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Source: HANDBOOK OF PETROLEUM REFINING PROCESSES

CHAPTER 11.2

BELCO EDV WET SCRUBBING SYSTEM: BEST AVAILABLE CONTROL TECHNOLOGY (BACT) FOR FCCU EMISSION CONTROL
Edwin H. Weaver and Nicholas Confuorto
Belco Technologies Corporation Parsippany, New Jersey

THE FCCUA UNIQUE PROCESS FOR EMISSIONS CONTROL


The control of particulate and SO2 emissions with wet scrubbing systems is not uncommon. However, the control of these emissions, combined with the special needs and requirements of the fluid catalytic cracking unit (FCCU) process, indeed makes this a special process for wet scrubbing systems. Uncontrolled particulate (catalyst) emissions from this source vary depending on the number of stages of internal and external cyclones. Although cyclones are effective in collecting the greater constituent of catalyst recirculated in the FCCU regenerator, the attrition of catalyst causes a significant amount of finer catalyst to escape the cyclone system with relative ease. Typically, emissions will range from 3.0 to 8.0 lb per 1000 lb of coke burn-off. Sulfur emissions in the form of SOx (SO2 and SO3) from the regenerator vary significantly depending on the feed sulfur content and the FCCU design. In the FCCU reactor, 70 to 95 percent of the incoming feed sulfur is transferred to the acid gas and product side in the form of H2S. The remaining 5 to 30 percent of the incoming feed sulfur is attached to the coke and is oxidized into SOx which is emitted with the regenerator flue gas. The sulfur distribution is dependent on the sulfur species contained in the feed, and in particular the amount of thiophenic sulfur. SO2 can range from 200 to 3000 parts per million dry volume basis (ppmdv), whereas SO3 typically varies from an insignificant value to a maximum of 10 percent of the SO2 content. The FCCU application presents the additional requirement that in order to match the reliability of the FCCU, the air pollution control equipment must operate on-line for 3 to
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SULFUR COMPOUND EXTRACTION AND SWEETENING

5 years without interruption. It must be able to tolerate significant fluctuations in operating conditions, withstand the severe abrasion from catalyst fines, and maintain operation through system upsets. The robust design of the wet scrubbing system must tolerate all operations without requiring a shutdown. It is paramount that the operability of the air pollution control system be no less than that of the FCCU process.

CONTROLLED EMISSIONSA TREND TOWARD LOWER LEVELS


By examining the trends of emissions regulations in the United States, a trend for better control of emissions from FCCUs can be established. The United States Environmental Protection Agency (USEPA) established New Source Performance Standards (NSPS) for emissions from FCCUs for new or significantly modified units. A summary of this standard is provided in Table 11.2.1. Additionally, a maximum achievable control technology (MACT) standard is in the final stages of promulgation. This standard, which is intended to regulate the amount of hazardous air pollutants (HAPs) from the FCCU, essentially established the particulate emission level at the same level as NSPS, or 1.0 lb/1000 lb of coke burned. The USEPA also has been aggressive in pursing enforcement actions against refiners who, in its opinion, have significantly modified their facilities but avoided the NSPS regulations. This has resulted in several consent decrees where a refiner has agreed to install pollution controls to mitigate the impact of any past modifications made to its facility. Refiners who have reached consent decrees with the USEPA include Koch Refining, British Petroleum, Motiva/Equilon/Shell, Marathon Ashland LLC, Holly Corporation, Premcor Refining, Conoco, and Murphy Oil. In many cases, the agreed-to emissions levels (25 ppm SO2 and 1. 0 lb/1000 lb of coke burned) are more restrictive than the NSPS regulations. Wet scrubbing systems are mandated for many of the facilities in the consent decrees.

A PROVEN WET SCRUBBER DESIGN FOR THE FCCU PROCESS


The worldwide leading technology to control emissions from this process is Belco Technologies Corporations EDV wet scrubbing system. This wet scrubbing system controls particulate (catalyst dust), SO2 (sulfur dioxide), and SO3 (sulfuric acid mist) all in one system. Removal of relatively coarse particulate, which constitutes the majority of the par-

TABLE 11.2.1 Pollutant Particulate SO2

New Source Performance Standards for FCCU Regenerator Emissions FCCUs affected Emission regulation 1.0 lb/1000 lb Coke burn-off and 30% opacity 50 ppm SO2 or 90% reduction, whichever is least stringent 9.8 lb SO2/1000 lb coke burn-off Or 0.3% Sulfur in feed (% by weight)

