Upcoming Refinery Flare Requirements for 40 CFR Part 60 Subpart Ja
Posted: June 12th, 2015Author: All4 Staff
On June 1, 2012, U.S. EPA Administrator Lisa Jackson signed a notice issuing final amendments for 40 CFR Part 60 Subpart Ja, Standards of Performance for Petroleum Refineries for Which Construction, Reconstruction, or Modification Commenced After May 14, 2007. Specifically, these amendments lift the September 2008 stay of effectiveness of the process heater and flare requirements of the standard. (See Bob Kuklentz’s previous ALL4 blog for more details.) As a result, flares that are new, have been reconstructed, or have been “modified” after June 24, 2008, are now required to demonstrate compliance, in accordance with several new procedures, by November 11, 2015. A “modification” to a flare is defined as any physical alteration that increases the flow capacity to a flare and any new piping physically connected to a flare, with the exception of the following:
- Connections made to install monitoring systems to the flare,
- Connections made to install or enhance a flare gas recovery system,
- Certain connections made to replace or upgrade existing pressure or safety valves,
- Connections made for flare gas sulfur removal,
- Connections made to install redundant equipment that does not increase the capacity of the flare,
- Replacement of an existing connection from a refinery process unit to a new location on the same flare, and
- Connections that interconnect two (2) or more flares.
This detailed definition of a flare “modification” includes actions that are often routine at many refineries, making the tracking of such actions that much more important.
Owners of flares installed, reconstructed, or “modified” after June 24, 2008 must complete the following:
- Develop a Flare Management Plan (FMP) pursuant to §§60.103a(a)(1) through (7).
- Conduct a root cause analysis and corrective action analysis for any occurrence in which sulfur dioxide (SO2) emissions exceed 500 pounds in any 24-hour period and any discharge to the flare exceeds 500,000 standard cubic feet (scf) in any 24-hour period.
- Install, operate, calibrate, and maintain an instrument for continuously monitoring and recording the concentration by volume (dry basis) of hydrogen sulfide (H2S) in the fuel gases before being burned in the flare, to demonstrate compliance with the H2S limit of 162 parts per million by volume (ppmv) determined hourly on a 3-hour rolling average. If applicable, instrumentation for continuously monitoring and recording of total reduced sulfur (TRS) may be used. Continuous monitoring to demonstrate compliance with the H2S limit is not required for fuel gas streams that are inherently low in sulfur.
As stated previously, the effective date of the compliance requirements is fast approaching – November 11, 2015. Now is the time for owners and operators to begin planning the implementation of the revised Subpart Ja flare requirements. Need help developing and implementing these requirements? Be sure to contact ALL4.