i December 3, 2015

Project Team

Jesse Madsen, Air Quality Specialist II Dave Torii, Air Quality Engineer II Steve Leonard, Senior Air Quality Engineer Chay Thao, Program Manager Errol Villegas, Permit Services Manager Leonard Scandura, Permit Services Manager Sheraz Gill, Director of Strategies and Incentives 

# Draft Further Study

Rule 4311 Flare Minimization Plans

2015DRAFT Further Study – Rule 4311 Flare Minimization Plan

December 3, 2015

i Table of Contents | SJVUAPCD 

### Table of Contents

I. Executive Summary .................................

................................................... .............. 1

II. Background ........................................

................................................... ................... 2

III. What is Flaring? ..................................

................................................... ................... 6

General Equipment Description .....................

................................................... ..... 6 A.

General Process Description .......................

................................................... ....... 7 B.

IV. Flaring in the San Joaquin Valley .................

................................................... ......... 8

V. Flare Minimization Plans ..........................

................................................... ........... 10

Rule 4311 Flare Minimization Plan (FMP) Requirement s .................................... 10 A.

Flare Minimization Practices ......................

................................................... ....... 11 B.

VI. Flare Control Technology Evaluation ...............

................................................... .... 16

VII. Further Study Findings and Recommendations......... ............................................. 16DRAFT Further Study – Rule 4311 Flare Minimization Plan

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1 Executive Summary | SJVUAPCD I. EXECUTIVE SUMMARY

The San Joaquin Valley air basin (Valley) faces uni que and unprecedented air quality challenges in attaining the federal air quality sta ndards (also called National Ambient Air Quality Standards, or NAAQS). The San Joaquin Vall ey Air Pollution Control District (District) must explore all available emission redu ction opportunities in order to demonstrate attainment for multiple federal ozone a nd PM2.5 standards in the coming years. In an effort to leave no stone unturned, in its 2015 Plan for the 1997 PM2.5

Standard ( 2015 PM2.5 Plan ), the District committed to a further study to rev iew submitted Flare Minimization Plans (FMPs) under District Rule 4311 (Flares) and identify the most effective flare minimization practices utilized by operators. As a result of this comprehensive study the District offers the followi ng findings and recommendations:

1. The District identified minimization practices c urrently performed at facilities that have the potential to be applied to other facilities.

a. The District recommends conducting a thorough ev aluation of the most effective flare minimization practices include d in approved FMPs and requiring the implementation of these prac tices where technologically achievable and economically feasibl e . Even though operators of flares in the Valley have already take n extensive measures to reduce flaring, through this study the District has identified effective minimization practices currently performed at some facilities that could be employed at other facilities to further reduce flar ing. To further evaluate opportunities for emission reductions from flaring, the District will perform

an exhaustive evaluation of these flare minimizatio n practices in its upcoming 2016 ozone and PM2.5 attainment plans and propose potential rule amendments requiring the use of these practice s where technologically achievable and economically feasibl e.

b. The District recommends exploring options to fur ther promote the implementation of the most effective flare minimiza tion practices during the FMP submittal and review process. Under Rule 4311, FMPs are required to be submitted and approved for existing, new, and modified flaring systems. For existing systems, an updated FMP is required to be submitted and approved every five ye ars. Working with operators to identify potential flare minimization practices during the FMP review process provides operators the opportunity t o incorporate feasible flare minimization practices when new and modified systems are proposed and during the ongoing review of FMPs.DRAFT Further Study – Rule 4311 Flare Minimization Plan

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2 Background | SJVUAPCD 2. Ultra low NOx technologies with the potential to further reduce emissions from flaring have recently become available. The D istrict recommends conducting a thorough evaluation of new ultra low N Ox control technologies for flaring and requiring the implemen tation of these technologies where technologically achievable and e conomically feasible. Through this further study, the District has identi fied new low NOx control technologies that may serve as suitable options for further reducing NOx emissions from flaring in the San Joaquin Valley. To further evaluate opportunities for emission reductions from flaring, the District will perform an

exhaustive evaluation of NOx emission reduction con trol technologies in its upcoming 2016 ozone and PM2.5 attainment plans and propose potential rule amendments requiring the use of these technologies where technologically achievable and economically feasible.

