Air Quality Compliance Continuous Monitoring Systems
ALL4 was asked to review a refinery’s compliance solution that incorporated process controls for flares subject to the monitoring requirements of 40 CFR Part 63, Subpart CC (MACT CC). The client’s goal was to evaluate the effectiveness of the refinery’s Data Acquisition and Handling System (DAHS) solution and ensure that the process controls used to operate the flares were aligned with the regulatory objectives of MACT CC. ALL4 was also tasked with the challenge of leveraging the notification, recording keeping, and reporting capabilities of the DAHS to optimize the client’s continuous monitoring program.
ALL4 identified then enrolled the stakeholders that would be impacted by the project. The stakeholders for this project included a third-party DAHS vendor and a multitude of refinery personnel from the Environmental, Instrumentation, Process Controls, Operations, and Information Technology (IT) departments. ALL4 aligned the stakeholder group towards a common goal by convening a roundtable discussion that clearly defined the positive impacts that the project would bring to each department. ALL4 also evaluated the barriers and objections presented by each stakeholder and specifically worked to develop solutions to address the following:
Environmental – Validating the DAHS to ensure it was functioning pursuant to the regulatory requirements and was confidentially considered as the final means of the refinery’s environmental compliance demonstration. Configuring the DAHS to efficiently generate the required reports and notify the appropriate personnel when operational deviations or monitoring downtime occurred.
Instrumentation – Completing the required quality assurance and quality control activities and evaluating the success of these activities. Notifying appropriate personnel when the monitoring systems were not functioning correctly and would require corrective actions.
Process Controls – Ensuring the correct operational parameters are monitored by the DAHS and are being used for compliance demonstrations. Understanding data flow between the DAHS and process controls for parameters being calculated. Evaluating the differences and acceptable tolerances between the calculation of parameters in the DAHS versus those determine by process controls.
Operations – Providing the information needed for operations to effectively operate the flare consistent with the regulatory requirements. Notifying appropriate personnel when operational deviations have occurred requiring corrective actions.
IT – Understanding the means by which the data will be transferred back-and-forth and providing accessibility to ensure it is consistent with refinery protocols.
ALL4 also provided web-based training to ensure that the roles and responsibility of each stakeholder were consistently communicated and clearly understood. The training also served as an onboarding resource and refresher training to existing employees.
ALL4 utilized the existing resources at the refinery and the collaboration of the stakeholders group to assist in the development of a robust solution for the operation of flares subject to MACT CC. This resulted in the following:
Operations (in conjunction with Process Controls) – utilizing well defined, measured parameters and calculations to operate the flares.
Instrumentation – properly equipped to operate and maintain the monitoring systems to provide representative and quality-assured data for use in compliance demonstrations.
Environmental – utilizing the DAHS to be notified in a timely manner of compliance issues and efficiently completing the required environmental compliance reports.
In addition, the web-based training program that accompanied this project resulted in the refinery establishing a repeatable program for new employees (or existing personnel with new responsibilities) to understand the relationships between each stakeholder to properly operate the flare.