EPA Compliance Solutions for Monitoring PRDs
Proconex offers solutions for EPA regulatory compliance with additional benefits—increased throughput, improved asset management, superior record keeping, early detection of leaking Pressure Relief Devices (pressure relief valves or PRVs, pressure safety valves, and rupture discs), and the knowledge to better manage your maintenance schedule.
Two critical sections of the EPA Regulation for controlling toxic air emissions from petroleum refineries (40 CFR Part 63 Subpart CC Sections 63.648 and 63.670), originally published in December of 2015 and later amended in July of 2016, require an electronic monitoring solution to be implemented less than a year from today—with a deadline of January 30, 2019. While this particular EPA regulation is focused on refineries, it is our opinion that other process industries will eventually fall under similar regulations.
There are approximately 130 petroleum refineries in the U.S. that must comply. We estimate that this regulation could affect between 5% and 10% of all PRVs installed—tens of thousands of units.
This rule will virtually eliminate smoking flare emissions and process upset emission events, and will require refineries to monitor emissions at key emission sources within their facilities and around their fence lines. According to the EPA, this rule will result in a reduction of 5,200 tons per year of toxic air pollutants, and 50,000 tons per year of volatile organic compounds (VOC).
According to the regulation, operators must:
- Install electronic monitors on Pressure Relief Devices (PRDs) that vent to the atmosphere in order to identify and record the time and duration of each pressure release
- Identify the source of each release on the flare systems for root cause analyses
- Implement at least three of the redundant prevention measures for each pressure relief valve that can discharge to the flare
- Report emissions during startup and shutdown
Note: There is an H2S exception if the exceeding emission was due to leakage and it has been repaired.
While the regulation applies to the flares, not necessarily PRDs, it is clear that monitoring PRDs is the path to compliance. PRDs should be closed all the time, except in an overpressure event, when they do their job by opening and releasing waste to the atmosphere. The EPA is requiring refineries to record any release and also enter that information in a way that it cannot be tampered. Prior to this regulation, operators were estimating hazardous waste releases, but they could not pinpoint specifically when and how releases were occurring.
There are two cases related to PRDs:
- Case 1: If emissions are vented to the atmosphere but not going to a flare system, you need to monitor that valve event and record it.
- Case 2: If emissions tie into a flare system, then that pertains to the entire plant, not just PRDs. The challenge is to trace the release back to where that emission is coming from. While an operator can theoretically trace it manually, they need better information to pinpoint that bad actor. Electronic monitoring is a good solution for allowing an operator to figure out where the release is coming from and mitigate the problem.
Proconex offers several cost-effective solutions to allow refineries and other plants to address these regulations with ease and full compliance.
Rosemount™ 708 Wireless Acoustic Transmitter
This Acoustic Transmitter is easy to implement and non-intrusive to the process. We can work with you and your team to attach these devices to your pressure relief devices. Installation is simple: the base is attached to the pipe with two clamps and it’s installed. As an acoustic device, the transmitter measures vibrations in the pipe, as well as the surface temperature. The data is then sent through a WirelessHART® gateway connected to your monitoring system. The PROs at Proconex can help take it a step further by offering customers the integration they need to produce the Continuous Emission Monitoring (CEM) reports required by the EPA. Acoustic monitoring is superior because it is not intrusive and can be installed immediately without any process disruption!
Fisher™ 4320 Wireless Position Monitor
The Fisher 4320 Wireless Position Monitor is designed to provide a direct connection to pressure relief valves. Installation requires the decommissioning of the valve in service in order to install the monitor on the valve stem with a bracket. Some customers prefer this because of its accuracy, providing a direct indication if the valve in question is really open or closed. With the Fisher Monitor, you can determine what percentage of the valve is open, which may have an implication on how much you are actually releasing. Furthermore, although rare, this monitor may be the only logical choice in environments that are too noisy for acoustic monitoring.
Rosemount™ 3051S Wireless Coplanar™ Pressure Transmitter
For pilot operated valves, the Rosemount 3051S Wireless Coplanar Pressure Transmitter incorporates patented coplanar technology and a scalable platform. This transmitter integrates with manifolds, primary elements and seals for a complete measurement solution. With WirelessHART® technology, you have access to consistent measurements, even in remote areas. This transmitter requires decommissioning prior to installation.
Plantweb™ Digital Ecosystem Solutions
The Emerson Plantweb Digital Ecosystem harnesses the power of proven technologies to expand digital intelligence to your entire manufacturing enterprise by helping you achieve Operational Certainty. Flexible, integrated and scalable, the Plantweb Digital Ecosystem features secure and robust, real-time insights utilizing pervasive sensing technologies.
With over 50 experts at multiple locations throughout the Mid-Atlantic region, Proconex can provide the expertise, technology, and resources to design, implement, maintain, optimize, and continuously improve your plant operations.