II. BACKGROUND

The development of the District’s 2012 PM2.5 Plan involved extensive research and analyses of technologies for potential opportunitie s to further reduce emissions of particulate matter (PM) and oxides of nitrogen (NOx ), which is a predominant pollutant in the formation of fine particulate matter (particula te matter that is 2.5 microns or less in diameter, or PM2.5) and ozone. Although the result s of the analyses for this plan did not indicate that regulatory action to further reduce f laring emissions would accelerate PM2.5 attainment, the District committed to continue eval uating flares through a further study measure. Furthermore, the District also committed to this further study in the District’s

2013 Plan for the Revoked 1-Hour Ozone Standard.

To satisfy these commitments, the District complete d and published the Rule 4311 (Flares) Further Study

report on September 16, 2014 ( 2014 Study ). 1 In that study, District

staff reviewed the submitted Flare Minimization Pla ns, Annual Monitoring Report data, Reportable Flaring Event data, and new NSPS require ments to identify and evaluate potential opportunities to further reduce emissions from flaring. In addition to the review committed in the plans, the District also reviewed the flare emission inventory in the Valley and analogous rules in other air districts in Calif ornia. As a result of that extensive effort, the District made the following findings:

1. Flare Emissions Comprise a Small Percentage of t he Overall NOx Emissions in the Valley A review of the flare emission inventory indicates that emissions from all flares operating in the Valley, regardless of permi t status and requirements,

1 SJVAPCD. (2014) Rule 4311 (Flares) Further Study 2014 . Retrieved from http://www.valleyair.org/Air_Quality_Plans/docs/R43 11.pdf

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3 Background | SJVUAPCD contributed to 0.14% of the total annual NOx emitte d from all Valley stationary and area sources in 2012. This is in part because these control devices are primarily engineered for emergency operation during process upsets and emergency situations and achieve 98% destruction ef ficiency when operated properly. 2

2. Rule 4311 is as Stringent as Other Air Districts ’ Rules District analysis confirmed that Rule 4311 is as st ringent as similar rules in South Coast Air Quality Management District (SCAQMD ), Bay Area Air Quality Management District (BAAQMD), Ventura Count y Air Pollution Control District (VCAPCD), and Santa Barbara County Air Pol lution Control District (SBCAPCD). Those analogous rules have some minor d ifferences in requirements, due to the differences in types of fa cilities and sizes of flares,

which would not result in additional emission reduc tions if implemented in the Valley. Furthermore, Rule 4311 has been confirmed by EPA in its most recent approval of amendments to the rule as satisf ying Reasonable Available Control Technology (RACT) requirements.

3. Flare Minimization Plans Contain Effective Measu res to Reduce Flaring In the Valley, 95 flares are either operated at pet roleum refineries or have large enough flaring capacities to trigger the FMP requirements of Rule 4311. These flares are operated in multiple industries, i ncluding the oil and gas industry, wastewater treatment, and wine and cheese production. Operators with FMPs are including feasible measures in the FM Ps and actively taking steps to reduce flaring at their facilities.

4. Annual Monitoring Reports Assist with Enforceabi lity Flares are subject to annual monitoring report requ irements if the flare is subject to flare minimization plan requirements and can produce a reportable flaring event. Many Valley operators of flares are proactive in reducing flaring emissions by including Specific Limiting Conditions (SLCs) to their permits that limit the amount of flaring possible by their flare; consequently many of the 95 flares subject to FMP requirements are not r equired to submit annual monitoring reports. Annual monitoring reports are submitted from a variety of industries including, but not limited to, oil and g as production, wastewater treatment, and wine and cheese making. The annual monitoring reports add an important layer of enforceability to Rule 4311 b y providing inspectors with verifiable data to ensure that larger sources of fl aring are compliant.

2 U.S. EPA Office of Air Quality Planning and Standa rds, “Parameters for Properly Designed and Operated Flares”. 2012. Retrieved from http://www.epa.gov/ttn/atw/flare/2012flaretechrepor t.pdf

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4 Background | SJVUAPCD 5. Reportable Flaring Events are Non-repeating A flaring event is considered a "Reportable Flaring Event” if, during a 24-hour period, more than 500,000 standard cubic feet (scf) of vent gas is flared or sulfur oxide emissions are greater than 500 pounds. Of the 235 flares in the Valley, 21 experienced reportable flaring events in the 2011-2012 reporting period. Most of these reportable flaring events we re planned flaring events and were due to new equipment installations—some of which were new air pollution control devices—and repair or maintenance at the facilities. Since most of the events were due to equipment installati on or repair, they are not likely to occur again in the near future. Of the g as flared, only 20% was salable quality.

6. Flared Gas Occurs Under Abnormal Conditions To provide a more in-depth look at different flarin g scenarios in the Valley the District performed case studies of flaring events a t a light-oil production facility and a wastewater treatment plant (WWTP). Both faci lities experienced abnormally high flaring activities over periods of several months.

