The State of Fenceline Monitoring Systems Lessons from the California Experience
Several air quality regulating bodies in California are requiring major petroleum refiners to implement fenceline monitoring programs using open path sensing technologies. The first continuous open path Fenceline Monitoring system in California was at the Unocal Rodeo refinery (now P66) installed in 1996. This TAS system is effectively the prototype for projects currently being required at most other California refineries. Broader interest in similar fenceline systems has increased in recent years for environmental impact and general safety. The California experience provides some good examples to discuss the state of the technologies and the successful implementation of fenceline monitoring programs and systems. TAS has a unique perspective having been instrumental in creating the design and guiding implementation for most of these systems in partnerships with several refiners and local companies. Success cannot be defined or achieved without realistic purpose. Communicating purpose and building this into design before committing to engineering is often a significant obstacle. Several purposes for the California fenceline monitoring initiatives were defined in early regulation support studies. However, most of the refinery projects were being started without design purpose awareness. Technology and product readiness for these systems were not as clearly defined as regulators or even manufacturers understood. Sensor detection capabilities were overstated by operators, consultants, and some manufacturers. This led to unrealistic expectations in regulations and monitoring plans. Community attention as well as regulations requiring standards for uptime and data quality presented challenges to current products and practices. This has driven improvements in methods, equipment, and support systems. It has required manufacturers to transition products and systems from various stages of commercial readiness to address full industrial implementation. As systems come online and continuous operations are scrutinized, further developments are ongoing. Designing open path systems is not as simple as it would appear. Regulations written to operate continuously at the limits of the technology require close attention to details usually not important to refinery engineers. This often becomes a challenge. It can be aggravated in plan execution as environmental and construction challenges are often met by compromising design details. Close attention at every step of implementation is important. Most of the new experts promoting themselves in this California initiative operate in effect under a batching support and quality assurance paradigm. This is largely accepted by regulators and customers, but it carries risks. Experience with dozens of safety and operations critical open path systems, TAS brings a design paradigm of continuous operations that is well suited to the demands of operating in refinery and other heavy industry environments.
Thursday, February 20, 2020