All With add-on SO2 control device Without add-on SO2 control device

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ticulate from the FCCU, is accomplished in the absorber vessel where caustic soda (NaOH) or other reagents are utilized to absorb SO2 and discharge it in the form of a soluble salt. Fine particulate control and significant reduction of SO3 in the form of sulfuric acid mist are accomplished in devices known as filtering modules. Excess water droplets are removed in highly efficient droplet separators. An EDV wet scrubbing installation in Texas is shown in Fig. 11.2.1. Another U.S. Gulf Coast refinery EDV wet scrubber is illustrated in Fig. 11.2.2. The flue gas from the FCCU enters the spray tower, where it is immediately quenched to saturation temperature. Although the flue gas normally enters the wet scrubber after passing through a heat recovery device, the system is designed so that it can accept flue gas directly from the FCCU regenerator at the temperature at which it exits the FCCU regenerator. The spray tower itself is an open tower with multiple levels of spray nozzles. Each level of nozzles can have one or multiple nozzles depending on the diameter of the absorber vessel. Since it is an open tower, there is nothing to clog or plug in the event of a process upset. In fact, this design has handled numerous process upsets where more than 100 tons of catalyst has been sent to the wet scrubber in a very short period of time. An illustration of this spray tower is provided in Fig. 11.2.3.

FIGURE 11.2.1

EDV wet scrubbing system in Texas.

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SULFUR COMPOUND EXTRACTION AND SWEETENING

FIGURE 11.2.2 EDV wet scrubber at U.S. Gulf Coast refinery.

In the spray tower, coarse particulate is removed through the simple process of liquid from the spray nozzles impacting on the particulate. Reduction of SO2 is accomplished by adding reagent, usually caustic, to the liquid being circulated in the absorber vessel. Assuming caustic is used, the SO2 reacts with caustic to form sodium sulfites, some of which oxidizes to sodium sulfates. Both of these are dissolved solids. These nozzles, used for both the quench and the spray tower, are LAB-G nozzles. They are a unique design and a key element of the system. They are nonplugging, constructed of abrasion-corrosion-resistant material, and capable of handling high concentrated slurries. Unlike in most nozzle designs, this nozzle has a large opening that cannot plug and is designed to operate at low liquid pressure, both important factors in long-term life. As previously noted, these nozzles remove coarse particulate by impacting on the liquid droplets. They also spray the reagent solution to reduce SO2 emissions. By design, they produce relatively large water droplets, which prevent the formation of mist and the need for a conventional mist eliminator that will be prone to plugging. This is unique in wet scrubbing system designs as any other design that uses a nozzle which produces mist size water droplets will require a mist eliminator to eliminate these droplets. Mist eliminators have

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FIGURE 11.2.3 EDV absorber vessel/spray tower.

plugged in the presence of catalyst. This nozzle is illustrated in Fig. 11.2.4 and is shown spraying liquid in Fig. 11.2.5. Upon leaving the spray tower, the saturated gases are directed to the EDV filtering modules for removal of the fine particulate. This is achieved through saturation, condensation, and filtration. Since the gas is already saturated, condensation is the first step in the filtering modules. The gases are accelerated slightly to cause a change in their energy state, and a state of supersaturation is achieved through adiabatic expansion. Condensation

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SULFUR COMPOUND EXTRACTION AND SWEETENING

FIGURE 11.2.4

Absorber vessel spray nozzle.

FIGURE 11.2.5 Absorber vessel nozzle spraying liquid.

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occurs on the fine particulate and acid mist. This causes a dramatic increase in size of the fine particulate and acid mist, which significantly reduces the required energy and complexity of its removal. A LAB-F nozzle located at the bottom of the filtering module and spraying upward provides the mechanism for the collection of the fine particulate and mist. This device has the unique advantage of being able to remove fine particulate and acid mist with an extremely low pressure drop and no internal components which can wear and be the cause of unscheduled shutdowns. It is also relatively insensitive to fluctuations in gas flow. This device is illustrated in Fig. 11.2.6.
GAS IN

CONDENSATION

FILTERING SPRAY

WATER OUT
FIGURE 11.2.6

GAS IN

WATER IN

Filtering module.

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SULFUR COMPOUND EXTRACTION AND SWEETENING

To ensure droplet-free gas, the flue gas then goes through a droplet separator. This is an open design that contains fixed spin vanes that induce a cyclonic flow of the gas. As the gases spiral down the droplet separator, the centrifugal forces drive any free droplets to the wall, separating them from the gas stream. This device has a very low pressure drop with no internal components which could plug and force the stoppage of the FCCU. This device is illustrated in Fig. 11.2.7.