The by-product of light-oil production, generally r eferred to as off-gas, is a high quality gas; therefore, these facilities norma lly sell as much of the off-gas as possible. However, in this aberrant instance, t he light-oil production facility discussed in the case study was unable to sell the gas during the 2012-2013 reporting period because the sales transmission pip eline was offline for repairs. The facility had no other feasible option s to flaring.

Wastewater treatment plants produce waste gas that has a far lower heating value than the off-gas from oil production faciliti es and requires more extensive treatment prior to use; it is therefore n ot considered to be salable. In the WWTP case study, the flare gas produced by t he facility is normally sent as a supplemental fuel to onsite equipment use d to produce electricity and generate heat for some of the treatment process es. However, during the 2011-2012 reporting period, the waste gases could n ot be sent to the equipment because additional air pollution control devices were being

installed.

As seen from the case studies, gas is typically fla red only under abnormal conditions. Most facilities actively avoid flaring because these control devices only operate during process upsets and emergency si tuations.DRAFT Further Study – Rule 4311 Flare Minimization Plan

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5 What is Flaring? | SJVUAPCD 7. Rule 4311 Requirements are more stringent than F ederal NSPS Requirements The 2012 promulgated NSPS requirements in 40 CFR 60 subparts Ja and OOOO do not implement requirements that are more st ringent than those already implemented in District Rule 4311. Therefo re, Rule 4311 satisfies the requirements of these NSPS requirements.

In the 2014 Study

, the District concluded that operators of flares i n the Valley were subject to the most stringent emission requirements and wer e proactively implementing alternatives and committing to activities that redu ce flaring. Based on that conclusion, the District recommended no rulemaking action for Rule 4311 at that time.

On April 16, 2015, the District’s Governing Board a dopted the 2015 Plan for the 1997

PM2.5 Standard

( 2015 PM2.5 Plan ) 3 . As demonstrated in the District’s 2015 PM2.5 Plan

, Rule 4311 already meets the Environmental Protectio n Agency’s (EPA) Best Available Control Measures (BACM) and Most Stringent Measure (MSM) requirements. In fact, EPA approved Rule 4311 as satisfying all applicable federal requirements on November 3,

2011. 4 However, due to the need to demonstrate attainmen t for multiple federal ozone and PM2.5 standards in the coming years and the nee d to search for all available emissions reductions, the District committed to und ertaking a comprehensive review of FMPs submitted under Rule 4311, publish a draft rep ort for public review and commenting by December 1, 2015, and finalize the report by Mar ch 31, 2016 after receiving input from flare operators and addressing public comments. Th is further study includes the following

elements:

1. Review submitted FMPs to identify the most effec tive flare minimization practices utilized by operators to reduce flaring i n various source categories and applications. Upon completion of review, work clos ely with affected operators to evaluate and implement, when feasible, the most eff ective flare minimization practices through the FMP submittal and approval pr ocess under Rule 4311.

2. Evaluate the technological achievability and eco nomic feasibility of implementing new/additional minimization practices or technologies at affected

facilities.

3 SJVAPCD. (2015). 2015 Plan for the 1997 PM2.5 Standard

. Retrieved from http://www.valleyair.org/Air_Quality_Plans/PM25Plan s2015.htm

4 EPA. 76 Federal Register 213, 68106-68107. 11/3/20 11. http://www.gpo.gov/fdsys/pkg/FR-2011-11- 03/pdf/2011-28391.pdfDRAFT Further Study – Rule 4311 Flare Minimization Plan

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6 What is Flaring? | SJVUAPCD III. WHAT IS FLARING?

Flares serve two basic functions: 1) as an emission control device for VOC emissions, and/or 2) as a safety device during unforeseeable a nd unpreventable emergency situations. Any unreasonable restrictions on flari ng could potentially result in catastrophic consequences which may lead to explosi ons resulting in loss of property, injury and potentially loss of human life.

Flaring is a high temperature oxidation process use d to burn mostly hydrocarbons of waste gases from industrial operations, with a dest ruction efficiency of 98 percent or greater. During combustion, gaseous hydrocarbons r eact with atmospheric oxygen to form carbon dioxide (CO2) and water. Flares used f or emergency situations generally have large flaring capacities to enable them to han dle large volumes of gas. Emergency situations, as defined in District Rule 4 311, include any situation or condition arising from a sudden and reasonably unfo reseeable and unpreventable event beyond the control of the operator and requiring im mediate corrective action to restore safe operation at the facility or site. Examples o f emergency events include, but are not limited to, equipment failure, natural disasters, e xternal power curtailment, and acts of terrorism. Operators consider feasible alternative s to flaring because it is generally costly, and therefore avoided when possible.

