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ENV-16-21 Comparison of MACT CC and NSPS Subpart Ja Requirements – Flares

Steve Walls, Trihydro Corporation

Format:
Electronic (digital download/no shipping)

Associate Member, International Member, Petrochemical Member, Refining Member - $0.00
Government, NonMember - $35.00

Description:

The November 11, 2015, compliance date for modified refinery flares subject to New Source Performance Standards (NSPS) Subpart Ja has come and gone. The primary goal of NSPS Subpart Ja was to reduce sulfur dioxide (SO2) emissions by establishing a H2S concentration limit demonstrating compliance via continuous sulfur compound monitoring. Additionally, NSPS Subpart Ja was geared to reducing emissions of other criteria pollutants by having refineries establish a site specific volumetric flow baseline combined with continuous monitoring of flare gas flow to determine when flows exceed a regulatory trigger requiring a Root Cause Analysis (RCA). Refineries are now faced with another three year compliance period (December 2015 through January 30, 2019) to address the revised requirements of the Refinery Sector Rule, also known as Maximum Achievable Control Technology (MACT) Subpart CC. Although some of the MACT Subpart CC requirements for flares overlap with the flare requirements of NSPS Subpart Ja (e.g., continuous flow monitoring), there are several new monitoring requirements under MACT CC that may require refineries to install new continuous monitoring devices. This paper will focus on the requirements of MACT Subpart CC by comparing the rule with similar requirements cited in NSPS Subpart Ja. This paper will address the applicability of the two rules, the specific numeric limitations, and the monitoring strategy for demonstrating compliance. This paper will also explore the subtle differences in the Flare Management Plan (FMP) and RCA requirements for the two rules. This paper will include a comparison table that summarizes the requirements of both NSPS Subpart Ja and MACT Subpart CC in a side-by-side comparison. This paper will incorporate response-to-comments language relevant to rule applicability and compliance. Lastly, the paper will include some specific examples of flare systems subject to the various rule provisions. The ultimate goal of the paper is to provide stakeholders an understanding of the requirements of both rules and how they overlap and where these rules diverge.

Product Details:

Product ID: ENV-16-21
Publication Year: 2016