How are you validating your MOC process? Ei presents a case study of a project in which we leveraged P&ID data to validate a site's MOC process, ensuring all relevant changes were getting properly addressed.Read More
Ei's undertook a case study to evaluate the payback period and long term cost savings associated with implementing Ei's new electronic P&ID highlighting service, showing a 3-5 month payback period and 12-19% long term compliance budget savings.Read More
HOW TO CREATE A CUSTOM LINE TYPE
BY: MICHAEL JOHNSON
You need to make a shape to create a line type, but first you'll have to create the shape using polylines.
Start a new drawing using the New Drawing symbol on your quick access toolbar, at the top left of your screen right next to the big A symbol.
Type PLine to start the polyline command. Type 0, 0 then ENTER for the starting point; type "A" then ENTER to draw an arc; drag the cursor to the right and type .09 then ENTER
Again drag the cursor to the right and type .09 then ENTER; you should have a poly line that looks like this:
Select the Polyline and type MOVE, move the poly line to the right and type .09 then ENTER.
Start a new Polyline by using the PLINE command; type 0,0 then ENTER; drag the cursor to the right and type .36 then ENTER; you should have 2 polylines that look like this:
Now you need to turn this into a shape file. Type the command MKSHAPE then ENTER; find an easy place to locate this shape file like the desktop and save it as ElectroMagnetic.shp; back in AutoCAD type ElectroMagnetic for the name then ENTER; Since this shape file has curves type 512 for the resolution then ENTER; type 0,0 then ENTER for base point; select both of the created polylines then ENTER.
Now you need to insert that shape file. Type SHAPE then ENTER; type the shape name which is ElectroMagnetic then ENTER; type 0,0 then ENTER for base point; then hit ENTER which leaves the scale at 1.0000; type 0 then ENTER for the rotation angle.
Now that the shape file is inserted we can create a line type. Type MKLTYPE then ENTER; save this file to the same location as the shape file with the same name "ElectroMagnetic"; back in AutoCAD type ElectroMagnetic then ENTER for the name; leave the description blank and then ENTER; type 0,0 then ENTER for the starting point; drag the cursor to the right and either type .36 then ENTER, or select the end point of our shape; select our shape then ENTER.
Now the ElectroMag line type exists in this drawing.Start the LINE command and create a long line anywhere in the drawing; select the line then navigate to the properties portion of the ribbon, select the linetype drop down menu as shown below and select ElectroMagnetic:
Now we need to put both the .shp and .lin files you created in the correct location (by creating a line type you should also notice a new .shx file where you saved the .shp and .lin files). Open Windows File Explorer; Navigate to the following location C:\ProgramFiles\Autodesk\AutoCAD 2015\PNID\en-us (if you're using a newer version of AutoCAD be sure to select that folder instead of AutoCAD 2015); You'll copy and paste .shp, .lin, and .shx files into this location.
Now you need to create the new ElectroMagnetic signal line in your p&id project setup. First select the lines pallet, located on your tool pallets. Now open your p&id project, in the project manager right click the project title and select Properties from the drop down list:
Expand P&ID DWG settings, expand Engineering Items, expand Inline Assets, expand Piping Fittings, select Flange, then in the Flange settings choose Edit Block as shown:
On the Edit Block screen, navigate to the Home tab at the top of the ribbon, navigate to the Properties tab on that Ribbon, select the drop down menu for Linetype, at the bottom of that list select Other:
On the next window select Load, in the next window select File, navigate to the location I that I had you put your new linetype in C:\Program Files\Autodesk\AutoCAD 2015\PNID\en-US, select your ElectroMagnetic Line type then select Open. In the next menu scroll down and select ElectroMagnetic then select Ok, In the next window scroll down and select ELECTROMAGNETIC, make sure that both scales in the bottom right corner are set to 1.000, select Load:
Back in the block editor, select Close Block Editor in the top right on the ribbon, save changes to block.
Back in project setup scroll down and expand Lines, expand Signal Lines, right click on Signal Lines and select new as shown:
For the name type Ei_ElectroMagnetic, for the display name you can remove the underscore and add a space.
Now select the new Signal Line Ei ElectroMagnetic, at the top of the signal line properties select Edit Line
In the window that pops up fill out the properties as shown, for the line type select the drop down and choose your ElectroMagnetic line, after you're done select Ok.
Now in your project setup, right below the Edit Line option for you Ei ElectroMagnetic line, select Add to Tool Pallet, select Apply in your project setup at the bottom right corner, then select Ok.
Now open one the drawings in the project using the project manager pallet, select your new Ei ElectroMagnetic line from your tool pallet and draw a line inside the drawing, it should look like this:
During part 2 of Ei's webinar series on cutting-edge LDAR enforcement priorities, Ei's LDAR experts presented on one of the most prominant enforcement and risk managment areas of industry: Low-Emission valves and packings. Click here to learn more.Read More
This past Tuesday, Ei hosted Kosta Loukeris from EPA Region 5 who serve's as the EPA's national contact for LDAR on a webinar titled CD ELPs: How ELPs are Preventable. Click here to learn more!Read More
Shane Kling of Ei and Philip Frazier of the Marathon Garyville Refinery co-authored a case study on the cost savings of converting standard refinery piping and instrumentation diagrams (P&IDs) to electronic, "intelligent" P&IDs.
The case study, which was published by the trade organization, American Fuels and Petrochemical Manufacturers, presented cost projection data illustrating a “break-even point” (e.g., where initial and ongoing costs for each method equal one another) of 7 years. A 50% reduction of current industry rates to convert electronic P&IDs, then, would present a break-even point of 3.5 years.
