Upload
dokien
View
299
Download
12
Embed Size (px)
Citation preview
3/22/2018
1
©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
3/22/2018
2
©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
3/22/2018
3
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 5
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.
3/22/2018
4
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 7
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
3/22/2018
5
©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.
3/22/2018
6
©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.”
3/22/2018
7
©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
3/22/2018
8
©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)
3/22/2018
9
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 17
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
3/22/2018
10
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 19
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
3/22/2018
11
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 21
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)
3/22/2018
12
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 23
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
3/22/2018
13
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 25
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
3/22/2018
14
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 27
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
3/22/2018
1
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
3/22/2018
2
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
3/22/2018
3
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
3/22/2018
4
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
3/22/2018
5
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
3/22/2018
6
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
3/22/2018
7
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
3/22/2018
8
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
3/22/2018
9
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
3/22/2018
10
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
3/22/2018
11
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
3/22/2018
12
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
3/22/2018
13
Questions?
Up Next: Flare Monitoring Systems
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC
3/22/2018
1
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
3/22/2018
2
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
Ima
ge
s C
ou
rte
sy o
f P
rim
e E
ne
rgy
Re
po
rts
©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
3/22/2018
3
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
3/22/2018
4
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
3/22/2018
5
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
3/22/2018
6
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
3/22/2018
7
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.
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 14
3/22/2018
8
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 15
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
Ima
ge
s C
ou
rte
sy o
f F
lare
& S
tack
s, I
nc.
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 16
3/22/2018
9
Assist Air Flow Monitoring Methods for determining air flow◦ Fan curve
◦ Challenges
◦ Direct flow measurement
◦ Challenges
Either option allowed under MACT CC
Ima
ge
co
urt
esy
of
OS
i
Ima
ge
co
urt
esy
of
Ele
ctro
nic
s C
oo
ling
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 17
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
3/22/2018
10
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
Ima
ge
s C
ou
rte
sy o
f P
rim
e E
ne
rgy
Re
po
rts
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 20
3/22/2018
11
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 22
3/22/2018
12
Instrument CriteriaResponse Time◦ Compliance timeframe
Cost◦ Direct Installation
◦ Operation and Maintenance
◦ Ancillary (Shelter, sampling system, etc.)
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 23
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
Ima
ge
s C
ou
rte
sy o
f H
ob
re.c
om
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 24
3/22/2018
13
Btu AnalyzerPros◦ Fast
◦ All constituents included in analysis
Cons◦ No speciation data
◦ Can requires second instrument/integrated hydrogen analyzer
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 25
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 26
3/22/2018
14
Hydrogen Analyzer Limitations
Temperature Limitations
Composition◦ Some analyzers are limited by the amount
of H2S in the vent gas.
◦ Cross-sensitivity
Ima
ge
s C
ou
rte
sy o
f C
osa
Xe
nta
ur
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 27
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 28
3/22/2018
15
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)
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 29
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 30
3/22/2018
16
Gas ChromatographPros◦ Potential for a single instrument for
sulfur and NHV
Cons◦ Slow cycle time
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 31
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 32
3/22/2018
17
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 33
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 34
3/22/2018
18
Sulfur Monitoring Options
Sulfur Monitoring Technologies◦ Gas Chromatographs (GC)
◦ Tunable Diode Lasers (TDL)
◦ Mass spectrometers (MS)
◦ Total Sulfur (TS) Analyzers
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 35
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%
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 36
3/22/2018
19
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.
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 37
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.
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 38
3/22/2018
20
Questions?
Up Next: Flare Control Parameters and DCS Integration
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 39
3/22/2018
1
©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
3/22/2018
2
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 3
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
htt
p:/
/cli
par
tpo
st.c
om
/wp
-co
nte
nt/
up
load
s/2
01
7/1
2/S
tack
-of-
bo
oks
-
text
bo
ok-
clip
art
-sta
cke
d-b
oo
ks-s
tack
-of-
wik
icli
pa
rt.j
pg
3/22/2018
3
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 5
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 6
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
3/22/2018
4
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 7
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)
100(%),2
,2
plumeplumeplume
plume
HCCOCO
COCE
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 8
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
1001(%)
in
plume
X
XDRE
3/22/2018
5
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 9
Determination of CE and DRE
Surrogate Parameters
Direct Measurements
Passive Extractive
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 10
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
3/22/2018
6
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 11
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
0.0
50.0
100.0
150.0
200.0
250.0
300.0
350.0
400.0
450.0
0 200 400 600 800 1000 1200 1400 1600
Exi
t V
elo
city
(ft
/s)
Net Heating Value (Btu/scf)
Steam and Unassisted
Air Assisted
Above each line represents
out of compliance for that
type of flare.
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 12
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)
.
3/22/2018
7
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 13
Maximum Permitted Exit VelocityConsolidates three equations for Vmax into one equation
Steam and Unassisted Flares
����� ��� ��� � � 28.8
31.7
Air Assisted Flare
��� 8.706 � 0.7084 ∗ ��� �
High Hydrogen Flares
��� ��� � �� ∗ ��
����� ��� ��� � � 1212
850
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 14
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.
3/22/2018
8
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 15
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.
n
i
iiT HCkH1
C20 is for re temperatuStandard ;1
10740.1 7 o
scm
moleg
kcal
MJ
scm
moleg
ppmk
Subpart A requires NHVvg
in excess of 200 Btu/scf
for unassisted flares and
300 Btu/scf for assisted
flares.