GAS IN

SPIN VANE

WATER OUT GAS OUT


FIGURE 11.2.7 Droplet separator.

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ALTERNATE CONFIGURATIONS
One of the great benefits of the EDV wet scrubbing systems modular design is that the same proven modules can be arranged in many different configurations to fit a specific site requirement. The system can be provided in an upflow configuration to reduce plot space. Several of these designs have been sold to date. The system can also be provided in a jet ejector configuration to offset pressure drop across the system. This configuration is marketed by Belco as its NPD design (which stands for no pressure drop). The major advantage of the Belcos NPD configuration over any other jet ejector configuration is that although it utilizes the same proven jet ejector units as the competition, the BELCO approach does not rely exclusively on the jet ejector to achieve the required efficiency. Belco places the jet ejectors after its primary scrubbing module (the quench and spray tower). Therefore, by the time the gas reaches the jet ejectors, it has already been cleaned of most of the particulates and SO2. The jet ejectors are used only for polishing and for developing the required draft. This provides higher efficiencies than other jet ejector designs; and by placing the jet ejectors on the clean end of the scrubber, the wear and maintenance typically associated with jet ejectors are greatly reduced.

SCRUBBER PURGE TREATMENT


Assuming that a sodium-based system is used, purge from the wet scrubbing system contains catalyst fines as suspended solids, and sodium sulfite (NaSO3) and sodium sulfate (NaSO4) as dissolved solids. The purge treatment system removes the suspended solids and converts the sodium sulfite to sodium sulfate to reduce the chemical oxygen demand (COD) so that the effluent can be safely discharged from the refinery. To remove the suspended solids, the purge treatment system contains a clarifier to separate the suspended solids and a filter press or dewatering bins to concentrate the solids into a filter cake which is cohesive and can be readily disposed of. The scrubber purge enters the clarifier from a deaeration tank. The solids settle out in the clarifier and are removed from the clarifier in the underflow. The underflow from the clarifier is sent to a filter press or dewatering bins where the excess water is removed. The solids are sent to disposal while the water is returned to the clarifier. The effluent is then sent to the oxidation towers. The oxidation system consists of towers where air is forced into the effluent to oxidize the sodium sulfite to sodium sulfate. Effluent from the oxidation towers, which is now cleansed of catalyst (suspended solids) and has a low COD level, can be processed in the refinery wastewater system or possibly directly discharged from the refinery. A typical purge treatment system that employs a filter press is illustrated in Fig. 11.2.8.

REAGENT OPTIONS
Historically, most wet scrubbing systems on FCCUs have utilized caustic (NaOH) as the reagent. Caustic is readily available in refineries, is easy to handle, and has no solid reaction by-product. These systems have proved to be very effective and reliable, with continuous operation in excess of 5 years while handling all upset conditions that can occur. With the escalating cost of caustic and the need to reduce the total liquid effluent from the system, some refiners are using soda ash (Na2CO3) as a reagent. The primary differ-

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SULFUR COMPOUND EXTRACTION AND SWEETENING

PURGE WATER

FLOCCULENT CLARIFIER MAKEUP WATER UNDERFLOW PUMP FILTER PRESS FILTER CAKE STORAGE TANK

EFFLUENT DISCHARGE

OXIDATION TOWERS AIR BLOWER


FIGURE 11.2.8 Typical purge treatment system.

ence between soda ash and caustic is that soda ash is delivered as a bulk solid and mixed into a liquid on site. However, it has the advantage of having no chlorides. High concentrations of chlorides attack the 316L stainless steel material used in the wet scrubber, so the level of chlorides must be controlled. With no chlorides from the soda ash, the dissolved solids concentration in the wet scrubber can be increased, thus reducing the amount of liquid that must be purged. Depending on the strategy for liquid effluent control, a low discharge volume is very important. In a typical system, soda ash is delivered in dry bulk form. As the soda ash is blown into the storage silo from the truck, an eductor-type wetting system is used to mix the dry soda ash with water and slurry the soda ash. Soda ash liquor is drawn from the top third of the tank and pumped to the wet scrubbing system, where some of the soda ash is used by the wet scrubber. The amount used by the wet scrubber is based on pH control. The remaining soda ash is returned to the storage tank. This ensures that there is a continuous flow both to and from the storage tank. A typical soda ash delivery system is illustrated in Fig. 11.2.9. Regenerative wet scrubbing systems are also gaining popularity. These systems have relatively low operating costs and have no liquid effluent discharge. In a typical regenerative system, the buffer is circulated in the EDV wet scrubbing system where it reacts with and removes the SO2 in the flue gas. The buffer, rich in SO2, is then sent to a regeneration plant. Before entering the regeneration process, the SO2-rich buffer is heated in a series of heat exchangers. The first heat exchanger utilizes the heat from the regenerated buffer being returned to the absorber vessel, while the second heat exchanger utilizes steam. After being heated, the buffer is sent to a double-loop evaporation circuit. These circuits use a heat exchanger, separator, and condenser to separate water and SO2 from the buffer. Buffer, which is free of SO2, is sent to a mixing tank, while the evaporated water and SO2 are sent to a stripper.

