Sufe Design and Optvation ofPI-oc.

ess Vents and Emission C o n t i d $wteins

by Center for Chemical Process Safety
Copyright 02006 John Wiley & Sons, Tnc.

2
MANAGEMENT OVERVIEW
A progression of societal drivers for air pollution control have prompted
the process industries to control process effluents and emissions. Laws and
regulations regarding protection of the natural environment and public
health have exerted an increasing impact on the refining, chemical, and
other process and related industries. In particular, the requirements
regarding air pollution controls have resulted in an increase in the use of
vent header systems. The development of regulations in the United States
and, in particular, the requirements of the Clean Air Act amendments and
related air pollution control regulations have greatly influenced the need
for vent header systems and their design and operation. Further discussion
of regulatory issues may be found in Chapter 3 of this book; an historical
perspective on air pollution control laws and regulations may be found in
Appendix I.
The importance of safe design and operation of vent header
systems has also been emphasized by recent incidents in the process
industries. Some of these incidents are described in Appendix H.
2.1. Impact on Vent Header Systems
Environmental air pollution control regulations over the past several decades
have arguably reduced the number of discrete emission points and increased
the number of emission vent collection systems. The economics of emission
reduction and treatment clearly encourage facilities to collect similar vent
streams into vent headers for processing in common treatment or disposal
systems before the final release to atmosphere.
Current air pollution control regulations have extended coverage to
more industry sectors and in many cases further restricted allowable end-of-
pipe post treatment releases in terms of either or both quantity or
concentration. Future regulations should be anticipated to continue this
general trend.

9
Safe Design and Operation of Process Vents and Emission Control Systems

So, what is the impact of these air pollution controls?

Vent header systems of some type have become commonplace in
many industry sectors for a wide range of processes. For the most part, they
have been added on to processes to meet the environmental requirements.
Possibly because of being viewed as an add-on, vent header systems have
often been treated similar to a utility service rather than as an extension of the
process operation. More often than not, utility systems are not accorded the
same level of safety technical review as would be given to a section of the
process. An objective of this book is to encourage the design and operation
of vent header systems and their treatment/disposal components with an
equivalent level of safety review as would be given the process itself.
Increasingly, regulations and operating permits have made the
availability of a functioning vent collection and treatment/disposal system a
requisite for the process to continue to operate within its approved legal
limits. This presents another reason to treat the vent header system as a part
of the process.
The regulations have had an impact on process economics as the
number of emission sources that require treatment have increased. As a
result, vent header collection systems have increased the number of
connected vents. Clearly, it is more cost-effective to treat a larger number of
vent streams in a common vent header system than to do so individually.
An increasing trend is the collection of vent streams from different processes.
However, the connection of multiple processes to a common vent header
system increases the probability of unsafe conditions due to differing process
start-up and shutdown schedules, vent header ownership issues affecting
maintenance or monitoring, and other factors such as:
Incompatible vent streams that could result in pluggage, violent
reaction, fire, or explosion in the header or treatment equipment
Unwanted flow of materials via the vent header from one
process vessel to another
Vent header and treatment system flow capacity or restriction
issues resulting from simultaneous multiple vent streams
Increasing difficulty of identifying hazards as the system
becomes more complex

10
 Chapter 2 - Management Overview

Current and future regulations may also have an impact on the

complexity of the treatment systems used. To meet certain requirements, it
may be necessary to add additional intermediate or end-of-pipe treatment
and disposal systems, such as a scrubber on the combustion products stream
from a thermal oxidizer. The addition of multi-step treatment and disposal
systems can increase the complexity of the overall vent header system and
may increase the probability of creating unsafe conditions.
Certainly there are other factors that impact decisions by a facility
regarding the use of vent header collection and treatment systems for control
of their emissions, including their public image and preservation of the right-
to-operate in their communities, but the compelling impact has been from the
air pollution control regulations.

11