Develop a ‘real-time’ emissions monitoring strategy for your facility

T o improve air quality, states and localities are requiring more intense 24/7 monitoring of listed air pollutants from hydrocarbon processing facilities. Affected facilities must develop reliable and accurate environmental data management systems for reporting purposes. In this case history, the BP Texas City site (a refinery and chemicals plant) successfully implemented a real-time environmental data management system to comply with the highly reac-tive volatile organic compound (HRVOC) rule from the Texas Commission on Environmental Quality (TCEQ). This unique rule is part of TCEQ's overall strategy within the Texas State Implementation Plan to bring the Houston area into attainment for ozone under the Clean Air Act. The BP Texas City site is located in the Houston/Galveston area in which this program applies. The BP facility is widely regarded as the most complex refinery in the world, with a capacity of 460,000 bpd. Additionally, the BP Texas City chemicals plant is the largest producer of paraxylene and metaxylene globally. The challenges faced and benefits attained, when implementing the real-time environmental data management system for HRVOC rule compliance, will be presented. The Air Emissions Management System (AEMS) HRVOC Project was very complex due to the size, intricacy and geographic diversity of the site; coordination required with other internal related projects, such as an HRVOC infrastructure project; and the ongoing re-commissioning of the facility from an extended shutdown after Hurricane Rita. In the future, the system will be expanded to include nitrous oxides (NO x) mass emissions cap and trade program, and flexible air permit requirements. Background. In 2002, TCEQ issued regulations on HRVOC and NO x emissions for the Houston/Galveston area. These regulations include monitoring, testing, record-keeping and reporting requirements as well as site emissions caps for atmospheric process vents, cooling water exchange systems and flares. It also included a regional NO x cap with a requirement to calculate NO x emissions within 5% accuracy. HRVOCs are defined by TCEQ as ethylene and propylene for the seven counties outside of Harris County that make up the Houston/Galveston area including Galveston County, where the BP Texas City site is located. These counties were also exempted from the emissions cap requirement but are still required to monitor and calculate HRVOC emissions on an hourly basis.