Quantifying VOC emissions for the strategic petroleum reserve
Lord, David L.
A very important aspect of the Department of Energys (DOEs) Strategic Petroleum Reserve (SPR) program is regulatory compliance. One of the regulatory compliance issues deals with limiting the amount of volatile organic compounds (VOCs) that are emitted into the atmosphere from brine wastes when they are discharged to brine holding ponds. The US Environmental Protection Agency (USEPA) has set limits on the amount of VOCs that can be discharged to the atmosphere. Several attempts have been made to quantify the VOC emissions associated with the brine ponds going back to the late 1970s. There are potential issues associated with each of these quantification efforts. Two efforts were made to quantify VOC emissions by analyzing VOC content of brine samples obtained from wells. Efforts to measure air concentrations were mentioned in historical reports but no data have been located to confirm these assertions. A modeling effort was also performed to quantify the VOC emissions. More recently in 2011- 2013, additional brine sampling has been performed to update the VOC emissions estimate. An analysis of the statistical confidence in these results is presented here. Arguably, there are uncertainties associated with each of these efforts. The analysis herein indicates that the upper confidence limit in VOC emissions based on recent brine sampling is very close to the 0.42 ton/MMB limit used historically on the project. Refining this estimate would require considerable investment in additional sampling, analysis, and monitoring. An analysis of the VOC emissions at each site suggests that additional discharges could be made and stay within current regulatory limits.