Chemical Engineering July 2023 - 29

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plications. Furthermore, there may
already be inaccuracies in the way
emissions are calculated, because
emission factors are often based
on old data that may not be comparable
to today's more progressive
processes. With emissions calculations
reliant on source counts and
factoring
applications,
you
don't
FIGURE 2. During the initial stages of startup
following a turnaround, conducting critical leak
checks is an effective way to improve regulatory
compliance
obstacles they face related to regulatory
programs and provide feedback
on recommended solutions fosters
a culture in which their experiences
matter. Furthermore, it guarantees
that plans and procedures are created
by the people who will implement
and be directly affected by
those plans. This not only ensures
that the plans are practical, but also
provides lessons learned and opportunities
for improvement, which will
help to streamline the program and
meet the targets more efficiently.
Continuous best practices
Establishing a workplace culture
that is supportive of emissions reduction
is fundamental, but it is not
sufficient by itself. Workers need
realistic solutions to the challenges
they face. The following sections
compile a list of practices that,
when employed within a workplace
with a positive emissions-reduction
culture, can help to reduce an organization's
emissions before they
break compliance.
Key functions are required to
achieve a quality program. When
supported as a regular part of daily
operations, the following practices
will assist facilities in meeting regulatory
targets in a practical manner.
Accurate inventory. Authorities
holding jurisdiction look for ways to
show noncompliance, which presents
economic and reputational imwant
to calculate sources that are
no longer in operation or miss new
sources that could put a facility out
of compliance.
Therefore, to obtain accurate
emissions testing results, you must
start with an accurate inventory -
and that inventory must be updated
continually as processes change.
In-scope sources must be accurately
Establishing
a
represented, and the list of
out-of-service equipment should be
updated frequently.
process to routinely assess inventory
is imperative and will save time
that would be wasted managing redundant
or out-of-date records, and
will also remedy potential sources
of noncompliance.
Internal leak targets. Organizations
should set reduction threshold targets
with strict rules to capture emissions
sources before they become a
compliance-driven concern. Leaks
that are allowed to continue until
they reach significant levels are quite
costly, due to additional handling
time from both inspection and maintenance
requirements. There is a relationship
between minor leaks and
dangerous events. All such events
represent failure in process control.
Adequate process control prevents
leaks before they happen.
Setting internal targets
that provide early indication
promotes a proactive
approach to correct
deficiencies without
stringent deadlines.
This will establish a total
quality-management approach
to support future
potential derogation. Additionally,
as leak thresholds
are reduced by
regulatory agencies, this
approach will support facility
confidence in meeting
changes in equipment
rule commitments.
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Maintenance and repair. Ensure
craft laborers receive adequate training
and are competent in specific
types of repair, such as taping, as
well as correct procedures and good
practices in tightening compression
and other threaded fittings. Additional
practices that aid in emission
management include the following:
* Selecting the proper gasket and
utilizing appropriate tightening practices
for flanged assemblies
* Applying the proper bolt load
based on valve type and service
* Selecting the proper valve based
on thermal cycling or frequent use
Training and trade competencies.
Another common source of leaks
is improper assembly of equipment
like compression fittings. Continuous
training of all personnel involved
in commissioning and startup is essential
to ensuring a leak-free startup
and preventing emissions before
they start.
Post-turnaround activities
Emissions programs often identify
an increase in regulatory emission
sources for repair following minor or
major turnaround activities, despite
focused efforts to correct identified
emission sources from previous campaigns.
This is because facility relaxation
and re-pressurization involve
many activities that can influence
joint integrity. Internal quality checks
on focused repairs are a valuable
part of any commissioning or startup
activity. However, such checks alone
are not enough to ensure a fully leakfree
startup. While they test the areas
that have been broken down, they
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FIGURE 3. Workers who have been trained in industry-standard
programs bring with them comprehensive expertise in inspection,
assembly and disassembly of leakage-prone equipment
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Chemical Engineering July 2023

Table of Contents for the Digital Edition of Chemical Engineering July 2023
