--`,,-`-`,,`,,`,`,,`---A P I P U B L * 3 3 1 74 0732290 05YY919 03T ACKNOWLEDGMENTS THE FOLLOWING PEOPLE ARE RECOGNIZED FOR THEIR CONTRIBUTIONS OF TIME AND EXPERTISE DURING THIS STUDY
Program-oriented Measurements
Pollution prevention activities can be effectively indicated by the implementation of waste minimization programs aimed at reducing waste Although these programs may include specific metrics to quantify the amount of waste reduced, the mere existence of such programs is a key factor in this category.
Many companies have instituted programs aimed at preventing pollution and all generators of over
1000 kilograms per month of hazardous waste are required to have a waste minimization program in place2 As EPA recognized in its Interim Final Guidance to Hazardous Waste Generators on the
A waste minimization program must be flexible in its design and implementation, accommodating both formal corporate-wide initiatives and informal facility-specific efforts These programs can focus on various types of waste, starting with hazardous materials and potentially expanding to include non-hazardous wastes over time Additionally, they may prioritize releases based on the medium—air, water, or land—focusing first on those that present the highest risk Specific waste types, such as used motor oil or office paper, can also be targeted for reduction.
Advantages Program-oriented measures can be used anywhere in a company or facility The information necessary is relatively easy to collect and can be obtained quickly at relatively low cost
Program measurements serve as indicators of pollution prevention progress; however, they offer limited insights into the specific activities undertaken These measurements do not quantify the actual amount of waste reduced or assess the effectiveness of the programs involved.
Used oil from motor vehicle fleets is a common waste stream in the petroleum industry Recycling and recovering oil from used oil not only benefits the environment but also enhances energy efficiency The primary objective of these programs is to ensure proper handling of nearly all used oil Additionally, assessing the percentage of vehicles participating in recycling programs serves as an effective measure of the program's reach and impact.
To meet the requirements of the Solid Waste Disposal Act, specifically sections 3002(b) and 3005(h), large quantity generators of hazardous waste are mandated to certify the implementation of a program aimed at reducing both the volume and toxicity of hazardous waste produced, to the extent that it is economically feasible.
In its guidance document, EPA specifies that waste minimization programs should have each of the following six elements:
Effective waste management programs require top management support, a clear understanding of waste generation and management costs, and regular assessments for waste minimization It is essential to allocate costs appropriately and encourage technology transfer to enhance efficiency Additionally, the implementation and evaluation of these programs are crucial While the Guidance document offers numerous examples of waste minimization activities, generators have the flexibility to choose the specific activities they wish to implement within these six key areas.
Table 1 below lists other examples of program-oriented measurements
Table 1 Examples of Program-Oriented Measurements
Companies have already initiated used oil recycling programs at service station outlets
Office workers can be contacted at different facilities for a quick confirmation of program status
May refer to sectors other than refining if TRI SIC codc list is expanded Because of
1 EPA definition of "facility," some refineries already repon releases from adjacent marketing facilities
Total # facilities generating hazardous waste
Total # facilities generating non-hazardous waste
Total # facilities generating or processing used motor oil
TRI releases # facilities with program/
Total # facilities reporting TRI releases
I wastes may already exist to comply with State or local requirements
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Activity-based Measurements
Activity-based measures are semi-quantitative indicators of pollution prevention efforts linked to existing equipment or procedures These measures focus on specific processes or operating practices that contribute to an overall program aimed at reducing waste streams or chemical releases To effectively implement activity-based measurements, detailed information on the benefits of specific processes or equipment is essential For instance, solvent-free paint stripping processes and the use of mixers in storage tanks to minimize settleable solids are examples of practices that can help develop these measurements.
Activity-based measurements offer enhanced insights compared to program-based measurements by providing specific data on waste reduction associated with each activity This approach enables companies to develop more quantitative metrics for residual waste reduction As these measures are linked to the equipment and procedures currently in operation, they provide a stronger basis for assessing actual waste reduction outcomes.
