i Project Team

Jesse Madsen, Air Quality Specialist I Erin Scott, Air Quality Inspector I Steven Davidson, Air Quality Engineer II Anna Myers, Senior Air Quality Specialist Renee Chavez, Senior Air Quality Inspector Steve Leonard, Senior Air Quality Engineer Jessica Fierro, Program Manager Errol Villegas, Program Manager Mike Oldershaw, Compliance Manager Leonard Scandura, Permit Services Manager 

# Rule 4311 (Flares) Further Study

2014Rule 4311 (Flares) Further Study

September 16, 2014

i Table of Contents | SJVUAPCD 

### Table of Contents

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

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

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

................................................... ................................................... .......... 4

III. What is flaring? .............................

................................................... ................................................... .......... 5

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

................................................... .................................. 5 A.

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

................................................... ....................................... 6 B.

IV. Valley Flares .................................

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

V. Methodology ....................................

................................................... ................................................... ........ 9

VI. Flare Minimization Plans ......................

................................................... .............................................. 13

Rule 4311 Flare Minimization Plan (FMP) Requiremen ts ................................................ .....13 A.

Summary of Facilities Required to Submit FMPs ....

................................................... ................14 B.

What was learned from collected FMPs .............

................................................... ........................17 C.

VII. Annual Monitoring Reports ....................

................................................... ........................................... 18

Rule 4311 Annual Monitoring Report Requirements ..

................................................... .........18 A.

Submitted 2012 Annual Monitoring Reports .........

................................................... ..................19 B.

What was learned from submitted Annual Monitoring Reports .........................................20 C.

VIII. Reportable Flaring Event ....................

................................................... ................................................ 21

Rule 4311 Reportable Flaring Event Requirements ..

................................................... ............21 A.

What is a Reportable Flaring Event?................

................................................... ............................... 21

What data are required to be reported to the Distri ct in the Reportable Flaring Event report? ...........................................

................................................... ................................................... .......... 21

Reportable Flaring Events ........................

................................................... .......................................22 B.

Case Studies .....................................

................................................... ................................................... ...22 C.

What was learned from collected Reportable Flaring Event reports ................................27 D.

IX. Regulatory Evaluation .........................

................................................... ................................................. 2 8

Federal Requirements .............................

................................................... ..........................................28 A.

40 CFR 60 Subpart J ...............................

................................................... ................................................ 29

40 CFR 60 Subpart Ja ..............................

................................................... .............................................. 30

40 CFR 60 Subpart OOOO ............................

................................................... ........................................ 30

State Requirements ...............................

................................................... .............................................31 B.

Local Requirements at Other Air Districts ........

................................................... .........................31 C.Rule 4311 (Flares) Further Study

September 16, 2014

ii Table of Contents | SJVUAPCD SCAQMD Rule 1118 (Emissions from Refinery Flares) .

................................................... .......... 31

BAAQMD Regulation 12 Rule 11 (Flare Monitoring at P etroleum Refineries) and Regulation 12 Rule 12 (Flares at Petroleum Refineri es) ............................................... ............ 32

VCAPCD Rule 54 (Sulfur Compounds) .................

................................................... .......................... 33

SBCAPCD Rule 359 (Flares and Thermal Oxidizers) ...

................................................... ............. 33

X. Valley Flaring Compared to Other Air Districts .

................................................... ........................ 34

Operations and Capacities ........................

................................................... .......................................34 A.

Comparison of Emission Inventories ...............

................................................... ............................36 B.

XI. Conclusion ....................................

................................................... ................................................... .......... 37

Attachment: Rule Requirement ComparisonsRule 4311 (Flares) Further Study

September 16, 2014

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). This further study r eport, analyzing District Rule 4311 (Flares), is a continuation of the San Joaquin Vall ey Unified Air Pollution Control District’s (District) mission to improve the Valley’s air qual ity through proactive efforts to identify and enforce feasible emission reduction opportunities.

Flares are employed to serve two basic functions: a s an emission control device for VOC emissions, and/or as a safety device used in emerge ncy situations, which include any situation or condition arising from a sudden and re asonably unforeseeable and unpreventable event beyond the control of the opera tor and requiring immediate corrective action to restore safe operation at the facility or site.

