Refinery Sector Rule (RSR) Compliance Countdown
Posted: January 23rd, 2019
Authors: Matt C.
On November 8, 2018, U.S. EPA finalized amendments to the petroleum refinery National Emission Standards for Hazardous Air Pollutants (NESHAPs) 40 CFR Part 63, Subparts CC and UUU, along with New Source Performance Standards (NSPS) 40 CFR Part 60, Subpart Ja, collectively referred to as the Refinery Sector Rule (RSR). 40 CFR Part 63, Subpart CC amendments included new requirements for maintenance vents, pressure relief devices (PRDs), delayed coking units (DCUs) and flares, and established fenceline monitoring requirements. The finalization of the most recent amendments, which have been litigated since the initial proposed rules were published in June 2014, brings the January 30, 2019 compliance date squarely into view for ALL4 and refineries alike.
What Stands Out?
Among the many revisions promulgated in the RSR, the continuous monitoring requirements applicable to flare control devices under §63.670 of 40 CFR Part 63, Subpart CC stand out to me for a variety of reasons. Why do they stand out to me?
Well, in addition to continuously monitoring the flow rate of the flare vent gas, the RSR requires continuous monitoring of either the flare vent gas composition or the net heating value of the flare gas. How is compliance demonstrated? 40 CFR Part 63, Subpart CC provides some options:
Continuously measure the individual components of the flare vent gas using one of these methods:
- Gas Chromatograph (GC)
- Mass Spectrometer [via U.S. EPA’s “Broadly Applicable Approved Alternative Test Method” for the Mass Spectrometry (or “ALT-124”)]
- Grab Sample System
OR
Continuously measure the net heating value of the flare vent gas using a calorimeter.
With less than two weeks to go until the January 30, 2019 flare monitoring compliance date, it’s likely that as a refinery your compliance methodology has been chosen and your instrumentation is in place. However, what stands out to me; is that 40 CFR Part 63, Subpart CC provides little detail as it relates to how these continuous parametric monitoring systems (CPMS) are to be operated and maintained by refineries. Consider just a couple example “grey areas” within the regulation:
- Although not explicitly mentioned by 40 CFR Part 63, Subpart CC, the net heating value of flare vent gas can be measured using a process mass spectrometer, provided it is operated in accordance with ALT-124. Additionally, U.S. EPA also recently posted ALT-131, which allows for alternative calibration procedures to those detailed in ALT-124 and PS-9.
- Speaking of ALT-124, what is the process for calibrating a mass spectrometer initially and on an ongoing basis? ALT-124 notes to follow the procedure in PS-9 of 40 CFR Part 60, Appendix B for calibrating a GC. The implication is that requirements for mass spectrometers are “as stringent” as those for gas chromatographs. Ok…reasonable. However, the process to “calibrate” a mass spectrometer is completely different and more complex than the process to “calibrate” a GC due to the measurement principles of each instrument. What’s the correct way to complete the “calibration” for a mass spectrometer using a procedure created for GCs?
- What are the initial and ongoing calibration requirements for a calorimeter used to measure net heating value of the flare vent gas? Table 13 of 40 CFR Part 63, Subpart CC notes to specify these requirements in the site-specific CPMS Monitoring Plan and should follow manufacturer’s recommendations “at a minimum”. What are the manufacturer’s recommendations? Do the recommendations provide enough detail for instrument technicians to apply the calibration methodology? Do I have an accurate CPMS Monitoring Plan that can be produced and relied upon during an inspection?
The Refinery Sector Rule (RSR) Compliance Bottom Line
While not all refineries will choose to operate a mass spectrometer or a calorimeter to demonstrate compliance, the takeaway is that the regulation does not provide a clear path to follow when it comes to operating and maintaining CPMS needed for compliance with the RSR. It is important for refineries to vet out these “grey areas” of continuous monitoring for flare compliance under 40 CFR Part 63, Subpart CC. We recognize many refineries received extensions on the January 30, 2019 compliance date and are still in the implementation process for CPMS used for RSR compliance. If you have questions about the RSR, the use of CPMS to comply with the RSR, or are still in the process of implementing new CPMS for flare compliance under the RSR, please reach out to me. I can be reached at 610.933.5246 extension 139, or at mcarideo@all4inc.com.
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