Deadline to Meet 40 CFR Part 63 Flare Requirements is Coming Up – Here’s Guidance on Measurement Devices

 January 30, 2019 is practically here. That’s the date the U.S. Environmental Protection Agency (EPA) requires petroleum refinery owners or operators of flares used as control devices for emissions points to meet the requirements of 40 CFR Part 63 Subpart CC regardless of the construction date of the flare. Prior to that date, refineries must:

  • Develop flare management plans and submit them to the EPA
  • Develop root cause analysis (RCA) and corrective action analysis procedures
  • Evaluate pursuing alternative means of emissions limitation (AMEL) and an AMEL test plan
  • Develop and submit an alternative monitoring procedure
  • Design, implement and operate flare continuous parameter monitoring system (CPMS) plans
  • Purchase, install, test and troubleshoot measurement devices and instruments
  • Implement a data acquisition handling system (DAHS)
  • Develop monitoring plans and quality assurance/quality control (QA/QC) plans
  • Conduct visible emissions training
  • Comply with flare monitoring requirements and operating limits
  • Complete initial compliance demonstrations for visible emissions monitoring.

It’s a lot to accomplish. Before a refinery can select and implement measurement devices and instruments, it must first decide what measurement devices are best for use. Refineries essentially have a choice of technologies among a calorimeter, a mass spectrometer, and a gas chromatograph.

This article in Hydrocarbon Processing magazine presents the pros and cons of each technology and discusses the role each might play in meeting the 40 CFR guidelines. Ultimately, every refinery needs to review and understand the 40 CFR Part 63 requirements to evaluate which of the three possible solutions makes the most sense for their application. From a cost/benefit and performance standpoint, however, no refinery should leave out consideration of the gas chromatograph in its planning on measurement systems for compliance.

Read the article in full to learn more.

Are you ready to meet 40 CFR Part 63?

Khadra Helminski