(145c) Flare Monitoring and Data Management Challenges

Recently promulgated revisions to existing regulations have incorporated the flare monitoring requirements used by the refining sector and codified at 40 CFR Part 63, Subpart CC: National Emission Standards for Hazardous Air Pollutants (NESHAP) from Petroleum Refineries (MACT CC). The revised regulations include the Maximum Achievable Control Technology Standards (MACT) for Ethylene Production (EMACT), MACT for Organic Liquid Distribution (OLD MACT) as well as the Miscellaneous Organic NESHAP (MON). These rules require an increase in the use of continuous parametric monitoring systems (CPMS) on flares and an increased reliance on the management of the measured CPMS data for purposes of proper flare operation and ultimate compliance demonstration. This presentation will explore the new flare monitoring requirements and data management challenges experienced during the implementation of MACT CC in the refining sector. Specifically, considerations concerning:

• What is required to be measured on flares?
• How is the flare CPMS data quality assured (i.e., distinguishing between good vs. bad data)?
• How is the measured flare CPMS data validated, calculated, and averaged?
• What does the measured flare CPMS data indicate about flare operation?
• What notification, recordkeeping, and reporting requirements are required for measured flare CPMS?