ENV-13-46 Finding and Fixing Heat Exchanger Leaks

Description:

Monitoring heat exchange systems in organic Hazardous Air Pollutant (HAP) service for leaks using the Modified El Paso Method (MEPM) is now something all refineries are familiar with. However, there are varying strategies for how to implement a compliance program to ensure that refineries can identify leaking heat exchangers and make any necessary repairs within the required timeframe. Here we identify the benefits and challenges for heat exchange monitoring compliance programs implemented at refineries nationwide. Specifically, the following aspects of these programs and their impact on compliance will be discussed: • Challenges in identifying leaking heat exchangers; • Challenges in making timely repairs; • Developing effective response procedures for detected heat exchange system leaks; • Identification of which heat exchangers either require a process unit shutdown/load reduction or can be bypassed, and when exchangers qualify for the Delay of Repair (DOR) provisions; and • Reasons/observations for unexpected MEPM readings.