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3/22/2018 1 ©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 1 Flare Essentials Introduction to the World of Flaring 4C CONFERENCE – FEBRUARY 2018 – SAN ANTONIO, TX ©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 2 Welcome! Safety Items Alarms, Exits, Meeting Point Meeting Logistics Focus for Today Topics Agenda Comments and remarks Introductions Image courtesy of epa.com

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Page 1: Flare Essentials Introduction to the World of Flaring · Flare System Components & Gas Lines ... Flare Gas Recovery Primary function of FGR To capture and compress flare gas Captured

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 1

Flare EssentialsIntroduction to the World of Flaring

4C CONFERENCE – FEBRUARY 2018 – SAN ANTONIO, TX

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 2

Welcome!•Safety Items

• Alarms, Exits, Meeting Point

• Meeting Logistics

•Focus for Today

• Topics

• Agenda

•Comments and remarks

•Introductions

Image courtesy of epa.com

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 3

Topics and Agenda8:00-9:30 Session 1 – History of Flaring

9:30-9:45 Break

9:45-10:15 Session 2 – Flare Components

10:15-11:15 Session 3 – Instrumentation

11:15-12:00 Session 4 – Calculations and Control

12:00-1:00 Lunch

1:00-2:00 Session 5 – Flare Regulations

2:00-3:00 Session 6 – Implementation

3:00-3:30 Break

3:30-4:30 Session 7 – A Look to the Future

Image courtesy of grandmagazine.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 4

Defining what is a flare?•Uncontrolled volume of air

•NSPS Ja Definition

•MACT CC Definition

Image courtesy of zeeco.com Image courtesy of shutterstockImage courtesy of zeeco.com

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Why did flaring start?•Alternative to direct venting

•Early flares were open pit flares

•Primarily a safety device to remove potentially explosive vapor clouds from people and equipment

•Not used as environmental control devices.

Image courtesy of google image

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 6

Reasons to Flare•Opposed to other combustion devices, flares allow for the combustion of

• Large volumes of hydrocarbons

• High flow rates

• Distant location to personnel and equipment

• Elevated flares allow for added dispersion

•As environmental regulations came into being, use of an “environmental control device” was encouraged.

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Why to minimize flaring?Flaring is a very visible reminder of

◦ lost raw material

◦ lost product

◦ lost fuel gas

Most facilities limit flaring for these reasons without regulation or enforcement.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 8

What affects flare performance?

Study Date

Flare

Size

(in)

DesignVelocity

(ft/s)Gas Flared

Measured

Efficiency (%)

Palmer 1972 0.5 Experimental Nozzle 50-250 Ethylene >97.8

Lee & Whipple 1981 2.0 Holes in 2” Cap 1.8 Propane 96 – 100

Siegel 1980 27Commercial Flaregas

(Coanda FS-6)0.7-16 Refinery Gas(a) 97 – > 99

Howes, et al. 1981 6(c) Commercial Air-Assist

(Zink LH)40-60 Propane 92 – 100

Howes, et al. 1981 3 at 4(b) Commercial H.P. Zink

LRGO

Near sonic

(est.)Natural Gas >99

McDaniel

Keller and Noble1983 8

Commercial Zink STF-S-

80.03-62 Propylene/Nitrogen(d) 67 – 100

McDaniel

Keller and Noble1983 6(c) Commercial Air-Assist

(Zink STF-LH-457-5)1.4-218 Propylene/Nitrogen(e) 55 – 100

Pohl, et al. 1984 3-12Open pipe and

commercial0.2-420 Propane/Nitrogen(f) 90 – 99.9

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 9

Steam to vent gas identified

“Figure 8 is a graph of the effect of steam-to-relief

gas ratios on the measured combustion

efficiencies of high Btu content relief gases. This

plot shows general tendencies for combustion

efficiencies to decline at higher or lower than

normal steam flows. This data suggests that

steam-to-relief gas ratios ranging from 0.4 to 1.5

yield the best combustion efficiencies.”

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 10

Key points of interest – 1980sEPA concluded that flares can be operated with

combustion and destruction efficiencies >98-99%.

Flame stability

Specific to flare tip design and vent gas composition

Largest influence on flame stability for a given flare tip are the gas exit velocity and heating value.◦ Levels of steam, air or pilot assist can also affect flame stability and combustion efficiency.

◦ Vent gases of equal heating value but different composition can have different combustion properties when flared from the same flare.

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 11

Where flare requirements beganNSPS Subpart A (60.18; 1986) and MACT Subpart A (63.11; 1994)

•No visible emissions

•Flame present at all times [as determined by paragraph (f)]

•Maintain adequate heating value >300 BTU/scf (with variation)

•Keep tip velocity <60 fps (with variation)

•Flares operated at all times that waste gases are directed to device

60.18(d) Owners or operators of flares used to comply with the provisions of this subpart shall monitor these control devices to ensure that they are operated and maintained in conformance with their designs. Applicable subparts will provide provisions stating how owners or operators of flares shall monitor these control devices.

Performance test to demonstrate per 40 CFR 60.18 ? ◦ “Net heating value shall be calculated….variable Ci determined for organics as measured by Method

18…”

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 12

AP-42 Provides GuidanceChapter 13.5.2 Emissions published in 1995

“Noise and heat are the most apparent undesirable effects of flare operation. Flares are usually located away from populated areas or are sufficiently isolated, thus minimizing their effects on populations.”

“Emissions from flaring include carbon particles (soot), unburned hydrocarbons, CO, and other partially burned and altered hydrocarbons. Also emitted are NOx and, if sulfur-containing material such as hydrogen sulfide or mercaptans is flared, sulfur dioxide (SO2). The quantities of hydrocarbon emissions generated relate to the degree of combustion. The degree of combustion depends largely on the rate and extent of fuel-air mixing and on the flame temperatures achieved and maintained. Properly operated flares achieve at least 98 percent combustion efficiency in the flare plume, meaning that hydrocarbon and CO emmissions [sic] amount to less than 2 percent of hydrocarbons in the gas stream.”

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 13

Changes to AP-42Revised February 2018

Added language concerning combustion efficiency◦ Oversteaming

◦ Combustion Zone Properties

◦ 270 Btu/scf in the combustion zone

Notable wording changes◦ Noise, heat, and heat visible flame and/or smoke are the most apparent undesirable

effects of flare operation.

◦ Properly operated flares achieve at least 98 percent combustion destruction efficiency in the flare plume, meaning that hydrocarbon and CO emmissions emissions amount to less than 2 percent of the hydrocarbons in the gas stream.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 14

AP-42 Emission Factors

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 15

Guidance on Visible Emissions

Images courtesy of epa.com, B.I. International and AACA

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 16

“Recent” Information1. TCEQ Air Quality Study - HRVOC issues

◦ Reconcile EI & Ambient Data in 2000

2. California Flare Rules

3. Community Impact Study

◦ Addyston, Ohio, 2004-2006

4. TCEQ Flare Study 2011

◦ Industrial Scale Flares

◦ State-of-the-art remote sensing analytical technique (PFTIR)

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HRVOC HistoryTexas Air Quality Study 2000

Objective – reconcile Emissions Inventory with actual Ambient Air quality data

The flare in the following slide was observed during intensive ozone monitoring on August 30, 2000.

Downwind of these two flares, ambient ground level concentrations of ozone in the range of 200 ppb were measured by the monitors.

Image courtesy of iconspng.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 18

TCEQ Air Quality StudyTCEQ’s Ozone Modeling of the “event” required the Flare Combustion Efficiency to be lowered from 98% to 90%.

(Estimated and calculated losses obtained from the site.)

Image from Karen Olson (TCEQ) 2003 TCEQ Technology Conference

Presentation and Image from Dennis Griffith 2003 TCEQ Technology

Conference Presentation

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HRVOC Rules (2004) Impact on Industrial FlaresIn-Line Composition Analyzers Thermal Mass or Ultra-Sonic Flow

Images courtesy of siemens.com and gemeasurement.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 20

SCAQMD Increases Pressure on Flares

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New ParadigmLanxess / Ineos in Addyston, Ohio

2004 - 2006 – high ambient air readings at local air monitor atop neighboring elementary school.

Facility was the only local user of acrylonitrile and 1,3-butadiene

Images Courtesy of Ohio

Citizen Action

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 22

Thoughts…Focus was on visible emissions – no smoke

Overall assumption is that high DRE/CE (96.5-98%) is routinely achieved by simply following §60.18

California – moves towards flare volume minimization (community desires no flaring)

Texas – flare events “could” significantly contribute to ambient impacts

Ohio - flares are easily “over-steamed”

Re-run confirmatory flare tests (TCEQ)

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As Steam to Vent Gas (S/VG) Ratio Increases, Combustion Efficiency Decreases

September 2010 “New Developments in

Flaring” presented by East Harris County Air

Partners

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 24

EPA’s Overall Target - Revised and Variable Net Heating Value Basis

Shift from

Header

Combustion Zone

Images courtesy of zeeco.com

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Flare Enforcement Alert – Oct 2000Enforcement was directed towards refining sector.

Issues were alleged excessive SO2.

Many refinery flares appeared to operate outside of the NSPS Subpart J requirements.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 26

EPA’s Flare Enforcement Focus continues

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Flare Rulemaking and EnforcementRevised Refinery Sector Rule (RSR) – MACT CC and UUU

Flare requirements for flares used as control devices – MACT CC contains flare operation requirements

Enforcement since revised RSR

Tesoro

Citgo Lemont

ExxonMobil

Shell Norco

Images courtesy of medium.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 28

Questions?

