimental installations) including catalytic
cracking
Sub-category 2.1 deals with combustion processes associated with the production and
processing of various gaseous and liquid fuels from oil, coal (excluding coal
gasification), gas or biomass. It also deals with process fluid heaters and other material
heaters where the combustion does not fall under another sub category.
Indirect heating processes, such as process fluid heaters or distillation may have two or
more emission sources:
• The flue gasses from the combustion process; and
• Volatiles or gasses evolving from the material being heated.
The combustion flue gas is regulated by this subcategory whereas emissions from the
process it is applied to must comply with an appropriate subcategory covering that
process (for example Sub-category 2.3 in which case distillation requires heating that
may be supplied by combustion).
Testing and experimental combustion installations that fit Sub-category 2.1 descriptions
are excluded from the regulations.
It is important to note that processes for the production of gaseous and liquid fuels as
well as petrochemicals from crude oil, coal, gas or biomass may be heated by steam in
which case Category 1 applies to those processes supplying steam. For combustion
processes involved in:
• Steam and/or power generation; refer to Category 1; and
• Carbonization and coal gasification; refer to Sub-category 3.1.
2.1-2
2.1.2 PROCESS OVERVIEW
2.1.2.1 Catalyst Regeneration
Figure 2-1: Process flow diagram for catalyst regeneration in crude oil cracking
One of the most common crude oil refining methods is cracking, where long carbon
chains are broken into lighter higher value products by the use of catalysts, extreme
temperatures or steam. One of the by-products of the cracking process is the formation
of coke. This coke can deposit on and inside the pores of catalysts and needs to be
removed to ensure proper efficiencies and selectivity during the cracking process.
2.1-3
Figure 2-2: Cracking reaction including the riser, catalyst regeneration and ancillary
equipment
• The catalyst is typically in granular form and used in a fluidized bed reactor or
vertical pipes called risers to crack the heavier carbon compounds;
• The catalyst separation fluidized bed is designed to separate the catalyst using
cyclones and sent for decoking or cleaning while the gases are sent for further
processing, as it is a product, not an off-gas;
• During decoking the coke is burned off of the catalyst, sometimes with added
oxygen to ensure proper combustion, heating the catalyst;
• The heated catalyst is then entrained from the decoking reactor and separated
from the gas (this time an off-gas) using another cyclone; and
• The heated catalyst is then returned to the cracking fluidized reactor or risers.
The off-gasses will contain the fly ash and gaseous pollutants in the flue gas obtained
from the decoking reactor which can be removed using scrubbers, cyclones and
baghouses.
2.1-1
Combustion can also be used to heat process fluids or provide heat to a reaction
without the combustion gases coming into contact with the material being heated.
One such example is where a fluid can be heated in the same way that steam is
generated using a boiler, with any number of fuels (except waste oils, in which case
Category 8 should be used) combusted as the heat source. The heater can be any of
a number of designs very similar to typically seen boilers.
Emissions from the heater will contain ash (bottom and fly ashes) and gaseous
pollutants that may need treatment (such as baghouses or scrubbers) and disposal,
depending on the fuel used and operating conditions.
2.1.2.3 Biomass Gasification
Figure 2-5: Biomass gasification process
Gasification of biomass involves the conversion of the biomass material into a gaseous
fuel, commonly called a syngas, consisting mainly of CO and H2. Syngas can be used
as the starting material for many other processes including Fischer-Tropsch fuel synthesis.
Typically gasification involves the combustion of a carbonaceous solid either in the
absence of oxygen or with a controlled amount of oxygen. The process can be taken
to completion in which case the only solid removed is the ash, or partially where char is
formed (in which case Sub-category 3.3 should also be taken into account).
Industrial scale gasification can be performed by combustion of the biomass itself with
a controlled amount of oxygen to do either complete or partial gasification. The
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resultant gas is treated to remove impurities and entrained particulate matter before
being used on site or stored as a saleable product. In the case of complete gasification
the bottoms ash will often be disposed of either in a landfill or ash dam or recovered if it
has further use/value elsewhere.
