Managing continuous emissions monitoring systems

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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) required more frequent monitoring which resulted in the installation of more monitoring systems at the facility. This large Gulf Coast refinery decided to utilize the opportunity to streamline all monitoring systems required for environmental regulatory compliance. Restructuring the entire process for managing the multiple Continuous Emissions Monitoring Systems (CEMS) was necessary for an effective system. An Environmental Management Information System (EMIS) was selected to assist in streamlining this process. For this large Gulf Coast refinery, the EMIS of choice was ESP’s opsEnvironmental Suite.

The volumes of data that are already being monitored at facilities are typically stored in non-relational process data historians. These data are key to assisting in CEMS management, calculating emissions and demonstrating regulatory compliance. Typically EMIS solutions do not directly interface with process data historians due to their configuration and the sheer volume of data that resides in them. Additionally, process data historians cannot properly determine the validity of data according to the strict regulatory guidelines; therefore, a more robust tool is required to both migrate reduced data (in 15-minute and 1-hour increments) while simultaneously performing the validation procedure prior to storing data in the EMIS. In order to process and validate data from the process historian into the EMIS, this facility chose to implement T3’s Data Integration and Averaging (DIA) application.

After configuring the interface between process data and the EMIS, the next step was to develop the interaction between personnel and the EMIS. To promptly address analyzer problems, field technicians needed a more effective notification system when analyzer faults occurred. Environmental personnel also needed notification in order to proactively schedule required monitoring in the instance that analyzers could exceed downtime allowances. In addition, environmental personnel needed to produce quarterly and semi-annual reports from the system to demonstrate compliance with the regulatory CEMS requirements. Both notification and reporting requirements were met with a properly configured EMIS.

The following sections provide an overview of the DIA application and the EMIS configuration for communication and reporting. Finally, the project results and lessons learned from this project will be explored.

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