1. Knowledge/experience with the MACT CC flare compliance rule

2. Company capabilities and experience related to all project aspects

3. Information about analytical alternatives – sample times, plugging problems, sensitivity to

contaminants, etc. 4. CEMS experience 5. Other important criteria

– Current efforts in this area – Other companies for which the firm is doing similar work

Talking Points

• Knowledge of the Regulations – Partnership with Sage for past 4 years

• Proven Project Execution – FEL process, checklists

• Knowledge in flares, instrumentation, controls, analyzers

• Strong Process Analytical Team • Two decades of CEMS design experience • Construction / Installation abilities

Critical Components for Success

MACT Rule What is the Plan?

First Steps EPA Refinery Sector RULE (RSR) CFR 40 63.670

Key Date: Existing flare compliance date – January 30, 2019

Evaluate

Plan

Execute

Comply

Evaluate - Bridging the GAP assessment Scope

1/16/2017

EPA

FEL – 1/2

http://christianimagesource.com/blog/archangel-raphael-part-2/

Sage Consulting

Defined Project Defined Scope Defined Deliverables

Burrow Global - EPC

GAP Assessment

Employee Training Updating FMP

RCA plan

Detail Design Installation Performance Testing

Proposed Roadmap - 2016

• 2016 • EVALUATE: Submit Initial Notification of Compliance Status to EPA • EVALUATE: Conduct flare specific Gap Assessments • PLAN: Develop a written Action Plan • PLAN: Conceptual Design

– Vendor discussions – Evaluate and select Instrumentation – Finalize estimates and budgets

1/16/2017

Boley, Allen 2012 Sage Environmental Consulting

Proposed Roadmap – 2017/2018

• 2017 • EXECUTE: Final Design and Engineering • EXECUTE: Instrumentation Purchase and Installation • EXECUTE: Troubleshooting and Optimization • 2018 • EXECUTE: Instrument Integration with control system • EXECUTE: Performance testing (failure modes, response times,

etc.) • EXECUTE: Incorporate into Data Acquisition and Handling System

(DAHS) • EXECUTE: Employee Training • EXECUTE: Updates to the Flare Management Plan (FMP • EXECUTE: Document the CPMS - continuous parametric

monitoring system • QA/QC Plan

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Boley, Allen 2012 Sage Environmental Consulting

Proposed Roadmap - 2019

• 2019—Due by January 30th • COMPLY: Meet monitoring requirements and applicable operating

limits (NHVcz, NHVdil, Vtip) • COMPLY: Submit updated or new written FMPs to EPA • COMPLY: Complete CPMS (submission not required) • COMPLY: Initial Compliance Demonstration for visible emissions

(Method 22)

1/16/2017

Boley, Allen 2012 Sage Environmental Consulting

Plan - Front End Loading (FEL) • Project Charter

– MACT compliance – Flare Initiative

• Field Survey – Flare process – Instrumentation – Valves – Shelter Location – Power – Grounding – Sample points – Control Strategy

• Scope • Schedule

– T.A. schedule • Budget

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Steam Assisted Flare Requirements • Operate with a pilot flame present at all times

• All flares must specify the design capacity and operate with no

visible emissions except a total of five minutes during any two consecutive hours.

• All flares must have a flow measurement accuracy of +-20% from .1 ft/sec to 1 ft/sec and +-5% for flows greater than 1 ft/sec.

This differs from the JA requirements that flares must have a flow measurement sensitivity of +-10 CFM or 5% of the actual volumetric flow rate, whichever is greater. The new rule is now promulgated into NSPS JA.

Key Points to note • Flare tip velocities may not exceed 400 ft/sec, and flare

tip velocity is subject limitations based on BTU content. • Operate at a minimum combustion zone Net Heating

Value of 270 BTU/scf on 15 minute time block averages. • Additionally, if air assist is used the operator must

monitor the flows of these gases to measure and report the dilution in the combustion zone and keep it above 22 BTU/ft2

• Flares will need to control, maintain, and demonstrate a 96.5% combustion efficiency or a 98% destruction efficiency.

