ENV-17-14 Flare Minimization – A Report from the San Francisco Bay Area after a Decade of Plan Implementation

Description:

Refineries in the San Francisco Bay Area were the first to be required by local regulations to adopt Flare Minimization Plans (FMP). The initial plans for the five Bay Area refineries were approved by Bay Area Air Quality Management District (BAAQMD) on July 16, 2007. In addition, monitoring and recording of emission data for flares has been implemented since 2004. This report will share publicly available information reported to BAAQMD from flare monitoring data collection efforts over the past decade, including trends in flaring frequency; magnitude; vent gas flow; and concentrations of methane, non-methane hydrocarbon, and sulfur dioxide (SO2) emissions released. This information will serve to provide the context for flare minimization opportunities of the past, present, and future for refineries around the world. This report will also provide a synthesis of information available from 10 years of FMPs updated annually by each refinery. As required by the local rule, these plans include: • Reductions previously realized – equipment, processes, and procedures that achieved the reductions. • Planned reductions - equipment, processes, and procedures that provide further opportunity for reductions. • Prevention measures to address: o Planned major maintenance activities, including startups/shutdowns; o Issues with gas quantity or quality; and o Recurrent failure of process equipment, control equipment, or process operations. This ten-year lookback is informative regarding best practices that have emerged and become common practice since initial implementation of the plans. This report will include an analysis of the flare data trends and best practices in the Bay Area over the last 10 years that may assist in addressing new flare management requirements under the Refinery Sector Rule (RSR) and New Source Performance Standards (NSPS) Subpart Ja. These lessons-learned topics include: changes and trends in different types of flaring activities; procedural, operational, equipment, and instrumentation approaches taken; benefits of minimization approaches; and examples of manpower commitment required to implement these practices.