General Equipment Description A.

There are two general types of flares: elevated and ground flares. Flares are further categorized by the height of the flare tip, and by the method of enhancing combustion by mixing at the flare tip (i.e., steam-assisted, a ir-assisted, pressure-assisted, or nonassisted).

Elevated flares are more common in the Valley and h ave larger capacities than ground flares. In an elevated flare, a waste gas stream i s fed through a stack and is combusted near the tip of the stack. An elevated flare consi sts of five components: a gas collection header (to collect gases from various process units ); a proprietary seal; a water seal, or purge gas supply (to prevent flash back); a single or multiple-burner unit in the flare stack; and gas pilots and an igniter. Figure 1, be low, depicts a typical configuration for

a steam-assisted elevated flare.

Ground flares, which are not typically found in the Valley, vary in complexity and can

consist of either conventional flare burners discha rging horizontally with no enclosures or multiple burners in refractory-lined steel enclo sures.DRAFT Further Study – Rule 4311 Flare Minimization Plan

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7 What is Flaring? | SJVUAPCD Figure 1. Flare Diagram 5

General Process Description B.

Complete combustion requires proper mixing of air a nd gas. Smoking may result from incomplete combustion, depending upon the flare gas components and the quantity and distribution of combustion air. Gases containing m ethane, hydrogen, CO, and ammonia usually burn without smoke, while gases containing heavy hydrocarbons may cause

smoke.

The tendency of a fuel to smoke or make soot is inf luenced by fuel characteristics and by the amount and distribution of oxygen in the com bustion zone. Fuel characteristics include the carbon-to-hydrogen ratio and the molecu lar structure of the gases to be burned. Soot is eliminated by adding steam or air; hence, most industrial flares are steam-assisted and some are air-assisted. Flare ga s composition is a critical factor in determining the amount of steam necessary.

Air is supplied to the flame as primary and seconda ry air. Primary air is mixed with the gas before combustion. If the amount of primary ai r is insufficient, the gases entering

5 EPA. (1995). 13.5 Industrial Flares. Retrieved from http://www.epa.gov/ttnchie1/ap42/ch13/final/c13s05. pdfDRAFT Further Study – Rule 4311 Flare Minimization Plan

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8 Flaring in the San Joaquin Valley | SJVUAPCD the base of the flare are preheated by the combusti on zone, and larger hydrocarbon molecules crack to form hydrogen, unsaturated hydro carbons, and carbon. The carbon particles may escape further combustion and cool do wn to form soot or smoke.

An external momentum force, such as steam injection , is used for turbulence and efficient mixing of air and waste gas, which promot es smokeless flaring of heavy hydrocarbon waste. Other external forces may also be used, including water spray, high velocity vortex action, or natural gas. Exter nal momentum force is rarely required in ground flares.

Combustion efficiency depends on flame temperature, residence time in the combustion zone, vent gas flammability, auto ignition temperat ure, heating value measured in British thermal units per standard cubic feet (Btu/ scf), and turbulent mixing. Through combinations of these factors, flares have a destru ction efficiency of 98 percent or greater. Complete combustion converts all volatile organic compounds (VOCs) to CO 2 and water.

Flare gases must have a fuel value of at least 200 to 250 Btu/ft 3 for complete combustion; otherwise another fuel must be added to achieve the required value. Flares for which supplemental fuel must be supplied are known as “fired” or “endothermic” flares. In some cases, even flaring gases with the necessary heat content will require supplemental heat to ensure co mplete combustion.

Flares are normally used to dispose of low volume c ontinuous streams of gases but are designed to handle large quantities of gases associ ated with potential plant emergencies. As safety devices, it is necessary fo r flares to have high volume capacities so that they may prevent injury and loss of property during unforeseeable and unpreventable emergency situations. Emergency flaring occurs when necessary, to prevent an accident, hazard, or release of vent gas directly into the atmosphere. Emergency events may occur because of process malfu nctions, relief valve leakage, power outages, and equipment breakdown. Consequent ly, flare gas volumes can vary from a few cubic feet per hour during regular opera tions up to several thousand cubic feet per hour under emergency conditions.

