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HRVOC Monitoring Requirements. Cooling Towers Must measure flow and continuous concentration in all cooling tower return streams Must file QA/QC plan with state for approval Approval - how long will it take? How consistent will reviews be? Will delay implementation of projects

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hrvoc monitoring requirements
HRVOC Monitoring Requirements
  • Cooling Towers
    • Must measure flow and continuous concentration in all cooling tower return streams
    • Must file QA/QC plan with state for approval
      • Approval - how long will it take? How consistent will reviews be?
      • Will delay implementation of projects
    • El Paso stripper, sparger or gas transfer membranes will be required, not a lot of experience with this in our plants
      • El Paso stripper and operating conditions, equations defined in Appendix P
    • Total strippable VOC measurement opens doors to other techniques
      • Methane/ethane exclusion
    • Minimum detection limits of no more than 10 ppbw in water
      • Review math in Appendix P, assumes total transfer to gas phase of VOCs
      • Henry’s Law evaluation not required
    • Cycle time for analysis
      • Shorter if using total hydrocarbons or some other aggregate property analyzer
      • If using speciation anyway the ability to get measurement done in 15 minutes is easier.
    • Calibration
      • Local calibration direct into analyzer
      • Periodic testing of water/hydrocarbon mix

Texas City ISA Section Meeting

monitoring cooling towers and flares
Monitoring Cooling Towers and Flares
  • Flares
    • Concentration and flow measurement required in header after last knockout, BTU measurement also required
      • Design and operating conditions for some flares will make this a very unique situation
    • Monitoring requirements list Performance Specification 9 (PS 9), a GC method for the calibration requirements
      • Too specific, should be able to use other analysis methods such as FTIR, mass spectrometers, and calorimeters
      • PS 9 performance requirements are too stringent, e.g., 120 deg. C sample lines and oven
    • Different test methods for organics and inorganics
      • Why not use a calibration gas method like we do with other analyzers rather than rely on lab tests?
    • Since we have to do compounds necessary for HRVOCs and BTU how far out do we analyze?

Texas City ISA Section Meeting