(160b) Flaring Enforcement into Next Generation Flare Rule Making: Flare Management Plans and Beyond

2020 Spring Meeting and 16^th Global Congress on Process Safety

The 32^nd Ethylene Producers’ Conference

Title: “Flaring Enforcement into Next Generation Flare Rule Making: Flare Management Plans and Beyond”

Topic: Flaring, Flare Management Plans, Sustainability,

Authors:

Linda Bartlett, Principal Consultant and Brian Woodbury, Senior Consultant

Environmental Resources Management (ERM), 3838 N. Causeway Blvd. Suite 3000, Metairie LA 70002

(504) 831-6700; linda.bartlett@erm.com, brian.woodbury@erm.com

Abstract:

Flaring has been a focus for EPA enforcement for several years. Regulations are now catching up with the Consent Decrees and the National Enforcement Initiative to cut Hazardous Air Pollutants (HAPs). Clean Air Act 114 information requests are now extending into other industries beyond refining including chemicals operations. These non-refinery operations can learn from the refinery journey and potentially stay a step ahead of coming regulations.

An early step in this next generation of flaring regulation is focused on refineries under Title 40 Code of Federal Regulations Part 60, New Source Performance Standards Subpart Ja (NSPS Ja) and Part 63, National Emission Standards for Hazardous Air Pollutants Subpart CC (NESHAP CC). Refineries are required to prepare and submit a lengthy, in-depth flare management plan (FMP) which prescribes how the facility will minimize flaring. ERM has been working with multiple refiners and chemical manufacturers on their flare management plans. In this process, ERM has identified key lessons which will be summarized in this presentation. ERM’s experience will provide historical context and “lessons learned” to the ethylene industry as they prepare for adapting to new proposed standards similar to refinery NSPS Ja and NESHAP CC. Examples of the lessons learned include:

• how to actively engage facility stakeholders to ensure understanding, particularly for developing minimization procedures;
• implications with multiple process units on a single flare header for minimization and alternate baseline flow rates,
• why and how summarized startup and shutdown procedures can be used; and
• important options to consider for monitoring such as sample conditions (wet or dry analysis).

Furthermore, with continued EPA and state enforcement pressure around flaring, ERM will present the following ideas on how to maintain compliance after the flare management plans have been submitted:

• programs and procedures needed to maintain an evergreen plan in a continuously changing facility environment,
• potential cost savings around plan structure and management,
• incorporation of minimization procedures into current operating procedures, and
• potential “red flags” associated with the content submitted in the FMP such as baseline flow compared against the production capacity.

Chemical manufacturers may want to consider a proactive review of flaring operations with respect to the journey that refineries have traversed. Actions taken now can position manufacturers not yet subject to such rigorous flaring regulations for coming capital and operating needs, and potentially reduce operating costs by enacting good flaring practices.

Bio:

Ms. Linda Bartlett is a chemical engineer from Tulane University in New Orleans, Louisiana. Prior to joining ERM in 2014, she supported a large refining and petrochemical complex in Louisiana in various positions including Environmental Manager.

She has over thirty years of experience in facility environmental support, process and project engineering, operations, management, and environmental consulting.

Her experience includes air, water, and waste compliance and permitting. Her expertise lies in air quality including Title V and PSD permitting, compliance management, and environmental personnel training. She has responded to numerous Clean Air Act 114 requests involving complex flare systems and recently permitted two large green field LNG facilities with supporting power plants and concrete batch operations.