2.1.2.4 Flaring
Figure 2-6: Flaring
2.1-4
Flaring is an open air combustion process usually on top of a stack. Flaring is used to
burn combustibles that cannot be safely processed, transported or taken off to storage
vessels. It is also sometimes added as a safety measure to burn off gasses and liquids in
a controlled manner during an emergency (i.e. fire, power failure etc.). Process upsets
and fluctuations may also result in excess gases that cannot be used in the process and
are thus flared.
Flaring presents the advantage of combusting gases (usually hydrocarbons*) which
may have toxic components to less toxic combustion products e.g. carbon dioxide and
water, but may be a source of other pollutants as well e.g.:
• Carbon monoxide from incomplete combustion;
• SO2 from combustion of compounds that contain sulphur;
• Particulate matter in the form soot from pyrolysis of organic compounds; and
• New compounds formed through de-novo synthesis.
* Not necessarily limited to hydrocarbons
2.1.5
2.1.2.5 H2S Combustion
Figure 2-8: Claus process diagram
Hydrogen sulphide (H2S) is one of the major by-products of petroleum liquid and gas fuel production and is treated
through combustion producing elemental sulphur with some SO2. In the Claus process, H2S rich flue gas is combusted to
produce elemental sulphur as a solid product and SO2.
2 H2S + O2 → S2 + 2 H2O
(hydrogen sulphide + oxygen react to produce elemental sulphur and water)
Some SO2 may be formed and thus the gasses are then catalytically processed to remove more of the sulphur (SO2 and
H2S) in the form of elemental sulphur.
2H2S + SO2 → 3S + 2H2O
(hydrogen sulphide + oxygen react to produce elemental sulphur and water)
The gasses exiting the catalytic process will be then be considered as off-gas (aka tail-gas).
2.1.6
2.1.3 ATMOSPHERIC EMISSIONS
Typical pollutants emitted to atmosphere from these processes include (but are not
limited to):
• Particulate Matter* (In the case of coal or crude oil use, particulate matter may
contain some metals);
• Sulphur Dioxide (SO2)*;
• Oxides of Nitrogen (NOx)*;
• Carbon Monoxide (CO);
• Volatile Organic Compounds (VOCs); and
• Hydrogen Sulphide (H2S).
* Regulated by the NEMAQA emission standards
The atmospheric emissions are expected to mainly be from the flue gas originating from
the combustion and are released to the atmosphere using a flue stack. Before being
released to the atmosphere the flue gas can be cleaned using a variety of processes,
depending on the target pollutant
• Scrubber: PM, SO2, NOx
• Cyclone: PM
• Baghouse: PM
Especially in the case of landfills, the improper handling of recovered particulate matter
can add to atmospheric emissions.
2.1.4 SPECIAL ARRANGEMENTS
• The NOx concentration shall be calculated as a flow-weighted average over all
combustion processes (refer to Section F: Calculations for method).
• No continuous flaring of hydrogen sulphide rich gases shall be allowed
• Allowable SO2 emissions from a refinery are calculated as the total sum of
emissions from combustion, sulphur recovery units, flares and catalytic cracking
units. For these purposes the catalytic cracking emissions will be calculated
without taking the hydro-treatment of feed into account.
2.2-1
2.2 SUB-CATEGORY 2.2: STORAGE AND HANDLING OF PETROLEUM
PRODUCTS
2.2.1 APPLICABILITY
Petroleum product storage tanks and product transfer facilities, except those used for
liquefied petroleum gas
All permanent immobile liquid storage tanks larger than 500 cubic meters cumulative
tankage capacity
Sub-category 2.2 covers the equipment specifications and air quality management
systems associated with storage and handling of liquid petroleum products with a total
cumulative storage capacity of 500 m3 or larger.
Liquid fuels are stored on producer, distributor and consumer sites which are covered in
this sub-category. The handling (loading and offloading of transport tankers) are also
covered in here as they may also release some volatiles into the atmosphere.
Liquefied petroleum gas (fuel gas that is temporarily liquefied for easier storage and
handling commonly referred to as LPG) is not covered.
2.2.2 PROCESS OVERVIEW
2.2-1
2.2.2.1 Fixed Roof Storage Tank
Figure 2-10: Fixed roof storage tanks
Figure 2-11: Diagram of a fixed roof storage tank
Fixed roof storage tanks vented to the atmosphere are used for liquids with a lower
vapour pressure as the lower vapour pressure will ensure very little vapour will form
2.2-2
and escape through evaporation or pose an explosive risk. The tanks can be various
shapes and sizes though all have a rigid shape with a fixed roof.