Images courtesy of kesaus.org

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Flare EssentialsFlare System Components

4C CONFERENCE – FEBRUARY 2018 – SAN ANTONIO, TX

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Flare System Components & Gas Lines

Process Units Ignition System

Flare Gas Header Vent Gas

Liquid Knockout (KO) Drum Sweep Gas

Water Seal Purge Gas

Flare Stack Supplemental Gas

Molecular Seal Pilot Gas

Flare Tip Ignition Gas

Pilots Assist Gas

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Flare System Terms & Concepts

Components

Components

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Process UnitsFlaring vs. Atmospheric Venting

Safety device and control device

Primary function of flare system stems from process units

Types of Contributions

Sizing, anticipated flow rates, and anticipated composition of process units and gases provides basis for flare system design

Image Courtesy of Hijet Engineering Ltd.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Vent (Flare) GasGenerated by process units

May be continuous and/or intermittent

May vary widely in flow and composition

Multiple point of contributions dependent on◦ Type of industry

◦ Size of facility

Strategic placement of certain connections

Monitoring◦ Vent gas composition

◦ Sulfur

◦ Flow

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Flare Gas HeaderSeries of piping that collects and transfers flare gas to the flare.

Function - accumulate and transfer gases to the flare tip for combustion

Potential for oxygen infiltration

Mostly hard-piped connections

Some connections for equipment depressurization and purging for maintenance

activities, such as startup, shutdown, and turnaround.

Low-Pressure vs. High-Pressure

Blowdown Network

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Liquid Knockout (KO) DrumFunction – remove any potential liquids from the flare gas prior to combustion

Boot can hold a specified amount of liquid

◦ Two-phase or three phase-separation devices

Typically upstream of seal devices

May also be located upstream of FGRU

Repercussions of flaring liquids

Image from Wikipedia

Image from www.pipingguide.net

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Water Seal (Liquid Seal) DrumDual functionality

Located downstream of KO drum

Can allow flare staging

Freezing concerns

Alternatives

◦ Pressure control valve

◦ Buckling pin

◦ Rupture Disk

Images Courtesy of NAO, Inc. (far left), Zeeco (left),

and Airoil Flaregas (above)

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Flare Gas RecoveryPrimary function of FGR◦ To capture and compress flare gas

◦ Captured gas to be used for its heating value

Recovered gas is sent back to the fuel gas system

Potential for product recovery

FGR systems do not compromise on safety

High pressure emergency releases can still be vented directly to flare

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Flare Gas Recovery

Images c

ourt

esy

of

Zeeco

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Flare Stack

ElevatedImage Courtesy of Thermal Solutions Asia

PortableImage Courtesy of Oil, Gas, & Petrochem Equipment

GroundImage Courtesy of virtualglobetrotting.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Buoyancy/Velocity SealFunction - impede ambient air from infiltrating down the flare stack

Installed just below the tip

Mechanical devices

Doubles up as purge reduction device

Potential condensation should be drained

Design Considerations

Images courtesy of Tornado Tech (above) and

enggcyclopedia.com (above right).

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Flare Tip (Flare Burner)Function – mix flare gas and assist gas at design velocities, turbulence, and concentration

Dynamic operation

◦ Design to handle baseload and emergency-case releases

Diameter of flare tip

Metallurgy considerations

Combustion Zone

Images Courtesy of Prema Service

Images C

ourt

esy

of

Zeeco

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Types Of Flare TipsNon-Smokeless (Unassisted) Flare Tip◦ Least form of flame control for entire capacity of flare

◦ Can be used without increasing emissions for gas streams that do not cause smoking

◦ Supplemental capacity for emergencies

◦ Most ground flares are unassisted flares

◦ Can be pressure assisted

Images Courtesy of Argo Flare Services

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Types Of Flare TipsSteam-Assisted Flare Tip◦ Upper steam

◦ Lower steam

◦ Center steam

◦ Help to shape the flare

◦ Continuous nominal flow of steam

◦ Smoking may occur even with full application of available steam flow at high flow rates

Images Courtesy of epa.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Types Of Flare TipsAir-Assisted Flare Tip◦ Compressed air or forced-draft air supply

◦ Use driven by steam unavailability and/or economy of air supply

◦ Approximately 20 % greater mass of air is required than that of steam

◦ Adds momentum and buoyancy to the flare, effectively entraining additional combustion air from the surrounding atmosphere. Images Courtesy of Zeeco

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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PilotsReliably ignites flare gas

Design considerations

Characteristics of pilots

Images Courtesy of Eagle Sight

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Ignition SystemUsed to reliably light the pilots

Typically piggy backs on pilot gas supply lines

Four primary types◦ Spark ignition at pilot tip

◦ Spark ignition of pilot gas and combustion air prior to flare tip

◦ Compressed-air flame-front generator (FFG)

◦ Self-inspirating FFG

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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CCTV in Control RoomFunction – continuous remote viewing of flare

Not vital to operation or performance of flare

Used by many (most) facilities

Can be used to monitor flare for smoking as per recent regulations

New refinery sector rule and most CDs require images to be stored

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Gas Lines

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Assist GasIntended to prevent smoking of a flare

Typically involves multi-tiered delivery system

Required to cool flare tip

Control may be automated and/or manual

Important to know minimum, maximum and normal expected operating flow rates

Image Courtesy of Air Alliance Houston

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Sweep Gas & Purge GasSweep Gas

◦ Function – to maintain constant flow of gas to prevent oxygen buildup in flare header

◦ Location – throughout the flare header

Purge Gas◦ Function – to prevent oxygen infiltration into the flare tip

◦ Location – between flare’s water seal and tip

Desired gases◦ Not contain oxygen – maintain <8% O2

◦ Above dew point under normal operating conditions

Natural gas or recovered gas advantage

Steam disadvantages

Nitrogen disadvantages

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Supplemental GasFunction – calorific boost to ensure adequate combustion

Typically only non-process gas that is adjustable with known Btu value

Location – just upstream or downstream of flow and composition monitors

Types of gas

Flow control can be automatedImage Courtesy of Shutterstock.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

Pilot GasFunction – continually burning gas stream in order to reliably ignite the vent gas

May use natural gas or recovered gas

Flow is constant and typically regulated by orifice plate

Image Courtesy of John Zink

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Questions?

Up Next: Flare Monitoring Systems

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC

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Flare EssentialsFlare Instrumentation

4C CONFERENCE – FEBRUARY 2018 – SAN ANTONIO, TX

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 1

Flare Instrumentation OverviewFlow Composition

• Vent Gas • Net Heating Value

• Steam Assist • VOCs and Inerts

• Air Assist • Sulfur

• Supplemental Gas

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 2

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Flare Flow MonitoringVent Gas◦ Types of flow meters

◦ Complexities and Challenges

Assist Gas and Supplemental Gas◦ Why this matters?

◦ Types of flow meters

◦ Complexities and Challenges

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 3

Vent Gas Flow Meter Accuracy RequirementsVery low (<0.1 fps) flow velocities are difficult to accurately measure.

Both NSPS Ja and MACT CC include allowance for greater inaccuracy (±20%) at low flows (0.1 tp 1 feet per second)

Accuracy requirements of ±5% at flows above 1 feet per second

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 4

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Vent Gas Flow Instrumentation

Technologies and Manufacturers◦Ultrasonic

◦ General Electric

◦ Sick

◦ Fluenta

◦Optical◦ OSi

Images Courtesy of

www.engineeringtoolbox.com

(top) and Optical Scientific, Inc.

(bottom)

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 5

Flow Meter InstallationNeed to find adequate upstream and downstream undisturbed distances

Manufacturer ModelMinimum Upstream

Distance

Minimum Downstream

Distance

GE GF 868 20 pipe diameters 10 pipe diameters

Sick FLOWSIC100 EX-S 20 pipe diameters 10 pipe diameters

Fluenta FGM-160 10 pipe diameters 5 pipe diameters

OSi OFS-2000F 2 pipe diameters 1 pipe diameters

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 6

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Ultrasonic Flow MeasurementUltrasonic Correlation Transit-Time Mode

Pressure and temperature corrected

Retractable, maintainable online

Accuracy ◦ ±20% between 0.1 and 1.0 fps

◦ ±5% above 1.0 fps

Different types of transducers

Image Courtesy of GE Measurement & Control

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 7

Good Flow Monitoring Solutions

Existing Bias 90 Single Path

◦ Can meet accuracy (“sensitivity”) requirements with smaller pipes

Add Second Bias 90 Path

◦ Can meet accuracy requirements for smaller pipes

◦ Paths flow rates are averaged together for better accuracy

Concerns remain, particularly for low flow, high hydrogen streams.

What else can you do?Images Courtesy of GE Measurement and Controls;

Presentation by Jed Matson at 2013 Flare Instrumentation Workshop

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 8

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Better SolutionDiagonal 45 T17 path

◦ Better accuracy at lower flow rates

Bias 90 T5 Path

◦ Demonstrate compliance at medium to high flow rates

Images Courtesy of GE Measurement and Controls;

Presentation by Jed Matson at 2013 Flare Instrumentation Workshop

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 9

Better SolutionSingle path flow meter with T17 transducers

Can be new installation or upgrade of existing transducers

◦ Requires 3 inch taps for insertion

Images Courtesy of GE Measurement and Controls;

Presentation by Jed Matson at 2013 Flare Instrumentation Workshop

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 10

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Best SolutionTwo crossed Diagonal 45 T17 Paths

Improved performance◦ Highest accuracy and repeatability

◦ Paths averaged

◦ Redundancy

◦ Excellent Cross/Convection Flow Immunity

Images Courtesy of GE Measurement and Controls;

Presentation by Jed Matson at 2013 Flare Instrumentation Workshop

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 11

Ultrasonic ComplexitiesGE Ultrasonic flow meters are the most popular choice in industry

Facilities have experienced difficulty with flow readings under certain conditions◦ Low flow

◦ Hydrogen flow

◦ Nitrogen flow

There are options to deal with such issues

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 12

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Flow Meter MaintenanceFlow meters must be maintainable online.

All components must be visually inspected on a quarterly basis.

“Recalibrate” biennially or at the frequency specified by the manufacturer.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 13

Molecular WeightUltrasonic flow meters provide an average molecular weight (MW)

Enables direct control through S/VG Ratio (lb/lb)

Vent gas MW measurement required by MACT CC if using a mass flow meter.

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Steam Flow MonitoringVolumetric or mass flow meters may be used under MACT CC

Steam flow meter technologies◦ Ultrasonic

◦ Vortex

◦ Differential Pressure

Installation issues Image Courtesy of GE

Measurement and Control

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Steam Flow Meter AccuracyMACT CC requires an accuracy of ±5% over the normal range measured for mass flow.