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WATER SUPPLY

TO SCRUBBER

WATER PUMPS

SODA ASH CAUSTIC


FIGURE 11.2.9 Typical soda ash delivery system.

In the stripper/condenser, the gas is cooled by counterflowing condensate from the condenser. The temperature of the SO2-rich gas that leaves the condenser is used to control the amount of cooling medium that must be sent to the condenser. Condensate from the stripper is returned to the buffer mix tank. The SO2-rich gas, containing at least 90 percent SO2 with the remainder being water, is ready for transport to a process unit. In the refinery, this normally would be the sulfur recovery unit (SRU), where it would be converted to elemental sulfur. Also, this SO2 that is sent to the SRU can help debottleneck the SRU process, especially if it is running close to capacity. At periodic intervals, a quantity of concentrated buffer is bled from the evaporation circuit along with some condensate from the stripper. This is done to maintain a constant concentration of sodium phosphate in the buffer system. Sulfates are removed from this bleed stream through a patented process utilizing a series of filters. The filtrate collected in this process is the only waste generated in the process. This is a very small quantity, representing only 1 to 2 percent of the sulfur removed in the process. Disposal of this waste is through normal solid disposal techniques. The liquid from the filtrate process contains buffer and is returned to the buffer mix tank. In the buffer mix tank, small quantities of buffer are added to make up for the buffer lost in the process, typically less than 2 percent. This regenerated buffer is then returned to the absorber vessel for removal of SO2 from the flue gas. Although lime-based systems are very common outside of refineries, they have not been popular for controlling FCCU emissions. This is primarily due to three factors. First, the buildups that occur in any lime-based scrubbing system necessitate the cleaning of the system every 2 years or less. This is not compatible with the turnaround cycles of 3 to 5 years for an FCCU. Next, the solids handling equipment associated with lime systems is extensive, resulting in high labor requirements and maintenance. Finally, a relatively huge quantity of gypsum is produced as a by-product. This is another large materials handling and disposal issue.

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SULFUR COMPOUND EXTRACTION AND SWEETENING

REAGENT SELECTION ECONOMICS


To illustrate the economic impact on the various design options available, a medium-size (30,000-BPSD) FCCU with a high (1800-ppm) SO2 level was selected for evaluation purposes. This case uses caustic (NaOH) as the reagent and has the wet scrubbing system and purge treatment unit previously described. To compare the different options available, a base capital investment cost for this option is assigned with a level of 1. All additional cases will be evaluated against the capital cost of this option and a relative difference assigned to each case. Operating cost is also a very important evaluation factor. Several factors were evaluated for operating costs. These include reagents (caustic at $300/ton, soda ash at $150/ton, phosphoric acid at $890/ton), power at $0.05/kWh makeup water at $0.02/m3, liquid effluent discharge at $0.04/m3, steam usage at $0.57/1000 kg, solids disposal at $44/1000 kg, and operation and maintenance costs per year at 2 percent of the capital investment. With the caustic scrubber being the base case, this option has been assigned an operating cost level of 1. However, it is interesting to see how the operating costs are distributed between the various factors. This is illustrated in Fig. 11.2.10. As can be seen, by far the major operating cost is the reagent. Power and operating and maintenance costs are relatively minor while the other costs are an extremely minor percentage of the total operating cost. As illustrated in Fig. 11.2.11, the capital cost of the system increases as additional equipment is added. Since little additional equipment is required for a soda ash system, there is only a minor increase in capital cost over the cost of a caustic system. A soda ash scrubber with a crystallizer has a much higher increase in capital cost, primarily due to the cost of the crystallizer. Finally, the regenerative system has the highest capital cost, mostly due to the cost of the regeneration plant. Operating costs also vary greatly. A caustic system has the highest operating cost due to the reagent cost. A soda ash scrubber has a lower operating cost, primarily due to lower reagent cost. A soda ash system with a crystallizer has a cost near that of a caustic system, mostly due to steam needs and additional power requirements. However, this option has the added benefit of no liquid effluent discharge which can be very important in some

100 90 Percent of operating cost 80 70 60 50 40 30 20 10 0 Caustic


FIGURE 11.2.10

Power

Makeup water

Water discharge

Solids disposal

O&M

Distribution of operating costs in a wet scrubbing system.