Good Engineering Practices Current regulations at 40 CFR 60.11(d), 60.18(d), 60.482-10(e), 63.6(e), 63.11(b)(1), 63.172(e) require: 1. Adhere to the flare system design documents 2. Use Good Air Pollution Control Practices 3. The flare’s design documents include a flare operating manual, usually provided by the

flare vendor 4. The flare operating procedures need to be reviewed against flare standards/regulation 5. A Flare Management Plan is starting to be more common and is required by the

Refinery Flare rule. 6. Elements of the plan are:

• A flare map to include all connections to the flare • Quantification of all flows: • Purge gas, sweep gas, flared gas operating and RV scenarios, supplemental gas,

pilot gas and steam flows

Key Components of a Successful Implementation

Execute

BG Engineering • FEL2 – Feasibility (FEED) • Analytics – Data Sheets • Process Flow / Flare design / CSE • Shelter Outline Design Package • Standard Facilities Engineering

Packages (Utilities, Tie-ins, Networking)

Where does BG fit in the RSR Initiative?

End User • Process Data • Engineering

Standards • Site Standards • Existing

Documentation • Permit (EPA/TCEQ) • Process knowledge • Funding/budget

System Integration • Tubing, electrical fab • Shelter assembly • Sample System assembly • Analyzer integration • SI FAT & Inspection

Analyzer Vendors – Standard solutions • Application Engineering • Detail Internal Design Packages • Commissioning & Start-Up • Service Support

BG Construction • Installation • Civil/Structural • I/E • Mechanical / Piping

BG Program Management – Concept to Operation • Integrated Cost / Schedule work processes • Complete Lifecycle accountability and transparency of data • Lessons Learned

SAGE • Environmental

Consultant • Flare Management

Plant • GAP Assessment • Fence line

Monitoring

BG Program Benefits • Comprehensive capability from an EPC – Concept to Operation

– Construction led design – smooth transition from engineering to construction – Analytics – Program Management

• Proven Methodology and Checklists – 16 analyzers shelters in Houston Area – Templates / Checklists / Modular design

• Proven Alliance/ Program Management model – Management of the entire program – Consistency on staffing plans – KPI’s and efficiency tracking

• Single source engineering for a repeatable/consistent design – Minimize engineering costs and re-work – Improves schedule

• Cost Accuracy and Predictability – TIC Estimating

• Lessons Learned – leverage institutional learning

One Program

Multiple Projects With Program Oversight

3 Refineries

7 Flare

Checklist Items

1/16/2017

1. Derivation and meaning of EPA equations for Net Heating Value, Flare tip velocity, dilution impacts of air assisted and steam assisted flares

2. New NHV reqt is 270 BTU/SCF in combustion zone and must include smokeless steam in BTU calc.

3. Discuss forward looking vs. instantaneous flare controls 4. Required speed of response of flare instrumentation and control 5. Definition and practical consideration of water seal breaches 6. Verify that pilot gas is not used in the NHV calculation 7. Need for refineries to go back to flare tip vendors to determine %

smokeless operating capacity and need to have documentation 8. Now 15 minute block averages and not 3 hour block averages 9. Use of H2 at 1212 Btu/SCF?? 10. Discuss pro's and cons of GC's vs. Mass Spec vs. separate BTU analyzers -

- or simple calorimeter or RAMAN/FTIR

Analytical Key Items

Typical Process Analyzer System Overview - Extractive

19 1/16/2017

Probe, inserted into the process

Sample line, often heated

Enclosure Package Walk-In House Package

Measurement Values & Alarms ↔ DCS/SIS/Reports, etc.