CDs include tighter accuracy requirements.◦ Marathon, BP Whiting, and CountryMark

◦ ± 1% from 100% to 15% of span

◦ ± 2% from 15% to 6% of span

◦ ± 3% from 6% to 4% of span

◦ Equistar Chemicals Baytown Complex◦ ± 2% from 100% to 6% of span

◦ ± 3% from 6% to 4% of span

◦ Shell Deer Park◦ ± 1% full scale on a volumetric basis

◦ ± 2.5% full scale on a mass basis

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Assist Air Flow Monitoring Methods for determining air flow◦ Fan curve

◦ Challenges

◦ Direct flow measurement

◦ Challenges

Either option allowed under MACT CC

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Supplemental Gas Flow MetersSupplemental gas addition required to ensure NHV requirements of RSR and the Flare CDs.

RSR accuracy options

CDs do not specify a required accuracy for flow measurement of supplemental gas.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 18

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Purge, Sweep, and Pilot GasPurge and sweep gas rates usually provided at a constant rate

Must ensure:◦ Minimum sweep/purge being sent to flare tip

◦ NSPS Ja requires sweep/purge gas to be minimized

Sweep/purge flow usually set by regulators, restriction orifices, or control valves.

Pilot gas flow is typically constant and controlled by orifice plates or regulators.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 19

Flare Gas Composition Monitoring

MACT CC and CDs◦ Net heating value and/or composition

NSPS Ja◦ Sulfur Monitoring

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Vent Gas CompositionUltimate goal of determining composition is to ensure NHV at the flare tip

Several instrument options ◦ Mass Spectrometer

◦ Btu Analyzer

◦ GC

◦ Hydrogen Analyzers

◦ Combination of two?

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 21

Vent Gas Composition

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Instrument CriteriaResponse Time◦ Compliance timeframe

Cost◦ Direct Installation

◦ Operation and Maintenance

◦ Ancillary (Shelter, sampling system, etc.)

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Btu AnalyzerDirectly measures the NHV of a sample

Fast response time

Hydrogen correction

Early CDs have not typically included Btu analyzers; MACT CC specifically list technology

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Btu AnalyzerPros◦ Fast

◦ All constituents included in analysis

Cons◦ No speciation data

◦ Can requires second instrument/integrated hydrogen analyzer

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Hydrogen AnalyzersMACT CC allows for a second instrument to be used to measure hydrogen.

Hobre – WimCompasTM is a Btu analyzer with an integrated hydrogen analyzer to measure the hydrogen concentration in the vent gas

Multiple manufacturers and technologies are available for hydrogen measurement◦ Electrochemical – COSA/Xentaur CHA

◦ EPA used a quote for this instrument as part of their cost estimation for MACT CC.

◦ Thermal Conductivity – GE XMTC

◦ Thin Film – H2scan HY – OPTIMA 2700

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Hydrogen Analyzer Limitations

Temperature Limitations

Composition◦ Some analyzers are limited by the amount

of H2S in the vent gas.

◦ Cross-sensitivity

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Mass SpectrometerVent gas constituents ionized and passed through a magnetic field to separate mass fragments

Charged mass fragments are detected

Provides very fast measurements; a single instrument can be used to monitor multiple nearby flares

Broadly applicable AMP for Extrel and Ametekmass specs

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Mass SpectrometerPros◦ Fast response time

◦ Full composition

◦ Can sample multiple streams

Cons◦ Different maintenance requirements

◦ Calibration gas

Images courtesy of Extrel (right) and

University of Maine (left)

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Gas ChromatographUses a series of columns to separate constituents of the vent gas

The instrument of many of the early CDs.◦ MACT CC includes additional requirements for GCs.

Multiple manufacturers◦ ABB

◦ Emerson Rosemount

◦ Siemens

◦ Yokogawa

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Gas ChromatographPros◦ Potential for a single instrument for

sulfur and NHV

Cons◦ Slow cycle time

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Sampling Probe LocationPerformance Specifications (PS) to be followed for sulfur monitoring refer one back to PS 2

Table 13 of MACT CC and PS 2: 8.1.2 – CEMS Measurement Location

◦ “Suggested that measurement location be

1) At least two equivalent diameters downstream from nearest control device, the point of pollution generation, or other point at which a change in the pollutant concentration or emission rate may occur

2) At least half equivalent diameter upstream from the effluent exhaust or control device

Further guidance available for point CEMS, path CEMS and Reference Method locations

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As if everything else wasn’t complicated enough…

Where should instruments be installed for a flare with a water seal?

Integrated KO drum and liquid seal in the base of the stack?

Supplemental gas addition point with respect to instrumentation

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NSPS Ja Sulfur Monitoring Instrumentation

Low range H2S monitoring◦ Requires instrument spanned to 300 ppmvd

High range total reduced sulfur monitoring◦ TRS, TS, H2S, or SO2 monitoring

◦ Total reduced sulfur includes H2S, carbonyl sulfide (COS), carbon disulfide (CS2), and other significant sulfur species

◦ Span should be 1.1 to 1.3 times the maximum anticipated vent gas sulfur concentration.

◦ Requires instrument with a minimum span of 5,000 ppmvd

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Sulfur Monitoring Options

Sulfur Monitoring Technologies◦ Gas Chromatographs (GC)

◦ Tunable Diode Lasers (TDL)

◦ Mass spectrometers (MS)

◦ Total Sulfur (TS) Analyzers

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State of the IndustryMost refinery flares installed sulfur monitoring in order to comply with NSPS Ja.

Type Low Span Market Share High Span Market Share

Gas Chromatograph 67% 33%

Tunable Diode Laser 10% 7%

Mass Spectrometer 6% 6%

Total Sulfur 8% 44%

Exempt 14% 10%

Other 0.4% 0.4%

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NSPS Ja Monitoring AlternativesLiquid seal level and pressure sensor in lieu of flow and sulfur monitoring

Applies only to emergency flares, secondary flares, or flares equipped with a FGR system designed, sized and operated to capture all flows.

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Other Issues to ConsiderNSPS Ja requires an affected facility to maintain an H2S CEMS - 162 ppmvd

limit.

H2S results to be reported on a dry basis.

Relative accuracy tests of sulfur monitoring instruments

◦ RATA

◦ Alternative RAA

◦ Does not require testing against Method 15A (TS)

NOTE – Method 15A is for reduced sulfur compounds on a dry basis and Ja standard is also 162

ppmvd. But many analytical systems report the H2S on a wet basis.

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Questions?

Up Next: Flare Control Parameters and DCS Integration

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 1

Flare EssentialsControl Parameters and the Use of Distributed Control System

4C CONFERENCE – APRIL 2018 – SAN ANTONIO, TX

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 2

Good Air Pollution Control PracticesBrian Dickens (USEPA) – April 2009 presentation draws enforcement inspiration from…

40 CFR 60.11(d) / 63.6(e) / 63.642(n)

“…maintain and operate any affected facility including associated air

pollution control equipment in a manner consistent with good air pollution

control practice for minimizing emissions.”

http://www.skeyebv.nl/wp/wp-content/uploads/2013/02/Drone-

Inspection-UAV-UAS-onshore-offshore-Gas-Flare-Stack-03-900x330.jpg

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Good Air Pollution Control PracticesEPA theorizes that it is “common knowledge” that steam and assist air impact combustion efficiency and that over-assisting is “not a good air pollution control.”

Enforcement actions have alleged that refineries and other petrochemicals facilities have failed “to use good air pollution practices by steam addition in excess of design parameters.” (Dickens and Foley)

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 4

Good Air Pollution Control PracticesAvailable literature◦ 1983 EPA/CMA Study

◦ 1984/1985 EPA Flare Studies

◦ API 521

◦ API 537

◦ 2010 TCEQ Flare Tests

◦ AP-42

◦ 2015 Refinery Sector Rule amendments

◦ Flare Tip Operating Manuals

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Indicators of the Flare PerformanceWhat indicators do we have that demonstrate a flare is achieving “good” combustion performance?◦ No visible emissions (i.e., no smoking)

◦ Combustion efficiency (CE)

◦ Destruction removal efficiency (DRE)

If these are the indicators, how are they measured?

https://www.viperimaging.com/flare-stack-monitoring

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Visible EmissionsVisible metric – less than five minutes in any two hour period allowed by regulations.

Smoke generation influenced by characteristics of combusted material and by oxygen distribution

Smokeless combustion requires sufficient excess air above stoichiometric to be supplied

Insufficient combustion air - gases preheated prior to combustion zone ◦ Cracking of larger hydrocarbon molecules

◦ Smoke/soot is cooled carbon particles which have bonded to other carbon molecules instead of oxygen

Rules of Thumb

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Combustion EfficiencyCE is the primary metric used to measure flare performance. It is the percentage of influent gas stream that completely oxidizes to form only carbon dioxide and water vapor (so called “complete combustion”).

CO2,plume = volume concentration of CO2 in the plume (ppmv)

COplume = volume concentration of CO in the plume (ppmv)

∑HCplume = volume concentration of all the unburned hydrocarbons in the plume multiplied by the number of carbons in the hydrocarbon (ppmv)

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Destruction Removal EfficiencyDRE is a theoretical metric for assessing flare performance because of the critical role that VOCs play in contributing to the formation of ozone. DRE focuses on the change in concentration for specific compounds, rather than the stoichiometric balance of complete combustion.

Xplume = amount of species X found in flare plume

Xin = amount of species X in the vent gas entering the flare

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Determination of CE and DRE

Surrogate Parameters

Direct Measurements

Passive Extractive

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Surrogate Parameters

Parameter FamilySubpart A

Parameter

Early CD

Parameter

MACT CC

Parameter

Exit Velocity Exit VelocityExit Velocity

Exit VelocityMFR

Assist Gas NoneS/VG

NoneSR

Heating Value NHVvg

NHVcz NHVcz

LFL NHVdil

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Exit Velocity as a Surrogate Parameter

Flame stability and lift off

Based upon EPA-funded studies conducted in early 1980’s ◦ Must either be less than 60

ft/sec or less than both 400 ft/sec and a maximum velocity based on NHVvg

◦ Studies did not show a decrease in combustion efficiency

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Momentum Flux RatioMomentum Flux Ratio (MFR)

◦ Based upon studies conducted by Peter Gogolek (Natural Resources Canada)

◦ Issue: scalability of test results

◦ Images at right show a 1-inch “flare tip”

Image Courtesy BP Whiting Consent DecreeJohnson, M., and L.W. Kostiuk. 2000. Efficiencies of low-momentum jet diffusion flames in

crosswinds. Combustion and Flame. 23:189-200 (via 2012 OAQPS Flare Report)

.

