Sources of Emissions in Refinery – Legal Regulations and Costs

Crude oil processing associated with the impact on the environment. Refinery production processes are a source of emissions in virtually all environmental components. The article characterizes the sources of emissions by dividing them taking into account various criteria and escribes the regulatory and legal environment, addressing the problems of industrial emissions, taking into account current and forecast guidance at European and national level. Highlighted the various aspects related to the effects of legislation and its implementation, among which, indicated as the most important implementation costs in relation to the underlying operating costs.


INTRODUCTION
The state of the natural environment depends on many factors, including pollution caused by the introduction of a substances into the air, water or soil /ground that cause risk, adversely affect human health and the state of the environment. The accumulation of solid, liquid, gaseous or energy substances in large amounts on the earth's surface may adversely affect human health, the animate nature, climate, soil, water or cause other unfavorable changes in the environment. Due to the fact that the level of environmental pollution is not the same everywhere, and various pollutants are released into the atmosphere from many sources, which spread in the atmosphere and, additionally, may be transformed into new compounds, regulations are being developed to reduce this process. Since the implementation of regulations and new strategies and measures for reducing emissions from various sources in the world and in Poland, its volume has significantly decreased. Pollution emission levels have now been regulated [1,2,3,4,5,6,7,8,9] and are falling with new information from research, awareness and development of environmentally friendly technologies. In addition to developing limit values for specific pollutants and setting emission levels at European and national level, the legislation provides the tools to take action in relation to the specific sectors consisting the source of pollution. Pollution can be caused by natural or anthropogenic sources. The anthropogenic sources include mainly industry [10]. Industry is a huge consumer of natural resources that are used in energy processes and transformed into products in technological processes. Both the main and the supporting processes are the source of emissions to the environment. The refining industry in particular, which processes crude oil, is a source of emissions to air, water, and soil / ground, and is also a source of waste, noise, lighting, smoke and odour nuisance. Therefore, integrated environmental protection management in the refinery is one of the most important elements of the environmental policy, which introduces many programs and activities aimed at reducing emissions. As a consequence, there is a downward trend in pollution generated by refineries per Mg of processed crude oil [11,12].

DIVISION OF EMISSION SOURCES AT THE REFINERY
The division of emission sources in a refinery is difficult since it depends on many factors, including source categories, the so-called SNAP (Selected Nomenclature for Sources of Air Pollution), the method of including in the calculations (modelling), determining what, where, how, in what amount and when it is emitted, and a precise inventory depending on the needs of forecasting concentrations or reporting to many public administration bodies [1,2,3,4,5,6,7,8,9,11,12,13]. A thorough analysis of the characteristics of processes and operations, including manufacturing as well as preparation and process streams, allows to identify places where emissions of substances may occur into the environment, which makes the identification of emission sources and their classification correct. Table 1 presents the distribution of emission sources in the refining industry with the identification of their sources.
In addition, the obligation to report emissions to reporting systems is related to different rules to various institutions, such as KOBiZE (The National Centre for Emissions Management), GUS (Central Statistical Office), or PRTR (Pollutant Release and Transfer Register). Moreover, in the greenhouse gas emission monitoring and reporting system, which is the basis of the EU ETS Table 1. Division of emission sources in the refining industry Refining processes can also emit odorous substances, including organic compounds (oxygen, sulfur, hydrogen sulfide, mercaptans) with a characteristic odour. The refinery itself, as a facility, may be a source of GHG (greenhouse gas) emissions or carbon footprint in the life cycle of engine fuels [14,15]. In many studies [11,12,16,17,18,19,20,21,22,23,24,25,26], the authors agree that refining processes in crude oil processing plants are the primary sources of emissions pollution to the environment, both to the air, can also be related to soil / ground and groundwater pollution as well as the generation of waste. The largest amounts are gaseous pollutants. Particulate pollutants are small amounts in the combustion of fuel oil, from waste incineration, fluid catalytic cracking and in the treatment of petroleum coke. Table 2 presents an example of air pollutants from refinery processes [12].