Limitations Most of these measurements, while simple technically, may require new data collection
The phaseout of chromium-based corrosion inhibitors in refinery cooling towers exemplifies an activity-based measure aimed at reducing pollution This initiative focuses on selecting less toxic alternatives to replace harmful chemicals in waste streams By tracking the number of cooling towers that have transitioned from chromium-based inhibitors to safer substances, companies can gauge their progress in minimizing pollution from this specific compound Furthermore, knowing the typical chromium usage in cooling towers allows for an estimation of the total reduction achieved through these substitutions.
A notable activity-based measure in the exploration and production (E&P) sector is the implementation of a multi-compartment, managed reserve pit system This system effectively segregates waste generated during drilling operations, including contaminated drilling fluids and rainwater By separating different types of drilling residuals, such as those contaminated by salt formations or oil-based muds, the managed pit system has been shown to reduce the volume of waste needing offsite disposal and may also decrease the overall amount of drilling fluids required.
Table 2 Examples of Activiợy-Based Measurements
Some additional data needed, procedures known
Conversion of non- segregated sewers to segregated sewers
Use of methods to reduce wastes from sandblasting
Significant new data needed Minimal
Use of domes in floating roof tanks
Substitution of soaps used to wash down terminal pads
Number of USTs with secondary containment
Use of diesel oil- based drilling muds
# of processes with dedicated sewer lines/Total
# of facilities with programs to reduce sandblasting fines/ Total refineries reporting
# facilities with street sweepers/Total # facilities
# times a tank must be cleaned/year
# floating roof tanks with domes/Total # of floating roof tanks
# terminal pads using low toxicity soaps/Total # terminal pad operations
# USTs with secondary containment/Total # USTs in use
# wells drilled using diesel oil-based drilling muds/
Total # wells completed in a given year
Measure requires capital investment; pay-back time varies from site to site
Inappropriate to measure progress quantitatively Count of methods in place will indicate progress
Progress tracked indirectly by measuring contamination in facility discharge water
Frequency data can be used to estimate/monitor generation of solvent waste Tank cleaning on
"as needed" basis can reduce solvent waste
Measure may require major capital investment
Substitution for a less toxic soap solution should not reduce cleaning quality
Company records on upgrading of petroleum UST systems contain most information
Measures reuse or replacement of diesel oil- based muds with other lubricants Purchases of lubra beads and gilsonite - based additives may provide an indirect indication of increasing replacement
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Mass-based measurements
Mass-based measurements provide quantitative data on the mass of waste or residual materials produced or managed, which can be obtained through precise weighing or professional estimates Due to potential variations in estimation accuracy, caution is necessary when comparing data from different facilities or over time However, when collected consistently and periodically, these measurements can effectively indicate a facility's performance Examples include the estimated releases reported in the Toxics Release Inventory and the quantities of residual streams in API’s Refining Survey.
Mass-based measurements offer greater detail than program or activity-based measures regarding the residuals managed by a facility When integrated with other facility data, these measurements can assess operational efficiency For instance, analyzing waste inventories over several years alongside production levels or throughput values can reveal the efficiency achieved over time.
Mass-based measurements have significant limitations, primarily because they often rely on estimates that depend on the accuracy of their underlying assumptions When comparing these estimates between different facilities or over time at the same site, it is crucial to ensure that the assumptions used are comparable; otherwise, the data may not be truly reliable Additionally, mass-based measurements do not consider variations in production rates influenced by product demand, the type of crude processed, or changes in process efficiency, all of which can affect waste generation rates Furthermore, obtaining accurate mass-based data can be resource-intensive.
The API Refining Survey, previously known as the Solid Waste Survey, aims to gather mass-based measurements of residuals produced by U.S refineries and their management practices Refineries report the wet tons of 28 different residual streams and classify the material's disposition according to the environmental management hierarchy, which includes source reduction, recycling, treatment, and disposal, detailing the quantity at each stage API collects this data annually, aggregates it, and publishes the findings in annual reports.
Data collected over various years allows for performance comparisons over time, as illustrated in Table 3 These mass-based measurements assess pollution prevention performance at three levels: industry-wide progress, facility-specific improvements, and aggregated data from individual refineries.
