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Industry:  Petroleum Refinery
Project Type:  StackVision (DAS) Implementation
Scope:  2 units; 1 Part 75 Boiler, 1 Part 60 Boiler
Driver:  A new permit, and a pilot for RSR
Regulation(s):  40CFR75, 40CFR60
Parameter(s):  NOX, CO, SO2
Location:  Kentucky
Year:  2018

Project Description

Two boilers were issued a new permit, with new requirements that would be hard to meet using spreadsheets. The environmental group also had a feeling that the first boiler would eventually have to report for Part 75 and decided to be preemptive. They requested that it be set up as identically as possible to a Part 75 system.

RSR was another driver for deciding to install a DAS. Using the boilers as a test project before converting their flares over was a good proof of concept, as well as satisfying their reporting requirements for the new permit.

Problems or Requirements

New permit with new requirements
They needed some way to report the data from the new permit they were issued. Even without the Part 75 designation that they could see was coming, there were new continuous monitoring requirements.
Wanted to move away from spreadsheets
Spreadsheets were time consuming and prone to errors at the best of times, and the CPMS requirements for the flares in RSR could not be handled with that kind of look-back approach. They wanted to start using a DAS, but wanted a real test of the system and a chance to familiarize themselves with it before committing to it for the MACT CC revisions.
Part 75, but not quite
The first boiler could not be completely Part 75 compliant right off the bat because they did not have a monitoring plan, but they wanted it set up for Part 75 calibrations, missing data substitution, etc.

Solutions and Outcomes

Second boiler added
The original project only covered the Part 75 boiler. But, once it was underway and they saw how much simpler and more comprehensive the QA/QC, monitoring and reporting would be, they quickly added the second boiler.
Part 75 designation received
Kentucky assigned the Part 75 designation toward the end of the year, as Ozone-season only reporters. ESC also created their electronic monitoring plan in a separate project. We will be helping them through their first ECMPS reporting experience in July 2019.
Pilot successful, flare project underway
The test run using the boilers gave the environmental group the confidence to move forward with using StackVision for their flares under RSR. This is an approach we are happy to take with any customer. We understand how different using a DAS is when you may be used to getting your data from the DCS through the historian and into spreadsheets.

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