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Regenerative scrubber

Soda ash scrubber with crystallizer

Soda ash scrubber

Caustic scrubber 0.0% 50.0% 100.0% 150.0% 200.0%

Cost as % of caustic scrubber cost Capital cost


FIGURE 11.2.11 Capital and operating cost comparison.

Operating cost

situations. Finally, the regenerative system has the lowest operating cost, with reagent costs only a small fraction of those of nonregenerative systems. It also has the benefit of no liquid effluent discharge and has a by-product of SO2 which can be processed into elemental sulfur in the SRU. With the regeneration plant properly designed, the system can also add scrubbers to other emission sources and process their buffer in the same regeneration facility. This is a great advantage if multiple scrubber systems are being considered or are required. Another way to look at comparative system costs is to look at the equivalent cost per ton of SO2 removed. The equivalent cost is determined by taking the system capital cost and determining an annualized cost. The annualized cost is calculated based on an interest rate of 10 percent and a 15-year equipment life. Once the annualized cost is calculated, the yearly operating cost is added to it to reach a total annualized cost. Dividing this cost by the tons of SO2 removed will result in an equivalent cost. The equivalent costs for the four options considered are provided in Fig. 11.2.12. The soda ash scrubber with a crystallizer has the highest equivalent cost while the regenerative scrubbing system has the lowest equivalent cost.

ACHIEVABLE EMISSIONSA CASE HISTORY


As an example of the type of performance that can be achieved with a modern wet scrubbing system, the installation of a new wet scrubbing system is examined. This wet scrubbing system is installed on a new FCCU residual fluidized catalytic cracker (RFCC) with a design capacity of 10,500 BPSD. The RFCC was designed to process a variety of residual feedstocks. The RFCC has two stages of internal cyclones in the regenerator. Also, a CO boiler was installed after the regenerator for the reduction of CO. To comply with NSPS for particulate and SO2 emissions, a wet scrubber was provided.

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SULFUR COMPOUND EXTRACTION AND SWEETENING

1000 Equivalent cost $/ton SO2 removed 900 800 700 600 500 400 300 200 100 0 Caustic scrubber
FIGURE 11.2.12

Soda ash scrubber

Soda ash scrubber with crystallizer

Regenerative scrubber

Equivalent cost comparison of different wet scrubbing solutions.

The system was placed into operation in 1997. Over the first several months of operation, the RFCC experienced multiple process upsets which resulted in as much as 20 to 30 percent of the catalyst inventory being carried out of the regenerator and into the wet scrubbing system. The wet scrubber readily handled all these process upsets. The operation of the scrubber was not interrupted. The system continued to operate, and the excessive solids were washed out of the system by overflowing the main scrubber recirculation tank to a tank where the solids could be settled out. These upsets also did not cause premature wear of the nozzles. To demonstrate compliance with environmental regulations, emissions testing was performed to verify the emissions performance of the system. Testing was performed both at the inlet to the wet scrubbing system and at the stack. The results of these tests were exceptional. First, the testing at the inlet to the EDV wet scrubbing system demonstrated that the system was operating at higher than design values for gas flow and SO2 loading while having a lower than design loading for particulate. The flue gas flow rate was approximately 20 percent over design on a mass basis. SO2 was approximately 3.1 times the design value on a mass basis. However, the particulate was approximately 50 percent of the design value on a mass basis. A summary of the average inlet test values, compared to the system design values, is presented in Table 11.2.2. The performance of the system was excellent. SO2 was only a small fraction of the design outlet value. The mass outlet SO2 emissions were only 12 percent of the design values, while the tested removal efficiency was 99.92 percent compared to a design efficiency of 97.90 percent. Particulate emissions were also very low. The mass emission rate was approximately 24 percent of the design value, while the tested removal efficiency was 92.24 percent compared to the design removal efficiency of 83.70 percent. A summary and comparison of these data are provided in Table 11.2.3.