See The Generationand Management of Waste and Secondary Materialsin the Petroleum Refiningindustry: 1987- I988,
API Publication No 849-300000, February 1991, and Generationand Managementof WastesandSecondaryMateria1s:Petroleum
Refining Performance 1989 Survey, API Publication No 849-30300, June 1992
The corporate profile of pollution prevention efforts is highlighted by the API PUBL*33L 9 4 = O732290 0544934 3 4 By combining residual generation quantities with other parameters, such as annual crude throughput, we can assess the efficiency levels of the refining process.
Data on the management of residuals, alongside the generated residuals data, can effectively showcase pollution prevention performance By plotting the quantities of residuals that are recycled, treated, and disposed of, one can visualize the evolution of management methods over time For instance, Figure 1 illustrates the changes in K-waste management from 1987 to 1989, revealing an increase in the percentage of materials being recycled and treated, while the rates of land treatment and disposal have declined This approach allows facilities or companies to present their pollution prevention performance by plotting data for each residual stream or as an aggregate for the entire facility.
Year / Thousands of Wet Tons
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Table 3 Waste Generation Estimates for the Total U.S Refining Industg
Spent Caustics Biomass Contaminated soils/solids DAF float
Other inorganic residuals NOS Pond sediments
Other residuals NOS API separator sludge FCC catalyst or equivalent Primary sludge (F038) Slop oil emulsion solids Residual coke/carbon/charcoal Residual amines
Primary sludge (F037) Nonleaded tank bottoms Spent acids
Oil contaminated waters (not wastewaters) High pWlow pH waters
Other oily sludges/organic residuals NOS Other contaminated soils NOS
Hydroprocessing catalysts Spent Stretford solution Other spent catalysts NOS Residual oilshpent solvents TSD Leachate (F039) Residual sulfur Spent sulfite solution Heat exchanger bundle cleaning sludge Leaded tank bottoms
From The Generation and Management of Residual Materials: 1991; Petroleum Refining Performance,
The Toxic Release Inventory (TRI) data, collected annually by the EPA, serves as a crucial example of mass-based measurements Facilities are mandated to report estimated quantities of over 300 toxic chemicals released into the air, water, land, or injected underground In 1990, the petroleum refining industry reported the amounts of the top 25 chemicals released across various media, as detailed in Table 4 This reporting format can be utilized at the facility or company level over multiple cycles to monitor chemical release quantities Additionally, TRI data can be integrated with other parameters, such as crude throughput or production amounts, to assess efficiency rates.
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Table 4 Refinery Releases and Transfers of Top 25 TRI Chemicals by Medium: 1990 (i mmonium nitrate
For industries not involved in the API Annual Refining Survey or TRI release reporting, alternative mass-based measurements can be established Specific residual streams can be identified within sectors, allowing for the tracking of generation and management quantities akin to current practices in refining Furthermore, chemicals can be categorized by sector or facility, enabling the development of a system to monitor releases over time Additional ideas for mass-based measurements are outlined in Table 5.
Table 5 Examples of Mass-based Measurements
# drums of hazardous waste generatedyear
Tons of off-spec products generatedyea
# gallons of waste water producedyear
Number of gallons lost in reportable spills/yeai
Some additional data needed, procedures known
Company records tracking hazardous waste management already exist
Company records trackthis ~ (If off-spec product RCRA hazardous waste, records document waste treatment anc disposal.)
This information may be required for discharge permits The amount of process & other water used provides an indication of the amount of waste water discharged
Company records already contain information on spills to land and water
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Concentration-based Measurements
In chemistry, concentration denotes the quantity of one substance within another, commonly expressed in units of weight or mass per volume (e.g., mg/kg, mg/L, mg/cm³) In the petroleum industry, key concentration measures include the levels of petroleum hydrocarbons in drilling muds for disposal, phenols in refinery effluent process water, and chromium-based compounds in cooling tower blowdown.
Advantages Concentration-based measurements are the best performance measures for processes designed to reduce pollutant concentrations These measures are also valuable where concentration-based sensitivities exist
Concentration-based measures often demand substantial resources, necessitating sample collection and analysis Additionally, the required precision plays a crucial role, as there is an inverse relationship between precision levels and the costs of analytical techniques.