Calibration/ Utilities

Sample Handling System Process Analyzer

Typical Layout

Analytical design notes • Utilize fast loop flow calculation program to ensure sample transport times and

pressure drops are correct • Separate or combined supply and return bundles pending locations

• Utilize phase calculation program to ensure sample heating temperature will

maintain single vapor phase

• Typical 240oF for flare samples, can be verified

• Knowledge of tube bundle coatings, sizing and heating to help eliminate potential plugging and plan for maintenance (include spare tubes in bundle for example)

• Optimize design based on local knowledge and experience with site specific conditions

• Utilize sample tube bundle heating calculations to ensure phase preservation and know the electrical load requirements

Analytical design notes

• Long lines may require dual 208V circuits, shelter power panels/load and electrical designs to suit, etc.

• Understanding of GC application details (must know all potential components), calorimeter speed of response, etc.

• Possibilities to re-apply existing GC’s – consult with vendors to understand cycle time changes and potential downtime for changes

• GC applications need comprehensive stream composition details under all conditions – Calorimeters are fast response, not composition dependent.

• Understanding of safe disposal and venting of samples and analyzer vents • Fast loops return to flare down stream of take-off probe, use heated head

pump, analyzer vents via TracErase typically

Overall, ensure the system is Safe, Compliant, Operable, Functional and Maintainable

Other Key Items

Process – Flare Tip Design

Need improved flare tip design Present over steaming UFL - LFL

Flow

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TIPS • Utilize your flow Vendor • Specify CERTIFIED design and

installation • Consider a spool piece for

simplicity during the turnaround • Note impact on cost • Develop the Lift plan early • Validate current supports

Steam Control

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TIPS • Calculate the steam low flow

design basis • Evaluate Split Range Control

System vs a V-Notch Ball Valve Design

• Consider T/A time for spool piece design

Make-Up gas

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TIPS • Decide on your Design Basis for

lowest BTU flow • Natural Gas vs Fuel Gas

• Very specific local decision • Do you need a bigger line up the

flare? • Metering? • Control Valve

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

Installation/Construction

• T/A window for modifications • Small construction crew • Work execution packages • Design Build packages and

execution • Fabrication of piping and

spools

Recent installation of shelter

Remote Instrument Enclosure 42’ x 21’

Flare Ja House 20’ x 8’

Recent Projects

• CEMS Ja Flare Analyzer project, 2-Flare systems one Analyzer Building.

• Started on this project July 2014. • The building and Analyzer detail design/build out

was provided by Siemens in Houston. • BGA took care of design reviews, infrastructure,

client technical, construction support, start-up and commissioning, etc., etc. We also consulted with SAGE throughout the project.

1/16/2017

Recent Project

Similar Ongoing Projects • Developing Integrated plan and partnership with

Sage/Dexter – developing training class • Completed two Ja flare analyzer shelter

commissioning in Houston Refinery • Complete one large Ja flare shelter in Beaumont • Currently engaged with three refinery for overall

flare/PSV program • Working with two major Refineries for new MACT

/RSR plan • Major Louisiana Refinery – Gate 1 design for RSR

1/16/2017

• 2019—Due by January 30th • COMPLY: Meet monitoring requirements and applicable

operating limits (NHVcz, NHVdil, Vtip) • COMPLY: Submit updated or new written FMPs to EPA • COMPLY: Complete CPMS (submission not required) • COMPLY: Initial Compliance Demonstration for visible

emissions (Method 22)

Comply – Back to SAGE

Staying Informed

Future Conferences • AFPM Environmental

• October 16 – 18, 2016 • New Orleans Marriott • New Orleans, LA

• 4C HSE Conference • Feb 19-22, 2017 • Hyatt Regency Austin • Austin, Tx

1/16/2017

Visit EPA Site and review latest ruling

Recent Conferences • ECC

– Palm Desert, CA. • AFPM

– 2015

• Questions? Next Steps? – info@burrowglobal.com

Evaluate/Plan/Execute/Comply