IV. FLARING IN THE SAN JOAQUIN VALLEY

The information in this section is based on data an alysis from the District’s Rule 4311 (Flares) Further Study report published on September 16, 2014. 6

6 SJVAPCD. (2014) Rule 4311 (Flares) Further Study 2014 . Retrieved from http://www.valleyair.org/Air_Quality_Plans/docs/R43 11.pdf

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9 Flaring in the San Joaquin Valley | SJVUAPCD There are 235 flares in the Valley subject to Rule 4311 requirements. Of those 235 flares, 126 are exempt (except for recordkeeping re quirements) from District Rule 4311 because they are subject to the requirements of Dis trict Rule 4642 (Solid Waste Disposal Sites), subject to the requirements of 40 CFR 60 Subpart WWW (Standards of Performance for Municipal Waste Landfills), subject to the requirements of 40 CFR 60 Subpart Cc (Emission Guidelines and Compliance Time s for Municipal Solid Waste Landfills), or are operated at stationary sources w ith the potential to emit for all processes of less than 10 tons per year of VOC and less than 10 tons per year of NOx. However, all new or modified flares are subject to New Source Review (NSR) requirements including Best Available Control Techn ology (BACT), meaning they may be required to implement even more stringent contro ls regardless of whether or not they are subject to the requirements of Rule 4311.

Of the 109 flares in the Valley subject to Rule 431 1 requirements, 95 are subject to FMP requirements. The remaining 14 flares are not requ ired to submit FMPs to the District because they have a flaring capacity less than 5.0 MMBtu/hr and are operated at facilities other than petroleum refineries.

Flares subject to Rule 4311 requirements in the Val ley are utilized by a diverse group of industries as illustrated by Table 1 below.

Table 1. Facility Types for Flares that Submitted FMPs

Facility Type # of Flares

Oil and Gas Production 68

Petroleum Refining 7

Natural Gas Processing 6

Natural Gas Transmission 2

Wastewater Treatment (Wastewater Treatment Plants, Cheese Production, Wineries, Dairy, Beef Packer) 10

Miscellaneous (Correctional Facility, Flat Glass Ma nufacturer) 2

Total 95

The majority of the Valley flares are standby or em ergency flares. Standby flares are only utilized intermittently to dispose of gas duri ng maintenance or periods when gas is in excess of steady state gas collection system cap acity, and are not used as a method of primary disposal for collected gases. Emergency flares are only used during emergency events, which include any situation or co ndition arising from a sudden and reasonably unforeseeable and unpreventable event be yond the control of the operator and requiring immediate corrective action to restor e safe operation at the facility or site.DRAFT Further Study – Rule 4311 Flare Minimization Plan

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10 Flare Minimization Plans | SJVUAPCD Of the 95 facilities subject to FMP requirements, 9 2 are permitted for standby or emergency use, while only 3 are permitted as primar y disposal devices.

Due to their limited use, flares are currently a sm all contributor to overall Valley emissions. The emissions from all 235 flares opera ting in the Valley contributed 0.14%

of the total annual NOx and 0.17% of total annual P M2.5 emitted from all stationary, area, and mobile sources in 2012.

V. FLARE MINIMIZATION PLANS

Rule 4311 Flare Minimization Plan (FMP) Requiremen ts A.

Sections 5.8 and 6.5 of District Rule 4311 require an FMP be submitted to and approved by the District for any petroleum refinery with a flare or any flare with a flaring capacity greater than or equal to 5.0 MMBtu/hr. Th e rule prohibits facilities subject to FMP requirements from flaring unless it is consiste nt with a District-approved FMP and

all commitments in that FMP have been met. To ensu re FMPs are up-to-date without undue redundancy in paperwork requirements from sta keholders, FMPs are to be updated every five years. Updates to the FMP are a lso required to address any new or modified equipment that requires an Authority to Co nstruct permit and impacts

emissions from the flare.

Pursuant to Section 6.5.1, FMPs submitted to the Di strict are required to include at least the following information:

• Description and technical specifications for each flare and associated knock-out pots, surge drums, water seals and flare gas recove ry systems

• Process flow diagrams of upstream equipment and pr ocess units venting to each flare, identifying the type and location of all con trol equipment

• Description of equipment, processes, or procedures the operator plans to install or implement to eliminate or minimize flaring, and planned date of installation or implementation

• Evaluation of prevention measures to reduce flarin g that has occurred or may be expected to occur during planned major maintenance activities, including startup

and shutdown

• Evaluation of preventative measures to reduce flar ing that may be expected to occur due to issues of gas quantity and quality. T his includes an audit of vent gas recovery capacity of each flare system, storage capacity for excess vent gas,DRAFT Further Study – Rule 4311 Flare Minimization Plan

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11 Flare Minimization Plans | SJVUAPCD and scrubbing capacity available for vent gas for u se as a fuel as well as determination of the feasibility of reducing flarin g through the recovery, treatment and use of the gas.

