Demonstrating Compliance through Integration of Continuous Monitoring Data with Environmental Management Information

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An essential ingredient for Emissions Management Information Systems (EMIS) to effectively manage compliance information is facility monitoring data, especially at a petroleum refinery where so much process data is already monitored to ensure optimum operating performance and safety conditions. EMIS solutions typically reside on corporate or facility servers that are readily available to environmental and other refinery staff. Facility monitoring data starts at monitoring systems and typically resides in non-relational process data historians in high volume (usually in the range of 30 second to 5 minute intervals between data points). However, much of this data is critical to calculating emissions and demonstrating compliance with operating limits or permit conditions (the core functionality of an EMIS). And since most EMIS solutions do not directly interface with these process data historians, it is necessary to develop a separate, yet seamless, integration of this data and the EMIS.

Beginning with recent rulemaking governing compliance determinations in regards to the emissions of nitrogen oxides (NOx) and highly reactive volatile organic compounds (HRVOCs), the Texas Commission on Environmental Quality (TCEQ) determined that it is necessary to monitor and record this compliance data on a more frequent basis than daily or annually. Specifically, key facility data related to the emissions of these pollutants, which is monitored continuously, must be reviewed and potentially reported in block 15-minute and hourly averages. Further, this data is subject to numerous faults and calibration periods based on plant and monitor cycles. Finally, the sheer volume of the data itself is intensely burdensome as there may potentially be tens of thousands of monitoring results that require collection, processing and storing in the EMIS every 15 minutes. The result of all of this information is the need for an application and system that not only integrates monitor data, but validates and averages the data before making it available to the EMIS solution of choice, and does so in a near real-time environment.

For this Large Gulf Coast Refinery, the EMIS of choice was ESP’s opsEnvironmental Suite and the method of integration was T3’s Data Integration and Averaging (DIA) Application. The following discusses the outline of the project, the need for compliance with HRVOC regulations, and the solution found in the DIA Application. Finally, the project results and lessons learned from this project will be explored.

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