Furthermore, the authors discussed benefits of the technology to non-environmental disciplines, such as Process Safety, Operations, Inspections, and Mechanical Integrity – who all maintain P&IDs for compliance or reference purposes. If non-environmental disciplines were included in a subsequent case study, it stands to reason that greater costs savings can be achieved.
Considering that the PSM regulation mandates P&IDs to be revalidated every 5 years, it is a feasible strategy to consider implementation of intelligent P&IDs alongside P&ID updates resulting from the PHA process. The case study also demonstrated that mobile technology utilizing electronic P&IDs can result in environmental productivity improvements representing 60% efficiency gains.
Read the entire case study here:
Leak Detection and Repair (LDAR) enforcement may seem to have trailed off in recent years, as US EPA/DOJ settlements have dwindled, but if you’re asking “Is LDAR compliance still an EPA Region and/or Air Toxics Initiative?”the answer is a resounding YES. EPA has changed the method through which it enters into LDAR consent decrees, but that doesn’t mean LDAR enforcement has gone away. In fact, it’s more important than ever to stay on top of the latest LDAR regulatory actions to mitigate compliance risk.
This blog post discusses a new generation of Consent Decrees with Enhanced LDAR Programs (ELPs), how they differ from previous LDAR CDs, and what you can expect from the new enforcement initiative. For more about how CD ELPs may affect you specifically, join our “Ask a Regulator” webinar with EPA expert Kosta Loukeris at 1pm central on September 6th (50-person limit, so register today).
Meet the New Generation of CDs: Enhanced LDAR Programs
Under leadership at EPA Region V, Consent Decree with Enhanced LDAR Programs undertook a heavy makeover in 2009 and 2010 with settlements between EPA/DOJ and INEOS Lanxess and Vertellus Agrosciences. In particular the settlements detail,
New-generation CDs differ from preceding LDAR CDs in that EPA amplified forward-looking expectations to re-prioritize “preventative maintenance” measures (i.e., Low-Emissions / Low-Leaking Equipment) in lieu of “find and fix it” standards, along with other LDAR program enhancements (increased audits, 3rd party QA/QC, and increased monitoring frequencies).
The 2009 and 2010 agreements with INEOS Lanxess and Vertellus Agrosciences pre-empted a Chemical Plant CD ELP Initiative that later resulted in the following companies also agreeing to ELP settlements: Dow Chemical Company (Midland, MI); Solutia, Inc. (St. Louis, MO); SABIC Innovative Plastics (Mt. Vernon, IN and Birkville, AL); as well as BASF (Wyandotte, MI).
What did all of these companies have in common?
Most Consenters of new-gen ELPs were major sources for hazardous air pollutants (HAP) and subject to LDAR regulations covered under a Maximum Achievable Control Technology (MACT) regulation.
CDs with Enhanced LDAR Programs and Refineries
It seemed that EPA was satisfied with its enforcement of US petroleum refiners, having negotiated CDs with >90% of US petroleum refining capacity by 2012, then came the daunting BP Whiting Consent Decree that lodged in November 2013. The BP Whiting CD ELP represented the most stringent CD ELP of its kind, irrespective of industry at the time:
Low-E requirements were mandated at 5 years at <100 ppm, quarterly QA/QC of all Management of Change (MOCs) to verify LDAR compliance, as well as NSPS VVa applicability and initial monitoring for all refinery process units.
EPA’s “New” LDAR Enforcement Focus: Oil & Gas?
It was rumored that several other refineries were in negotiations for “2nd round” CDs that would include “BP Whiting ELP language” as a starting point. However, 2014 and 2015 passed without another major refining group entering into an ELP. With increased enforcement and notice of violations (NOVs) targeted at oil and gas (O&G) operators, along with the lodging of the Merit Energy ELP on 5/1/15 it appeared that EPA was focusing its resources on O&G, not US refining and chemical plant operators.
Then, in July, Tesoro Corporation lodged a CD with ELP requirements that apply to its 5 refineries in Mandan, North Dakota; Salt Lake City, UT; Anacortes, WA; Martinez, CA; as well as Kenai, AK (note: its two California refineries in Carson and Wilmington are not applicable to the ELP). An early read of Tesoro’s ELP indicates that much of the language from the BP Whiting CD was indeed “boiler-plate” language that likely served as the “starting point” for negotiations between Tesoro and EPA/DOJ. Among other requirements,
Tesoro has mandates to implement Low-E, increased auditing and QA/QC, as well as to engage in a certification of compliance to “certify that all LDAR equipment subject to a Federal and/or State regulation is included within the affected facility’s LDAR program.”
So, Yes. LDAR is (Still) an EPA Enforcement Priority (for Petroleum, Chemicals, and O&G)
The Tesoro CD signifies that EPA is continuing to allocate resources to ensure compliance with Federal, State and/or CD LDAR requirements, albeit with numerous other EPA compliance initiatives (e.g., Refinery Residual Risk and fenceline monitoring).
Stay tuned for a follow-up blog post next week with knowledge, lessons learned, and best practices on how to manage and mitigate LDAR compliance risk at your facility. Feel free to post questions/comments below for Environmental intellect’s (Ei’s) team of LDAR experts, who have collectively negotiated over a dozen new-gen ELPs. And remember to join our “Ask a Regulator” webinar with EPA expert Kosta Loukeris for more about CD ELPs.
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