2.2.2.2 Floating Roof Storage Tank
Figure 2-12: Diagram of external and internal floating roof storage tanks
Floating roof storage tanks are used for liquids with higher vapour pressures to
eliminate the amount of vapours formed in the headspace thereby reducing the risk
of vapour build up which may lead to fire or explosion. The floating roof can be
either the actual roof of the tank or a floating bed that is used inside of a fixed roof
tank. In either case, the roof floats on top of the stored liquid. The floating roof thus
rises or falls as the liquid level rises or falls such that there is little if no void between
the roof and the free surface of the liquid. The roof will have seals around its edges
and in the sleeves around the legs and guide posts to minimise leakage and fugitive
release of vapours.
2.2-3
2.2.2.3 Pressure Vessel Storage Tank
Figure 2-13: Pressure vessel storage tank
Figure 2-14: Diagram of a pressurized storage tank
2.2-4
Pressure vessel storage is used for liquid or gaseous mixtures at pressures above
atmospheric pressure. Storage under pressure for gasses improves the mass of gas
that can be stored as the gas density is increased under pressure. Volatile liquids
require storage under pressure to contain, and prevent the release of, vapours.
These vessels are usually reinforced and cylindrical or spherical in shape to be able
to handle elevated pressures.
2.2.3 ATMOSPHERIC EMISSIONS
The atmospheric emissions to be expected from these sites are the vapours from the
stored petroleum products and will largely be made up of various VOCs. These may
be fugitive releases from seals, couplings, and handling activities, but may also be
vapours vented during filling or to relieve pressure build-up.
VOCs can be treated either destructively, using methods like flaring, or by
absorption and or adsorption scrubbers. Vapours may also be captured, condensed
and returned to bulk storage.
The collected vapours are sometimes stored in holding tanks to be reused when
fixed volume storage is emptied or for later processing.
2.2.4 SPECIAL ARRANGEMENTS
The following transitional arrangement shall apply:
• Leak detection and repair program approved by the licensing authority
should be instituted within two years following the date of publication of the
NEMAQA Section 21 notice (i.e. before 1 April 2012).
The following special arrangements shall apply for control of TVOCs from storage,
loading and unloading of
• Raw Materials;
• Intermediate Products; and
• Final Products.
With vapour pressures above 14kPa at normal storage temperature, alternative
control measures that can achieve the same or better results may be used instead:
• Storage vessels for liquids shall be of the following types:
o Vapour pressure up to 14 kPa: Fixed roof vented to atmosphere.
o Vapour pressure above 14 kPa up to 91 kPa: External floating roof tank with
primary and secondary seals for tank diameters larger than 20m, or fixed roof
tank with internal floating deck fitted with primary seal, or fixed roof tank with
vapour recovery system.
o Vapour pressure above 91 kPa: Pressure vessel
• The roof legs, slotted pipes and/or dipping well on floating roof tanks (except
for domed floating roof tanks or internal floating roof tanks) shall have sleeves
fitted to minimize emissions.
• Relief valves on pressurized storage should undergo periodic checks for
internal leaks using a portable acoustic monitor or, if venting to atmosphere
2.2-5
with an accessible open end, tested with a hydrocarbon analyser as part of
an LDAR programme.
• Loading and unloading: All installations with a throughput of 5000m3 per
annum must be fitted with vapour recovery units. All liquid products with a
vapour pressure above 14 kPa shall be loaded/unloaded using bottom
loading, with the vent pipe connected to a gas balancing line. Vapours
expelled during loading operations must be returned to the loading tank if it is
of the fixed roof type where it can be stored prior to vapour recovery or
destruction. Where vapour balancing and/ or bottom loading is not possible,
a recovery system utilising adsorption, absorption and condensation and/or
incineration of the remaining VOC, with a collection efficiency of at least 95%
shall be fitted.