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Maximum Permitted Exit VelocityConsolidates three equations for Vmax into one equation

Steam and Unassisted Flares

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Effects of Assist Gas on CEStudies from the 1980s touched on the effects of assist gas on combustion efficiency, but regulations did not explicitly address these effects.

2010 TCEQ Flare Study revisited these effects.

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Assist Gas Parameters

Steam to Vent Gas Ratio

◦Mass basis < 3.0 lb steam / lb vent gas

Stoichiometric Air Ratio

◦No consistent limit between the CDs and other literature

◦Values between 6 and 10

RSR amendments do not specify required ratios.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 16

NHVvg as a Surrogate ParameterNSPS Subpart A and MACT Subpart A both focused on NHVvg

HT = Net heating value of the sample, MJ/scm; where the net enthalpy per mole of offgas is based on combustion at 25 ºC and 760 mm Hg, but the standard temperature for determining the volume corresponding to one mole is 20ºC;

Ci = Concentration of sample component i in ppm on a wet basis, as measured for organics by Reference Method 18 and measured for hydrogen and carbon monoxide by ASTM D1946-77 or 90 (Reapproved 1994) (Incorporated by reference as specified in§60.17); and

Hi = Net heat of combustion of sample component i, kcal/g mole at 25ºC and 760 mm Hg. The heats of combustion may be determined using ASTM D2382-76 or 88 or D4809-95 (incorporated by reference as specified in§60.17) if published values are not available or cannot be calculated.

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Combustion Zone Net Heating Value Parameters in the Consent DecreesConsent decrees started to the shift the focus to the combustion zone.

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Combustion Zone Net Heating Value Parameters in MACT CC

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EPA Basis for NHVcz Limit

Source:

“Operating Limits for Flares.” RTI International

Memo to USEPA. December 12, 2013.

No. of Times Operating Limit was Achieved but

CE < 95%: 0

No. of Times Operating Limit was Achieved but

CE < 96.5%: 0

No. of Times Operating Limit was Not Achieved

but CE ≥ 98%: 347 (11% of data points)

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 20

EPA Basis for NHVdil Limit

Source:

“Operating Limits for Flares.” RTI International

Memo to USEPA. December 12, 2013.

No. of Times Operating Limit was Achieved but

CE < 96.5%: 0

No. of Times Operating Limit was Not Achieved

but CE ≥ 96.5%: 1

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Automating Flare Control

We are seeking to automatically adjust NHVcz (and NHVdil

where appropriate).◦ What can we actually control?

Automatic or manual control?

MACT CC Calculation Methods◦ Feed forward calculation

◦ Direct calculation method

http://www.skyreel.com/workspace/images/articles/web-stack-img183.jpg

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Flare Control ChallengesControlling a system with varying data capture frequencies is very difficult!◦ Instantaneous changes to contributions from process-limited monitoring and

controls

◦ Cycle times

◦ Normalizing the different inputs

◦ For Ja, the rules are in 3 hour rolling average limits.

◦ For MACT CC, regulated material must be routed to the flare for at least 15 minutes.

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Flaring at the Incipient Smoke PointThe greatest combustion efficiency is achieved at or near the incipient smoke point.

The EPA considered amending the visible emission standards for refinery flares as part of MACT CC, but decided against it.

https://upload.wikimedia.org/wikipedia/commons/8/8f/Gunvor_brulig

as_rubgason%2C_1.jpeg

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Predicting the Incipient Smoke PointIncipient smoke affected by several different factors

Currently no method to predict incipient smoke point for complex mixtures like flare vent gas.

Control system goal: comply with regulatory limits while minimizing steam usage to operate as close to the incipient smoke point as possible.

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MACT CC Compliance Calculations

Direct Calculations

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MACT CC Compliance Calculations

Feed Forward Calculations

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Compliance vs. Control

Demonstrating compliance (i.e., at the end of each 15-minute block) will come through either the direct or feed forward calculation method.

Achieving control (i.e., as new measurements are reported) is not discussed.

http://subcusa.com/wp-content/uploads/2017/11/iStock-638355596.jpg

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Achieving Control Under MACT CC

Both the direct and feed forward calculation methods can break when confronted with reality.

Control system options

◦ Good, better, besthttp://airgasthinks.com/refinery-sector-rule-rsr-update-part-2-monitoring-flare-nhv/

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Steam Control

Steam control: variability

Tiered control scheme – most common approach

https://www.thermoeng.it/assets/Uploads/scroll-home-sesta.jpg/

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Steam-to-Vent Gas Control

Primary focus: destruction efficiency (>98%)

Early CDs required facilities S/VG < 3 and automatic control

MACT CC does not specify a S/VG ratio and does not require automated control. http://www.aetosgroup.com/images/air-slides/air-flare-stacks.jpg

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Supplemental Gas ControlSupplemental gas may be required to boost NHV

May be able to combine supplemental gas control with purge gas

https://www.linkedin.com/pulse/flares-4c-hse-2017-conference-4c-h-s-e-conference/

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Supplemental Gas Addition Criteria

Consent Decrees – Assumed to be 3-hour rolling averages◦ NHVvg < 300 Btu/scf

◦ NHVcz < NHVcz-limit

MACT CC – 15 minute block average◦ NHVcz < 270 Btu/scf

◦ NHVdil < 22 Btu/ft2

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Competing ControllersS/VG vs. NHV

◦ Vent gas flow increases, causing an increase in steam flow

◦ Steam has a zero HV, which drops the NHVcz

◦ Supplemental fuel is added, which increases the vent gas flow

◦ Controllers will “walk” each other up until the control valves are fully open

◦ Need to add to the control logic to look at both the “waste gas” flow and total vent gas flow.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 34

Hypothetical Flare Control PointsTargets will depend on type of facility◦ Automated supplemental gas additions

◦ Add supplemental gas to ensure adequate combustion efficiency

◦ NHVcz

◦ NHVdil

◦ Add supplemental gas if special emergency case / PHA HAZOP concern such as a high temp gas release, prevent “contraction”.

◦ Automated steam addition https://theskyguys.ca/wp-

content/uploads/2017/10/Flare%20Stack%20Inspection.png

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Complexity of RealityEach flare control system could potentially require 100+ DCS tags.

◦ Multiplied by the number of flares at the facility…

◦ Complexity around each tag

Ensure that information required by 63.655(i)(9)(i-xii) is retained.

http://www.schroeter-ht.de/sites/default/files/styles/glalerie-big/public/galerie/flugdrohne-7.jpg

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 36

DCS Management – Data Path Concerns

Control calculations

Compliance calculations

Alarms

Data storage https://www.thermoeng.it/assets/Uploads/carosello-home-1new.jpg

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 37

Challenges to a Well Controlled Flare

Equations in CDs and MACT CC allow for instantaneous control

◦ Instrument Lag

◦ Valve Response Time

◦ Time to Tip https://blog.millerenergy.com/

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 38

Instrument LagSpeed ◦ Lag can be a serious problem for GCs – 7 to 10 minute analysis time

◦ The feed forward approach in MACT CC appears to be an attempt to address this.

◦ Real time control is difficult with an instrument that reports from the past.

Mass spectrometers and calorimeters provide much faster measurements.

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 39

Feed Forward Control as a Response to Instrument Lag

◦ With an analytical cycle time of 10 minutes, the instrument will not see the effects of any supplemental gas addition until two cycles past the event.

◦ Results within a given 15-minute block are applied to the subsequent 15-minute block.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 40

Valve Response Time and Time to Tip

Valve Response Time◦ May exacerbate issues caused by instrument lag

Time to Tip

◦Calculation concerns

http://tcd-italia.com/images/foto-1.jpg

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©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 41

ConclusionsDCS Integration Issues Require Significant Attention◦ Accurate Data Collection

◦ Data compensation – to STP, time, corrected units

◦ Data validity and use in calculations (create and store new PI tags)

◦ Instrument downtime

◦ Where are calculations performed and where is data stored?

◦ Calculation of values to proper units and averaging periods

◦ Operational alarms

◦ Ability to report and trend

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 42

Questions?