3/22/2018
9
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 17
Combustion Zone Net Heating Value Parameters in the Consent DecreesConsent decrees started to the shift the focus to the combustion zone.
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 18
Combustion Zone Net Heating Value Parameters in MACT CC
3/22/2018
10
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 19
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
3/22/2018
11
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 21
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 22
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.
3/22/2018
12
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 23
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 24
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.
3/22/2018
13
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 25
MACT CC Compliance Calculations
Direct Calculations
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 26
MACT CC Compliance Calculations
Feed Forward Calculations
3/22/2018
14
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 27
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 28
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/
3/22/2018
15
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 29
Steam Control
Steam control: variability
Tiered control scheme – most common approach
https://www.thermoeng.it/assets/Uploads/scroll-home-sesta.jpg/
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 30
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
3/22/2018
16
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 31
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/
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 32
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
3/22/2018
17
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 33
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
3/22/2018
18
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 35
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
3/22/2018
19
©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.
3/22/2018
20
©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
3/22/2018
21
©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
3/22/2018
1
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
3/22/2018
2
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 4
3/22/2018
3
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
3/22/2018
4
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
3/22/2018
5
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
3/22/2018
6
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
3/22/2018
7
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
3/22/2018
8
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
3/22/2018
9
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
3/22/2018
10
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
3/22/2018
11
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
3/22/2018
12
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
3/22/2018
13
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 26
3/22/2018
14
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
3/22/2018
15
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
3/22/2018
16
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
3/22/2018
17
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
3/22/2018
18
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
3/22/2018
19
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
3/22/2018
20
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
3/22/2018
21
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
3/22/2018
22
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
3/22/2018
23
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
3/22/2018
24
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 48
3/22/2018
25
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 49
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 50
3/22/2018
26
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.
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 51
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 52
3/22/2018
27
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 53
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.
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 54
3/22/2018
28
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 55
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 56
3/22/2018
29
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 57
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 58
3/22/2018
30
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 60
3/22/2018
1
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 1
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
http://aerialindustrial.com/wp-content/uploads/2014/08/live-flare-inspections-onshore.jpg
3/22/2018
2
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 3
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 4
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
3/22/2018
3
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 5
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
3/22/2018
4
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 7
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
3/22/2018
5
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 9
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 10
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
3/22/2018
6
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 11
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 12
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)
3/22/2018
7
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 13
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
http://perfectsurroundingsintl.com/wp-content/uploads/2012/12/question1.jpg
3/22/2018
8
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 15
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
3/22/2018
9
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 17
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
3/22/2018
10
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 19
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 20
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
3/22/2018
11
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 21
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 22
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?
3/22/2018
12
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 23
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 24
Minimization AssessmentProvide justification for selected minimization measures based on◦ Technical feasibility
◦ Costs
◦ Safety considerations
◦ Secondary environmental impacts
◦ Natural gas offset credits
http://www.schroeter-ht.de/sites/default/files/styles/glalerie-big/public/galerie/flugdrohne-6.jpg
3/22/2018
13
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 25
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 26
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)
https://www.thecyberhawk.com/wp-content/uploads/2016/02/Sabic-Olefins.jpg
3/22/2018
14
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 27
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 28
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
3/22/2018
15
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 29
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
https://www.europages.com/filestore/opt/product/f5/f4/flare-3_c4109165.jpg
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 30
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
3/22/2018
16
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 31
Questions?Up Next: Consent Decrees and Future Flaring Regulations
https://d1w9csuen3k837.cloudfront.net/Pictures/1280x720/3/2/9/130329_gas_flare_shutterstock_548204362_hero.jpg
3/22/2018
1
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 1
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
3/22/2018
2
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 3
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/
3/22/2018
3
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 5
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?
http://www.schroeter-ht.de/sites/default/files/styles/glalerie-
big/public/galerie/flugdrohne-2.jpg
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 6
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/
3/22/2018
4
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 7
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 8
Minimization Assessments
Flare gas recovery
Level of recovery
Chemical plant unique concerns
http://www.gdnash.com/uploadedimages/library/e-newsletters/en_july_08/garo-flare-gas-pkg-
1c.jpg?n=5166
3/22/2018
5
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 9
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
3/22/2018
6
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 11
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 12
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.
3/22/2018
7
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 13
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 14
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
3/22/2018
8
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 15
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 16
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
3/22/2018
9
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 17
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
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 18
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
3/22/2018
10
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 19
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/
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 20
Spectrum’s Environmental Services TeamTroy Boley
Vice President and Co-Founder
(770) 883-7082
Derek Stuck
Senior Project Manager
(404) 710-0974
Kevin Lingard
Technical Specialist
(470) 409-4590
Herman Holm
Director – Specialty Environmental Services
(678) 727-2147
Rishabh Jaishankar
Project Manager
(404) 435-8070
3/22/2018
11
©SPECTRUM ENVIRONMENTAL SOLUTIONS, LLC 21
Thank You for Attending!
Any questions or comments?
http://www.skeyebv.nl/wp/wp-content/uploads/2013/02/Drone-Inspection-UAV-UAS-onshore-offshore-Gas-Flare-Stack-04-900x330.jpg