ENV-17-23 Practical Approach to Preparing the Refinery MACT 1 Flare Management Plan and CPMS Monitoring Plan

Description:

One aspect of maintaining continuous flare efficiency under the refinery sector rules (RSR) for flares used as air pollution control devices under Refinery MACT 1 and 2, is the implementation of work practices for emergency flaring events. The work practices include the preparation of a flare management plan (FMP) and Continuous Parameter Monitoring System (CPMS) plan together with root cause analysis and corrective actions for certain flaring events. The FMP required under Subpart CC (Refinery MACT 1) has many similar elements to the NSPS Ja flare management plan and some very unique elements. The two flare management plans and CPMS Monitoring Plan also share many aspects with the Waste Gas Minimization Plan and flare monitoring plan required by the flare efficiency Consent Decree. Experience gained in the preparation of the previous NSPS Ja flare management and monitoring plans will be useful in meeting the requirements of the Subpart CC FMP. This presentation will provide conference attendees with a comparison of the plan elements, opportunities for using methodologies developed during NSPS Ja FMP development for completion of the elements of the Subpart CC FMP and the pros and cons of maintaining a single FMP or two separate plans.