Efforts in refining have prioritized minimizing the use of chromium-containing inhibitors in cooling towers Phosphate-based corrosion inhibitors, which are less toxic, can effectively replace these chromium-based options Traditionally, the concentration of chromium in the cooling tower blowdown is measured to assess its presence.
Normalized Efficiency Measures
Normalization is a technique that allows for the comparison of different facilities by relating one variable to another on a "per unit" basis, enabling an assessment of their efficiency This method helps to mitigate issues that may arise when evaluating operations at a single facility over time By indexing one parameter against another variable, such as activity or production, for a comparable time frame, it becomes possible to evaluate the performance or efficiency of the activity without being affected by fluctuations in operating rates.
For example, a large facility may generate 100 pounds of waste per day, and be viewed as less
A larger facility producing 100 units of product daily may be perceived as more environmentally friendly than a smaller facility that produces only 1 unit, despite generating 100 pounds of waste compared to the smaller facility's 10 pounds This perception shifts when considering waste per unit of product; the larger facility generates only 1 pound of waste per unit, while the smaller facility produces 10 pounds per unit, highlighting the importance of evaluating waste generation relative to production output.
"Normalization" of the residual generation relative to the output of the facility indicates that the larger facility has a more environmentally efficient operation than the smaller one
Measures of the efficiency of pollution prevention activities can be normalized or indexed against a variety of related measures Three methods of normalizing are discussed in this report:
Measuring performance through activities and operations aligns with the initial category of measures discussed in this report, as it requires less detailed and more accessible information The most prevalent production measure is throughput, applicable to both crude processed at refineries and products managed at various terminals In exploration and production (E&P) operations, well-depth serves as a typical production measure, helping to normalize the use of water and drilling muds Additionally, normalizing by residual generation is a unique measurement method that assesses pollution prevention progress by evaluating the fractions of waste managed beneficially or the percentage change from theoretical values.
Normalization of pollution prevention activities allows for effective comparisons between facilities and assesses the relative efficiency of different approaches Utilizing throughput as a measurement method simplifies the evaluation of pollution prevention progress By normalizing based on residual generation, facilities are incentivized to discover beneficial uses for materials typically considered waste, promoting overall efficiency This approach also encourages a reduction in reliance on already burdened waste disposal processes and landfills.
Limitations The primary disadvantage is that normalization can oversimpliQ the situation and may give misleading information Conversely, a normalization process that is more complex than a linear
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The relationship between reportable spills and the total number of transfer operations at marketing or marine terminals can be complex, leading to potential misunderstandings among the target audience For instance, while normalizing refining wastes to crude input may seem straightforward, it fails to consider crucial factors such as the type of crude oil available, the specific product mix needed, and other significant variables like rainfall and airborne dust levels that impact refinery operations.
Marketing Some additional data needed, but procedures known
Normalizing by waste generation can be counterproductive as it may promote the use of waste rather than emphasizing the reduction of residuals For instance, a process change that decreases the amount of recyclable oil in an API separator, while not affecting the non-usable residual, can still represent a positive pollution prevention effort However, this normalization approach would inaccurately portray such changes negatively, as it would show a decrease in the percentage of waste that is beneficially reused.
Examdes As noted above, measurements normalized by activity or operations are the easiest to obtain Several examples are provided in Table 6
Table 6 Efficiency Measures Normalized By Activity
Transfer spills at marketing or marine terminals
OMoad spills for delivery trucks
# spills/Total # deliveriedyear Marketing New data to be I I retrieved
# reportable spills/miles traveled by tmcks/year data needs involved
Measure reflects quality of transfer operationsípractices Variables can be retrieved from company records
Variables could be determined from facility records
Measure captures rate of spills at deliveries and potential for spills on the road associated with accidents
Additional examples of measures normalized by production for each segment of the industry are presented below
The effectiveness of pollution prevention at a refinery can be accurately assessed by aggregating the total volumes of API, DAF, and slop oil emulsion solids, as numerous processes contribute to these streams The annual production of these sludges is then normalized against the total throughput of the facility.