• Evaluation of preventative measures to reduce flar ing caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. This includes determination of adequacy of existing maintenance schedules and protocols for su ch equipment. A failure is

considered recurrent if it occurs more than twice d uring any five year period as a

result of the same cause.

Flare Minimization Practices B.

District staff with extensive expertise in flare op erations conducted a detailed review of all approved FMPs to identify the variety of flare minimization practices used by affected facilities. In addition, District staff also worke d closely with affected facilities to gain more in-depth understanding of the minimization pra ctices.

In reviewing the FMPs, the District found a variety of flare minimization practices specific to each facility that could potentially be employed at other facilities to further reduce flaring at their operations. These practice s may not only serve to reduce flaring activities and associated emissions but may also pr ovide economic, safety, and other

benefits to affected facilities. Because of the un ique nature of each facility, the technological achievability and economic feasibilit y of transferring these minimization practices or technologies from one facility to anot her will require further analysis. A description of effective flare minimization pract ices identified in approved FMPs is presented below:

Alternatives to Flaring

One way to prevent flaring is to capture the gas an d utilize it for some beneficial purpose as flaring can be a waste of a precious res ource. The following alternative uses for flare gas were identified in submitted FMP s to minimize flaring.

• Use gas as a fuel for equipment rather than flaring

. Capturing gas and routing it into a fuel gas system to power various processes i s a great means of utilizing gas

that would otherwise be flared. There is a financi al incentive to utilize this practice to the greatest extent feasible across all facility ty pes as the gas can be used to supplement, or in some cases even completely supply , the process energy needed, (i.e. IC engines) to produce electricity, and boile rs for steam generation and process heating.DRAFT Further Study – Rule 4311 Flare Minimization Plan

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12 Flare Minimization Plans | SJVUAPCD There are several barriers with implementing this p ractice. Some facilities do not have a use for combustion equipment on-site. For t hose that do have a use for the combustion equipment, it may not be economically fe asible to purchase, install and operate such equipment, the multiple stages of trea tment equipment to make the gas suitable for use at the facility, and the infra structure required to connect process streams and utilities to the fuel gas system. Addi tionally, the installation of extra equipment to handle the waste gas can potentially a dd more complexity to the maintenance and testing, and can increase the numbe r of potential points of failure.

• Injection of oil field gas into DOGGR-approved disp osal wells

. Reinjection of gas into subsurface geologic formations disposal we lls is a potential alternative to flaring. These wells are regulated by the Californ ia Department of Conservation, Division of Oil, Gas and Geothermal Resources (DOGG R). However, the permits for these wells can be extremely difficult to obtain fr om the state, and require significant capital investment to complete the various studies and installation of infrastructure in California. Additionally, the permits place a limi t on volume reinjected that if exceeded requires the facility to dispose of gas by other means.

• Send oilfield gas to a sales gas line . Gas that is of high enough quality (i.e. high energy content, low sulfur or nitrogen content) can be sold through a sales gas line. There can be many barriers associated with this alt ernative including proximity to an existing gas line, quantity and quality of gas gene rated, and the economics of purchasing, installing, and maintaining a new sales gas line and all the associated treatment and transmission equipment and infrastruc ture.

Maintenance and Testing

A proactive and preventative maintenance and testin g program can greatly reduce flaring by minimizing downtime from equipment failu re. Furthermore, testing helps predict potential equipment failure and provides an opportunity to coordinate repair/replacement in a way that reduces flaring. If failures occur unexpectedly, the equipment may need to be taken offline immediately, requiring gas to be routed to flares to prevent an unsafe situation. The following main tenance and testing practices were identified in submitted FMPs to minimize flaring.

• Implement a preventative maintenance program to pre dict failure in pipelines and stationary equipment (measure corrosion). The gas going through pipelines and stationary equipment can be very corrosive. A predictive method such as using x-rays to measure pipe thickness is used to determi ne when to replace the equipment. This testing is performed on a periodic basis as dictated by the equipment type and the service it is in.DRAFT Further Study – Rule 4311 Flare Minimization Plan

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13 Flare Minimization Plans | SJVUAPCD • Install high-pressure alarms on process vessels . Installation of alarms on process vessels can indicate a high pressure build- up (before pressure relief valves opens and directs gasses to flares) so that operato rs can intervene before flaring

occurs.

• Inspect pressure relief valves routinely to ensure proper operation . If a pressure relief valve improperly seats or is otherw ise defective, gases will leak and be combusted in the flare. In an attempt to reduce such occurrences, the pressure relief valves can be inspected periodically.