Up Next: New Flare Requirements

https://financialtribune.com/articles/people-environment/71424/gas-flaring-aggravates-khuzestan-pollution-by-60

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Flare EssentialsRegulations on Flaring – NSPS Ja and MACT CC

4C CONFERENCE – FEBRUARY 2018 – SAN ANTONIO, TX

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 1

NSPS JaFocused on improved monitoring of flares, not performance

Compliance date for new or modified flares constructed prior to 6/24/2008: 11/11/2015

Compliance date for new or modified flares constructed after 6/24/2008: upon startup

Image courtesy ofchemistryworld.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 2

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NSPS Ja – Rule HighlightsApplicable to new, reconstructed, or modified flares at petroleum refineries

Special modification provisions

Flares are now a separate affected facility

◦ Used to be a subcategory of a fuel gas combustion device under NSPS J

Flare means a combustion device that uses an uncontrolled volume of air to

burn gases. The flare includes the foundation, flare tip, structural support,

burner, igniter, flare controls, including air injection or steam injection

systems, flame arrestors and the flare gas header system

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 3

NSPS Ja – Compliance RequirementsFlow and sulfur monitoring

Develop Flare Management Plan (FMP)

Assess means to minimize flows to flares (included in FMP)

Root Cause Analyses (RCA) and Correct Action Analyses when RCA thresholds are exceeded

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Root Cause Analysis – Flow and SulfurThresholds

◦ Vent gas flows > 500,000 scf above baseline flow in a 24-hour period

◦ SO2 emissions > 500 lbs in a 24-hour period

◦ Flare header pressure > back pressure set by water seal

◦ Only for flares using alternative monitoring method

Specific provisions for conducting RCAs after certain events

Exemptions for requirement to not conduct RCA

RCA and Corrective Action Analysis must be conducted within 45 days

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 5

Monitoring Alternative – §60.107a(g)Potentially applies to emergency flares, secondary flares, and flares designed with FGRU to capture all flows (except startup, shutdown, and malfunction)

Flare header pressure monitoring instead of installing flow/sulfur◦ Allowed 4 pressure exceedances in a rolling 365 day period

◦ After 5th exceedance, 180 days to comply to flow/sulfur monitoring Image courtesy of Honeywell

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 6

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Conducting RCAs and Corrective ActionsMaintain RCA reports which include◦ Date, time, and description of discharge

◦ Total quantity of gas flared

◦ TRS and H2S concentration

◦ If using H2S monitor for total sulfur, the TS-to-H2S ratio, confidence interval, sampling data

◦ Total quantity of SO2 emitted

◦ Steps to minimize flaring during discharge

◦ Statement that RCA not necessary if FMP was followed

◦ Identification of root cause of event and corrective actions to reduce likelihood of similar event

◦ Status of implemented corrective actions and implementation schedule

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 7

Flow Monitoring RequirementsRepresentative of total flow to the flare

Must be maintainable online

Must correct for pressure and temperature to standard conditions

Must meet specified accuracy requirements – updated with NSPS Ja amendments

Follow prescribed inspection and recalibration schedules

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 8

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Sulfur Monitoring RequirementsTwo different sulfur monitoring requirements

Operational Limit

◦ 162 ppmvd H2S limit (3 hour rolling average)

◦ Instrument spanned from 0-300 ppmv H2S

RCA Threshold

◦ 500 lbs SO2 in a 24-hour period

◦ Instrument spanned between 1.1 and 1.3 times the maximum anticipated sulfur concentration

Image courtesy of Thermo Fisher Scientific

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 9

Sulfur Monitoring RequirementsFor RCA threshold, multiple monitoring options

◦ TRS Monitor

◦ SO2 Monitor

◦ H2S Monitor

◦ Requires additional correlation for H2S to total sulfur

Exemptions

◦ Inherently Low Sulfur Fuel Gas

◦ Flares complying using the monitoring alternative

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 10

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Performance TestingAmendment published as part of MACT CC

Initial performance test must be performed to demonstrate initial compliance with 162 ppmvd H2S limit.

Must be completed no later than 180 days after initial startup

Image courtesy of housingwire.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 11

QA/QC RequirementsNSPS Ja states QA/QC requirements for the CEMS installed on the flare system

H2S Monitors TRS Monitors

Operation and

Maintenance

Performance

Specification (PS) 7PS 5

Performance

Evaluations§60.13(c) & PS 7 §60.13(c) & PS 5

Relative Accuracy

Evaluations

Method 11, 15, 15A or

16 or PS 2 –

Alternative RATA

Method 15A or PS 2 –

Alternative RATA

Quality Assurance

ProceduresAppendix F to Part 60 Appendix F to Part 60

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 12

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QA/QC Requirements Both Analyzer Spans

Certification Accuracy Assessment Out-of-Control (OOC) Criteria

Daily Calibration Calibration Drift (CD) Test

Drift exceeds twice the applicable drift specification for five

consecutive daily periods or drift exceeds four times the applicable

drift specification for any single test event.

Quarterly

Calibration

Cylinder Gas Audit (CGA)Relative accuracy (RA) exceeds 15% of the average audit value, or

±5 ppm, whichever is greater

Relative Accuracy AuditRA exceeds 15% of the three run average, or ± 7.5% of the

applicable standard, whichever is greater

Annual Certification

Relative Accuracy AuditRA must be no greater than 20% of the Reference Method Value,

or 10% of the emissions standard

Alternative Relative Accuracy AuditRA exceeds 15% of the average difference between measured

value and audit value

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 13

Flare Management PlanNSPS Ja requires development of FMP and submission to EPA

FMP Includes◦ Flare system description

◦ Flare design information

◦ Flare connection list

◦ Flare tip drawing

◦ Process flow diagram

◦ Minimization assessment

More on FMP and minimization assessment laterImage courtesy of RTI International

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 14

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Reporting & RecordkeepingAppendix F of Part 60 outlines the record keeping requirements◦ Subpart A - §60.7(d) requires all CEMS data must be retained for 2 years◦ NSPS Ja – §60.108a has its own reporting & recordkeeping requirements

Other records to keep◦ Copy of FMP◦ Documentation for sulfur exempt streams◦ RCA Reports

Report at interval specified by regulation◦ CEMS accuracy results◦ Calibration drift assessment

Drift and accuracy to be reported as a Data Assessment Report (DAR) for each quarterly audit

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 15

NSPS Ja Alternative Monitoring PlansThe EPA has approved several different types of Alternative Monitoring Plans (AMPs) for NSPS Ja

Allowances for alternative requirements for unique flares that do not exactly fit into categories outlines in NSPS Ja

◦ Particularly helpful for flares which operate infrequently.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 16

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MACT CC

Image courtesy of ProgressNow NM

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 17

MACT CCGeneral Provisions: Destruction efficiency of a flare used for air pollution control should achieve a destruction efficiency (DRE) of at least 98%

◦ Considered to be the MACT floor

EPA believes that existing requirements for flares do not ensure 98% DRE is met

◦ Recent efforts in minimization have lead to over assisting flares, causing poor combustion efficiencies

MACT CC adds new operating constraints and monitoring requirements to ensure good combustion at flare tip

Operational requirements only in effect when regulated material is sent to a flare for at least 15 minutes

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 18

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MACT CCMay 15, 2014: Proposed Rule Issued

June 30, 2014: Published in the Federal Register

October 28, 2014: Comment period closed after 60 day extension

December 1, 2015: Final Rule published in the Federal Register

January 30, 2019: Flare compliance date

300 days to go!

Image courtesy of The Telegraph

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 19

MACT CC – Flare RequirementsRequirements from Subpart A

◦ Pilot flame monitoring

◦ Visible emissions

◦ Flare tip velocity

New Operating Limits

◦ Net heating value in the combustion zone

◦ Net heating value dilution parameter

Updates to Flare Management Plan

Continuous Parameter Monitoring System Plan

Alternative Means of Emission LimitationImage courtesy of Combustion Research Associates

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 20

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No More Subpart A§63.640(s)

On January 30, 2019, flares that are subject to the provisions of 40 CFR 60.18 or 63.11 and subject to this subpart are required to comply only with the provisions specified in this subpart. Prior to January 30, 2019, flares that are subject to the provisions of 40 CFR 60.18 or 63.11 and elect to comply with the requirements in §63.670 and §63.671 are required to comply only with the provisions specified in this subpart.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 21

Term NSPS Ja MACT CC

FlareFlare means a combustion device that uses an

uncontrolled volume of air to burn gases. […]

Flare means a combustion device lacking an

enclosed combustion chamber that uses an

uncontrolled volume of ambient air to burn

gases. […]

Ancillary

Equipment

Ancillary equipment means equipment used in

conjunction with or that serve a refinery

process unit. Ancillary equipment includes, but

is not limited to, storage tanks, product loading

operations, wastewater treatment systems,

steam- or electricity-producing units (including

coke gasification units), pressure relief valves,

pumps, sampling vents and continuous analyzer

vents.

Not defined, but referenced

New Definitions

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 22

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Term NSPS Ja MACT CC

Fuel Gas

System

Fuel gas system means a system of

compressors, piping, knock-out pots, mix

drums, and units used to remove sulfur

contaminants from the fuel gas (e.g., amine

scrubbers) that collects refinery fuel gas from

one or more sources for treatment as necessary

prior to combusting in process heaters or

boilers. A fuel gas system may have an

overpressure vent to a flare but the primary

purpose for a fuel gas system is to provide fuel

to the refinery.

Fuel gas system means the offsite and onsite

piping and control system that gathers gaseous

streams generated by refinery operations, may

blend them with sources of gas, if available, and

transports the blended gaseous fuel at suitable

pressures for use as fuel in heaters, furnaces,

boilers, incinerators, gas turbines, and other

combustion devices located within or outside of

the refinery. The fuel is piped directly to each

individual combustion device, and the system

typically operates at pressures over

atmospheric. The gaseous streams can contain

a mixture of methane, light hydrocarbons,

hydrogen and other miscellaneous species.

New Definitions

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 23

Term MACT CC

Assist Air

All air that intentionally is introduced prior to or at a flare tip through nozzles or other

hardware conveyance for the purposes including, but not limited to, protecting the design of

the flare tip, promoting turbulence for mixing or inducing air into the flame. Assist air includes

premix assist air and perimeter assist air. Assist air does not include the surrounding ambient

air.

Perimeter

Assist Air

The portion of assist air introduced at the perimeter of the flare tip or above the flare

tip. Perimeter assist air includes air intentionally entrained in lower and upper steam. Perimeter

assist air includes all assist air except premix assist air.

Premix Assist

Air

The portion of assist air that is introduced to the flare vent gas, whether injected or induced,

prior to the flare tip. Premix assist air also includes any air intentionally entrained in center

steam.

New Definitions

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 24

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Regulated MaterialAny stream associated with emission sources listed in §63.640(c) required to meet control requirements under this subpart as well as any stream for which this subpart or a cross-referencing subpart specifies that the requirements for flare control devices in §63.670 must be met.

How to determine when regulated material is sent to the flare?

◦ Especially challenging for flares without water seals

§63.655(i)(9)(ix) – maintain record of every time that regulated material is sent to the flare

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 25

Pilot Flame MonitoringPilot must be present at all times that regulated material is sent to the flare

Deviation is any period ≥ 1 minute without a pilot when regulated material is sent to the flare for at least 15 minutes

Continuous monitoring of pilot flame required

Image courtesy of Mason Dixon Gold Club

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Visible EmissionsMust operate with no visible emissions except for a total of 5 minutes during any 2 consecutive hours when regulated material is sent to the flare and flare vent gas flow rate is less than the smokeless capacity

Two monitoring options

◦ Daily Method 22 monitoring, or

◦ Video surveillance

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 27

Visible Emissions Monitoring Method 22

Initial 2-hour Method 22 compliance demonstration

On or before January 30, 2019

Daily 5-minute Method 22

At any point, are

visible emissions

observed?