To assess the quality of feedstock, it is essential to normalize against the total ash content, calculated by multiplying the total crude throughput by the percentage of ash in the feedstock This metric serves as an efficiency measure for recapturing impurities within the feedstock Enhancements in this weighted figure indicate progress in minimizing other contaminants.
The API PUBL X3317407322900544742412 indicates that residuals, including water, sands, and fines, increase with larger sludge volumes Measuring the reduction in sludge volume is straightforward, as these volumes can be easily quantified, even in the absence of existing measurement programs However, normalizing these measurements over time may pose challenges due to the irregular cleaning schedules of sludges.
Reducing storm basin sludges presents a challenge due to limited available data These sludges consist mainly of petroleum-based emulsions mixed with sand, soil particles, dust, and rainwater The volume of these materials is influenced by site size, prevailing winds, atmospheric conditions, and rainfall, but can be decreased through onsite cleanup efforts The reduction of storm sludges can be effectively normalized by considering the facility's throughput and annual rainfall.
Specialized drilling techniques, such as multidirectional or horizontal drilling, can enhance pollution prevention efficiency as a secondary benefit These methods not only boost field productivity but also minimize reserve pit waste and reduce the overall land surface disturbance relative to the total oil recovered.
Normalized efficiency measures in marketing operations include the reduction of contaminated soils from spills, which reflects the effectiveness of quick spill response in minimizing total losses The Federal Government utilizes the cubic feet of contaminated soils as a standard metric to assess the necessary remedial actions under Superfund or RCRA, highlighting its acceptance as a reliable measure.
"measure" of pollution, data is already available wherever a spill has resulted in a formal remedial action Thus the burden of calculating an internal reporting measurement is reduced
To enhance marketing operations, it is essential to focus on minimizing product loss due to storage tank leaks Implementing this measure necessitates gathering more data, as the extent of product loss from leaks is often unquantified.
Table 7 presents other examples of normalized measures for each segment of the industry
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Marketing Additional data needed, procedures known
Table 7 Examules of Efficiencv Measures Normalized Bv Production
Sector Reauirements Comments ùRI emissions for specific rhemical/Barrel throughput/ year iefining Data already collected
Extensive TRI data on fugitive emissions available by chemical Heat exchanger sludge/
Refining Some additional data needed, procedures known
Reducing bundle sludge volume & improving efficiency possible through addition of nontoxic antifoulant chemicals
Spent catalyst can be recycled by cement processors offsite
As with primary process sludges, reductions in biotreater sludge represent improved recovery of usable oils
Tons catalysts sent to disposalBarre1 throughput
Significant new data needed Refining cubic feet of contaminated soils/Barrel throughput/year
Although a useful measure of damage caused by a release, it may not correlate with volume of product lost May be better to total product losses Der vear
Marketing Significant new data needed
Leaks from storage facilities andor pipelines cannot be reliably differentiated Leak detection equipment & SOPS, maintenance, and other means can reduce total product lost
Statistic measures national trends in waste generation/ volume of wellbores drilled
Not for use in management of well operations
Reclamation processes at large centralized facilities can reduce amine usage rates
Waste in reserve pit at closure/volume of wellbore
Total purchases (MEA, DEA, MDEA)/total gas processed (MMCF)
New data, instrumentation & procedures needed
New data, instrumentation & procedures needed
E&P (large natural gas processing plants)
E&P (large natural gas processing D1ant.S)
Total purchases TEG/Total gas processed (MMCF)
Reclamation processes at largt centralized facilities can reduce TEG usage rates
The third type of normalized efficiency measure relies on residual generation data It assesses the percentage of oily sludges needing disposal compared to total oily sludges, serving as an efficiency metric indexed by waste generation This measure indirectly reflects the volume of sludge that is effectively managed through reclamation or repurposed for energy recovery.
Disposal does not include sludge destined for reclamation or recycling
Statistic standardizes measurement of subsurface injection of produced water
Normalization of waste management can be observed in the increased handling of produced water by Class II designated disposal wells and the rising proportion of produced water that is beneficially reused instead of being discharged under an NPDES permit Beneficial uses of produced water encompass irrigation, livestock watering, and reinjection for disposal or enhanced recovery in Class II wells.