ENV-10-70 CEMS AND FLOW MEASUREMENT ON REFINERY FLARE HEADERS

Description:

Delek operates a small refinery located in what has been an attainment area. Regulatory and permit conditions, as well as enforcement actions, requiring emissions and flow measurement analyzers for flare streams are only recently applicable. Challenges that Delek faced included: 1) a changing work scope as regulatory, permit and other requirements were added; 2) vendor and technology selection; 3) an installation strategy to collectively address all flare header systems (as no flare system previously had CEMS or flow measurement devices); 4) coordinating manpower and refinery resources; 5) a major rework when the initial CEMS technology failed to meet performance expectations; 6) implementation that required debugging of communications between analyzers and the refinery DCS, and; 7) addressing sour streams in order to certify the CEMS. This paper will focus on the problems encountered, measures taken, and lessons learned. While, this paper addresses issues specific to implementation of monitoring at Delek, there are lessons to be learned for broader understanding and application by industry and regulatory agencies.