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TABLE 11.2.2 Conditions Item Flue gas flow

Scrubbing System InletDesign and Tested Tested value 312,628 lb/h 133,904 ACFM 483F 0.064 gr/DSCF 38 lb/h 1314 ppmdv 970 lb/h Design value 261,886 lb/h 106,644 ACFM 550F 0.178 gr/DSCF 76 lb/h 626 ppmdv 313 lb/h

Flue gas temperature Particulate loading SO2 loading

TABLE 11.2.3 Item

Scrubbing System EmissionsDesign and Tested Conditions Tested value 0.0047 gr/DSCF 2.95 lb/h 92.24% removal efficiency 1.0 ppmdv 0.79 lb/h 99.92% removal efficiency Design value 0.029 gr/DSCF 12.39 lb/h 83.70% removal efficiency 13.1 ppmdv 6.55 lb/h 97.90% removal efficiency

Particulate emissions

SO2 emissions

A WEALTH OF EXPERIENCE
The EDV wet scrubbing system has presently been installed on more than 20 FCCUs with a total refining capacity of more than 1,000,000 BPSD. Many refiners have selected the EDV wet scrubbing system for multiple FCCUs within their system based on the reliability, ease of operation, durability, and satisfaction with the system design and performance. Additionally, more than another 200 EDV wet scrubbing systems have been installed in other non-FCC applications. Table 11.2.4 shows all EDV applications as of October 2002. As the need to reduce emission levels continues to be an important focus, refiners will focus on wet scrubbing solutions as a way to meet present and future needs, while allowing them the maximum flexibility in refinery feedstock selection and operation. As they select the vendor of choice, refiners will focus on experience, system reliability, quality of service, and the ability of the system to achieve todays emissions consistently while having sufficient ability to be able to meet tomorrows requirement without major rework. A modular-type design with the ability to meet or exceed all present requirements, such as the EDV wet scrubbing system, and which can easily be upgraded as the future environmental demands on the refinery increase is a great benefit to a refinery struggling to decipher the future of its environmental requirements.

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BELCO EDV WET SCRUBBING SYSTEM: BEST AVAILABLE CONTROL TECHNOLOGY (BACT) FOR FCCU EMISSION CONTROL 11.30 TABLE 11.2.4
SULFUR COMPOUND EXTRACTION AND SWEETENING

EDV Wet Scrubbing Installation List of FCCU Applications Refinery location Corpus Christi, Tex., USA Westville, N.J., USA Shreveport, La., USA Norco, La., USA Mai Liao, Taiwan Mai Liao, Taiwan Vadinar, India Haldia, India Port Arthur, Tex., USA St. John, NB, Canada Robinson, Ill., USA Barauni, India Messaieed, Qatar Texas City, Tex., USA Ferndale, Wash., USA Visakh, India Gujarat, India (new FCC) Gujarat, India (existing FCC) Texas City, Tex., USA Sannazaro, Italy Hartford, Ill., USA Europe Deer Park, Tex., USA El Dorado, Ariz., USA Paulsboro, N.J., USA Capacity,* BPSD 85,000 50,000 10,500 100,000 73,000 73,000 59,500 14,000 83,000 70,000 48,000 26,500 30,000 60,000 30,000 20,000 60,000 30,000 43,000 34,000 30,000 30,000 67,500 20,000 65,000 Reagent Caustic Caustic Caustic Caustic Caustic/MgO Caustic/MgO Lime/caustic Caustic Caustic Caustic Soda ash Caustic Caustic Caustic Caustic Caustic Caustic Caustic Caustic LABSORB Caustic Caustic Caustic Caustic Caustic

Refining company 1. Valero Refining Company 2. Coastal 3. Quakerstate/Pennzoil 4. Orion/TransAmerica 5. Formosa Petrochemical1 6. Formosa Petrochemical2 7. Essar Oil Limited 8. Indian Oil Corp. Limited 9. Motiva 10. Irving Oil Limited 11. Marathon Ashland Pet. LLC 12. Indian Oil Corp. Limited 13. National Oil Distribution Co. 14. Valero Refining Company 15. TOSCO Refining Company 16. HPCL 17. Indian Oil Corp. Limited 18. Indian Oil Corp. Limited 19. Marathon Ashland Pet. LLC 20. AGIP 21. Premcor 22. Confidential Client 23. Shell Oil 24. Lion Oil 25. Valero Refining Company

*Total capacity of FCCU applications by EDV wet scrubbing: 1,212,000 BPSD (as of October 2002)

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