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ENV-16-75 Refinery Sector Rule Implementation – “Mind the Gap(s)”

Becca Bradley, Trihydro Corporation

Format:
Electronic (digital download/no shipping)

Associate Member, International Member, Petrochemical Member, Refining Member - $0.00
Government, NonMember - $35.00

Description:

EPA published updates to several refinery-specific air regulatory programs on December 1, 2015, including MACT Subparts CC and UUU (Refinery MACT 1 and Refinery MACT 2). Collectively, this rulemaking package is known as the Refinery Sector Rule (RSR). Because of this rulemaking, refineries should be developing programs to ensure that they can meet these upcoming new requirements. Various refinery departments will be involved in implementing the numerous RSR requirements. An integrated approach to evaluate and establish action plans to manage the numerous evaluations and considerations is critical. Refinery environmental departments cannot be the sole owners of these programs. This paper will present an approach to conducting a “gap analysis” by sub dividing compliance evaluation tasks into components that can be assigned to the best resources. For example, there are many details to verify proper temperature/pressure instrumentation required under the RSR rules. Step 1 may involve evaluating current instrumentation and whether the instrumentation is located properly (often this evaluation can best be done by operations personnel). If instrumentation exists, Step 2 may involve evaluating whether the current instruments meet EPA’s accuracy requirements (this evaluation would be done by the Instrument Department). If there are issues noted with either of these evaluations, a project may be required to update the instrument. Step 3 looks at whether the instrumentation readings are currently going to the refinery distributed control system (DCS), and whether DCS tags are providing the correct level of detail (DCS engineers are likely involved in this phase). Some of these requirements specify recalibration, if the analyzer is out of range for more than 24 hours, requiring an additional DCS alarm and the generation of a maintenance work order. Finally, data capture of the instrument data should be archived appropriately in the plant data historian to meet the five-year records retention requirements. For these instrumentation requirements, at least six different functions (e.g., environmental, operations, instrumentation, maintenance, DCS, and data historian) at the refinery are involved. Each team needs to “own” its part of the evaluation to establish a compliant program.

Product Details:

Product ID: ENV-16-75
Publication Year: 2016