• Maintain and calibrate flare gas control valves on a routine schedule . Flare gas lines are typically equipped with control valve s to regulate the volume of gas going to flares. Should these valves malfunction, it is possible that excessive gas

would be directed to the flare. These valves could be calibrated on a routine

schedule.

• Retain spare parts onsite to minimize system downti me . Quick and easy access to spare parts reduces equipment downtime and assoc iated flaring. While the economic feasibility of purchasing and maintaining backup equipment will need to be considered on a case-by-case basis for each facilit y, some facilities maintained the following types of equipment onsite to minimize fla ring:

o Compressors . Compressors are ubiquitous in the gas and petrol eum industry and play a critical role in many different stages of oil and gas production, processing/refining, and transmission.

o Sulfur scrubber components/media . If the sulfur scrubber system is down, the fuel cannot be processed for onsite use and mus t be flared instead.

o Spare parts for primary combustion equipment (blowe rs, etc.) . If the primary combustion equipment is down, the fuel cann ot be utilized onsite and

must be flared instead.

Procedures to Reduce Flaring during Maintenance and Shutdowns

Another effective flare minimization measure is to optimize and coordinate maintenance activities so that equipment failure and downtime i s minimized to the extent feasible. A proactive and preventative maintenance program can greatly reduce downtime and thereby minimize flaring. However, during maintena nce and shutdown events, operators can take additional measures to avoid or reduce flaring. The following procedures were identified in submitted FMPs.DRAFT Further Study – Rule 4311 Flare Minimization Plan

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14 Flare Minimization Plans | SJVUAPCD • Perform maintenance on one area without impacting o ther operations on site. Designing a facility in a manner that allows mainte nance to be performed in one area of a facility without affecting other operatio ns can reduce flaring. This allows the other operations to continue normally without t he need to flare excess gas.

• Curtail oil/gas production during planned shutdown of sales line . In the event of a planned shutdown of a sales gas pipeline, and/ or major maintenance activities, oil/gas production can be curtailed. This could po tentially result in lost revenue.

• Close oil well casing vents during vapor control sy stem maintenance . Casing gas remains in reservoir instead of being flared, b ut this can potentially result in reduced oil production rate until vents are opened.

• Store gas in bladder tank. For waste water treatment plants, limited amounts of digester gas can be stored in bladder tanks during maintenance, testing, or process upsets and later be routed to combustion devices fo r beneficial use on-site.

• Plan maintenance activities during optimal periods. Scheduling maintenance during periods of minimum capacity needs and/or fol lowing planned process unit shutdowns has the potential of minimizing flaring a ctivities.

• Optimize planned shutdowns for major maintenance. Most inspection, repair, and minor maintenance work can be performed while a facility is in operation. However, there are times when a facility has to shu t down and flare process gas to conduct major maintenance work. The management of a facility shutdown is known as a “turnaround”. Scheduled facility shutdowns ar e expensive and labor intensive due to the loss of production and the expense of th e turnaround itself. While turnaround procedures are primarily focused on mini mizing downtime, the following specific procedures were identified in submitted FM Ps to minimize flaring during plant turnaround.

o Have extra personnel on site to re-start the plant as quickly as possible

o Recycle discharge gas back to compressor inlets un til minimum operating pressure is obtained

o Prior to turnaround, identify critical equipment t o be serviced to avoid refinery downtime and associated flaring

o Phase equipment and process unit shutdowns to mini mize fuel gas imbalances that may result in additional flaring

o Identify alternate disposition of process gases to minimize flaring;

o Identify key process unit operations such as fuel gas systems and sulfur recovery operations that must remain in operation t o minimize flaring of sulfur-containing gases

o Phase equipment and process unit start-ups to mini mize start-up duration and the flaring associated with these transitional oper ationsDRAFT Further Study – Rule 4311 Flare Minimization Plan

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15 Flare Minimization Plans | SJVUAPCD Redundant Systems

Even with the most rigorous and proactive maintenan ce programs in place, there is always the potential for critical equipment failure . Installing redundant systems minimizes the potential of downtime by allowing ope rators to quickly switch from one system to another in the event of equipment failure or during maintenance. The following redundant systems were identified in FMPs to minimize flaring.

• Redundant compressors. Compressors can fail, and as a result the gas may

need to be flared. Installation of a redundant sec ondary compressor can minimize flaring when the primary compressor is down.

• Redundant gas treatment systems (sulfur scrubber). This allows gas to continue to be treated and burned in combustion equipment wh en one unit is not available.

• Redundant digester gas-fired turbines. Some wastewater treatment plants have incorporated redundant digester-gas-fired turbines into their system design. The redundant system allows the turbines to be maintain ed without the need to flare. This has potential to reduce a considerable amount of flaring, as the turbines for these types of operations typically require frequen t maintenance. In addition, a redundant system reduces downtime and extends the l ife of the turbines.

