ENV-17-16 Key Technical Challenges and Approaches to Compliance for the 2019 Refinery Flare MACT Requirements

Description:

The U.S. EPA finalized new requirements for flares in 40 CFR Part 63 Subpart CC (MACT CC) via the Refinery Sector Rule (RSR) on December 1, 2015. The new requirements address flare combustion efficiency (96.5% combustion or 98% destruction) using limits on tip velocity (Vtip), net heating value in the combustion zone (NHVCZ), and operating without visible emissions (VE). Refineries working to comply with these limits prior to the January 30, 2019, compliance date have recognized and addressed several challenges. This paper will outline the RSR flare requirements, key technical challenges, and potential approaches to compliance management based on lessons learned through the process of initially implementing these provisions. Our review of technical challenges will include NHVCZ monitoring, gas chromatograph (GC) calibration gas specifications and GC certification, NHVCZ calculation elections and implications, Vtip limit elections and calculations, and flow measurement and instrumentation.