• The actual temperature in the tank should be used for vapour calculations
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2.3 SUB-CATEGORY 2.3: INDUSTRIAL FUEL OIL RECYCLERS
2.3.1 APPLICABILITY
Installations used to recycle or recover oil from waste oils
Industrial fuel oil recyclers with a throughput > 5000 tons/month
This sub-category covers processes that convert waste oils (or oily mixtures) into oils
that have commercial use/value for example fuel oils for use in boilers and other
equipment. Used industrial oils (hydraulic oil, engine oil, etc.) can generally be
recycled into fuel oils (sometimes referred to as furnace fuels) or recycled to be
reused instead of being disposed of or destroyed (a common alternative to
recycling, covered in Category 8).
Processes that carbonize oils, are covered by Category 3.
Combustion of waste oils falls under Category 8.
2.3.2 PROCESS OVERVIEW
2.3.2.1 Waste oil processing
Figure 2-15: A centrifuge and distillation column, common process equipment
pieces in waste oil processing
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Figure 2-16: Waste oil recovery process
The primary aims of waste oil processing are usually to remove solid impurities and
water, and then separate the oil into different valuable fractions. Solids are typically
removed by centrifuging but other solids removal processes may be employed.
Water is typically removed by allowing the material to settle and separate. The oil is
then distilled to separate various fractions based on their volatility. The products can
then be sold for combustion to produce heat and steam for process and power
generation use. The distillation process required a heat source. This heat source may
qualify as a combustion installation (Sub-category 2.1, or Category 1).
Sometimes further processing is required to remove pollutants from the oil before
combustion as the flue gas would contain dangerous compounds or have
constituents that would be more expensive to remove after combustion than before,
such as the removal of aromatics by liquid-liquid separation.
Sources of emissions to air will be from the cleaning processes involved as well as the
handling of the products. Filtered sludge and the water removed will also contain
waste materials and the handling thereof can contribute to the air emissions. Some
of the vapours removed during distillation will also contribute to emissions.
2.3.3 ATMOSPHERIC EMISSIONS
Expected atmospheric emissions will be the vapours from the distillation and pyrolysis
processes. They will include but are not limited to:
• Volatile organic compounds (VOCs)*
• Carbon dioxide (CO2)
• Carbon monoxide (CO)*
• Heavy metals
• Sulphur (SO2)* (H2S and other reduced sulphurs)
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*Controlled by the NEMAQA standards
These can be treated using scrubbers as particulate matter will usually be low
enough for a wet bed scrubber to handle.
2.3.4 TRANSITIONAL AND SPECIAL ARRANGEMENTS
The following transitional arrangement shall apply:
• Leak detection and repair program approved by the licensing authority
should be instituted within two years following the date of publication of the
NEMAQA Section 21 notice (i.e. before 1 April 2012).
The following special arrangements shall apply for control of TVOCs from storage,
loading and unloading of
• Raw Materials;
• Intermediate Products; and
• Final Products.
With vapour pressures above 14kPa at normal storage temperature, alternative
control measures that can achieve the same or better results may be used instead:
• Storage vessels for liquids shall be of the following types:
o Vapour pressure up to 14 kPa: Fixed roof vented to atmosphere.
o Vapour pressure above 14 kPa up to 91 kPa: External floating roof tank with
primary and secondary seals for tank diameters larger than 20m, or fixed roof
tank with internal floating deck fitted with primary seal, or fixed roof tank with
vapour recovery system.
o Vapour pressure above 91 kPa: Pressure vessel
• The roof legs, slotted pipes and/or dipping well on floating roof tanks (except
for domed floating roof tanks or internal floating roof tanks) shall have sleeves
fitted to minimize emissions.
• Relief valves on pressurized storage should undergo periodic checks for
internal leaks using a portable acoustic monitor or, if venting to atmosphere
with an accessible open end, tested with a hydrocarbon analyser as part of
an LDAR programme.
• Loading and unloading: All installations with a throughput of 5000m3 per
annum must be fitted with vapour recovery units. All liquid products with a
vapour pressure above 14 kPa shall be loaded/unloaded using bottom
loading, with the vent pipe connected to a gas balancing line. Vapours
expelled during loading operations must be returned to the loading tank if it is
of the fixed roof type where it can be stored prior to vapour recovery or
destruction. Where vapour balancing and/ or bottom loading is not possible,
a recovery system utilising adsorption, absorption and condensation and/or
incineration of the remaining VOC, with a collection efficiency of at least 95%
shall be fitted.
• The actual temperature in the tank should be used for vapour calculations
Combustion of waste oil shall be subject to emission standards of Category 8.