LEGAL CONDITIONS
For the operators of refining installations, whose activities are related to the use of natural resources, it becomes a practice to constantly commit to intensive activities aimed at adapting to changing legislative requirements. Refineries operate in a legal environment, both international, European and national, as well as local ( Figure 1).
From the point of view of a refinery, the industrial emissions directive, the so-called IED Directive [9] plays the most important role. It introduced, inter alia, significant reduction of SO 2 , NOx and dust emission limits from power plants and sanctioned the BAT conclusions, which are part of the BREF reference documents, as legally binding [27].
The most important current or future BAT conclusions for refineries and / or self-powered refinery / petrochemical complexes are [16]: The changing legislation is of great importance for the refining industry and may cause it to incur additional costs in terms of adjustment to the applicable law, but also in anticipation and development activities. Figure 2 shows selected regulations that have a significant impact on the refining industry.
Over the years, in the perspective to 2050, the industry will face challenges not only related to the BAT conclusions. The European Union is introducing more and more strict environmental requirements (Figures 1 and 2). In addition,  [28,29,30,31]. The principles of the circular economy aimed at minimizing the consumption of raw materials and utilities from primary sources, or the National Emission Ceilings Directive (NEC) introducing restrictions on annual mass emissions in individual Member States of the European Union [27] are also important.
The Water Framework Directive [32], organizing and coordinating existing European water legislation to protect water from pollution at its source, with the requirement that Member States gradually reduce water pollution from the group of substances referred to as priority substances is becoming important. In accordance with the above-mentioned the Directive requires Member States to cease or phase out emissions, discharges and losses of more hazardous pollutants known as priority hazardous substances.
Public access to information on industrial pollution has improved significantly over the past few decades. The European Pollutant Release and Transfer Register (E-PRTR), which provides comprehensive records of emissions and transfers of pollutants from major industrial activities, provides annual information on over 30,000 pollutants. industrial plants in 33 European countries, on the amount of pollutants released into air, water, soil / ground and on off-site waste transfers, as well as pollutants in waste water.
Sustainable development criteria have also been introduced to reduce the impact of industry on the natural environment. Examples of industry initiatives include the widespread adoption of environmental management practices under the European Eco-Management and Audit Scheme (EMAS) and the ISO14001 standard. Voluntary corporate social responsibility initiatives have been implemented to achieve social and environmental goals that go beyond the legal requirements, such as the Chemical Industry Initiative "Responsibility and Care". At EU policy level, the Commission has adopted a CSR strategy, while at international level, the ISO 26000 CSR standard provides guidance on how companies and organizations can act in a socially responsible manner.
The work of the European Environment Agency (EEA), which supports the implementation and evaluation of EU policies to reduce industrial pollution is noteworthy. The EEA helps the EU develop long-term strategies to reduce the negative environmental impact of industry by providing assessments and informing policy makers. Its main tasks include the release of data reported by European countries under the reporting obligations under European legislation.
European oil refineries work closely with regulatory standards setting bodies, but also with various sectors and industries, including the automotive sector, making the EU a world leader in fuel specifications and many clean fuel and engine technologies, helping to improve air quality. This partnership phased out leaded petrol in Europe thanks to technological advances in European refineries. Refineries reduced the share of aromatic compounds, olefins, benzene and PAHs (polycyclic aromatic hydrocarbons) in the produced motor fuels, which contributed to the reduction of pollution in exhaust gases. Sulfur from fuels has also been practically eliminated, which is a necessary condition for the effective operation of the catalysts.

COSTS OF THE IMPLEMENTATION OF THE LAW
The negative environmental impact of the European refining industry has improved over the past several decades. Several factors contributed to the changes: stricter environmental regulations, improved energy efficiency, a general trend in European industry to change production technology, and the participation of companies in voluntary programs to reduce their negative impact on the environment. Figures 3 and 4 show trends in the emissions to air of sulfur oxides and nitrogen oxides from European refineries in the years 2007-2017 [33].
The emission reductions contribute significantly to the improvement of air quality in Europe. These are expensive investments in the refining industry and should therefore be achieved in the most cost-effective way to avoid that compliance investments displace investments in other improvement projects such as technological upgrades or energy efficiency.
For example, the costs incurred by the Dutch refining industry are quantified at EUR 42 million / year for SO 2 activities, EUR 5 million/year for NOx activities and EUR 14 million/year for NMVOC activities. This adds up to a total cost of EUR 61 million per year for the Netherlands to achieve the emission reductions observed between 2005 and 2012 [34].
Based on the report on Cumulative cost assessment for the EU chemical industry commissioned by the European Commission [35], The CONCAWE reports [36,37] and the report prepared by ECN Wood Mackenzie [23] provide an estimate of the costs to be incurred by the refining industry due to the change in EU regulations. The total cost assessment is presented in Table 3, and per barrel of oil in Figure 6.
According to the estimates contained in the Fuels Europe report on Vision 2050 a pathway for the evolution of the refining industry and liquid fuels 2018 [38], the costs of adjusting the refining industry in the years 2030-2050 (depending on the scenario of the global energy policy) may amount to as much as EUR 50 billion for the entire EU refining system (CONCAWE calculations). This estimated cost relates only to the   [33] overall cost of introducing various technologies, the so-called CAPEX (capital expenditures) in terms of identified technological possibilities. It does not take into account investment costs outside the refining site, as well as corresponding changes in operating costs, the so-called OPEX (operating expenditures) [38].

CONCLUSIONS
The European refining industry offers many important economic and social benefits, including producing goods and products as well as generating employment and tax revenues. The burden of costs related to tightening legislation will have a significant impact on the competitiveness of the refining sector, reducing aggregate gross and net margins as well as lowering the value added of this sector's industry for domestic economies.
This could ultimately lower the attractiveness of operating or investing in the sector and increase the risk of refineries closing. The new restrictive legislation and social expectations also require a technological change towards biofuels, synthetic and artificial fuels, which is associated with additional costs.
While the refining sector is now at the forefront of environmental performance, new stringent measures have been established to further reduction of emissions. The challenge will be to reduce fugitive emissions of VOCs (Volatile Organic Compounds) and aromatic substances. However, it should be borne in mind that the technical and thermodynamic possibility of further emission reductions from refining sources may soon be exhausted, not without consequences for an increase in energy consumption or a reduction in production, and thus an increase in environmental impact.

Note:
EU-ETS -regulations related to the European Trading System for Greenhouse Gas Emission Allowances. IED -regulations related to the adaptation to the requirements of the Directive on industrial emissions. IMO -regulations related to the adaptation to the requirements for sulfur content in marine fuels. RED -regulations related to the requirements for biocomponents and biofuels. REACH -regulations related to registration. evaluation. authorization and restriction of chemicals.