5-minute

Method 22

2-hour

Method 22

Yes

Continuous visible

emissions for more

than 1 minute?

Yes

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 28

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Visible Emissions Monitoring Video SurveillanceRecord a reasonable distance above flame with date and time stamp

Minimum recording rate: 1 frame every 15 seconds

Output should be located in control room or another continuously manned location

Image Courtesy of Home Security DC

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 29

Maximum Allowed Flare Tip VelocityConcerns about “lift off” and proper combustion at the flare tip

Limits in MACT CC reflect those found in NSPS and MACT Subpart A.

◦ Vtip < 60 ft/s, or

◦ Vtip < 400 ft/s and Vtip < Vmax

Applies only when regulated material is flared for at least 15 minutes

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 30

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Maximum Allowed Flare Tip VelocityIn MACT CC, only one equation to determine Vmax

Where:

Vmax = Maximum allowed flare tip velocity (ft/sec)

NHVvg = Net heating value of flare vent gas (Btu/scf)

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 31

Flare Tip VelocityData required for Vtip calculation

◦ Cumulative volume flow (Qcum)

◦ Unobstructed cross sectional area of the flare tip

Qcum must be cumulative over each discrete 15-minute period starting at midnight

◦ Only needs to include flow during periods when regulated material is sent to the flare, but can include all flows

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 32

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Flare Tip Velocity Calculation

���� ����

�� � 900

Where:Vtip = Flare tip velocity, feet per second

Qcum = Cumulative volumetric flow over 15-minute block average period, standardcubic feet

Area = Unobstructed area of the flare tip, square feet

900 = Conversion factor, seconds per 15-minute block average

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 33

Flow Monitoring RequirementsContinuous volumetric flow monitoring required for:

◦ Flare Vent Gas

◦ Assist Gas (steam and/or air, as applicable to your flare)

◦ Supplemental Gas

Monitors must correct to standard conditions prescribed by MACT CC

◦ Tstd = 68°F

◦ Pstd = 1 atm

Engineering calculation with continuous pressure/temperature monitoring may be used instead of continuous flow monitoring if the molecular weight of the vent gas is monitored as part of composition analysis

Image courtesy of General Electric

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 34

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Flow Monitoring RequirementsFor mass flow meters, flow must be converted to volumetric basis to demonstrate compliance

���� ����� � 385.3��

Where

Qvol = Volumetric flow rate, scf per second

Qmass = Mass flow rate, lb/second

385.3 = Conversion factor, scf per lb-mol

MW = Molecular weight of the gas at the flow monitoring location, lb/lb-mol

Mwsteam = 18 lb/lb-mol

MWair = 29 lb/lb-mol

MW of vent gas as monitored by compositional analysis at measurement location

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 35

Vent Gas NHV MonitoringMonitoring options

◦ Composition Monitoring

◦ Calorimeter and Hydrogen Analyzer

◦ Calorimeter Only

◦ Grab Samples

Composition monitoring not required for specific types of streams

◦ Pipeline quality purchased natural gas

◦ Streams which has demonstrated constant composition

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 36

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NHVvg Calculation MethodsComposition Monitoring

����� � !� . ����"

�#$

Calorimeter and Hydrogen Analyzer

����� ����%���&%' ( 938 � !)*

Calorimeter Only

����� ����%���&%'

Note: Refiners can use 1,212 Btu/scf as the NHV of hydrogen

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 37

Flare Performance Operating LimitsNet heating value in the combustion zone (NHVcz) ≥ 270 Btu/scf

◦ All flares must comply

◦ 15-minute block average basis when regulated material sent to the flare for at least 15 minutes.

Net heating value dilution parameter (NHVdil) ≥ 22 Btu/ft2

◦ Applies to flares actively receiving perimeter assist air

◦ 15-minute block average basis when regulated material sent to the flare for at least 15 minutes.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 38

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Calculation MethodsTwo methods to determine 15-min block average NHVcz and NHVdil

Feed Forward Calculation Method

◦ Results from first sample can be used for first, second, and potentially third 15-min blocks

◦ Otherwise, results from most recent sample from pervious block are used for current 15-min block

Direct Calculation Method

◦ Results from first sample must be used for first 15-min block

◦ Use average of all results available in current 15-min block

Different methods can be used for different flares

◦ Must be specified to Administrator

◦ Notify Administrator 30 days prior to a change in methodImage courtesy of Techwalla.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 39

Feed Forward Calculation Method

Results within a given 15-minute block are applied to the subsequent 15-minute block.

Sample 1 Taken Sample 2 Taken Sample 3 Taken Sample 4 Taken Sample 5 Taken

Sample 1

Reported

Sample 2

Reported

Sample 3

Reported

Sample 4

Reported

12:00 AM 12:15 AM 12:30 AM 12:45 AM 1:00 AM 1:15 AM

Sample 1

Applied

Sample 1

Applied

Sample 1

Applied

Sample 2

Applied

Sample 3

Applied

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 40

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Combustion Zone ParameterNHVcz designed to take into account the dilution effect of assist gas, which decreased combustion and destruction efficiencies of flares

First seen in CDs, although some changes for MACT CC

◦ Static Limit

◦ Volume basis

Image courtesy of SkyReel

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 41

NHVcz Operating LimitDirect Calculation Method

����+ ���� � �����

��� ( �� ( ��,�&%�-

Feed Forward Calculation Method

����+ ���� . �/01 ( �/0$ ������ ( �/01 . �/0$ ����/0

��� ( �� ( ��,�&%�-

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 42

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Dilution ParameterDeveloped by EPA considering the amount of time gas spends in the combustion zone

Not part of any previous enforcement action

234563789 :67�;29< � ��� � 23 =��� ( �� (��,�&%�- (��,�%&�%�%&

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 43

NHVdil Operating LimitDirect Calculation Method

���'�� ���� � 23 = � �����

��� ( �� (��,�&%�- (��,�%&�%�%&

Feed Forward Calculation Method

���'�� ���� .�/01 ( �/0$ � ����� ( �/01 . �/0$ � ���/0 � 23 =

��� ( �� (��,�&%�- (��,�%&�%�%&

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 44

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CPMS RequirementsTable 13 – accuracy and QA/QC requirements

Measure over the expected range

Readout must be easily accessible

Complete at least one analytical cycle every 15 minutes

Collect data continuously when regulated material sent to flare, except malfunction, repairs, and QA/QC

Comply with Out of Control (OOC) procedures (except pilots)

Reduce data from CPMS as specified in procedures

Data Reduction System (DRS) associated with CPMS must have equal to or better than required system accuracy

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 45

CPMS QA/QCQA/QC OOC limits are defined by the Rule

◦ Low-level, mid-level or high-level calibration exceeds two times the accuracy requirements in Table 13

OOC Period

◦ Starts hour of performance check that shows exceedance of limit when CPMS found to be OOC

◦ Ends hour after correction action taken and system checks demonstration CPMS is back within limits Image courtesy of workinginpeelhalton.com

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 46

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CPMS Monitoring PlanRequired for each flare and each CPMS subject to §63.670

Owner or operator shall have the CPMS plan readily available on-site at all times – not required to be submitted to EPA unless requested

More on CPMS Plan development later

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 47

Emergency Flaring Provisions - FMP§63.670(o)

The owner or operator of a flare that has the potential to operate above its smokeless capacity under any circumstance shall comply with the provisions in paragraphs (o)(1) through (o)(7) of this section.

If no smokeless capacity, no FMP or RCA requirements under MACT CC

◦ Still will have to meet NSPS Ja requirements for FMP and RCA if applicable

More on development of FMP for MACT CC later

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Root Cause AnalysisRCA required if:

◦ The vent gas flow rate exceeds the smokeless capacity of the flare and visible emissions are present from the flare for more than 5 minutes during any 2 consecutive hours during the release event.

◦ The vent gas flow rate exceeds the smokeless capacity of the flare and the 15-minute block average flare tip velocity exceeds the maximum flare tip velocity determined using the methods in paragraph (d)(2) of this section.

◦ Only references the <Vmax and <400 ft/s options

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Smokeless CapacityMACT CC does not clearly define smokeless capacity or specify units that it must be reported it

Typical design is a relief rate at defined molecular weight

63.670(o)(1)(iii)(B) –a single value must be supplied for the smokeless capacity

◦ No allowance for developing a sliding scale based on the composition

◦ Smoking a function of carbon number and bonding structure of a molecule

Image courtesy Inforum

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Alternative Means of Emissions Limitation (AMEL)Option for flares that may have difficulty meeting operational limits in MACT CC◦ Vtip

◦ NHVcz or NHVdil

May request approval for site-specific operating limits that apply specifically to a single selected flare.

Site specific limits must demonstrate that the subject flare achieves 96.5% CE (or 98% DRE) by a performance evaluation.

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AMEL Test PlanFlare description

◦ Flare design, dimensions, and type

◦ Quantity of gas flared

◦ Frequency of flaring events

◦ Expected net heating value of flare vent gas

◦ Minimum total steam assist rate

Operating conditions

◦ Vent gas compositions

◦ Vent gas flow rates and assist flow rates

◦ Conditions during normal operations and the test period

Image courtesy of Zecco

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AMEL Test PlanDescription and sample calculations illustrating the planned data reduction to determine the flare combustion or destruction efficiency.

Site-specific operating parameters to be monitored continuously during the flare performance evaluation.

◦ Vent gas flow rate

◦ Steam and/or air assist flow rates, and

◦ Flare vent gas composition

◦ If new operating parameters are proposed for use other than those specified in the rule, an explanation of the relevance of the proposed operating parameter must be provided

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AMEL Test PlanTest Conditions

◦ Minimum number and length of test runs

◦ Range of operating values to be evaluated

◦ A sufficient number of test runs shall be conducted to identify the point at which the combustion/destruction efficiency of the flare deteriorates.

