refinery, LDAR, leak detection, RFS Compliance Solutions

Mediating Fugitive Emissions in Environmental Engineering

Environmental engineers are essential to the protection of the environment as well as the health and safety of vital industry workers. Their careers are dedicated to ensuring that the integrity of equipment used in industrial processes are up to global standards, and are performing on the frontline against leakage and fugitive emissions.
 
Fugitive Emissions Journal was thrilled to speak with Environmental Engineer Carl Anderson, about his experience managing leak detection & repair programs, handling consent decrees, inspecting valve components and ensuring safety during operations and turnarounds.

Leak Detection & Repair


As an Environmental Engineer, Anderson’s role consists of controlling and managing the fugitive emissions program at refineries. Within a refinery, each environmental engineer has a specific function. “We wake up, come to work, warm up the detection machine and map out the route for the day; we often find ourselves in different areas of the plant, depending on the work to be done,” stated Anderson.

The leak detection and repair (LDAR) program is generally built into a facility’s Title V permit. Title V of the Environmental Protection Agency (EPA) Clean Air Act requires major sources of air pollutants, like refineries, and certain other sources to; obtain an operating permit, operate in compliance with that permit, and certify their compliance annually with permit requirements. “Title V includes all of the permits that are applicable to a facility in one neat, condensed package. The Clean Air Act drives all of our leak detection programs with the exception of the consent decree requirements, and those are all funneled into the Title V permit. The consent decree forces us to upgrade chronically leaking valves to meet the standard for certified low leak technology (CLLT) which is no more than 100 ppm for five years,” Anderson explained.

The LDAR program mandates a quarterly monitoring schedule for all of the plant’s covered valves. “We monitor every valve at minimum, four times a year and we monitor pumps monthly, 12 times a year. This schedule is driven by the EPA VVa/GGGa regulation, but we try to monitor more frequently than is required by law, in order to identify trends and remain conservative within the program.”

Managing Safety & Turnarounds

Anderson advocates that the Clean Air Act is designed to both reduce emissions and protect communities and workers alike. “I always tell my technicians to get more enhanced medical screenings, as they are often in the plant all day long. Nine hours in the refinery and then five or six hours in the field in a day is a lot of exposure, so it is important to protect yourself.” Although he does not handle the safety aspects at the refinery directly, it is always a primary focus of his. “The refinery’s safety procedures are driven from the top down by a Health, Safety & Environmental (HSE) Director, but I try to enforce those procedures as much as possible.”

Many facilities similarly follow a routine turnaround program, on average every three to five years depending on throughput and other operational considerations. “If we are planning a turnaround, we will look at the units that are going to shut down and try to be proactive with maintenance. We cannot always mitigate a leak within the 5/15 day window, and leaks become apparent right after the turnaround,” said Anderson. “If you take a more proactive approach and figure out the work that has to be done prior to the shutdown, you can usually isolate a  line, valve or other piece of equipment since the entire unit is shut down.”

The biggest challenge with turnarounds in most facilities is the intense pressure on the team to keep the project on time and within budget. “Time is always a factor because every hour that you go over schedule it delays the next project,” explained Anderson. Many plants therefore schedule large turnarounds more than a year in advance, so the team can adequately prepare in order to mitigate the risk of unforeseen complications.

Turnarounds provide an opportunity to make mandatory repairs under Title V guidelines. There is a 15-day repair
window for valves and pumps. If, for some reason, the equipment cannot be repaired during that time frame, there is a ‘delay of repair’ option. This option allows the operators to keep using the equipment, as long as they agree to repair it during the next process unit shutdown. Turnarounds provide the outage necessary to make those repairs.

Leak Detection Technologies

Most refineries employ several leak detection technologies to help maintain the safety and integrity of their assets. A team will often use thermal imaging cameras by FLIR both for safety and leak detection applications. “We might use the FLIR camera to examine, for example, a heat exchanger for leakage. Though it is not a valve, pump or any equipment designated under LDAR, we monitor them closely regardless of the lack of surrounding regulation. We strive to use the best available technology to maximize worker safety,” said Anderson. The FLIR camera is also often used for monitoring equipment after the start-up of a process unit. “We can take a picture using a very wide view of the field or process area so you can zoom in on a bad leak remotely, thereby reducing risk to the worker.”

When out in the field Anderson uses two brands of toxic vapor analyzers (TVAs) for leak detection: the phx42
by LDARtools and the Thermo Scientific TVA2020. “These two pieces of equipment are essentially industry standard now; both have their pros and cons, but they quickly and accurately detect fugitive emissions of organic and inorganic compounds for Method 21 compliance, LDAR applications, and site remediation. The phx42 is slimmer and lighter, which makes it ideal for use in difficult applications like when climbing a tower 150 feet in the air. Relieving 3 to 5 lbs from your back will make a huge difference,” explained Anderson. The data is recorded by the handhelds from the TVA via Bluetooth then downloaded to a computer for further analysis in real time. As time is a significant factor for leak detection, real time data allows the clock to start recording information at the precise moment the leak is discovered. Once a leak has been detected, Anderson and his team monitor the aspects of leak detection while the maintenance team manages the repairs. The repairs to an application can be handled internally or through external third parties’ sources.

As previously stated, the most common piece of equipment to experience emission leaks are valves. Valves are used throughout refineries in a variety of applications, such as process units. “I see valves in every size from 36 inches, down to a 1/4-inch in the LDAR program,” stated Anderson. “We also use a lot of ball valves for isolation, rising stem/ gate valves as well as a number of globe and ball valves. Each type has a unique function and all need to be monitored on a constant basis.”

Liquid transfer pumps, such as centrifugal and propeller pumps, are similarly closely monitored. As they are typically located in high volatile areas, these applications have an odorant added to the gas that will omit a distinct odor if there are any emissions. If the odor or leak from a valve is detected, Anderson’s team will assess the leak and determine the most suitable course of action to minimize the amount of emissions entering the atmosphere.


Final Thoughts

Although the practice of monitoring emissions can be seen as relatively new age, there is a lot to learn from the more experienced engineers. “We have a lot of older engineers moving towards retirement, so I try to absorb as much information from them as possible while I can,” said Anderson. Based on the expertise they have gained, Anderson calculates that senior engineers have conducted every test and procedure at least three times each in their lifetimes. “Engineers’ practical, hands on knowledge is so valuable. Unless you are super smart or very lucky, chances are you are never going to get it right the first time. That is why I find it is important to talk through scenarios with engineers to gain different perspectives.”
Anderson’s biggest piece of advice for young engineers is to benefit from others’ experiences, “Give people the opportunity to share their experiences, ask them how did they did the project, then personally apply your own set of experiences to further add to your skillset. The Internet of Things (IoT) and rapid digitization has added another layer of difficulty to knowledge transfer. It is fantastic how far we have come with technology, but we cannot forget the benefit of working hands on, with real world applications.”

“Unless you are super smart or very lucky, chances are you are never going to get it right the first time. That is why I find it is important to talk through scenarios with engineers to gain different perspectives.”

 

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