Procedures to Prevent or Mitigate the Effects of Po wer Outages to Reduce Flaring

A power outage has the potential to result in flari ng as vapors are sent to flares to protect the facility from being over-pressurized. The following specific procedures were identified in submitted FMPs to mitigate the effect s of power outages and reduce flaring.

• Backup generators. Install emergency IC engine/generators to power equ ipment during power outages.

• Power outage alarm. Send alarms to all operators when power outage occu rs to ensure rapid response.

• Infrared testing. Implement infrared testing of electrical equipment on a routine basis to identify hot-spots that could result in a power outage.

• Avian guards. Install avian guarding in substations to deter bi rds from contacting energized equipment.DRAFT Further Study – Rule 4311 Flare Minimization Plan

December 3, 2015

16 Flare Control Technology Evaluation | SJVUAPCD VI. FLARE CONTROL TECHNOLOGY EVALUATION

As a component of this further study, the District evaluated the feasibility of new ultra low NOx flare emission control technologies. While the modernization of flare technology will not reduce the frequency or volume of flaring activities, it can reduce the emissions from such activities, thereby accomplishi ng the same end goal.

The District has identified a new class of VOC dest ruction devices that are similar to enclosed flares but operate with mixing controls an d are being put into practice in the petroleum industry as control devices. These devic es offer ultra low NOx emissions of approximately 0.02 lb NOx/MMBtu (compared to existi ng District Rule 4311 requirement of 0.068 lb NOx/MMBtu). These devices may not cons idered flares by the Rule 4311 definition, but are an alternative method for VOC c ontrol. One Permit to Operate and at least eight Authority to Construct permits have bee n issued to facilities in the Valley for

these new devices.

These new devices may not be a viable replacement f or some emergency flares, particularly those with high intermittent gas volum e capacity requirements. These devices appear suitable for use at sites with more predictable gas disposal needs. To further evaluate opportunities for emission reducti ons from flaring, the District will perform an exhaustive evaluation of NOx emission re duction control technologies in its upcoming 2016 ozone and PM2.5 attainment plans and propose potential rule amendments requiring the use of these technologies where technologically achievable and economically feasible.

VII. FURTHER STUDY FINDINGS AND RECOMMENDATIONS

As a result of this comprehensive study the Distric t offers the following findings and

recommendations:

1. The District identified minimization practices c urrently performed at facilities that have the potential to be applied to other facilities.

a. The District recommends conducting a thorough evalu ation of the most effective flare minimization practices include d in approved FMPs and requiring the implementation of these prac tices where technologically achievable and economically feasibl e . Even though operators of flares in the Valley have already take n extensive measures to reduce flaring, through this study the District has identified effective minimization practices currently performed at some facilities that could be employed at other facilities to further reduce flar ing. To further evaluate opportunities for emission reductions from flaring, the District will perform

an exhaustive evaluation of these flare minimizatio n practices in itsDRAFT Further Study – Rule 4311 Flare Minimization Plan

December 3, 2015

17 Further Study Findings and Recommendations | SJVUAP CD

upcoming 2016 ozone and PM2.5 attainment plans and propose potential rule amendments requiring the use of these practice s where technologically achievable and economically feasibl e.

b. The District recommends exploring options to furthe r promote the implementation of the most effective flare minimiza tion practices during the FMP submittal and review process. Under Rule 4311, FMPs are required to be submitted and approved for existing, new, and modified flaring systems. For existing systems, an updated FMP is required to be submitted and approved every five ye ars. Working with operators to identify potential flare minimization practices during the FMP review process provides operators the opportunity t o incorporate feasible flare minimization practices when new and modified systems are proposed and during the ongoing review of FMPs.

2. Ultra low NOx technologies with the potential to further reduce emissions from flaring have recently become available. The D istrict recommends conducting a thorough evaluation of new ultra low N Ox control technologies for flaring and requiring the implemen tation of these technologies where technologically achievable and e conomically feasible. Through this further study, the District has identi fied new low NOx control technologies that may serve as suitable options for further reducing NOx emissions from flaring in the San Joaquin Valley. To further evaluate opportunities for emission reductions from flaring, the District will perform an

exhaustive evaluation of NOx emission reduction con trol technologies in its upcoming 2016 ozone and PM2.5 attainment plans and propose potential rule amendments requiring the use of these technologies where technologically achievable and economically feasible.DRAFT Further Study – Rule 4311 Flare Minimization Plan

December 3, 2015

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