Final Test Report is submitted to EPA administrator for review.

Acceptance requires notice in the Federal Register.

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Reporting & Recordkeeping§63.655(i)(9) – outlines requirements for flares

May need to reconcile data retention times from MACT CC with permit requirements

Other records to keep

◦ Copy of FMP

◦ Copy of CPMS Plan

◦ RCA Reports Image courtesy of cleaner-and-launderer.com

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Technical CorrectionsProposed Amendments signed by EPA Administrator on March 19, 2018 include:

• Definitions – purge gas, supplemental gas, pressure relief device

• Visible emissions monitoring for intermittent flares

• Flow meter accuracy

• Clarification of PRD prevention measures

• Requirements and calculation methodology for steam assisted flares with entrained assist air

• Change units for flow to calculate Vtip

• Smokeless capacity

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Corrections – Steam Assisted FlaresCertain ring steam designs intentionally entrain air as steam is injected

Assessment was performed to determine at which tip diameters enough air is added to fall below 22 Btu/ft2 limit

◦ Preamble: Effective diameter ≥ 9 inches, comply with NHVcz

only

◦ Proposed rule: Diameter ≥ 9 inches, comply with NHVcz only

For flares with tip diameters < 9 inches, must demonstrate NHVdil and NHVcz compliance

◦ Estimate air flow rate using maximum air-to-steam ratioImage courtesy of Zecco

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Corrections – Exit VelocityEPA corrected “an error in the units” for Qcum to actual to standard cubic feet.

Revised equation:

���� ����

�� � 900

Where:

Vtip = Flare tip velocity, feet per second

Qcum = Cumulative volumetric flow over 15-minute block average period,standard cubic feet

Area = Unobstructed area of the flare tip, square feet

900 = Conversion factor, seconds per 15-minute block average

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Corrections – Smokeless CapacityHow to determine when the smokeless capacity has been exceeded? Would 1 minute of operation above the smokeless capacity be enough to require an RCA?

Clarification:

◦ FMP must specify smokeless capacity on a 15-minute block average and design conditions

◦ Smokeless capacity still must be one value

◦ 15-minute block average smokeless capacity will be used to determine if an RCA is required per the emergency flaring provisions

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 59

Questions?Up next: Implementation of Flare Requirements

Image courtesy of Quora

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Flare EssentialsImplementing Flare Requirements

4C CONFERENCE – FEBRUARY 2018 – SAN ANTONIO, TX

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 2

What is needed for flare compliance?

Upgrade or install monitoring equipment

Develop CPMS Plan

Update or develop FMP

Flare Minimization

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Flow MonitoringFlare regulations require monitoring of◦ Vent Gas

◦ Supplemental Gas

◦ Assist Gas

◦ Steam or Air

Volumetric flows must be corrected to standard conditions for all compliance points except Vtip, which uses actual volumetric flows

Table 13 of MACT CC outlines accuracy requirements

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Flow MonitoringParameter Minimum Accuracy Requirement

Temperature

±1 percent over the normal range of temperature measured,

expressed in degrees Celsius (C), or 2.8 degrees C, whichever is

greater

Pressure±5 percent over the normal operating range or 0.12 kilopascals (0.5

inches of water column), whichever is greater

Temperature and pressure sensors that correct flow measurements to standard conditions are

considered CPMS and have their own minimum accuracy requirements

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Flow Monitoring – Vent GasParameter Minimum Accuracy Requirement

Flare Vent Gas Flow Rate

±20 percent of flow rate at velocities ranging from 0.03 to 0.3 meters

per second (0.1 to 1 feet per second)

±5 percent of flow rate at velocities greater than 0.3 meters per

second (1 feet per second)

Note: Vent gas flow monitoring is required for NSPS Ja and MACT CC. Both rules have the same

minimum accuracy requirements

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 6

Flow Monitoring – Supplemental GasDefinition of flare vent gas

Flare vent gas means all gas found just prior to the flare tip. This gas includes all flare waste gas (i.e., gas from facility operations that is directed to a flare for the purpose of disposing of the gas), that portion of flare sweep gas that is not recovered, flare purge gas and flare supplemental gas, but does not include pilot gas, total steam or assist air.

Supplemental gas is considered flare vent gas, so flow meters must meet the vent gas flow meter accuracy requirements

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Flow Monitoring – Supplemental GasDo I need a dedicated supplemental gas flow meter?

Yes, if◦ Using the feed-forward method to calculate NHVcz

◦ Supplemental gas is injected downstream of the vent gas flow meter

No, if◦ Supplemental gas is injected upstream of the vent gas flow meter and the direct calculation

method is used

Even if no, a flow meter is recommended, but is not required to meet requirements of Table 13

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 8

Flow Monitoring – Assist GasParameter Minimum Accuracy Requirement

Flow Rate for All Flows

Other Than Flare Vent Gas

±5 percent over the normal range of flow measured or 1.9 liters per

minute (0.5 gallons per minute), whichever is greater, for liquid flow

±5 percent over the normal range of flow measured or 280 liters per

minute (10 cubic feet per minute), whichever is greater, for gas flow

±5 percent over the normal range measured for mass flow

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Flow Monitoring – Assist Gas

Flow monitoring requirements are fine for steam lines, but what about assist air

Blower flow rates for single or multi-speed fans that have specified speeds

Fan curves for VFDs

https://www.thecyberhawk.com/wp-content/uploads/2016/02/flare-cyberhawk-20-

900x525.jpg

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Composition MonitoringParameter Minimum Accuracy Requirement

Calorimeter ±2 percent of span

Gas ChromatographAs specified in Performance Specification 9 of 40 CFR part 60,

Appendix B

Hydrogen analyzer±2 percent over the concentration measured or 0.1 volume percent,

whichever is greater

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Composition Monitoring - GCs

Additional requirements in §63.671(e)(1) through (3)

Calibration Gas Options

◦ Includes list of gases in rule

◦ Surrogate calibration gas (Hydrogen and C1 through C5 normal hydrocarbons)

If surrogate calibration gas chosen – use response factors for the nearest normal hydrocarbon

https://www.ssi.shimadzu.com/products/images/gc/n9j25k0000010h3z.jpg

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Composition Monitoring – Mass Spec

§63.670(j)(1) Except as provided in paragraphs (j)(5) and (6) of this section, the owner or operator shall install, operate, calibrate, and maintain a monitoring system capable of continuously measuring […], calculating, and recording the individual component concentrations present in the flare vent gas.

Mass spectrometers are not explicitly listed in Table 13

EPA released alternative test method on February 5, 2018 allowing for use of mass spec

Requirements largely mirror the requirements for GCs

◦ Includes additional requirements from §63.671(e)

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CPMS PlanOne plan to compile documentation for each flare monitoring system

Will require input from many different departments

◦ Instrumentation

◦ Operations/Maintenance

◦ Controls

◦ Environmental

Not required to be submitted to EPA unless requested by the administration

Plan should be completed no later than January 30, 2019

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 14

What Goes in CPMS Plan?Identification of the specific flare being monitored and the flare type.

Identification of the parameter to be monitored by each CPMS including

◦ Expected parameter range

◦ Worst case range

◦ Normal operating range

Three categories of information

◦ Description of monitoring equipment

◦ Routine QA/QC Procedures

◦ Description of data collection and reduction system

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What Goes in CPMS Plan?Description of monitoring equipment

◦ Make & model number

◦ Manufacturer performance specs and if any deviation expected

◦ Location of probe & justification of how location meets Table 13

◦ Placement of the CPMS readout, indicating how it meets the requirements.

◦ Span of CPMS

◦ Data outside of the span of the CPMS and the corrective action

◦ Algorithm used to convert signal analyzer to operating parameter monitored

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 16

What Goes in CPMS Plan?Routine QA/QC Procedures

◦ Initial & subsequent calibration of the CPMS

◦ Determination & adjustment of calibration drift of the CPMS

◦ Daily checks for indications that the system is responding

◦ Preventive maintenance of the CPMS

◦ Data recording, calculations and reporting

◦ Program of corrective action for a CPMS that is not operating properly

https://www.sky-futures.com/wp-content/uploads/2016/09/Live-Flare-

UAS-inspection-768x431.png

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What Goes in CPMS Plan?Description of data collection and reduction system◦ Copy of the data acquisition system algorithm used to reduce measured data

into the reportable form

◦ Identification of whether the algorithm excludes data collected during CPMS downtime

◦ If the data acquisition algorithm does not exclude data collected during situations listed above, description of procedure for excluding this data when the averages calculated as specified in paragraph (e) of this section are determined.

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 18

Flare Management PlanOriginally submitted to EPA for NSPS Ja compliance will need to be updated and resubmitted for MACT CC

◦ New information required

◦ Revisit minimization assessment

Resubmission of FMP required when:

◦ Revision or addition of baseline

◦ Installation of flare gas recovery system

◦ Change of flare designation of monitoring methods

◦ Alteration of the smokeless capacity

https://en.wikipedia.org/wiki/Gas_flare

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FMP Contents – NSPS Ja§60.103a(a) requires the following to be included in FMP◦ Listing of process units, ancillary equipment, and fuel gas systems connected to the

flare

◦ Flare Design Parameters

◦ Including sweep, purge, pilot, and assist gas flow rates

◦ Description of Flare System

◦ Description of Monitoring Systems

◦ Minimization Assessment

◦ Flare Tip Drawings

◦ Process Flow Diagrams (PFDs)https://www.automation.com/automation2/Yoko1.jpg

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FMP Contents – MACT CC§63.670(o)(1) adds new data points to FMP:◦ Smokeless capacity – single value

◦ Maximum steam flow rate

◦ Additional monitoring systems to incorporate

◦ For air assisted flares, type of fan◦ Fixed (single or multi) speed fans – provide flow rate at each

speed

◦ Variable speed fans – provide fan curve

◦ PRD List

◦ Minimization Assessment◦ Minimize flaring as a result of startup, shutdown, and

malfunctionhttp://www.joulon.com/wp-content/uploads/Inspection-2-1024x576.jpg

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Pressure Relief DevicesDetailed description of each PRD vented to flare including◦ Type (rupture disc, valve type, etc.)

