MACT ZZZZ Semi-Annual Compliance Reporting0104.nccdn.net/1_5/214/0ed/092/06-B-ACTS... · © 2012...

© 2012 The Williams Companies, Inc. All rights reserved. © 2012 The Williams Companies, Inc. All rights reserved.

MACT ZZZZ

Semi-Annual Compliance Reporting

ACTS User Conference

August 14th, 2013

Laura London, P.E. Environmental Specialist

Piceance Basin


Disclaimer

This material is intended to be helpful. However, this presentation is not

intended to be legal advice and is not intended to cover all laws that may

apply.

Semi-Annual Reporting | August 14, 2013 | 2


Outline

> Piceance Basin

> MACT ZZZZ Applicability

> Semi-Annual Reports

> PI System

> PI Integration

> Final Product

> Lessons Learned

> Future Goals



Piceance Basin



Piceance Basin

> Gathering, Treating and Processing

– 350 miles of pipeline ranging up to 30”

– 4 Gas Plants

– 23 Compressor Stations



MACT ZZZZ Applicability

Major Source of HAP

Site Rated RICE >500 hp

New: RICE constructed/reconstructed

on or after 12/19/2002

RICE 4 SLB

4 SLB reduction CO by >93%

Semi-Annual Reporting | August 14, 2013 6

Using CPMS

Semi-Annual Reports

Source: tceq.texas.gov/assests/public/permitting/air/Rules/Federal/63/zzzz/f63zzzz.pdf


Semi-Annual Reports

> Continuous Parameter Monitoring System (CPMS)

> Collects data at least once every 15 minutes (40 CFR Part 63.6625(b))

> Key Reporting Needs

– The date, time, and duration that each CMS was out-of-control

– The date and time that each deviation started and stopped, and whether each

deviation occurred during a period of malfunction or during another period.

– A summary of the total duration of the deviation during the reporting period, and the

total duration as a percent of the total source operating time during that reporting

period.

– A breakdown of the total duration of the deviations during the reporting period into

those that are due to control equipment problems, process problems, other known

causes, and other unknown causes.



Semi-Annual Reports

> Our CPMS is the PI (Process Information) historian

> Parameters Monitored

– Engine runtime percentage

– Catalyst pressure drop +/- 2” H2O

– Lean burn engines: pre-catalyst temperature 450-1350°F

– Flare: on/off

> Piceance Basin

– 4 sites

– 31 engines

– 3 flares



PI Historian Architecture


Source: osisoft.com


PI Integration into ACTS

> Text files containing hourly PI data values are generated nightly from PI

and sent to ACTS for processing

> PI tag identifiers are stored as equipment attributes in ACTS for easy

reference and updating



PI Integration into ACTS (cont.)

> PI data is stored as operational data in ACTS

> Deviation reports are based on this operational data



Data Chain


Real time data:

Thermocouple

Plant System:

Scada/DCS

Interface:

Industrial PC for Buffering

PI Server:

Historian ACTS


Final Product

> Document Generator (DocGen)

> Define standard report template language and formatting

> Creation of report logic uses existing ad hoc report tool function



Final Product (cont.)

> Allows for insertion of report results in table format

> Use of Word bookmarks or Excel cell references to define data table

positions

> ACTS Document Delivery



Lessons Learned

> Communication between various roles

– PI Administrator

– Business Process Analyst

– Operations Technician

– Control Technology Specialist

– Project Engineer

– Ecocion Associates

– Environmental Specialist

> Data chain reliability

> Standardized tag/equipment set-up

> Logic refinement



Future Goals

> Take burden of readsheets away from operators

> Create real-time alarms when out of range

> Expand to other facilities and data types

> Development of new tool for baseline differential pressure

> Entry of intermittent operational data

> Work to limit data interpretation



Questions


Laura Cooper

[email protected]

720.305.0050

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