◦ Diameter

◦ Set pressure

◦ Listing of prevention measures implemented

Diameter and set pressure should be on most P&IDs

PRD list can be stored as an electronic database onsite

◦ Does not initially need to be submitted with FMP, but can be requested by administrator

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Pressure Relief DevicesEvaluation of prevention measures is required as part of minimization assessment

◦ Flow, temperature, level, or pressure indicators with deadman switches, monitors, or automatic actuators

◦ Documented routine inspection and maintenance programs

◦ Inherently safer designs or safety instrumentation systems

◦ Deluge systems

◦ Staged relief system where initial pressure relief valve (with lower set release pressure) discharges to a flare or other closed vent system and control device.

List is intended for atmospheric PRDs, how does it translate to flares?

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Minimization AssessmentOverall Goal

◦ Identify opportunities to maximize gas recovery

◦ Minimize flaring

NSPS Ja – No RCA during startup, shutdown, and malfunction as long as procedures incorporate minimization steps and are followed

MACT CC – minimization to include minimization during these releases

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Minimization AssessmentProvide justification for selected minimization measures based on◦ Technical feasibility

◦ Costs

◦ Safety considerations

◦ Secondary environmental impacts

◦ Natural gas offset credits

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Minimization AssessmentFlare Mapping

◦ P&ID review

◦ PRD list

Recent CDs have required grouping connections by subheader and quantifying some flows

How are flare connections used?

◦ Frequency

◦ Operator interviews

http://www.piping-engineering.com/wp-content/uploads/2014/11/flare-

p-n-id.jpg

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Minimization TechniquesCan flows from frequently used connections be minimized?

◦ Process changes

◦ Procedural changes

◦ Operator training

Minimization of Leaks

◦ Acoustic monitoring

◦ Monitoring network or individual assessment

◦ Site wide or targeted (i.e. high H2S connections)

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Minimization TechniquesStartup and shutdown procedures◦ Procedures must be reviewed and potentially modified to minimize flaring

◦ How long will it take to review/modify procedures?

◦ Need to provide a schedule for procedures that won’t be reviewed before submitting FMP

http://www.petroleum-economist.com/articles/politics-economics/middle-east/2017/iraq-time-to-quit-smokingv

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Minimization TechniquesFlare Gas Recovery (FGR)

Installation of a flare gas recovery system or, for facilities that are fuel gas rich, a flare gas recovery system and a co-generation unit or combined heat and power unit.

FGR assessment required for NSPS Ja and MACT CC minimization assessments

Technical, economic feasibility assessments may be required

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Baseline Flow DeterminationBaseline to be establish after minimization techniques are implemented

Analysis of historical flow data

◦ Does not have to include pilot or purge gas

Selection criteria

◦ Average of flow data

◦ Percentage of flows captured by baseline

◦ A different method – rule does not prescribe how to select baseline

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Baseline Flow DeterminationAlternative baselines also allowed for different operating scenarios◦ Ex. Seasonal changes, high hydrogen, specific process unit condition

◦ Documentation of criteria for alternative baseline condition

◦ How do you show start/stop of operating with alternative baseline?

Recall: baseline revisions or addition of alternative baseline require resubmission of FMP to EPA◦ Now is a good time to evaluate your current baseline and assess the need for

alternatives before submitting MACT CC FMP

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Questions?Up Next: Consent Decrees and Future Flaring Regulations

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Flare EssentialsConsent Decrees and Future Flare Regulations

4C CONFERENCE – APRIL 2018 – SAN ANTONIO, TX

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 2

Best Management Practices for FlaresIf you are a site subject only to the basic flare requirements (Subpart A), what proactive steps can you take before the EPA comes knocking?◦ Attending this class is a good start!

◦ Review flare operating manuals

◦ Review OAQPS document, Parameters for Properly Designed and Operated Flares

◦ Review existing CDs

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Flare Enforcement Timeline

Section 114 Request

• Involve legal quickly

• Determine what can be collected quickly and consider requesting extension

• Data collection

Negotiations

• Post-mortem analysis

• Potential for additional data requests

• Control and instrumentation assessments

Enforcement

• Capital projects

• Data and Initial Monitoring System Reports

• Waste Gas Minimization Plans

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 4

After the 114 Request

Interim control measures

Monitoring assessments

Control assessments

Minimization assessments

Scheduling of installation activitieshttps://www.hydrocarbons-

technology.com/features/featureflaring-for-a-cause-

saving-resource-worth-billions/

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Interim Control Measures

Now that the Section 114 data has been submitted: Review data to anticipate EPA questions and/or concerns

What can you do today to mitigate these periods going forward?◦ Administrative fixes?

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Monitoring System Assessments

Flow meters (Vent Gas and Assist Gas)◦ Installed? Good placement?

◦ Accurate?

Composition Analyzers◦ Installed? Good placement?

◦ Speed of analysis

◦ Sufficient speciation

http://www.canadianfuels.ca/Blog/June-2017/What-s-that-flame-at-the-top-of-a-refinery-pipe-

stack-Flaring-101/

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Control System AssessmentsConsider control and monitoring of:

◦ Steam assist

◦ Air assist

◦ Supplemental fuel addition

Consider for each gas:

◦ Distance to sufficient gas supply

◦ Quality and quantity

https://www.zeeco.com/flares/flares-air-assisted-af.php

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Minimization Assessments

Flare gas recovery

Level of recovery

Chemical plant unique concerns

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Minimization Assessments

At source reduction

PSV and valve leakage

Pressure control schemes

Low pressure offgas vessels

Procedures

Sweep and purge gas

©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 10

Scheduling Projects on Your TimelineConsider time for:◦ Getting managers onboard!

◦ Engineering

◦ MOC process

◦ Request for quotes

◦ Selection of vendors

◦ Delivery

◦ Installation (Is a turnaround scheduled?)

◦ Startuphttps://crewapp.com/c/wp-content/uploads/2017/09/plan-ahead.jpg

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Flare Consent DecreesConsent Decree No. of Flares Date Penalty

Equistar Chemicals (multiple facilities; terminated 2012) 24 July 2007 $1.9 MM

INEOS/Lanxess 1 July 2009 $3.1 MM

Marathon Petroleum (multiple refineries) 22April 2012

Amended June 2016

$460,000

$326,500

BP – Whiting Refinery 8 May 2012 $8.0 MM

CountryMark Refining 1 February 2013 $168,000

Shell – Deer Park Refinery 12 July 2013 $2.6 MM

Flint Hill Resources 3 March 2014 $350,000

Tesoro (multiple refineries) 17 July 2016 $10.45 MM

Citgo – Lemont Refinery 5 November 2016 $1.955 MM

ExxonMobil (multiple facilities) 26 October 2017 $2.5 MM

Shell Chemical, LP – Norco Refinery 4 February 2018 $350,000

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Evolution of the Flare CDINEOS/Lanxess◦ NHV of the Flare Gas – Allowed to take credit for the enthalpy of the

assist steam

◦ Steam Contribution Factor – Accounts for steam which may not impact the combustion zone during low vent gas momentum.

◦ S/VG Ratio: 3.6 max (0.91 in automatic)

◦ NHVvg Limit: 385 Btu/scf

◦ NHVFG Limit: 200 Btu/scf

Neither of these concepts has appeared in any other CD.

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Evolution of the Flare CDMarathon◦ Flaring limits for each refinery

◦ Flare Data and Monitoring System and Protocol Report◦ Flare gas recovery not required...initially

◦ Waste Gas Minimization Plans

◦ S/VG Ratio: 3.0 (2.7 on a volumetric basis)

◦ NHVvg Limit: 300 Btu/scf

◦ Variable NHVcz Limit

◦ Momentum Flux Ratio Limit: 0.0030 (Detroit Refinery: 0.0005)

◦ PFTIR Testing required at Garyville

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Evolution of the Flare CDBP Whiting◦ Similar to Marathon except:

◦ Flaring limits for each flare

◦ Flare gas recovery required

◦ PFTIR testing required at 2 flares

CountryMark◦ Similar to Marathon except no MFR limit

◦ No FGR requirement

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Evolution of the Flare CD

Shell Deer Park

◦ Covers refinery and chemical plant flares

◦ NHVvg Limit for Ground Flare: 500 Btu/scf

Flint Hills Resources Port Arthur

◦ Unique operating limits based on PFTIR testing

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Evolution of the Flare CDTesoro

◦ First CD to mirror the requirements of MACT CC

◦ FGR installation required at several refineries

◦ PFTIR testing on air-assisted flare

CITGO Lemont

◦ WGMP only required for 2 flares; no update required

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Evolution of the Flare CDExxonMobil

◦ Covers Olefins and Plastics Plants in Louisiana and Texas

◦ Requirements mirror MACT CC with a few small differences (pilot gas can be included in calculation of NHVcz)

Shell Norco

◦ Ground Flare NHVcz Limit: 470 Btu/scf

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Future Flaring RegulationsTechnical Corrections to MACT CC◦ Proposed March 19, 2018

◦ Few changes to the flare provisions

Ethylene MACT◦ Requirements are expected to reflect MACT CC

◦ Assuming a 3-year compliance window, compliance date no sooner than 2021

Amendments to HON/MON rules◦ No timetable, but likely to be very similar to MACT CC

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Flare Essentials RecapFlare Regulatory History

Flare Components and Configurations

Instrumentation

Flare Control Parameters and DCS Control

Recent Flare Regulations

Implementation of Flare Regulations

Consent Decrees and Future Flare Regulations http://rccostello.com/wordpress/relief/pressure-relief-disposal-

systems-flares/

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Spectrum’s Environmental Services TeamTroy Boley

Vice President and Co-Founder

[email protected]

(770) 883-7082

Derek Stuck

Senior Project Manager

[email protected]

(404) 710-0974

Kevin Lingard

Technical Specialist

[email protected]

(470) 409-4590

Herman Holm

Director – Specialty Environmental Services

[email protected]

(678) 727-2147

Rishabh Jaishankar

Project Manager

[email protected]

(404) 435-8070

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Thank You for Attending!

Any questions or comments?

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