District Rule 4311 was adopted in June 2002 to redu ce emissions from flaring activities. Subsequent amendments to Rule 4311 have made it one of the most stringent rules in the nation for flaring activities. The most recent ame ndments, in June 2009, incorporated new requirements for operators to submit annual reports of reportable flaring events and annual gas flow from each flare subject to rule requiremen ts, submit flare minimization plans (FMP) to the District, obtain approval of those FMPs, and operate under the conditions specified in the approved FMPs. The purpose of this report is to summarize results of a District analysis of FMPs and annual reports submitted to the Distric t as a result of the 2009 rule amendments

and to make a recommendation for future rule action s, if any, as a result of the study.

Through this further study action, the District rev iewed data from FMPs, annual monitoring reports, and reportable flaring events submitted to the District in July 2012 accounting for the fiscal year of 2011/2012, and reviewed New Source P erformance Standards (NSPS) promulgated by EPA in 2012. In addition to the fla re information review committed to in the plans, the District also reviewed the flare emi ssion inventory in the Valley and analogous rules in other air districts in Californi a. As a result of this extensive effort, the District made the following findings.Rule 4311 (Flares) Further Study

September 16, 2014

2 Executive Summary | SJVUAPCD 1. Flare Emissions Contribute a Small Percentage to th e Overall NOx Emissions Inventory A review of the flare emission inventory indicates that emissions from all flares operating in the Valley, regardless of permit statu s and requirements,
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 1

.

2. Rule 4311 is as Stringent as Other Air Districts’ R ules District analysis also confirmed that Rule 4311 is as stringent as similar rules in South Coast Air Quality Management District (SCAQMD ), Bay Area Air Quality Management District (BAAQMD), Ventura County Air Po llution Control District (VCAPCD), and Santa Barbara County Air Pollution Co ntrol District (SBCAPCD). Those analogous rules have some minor differences i n requirements, due to the differences in types of facilities and sizes of fla res, which would not result in additional emission reductions if implemented in th e Valley. Furthermore, Rule 4311 has been confirmed by EPA in its most recent a pproval of amendments to the rule as satisfying Reasonable Available Control Technology (RACT) requirements.

3. Flare Minimization Plans Contain Feasible Measures 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 requir ements of Rule 4311. These flares are operated in multiple industries, includi ng the oil and gas industry, wastewater treatment, and wine and cheese productio n. Operators with FMPs are including feasible measures in the FMPs and act ively taking steps to reduce flaring at their facilities.

4. Annual Monitoring Reports Assist with Enforceabilit y 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 required to submit annual monitoring reports. For the 2011-2012 reporting pe riod, 55 reports were submitted to the District and analyzed for this fur ther study report. These

1 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

.Rule 4311 (Flares) Further Study

September 16, 2014

3 Executive Summary | SJVUAPCD reports were submitted from a variety of industries including, but not limited to, oil and gas production, wastewater treatment, and w ine and cheese making. Operators of each of these flares are taking action s to reduce flaring at their facilities pursuant to their District approved FMPs . The annual monitoring reports add an important layer of enforceability to Rule 4311 by providing inspectors with verifiable data to ensure that larg er sources of flaring are compliant.

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 th e 235 flares in the Valley, 21 experienced reportable flaring events in the 2011-2 012 reporting period. Most of these reportable flaring events were planned fla ring 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 installation or repair, they are not likely to occur again in the near future. Of the gas 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 normally s ell as much of the off-gas as possible. However, in this aberrant instance, the 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 options to flari ng (see discussion later in report).

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 not conside red to be salable. In the WWTP case study, the flare gas produced by the facility is normally sent as a supplemental fuel to onsite equipment used to produ ce electricity and generate heat for some of the treatment processes. However, during the 2011-2012 reporting period, the waste gases could not be sent to the equipment because additional air pollution control devices were being installed.Rule 4311 (Flares) Further Study

September 16, 2014

4 Background | SJVUAPCD 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.

7. Rule 4311 Requirements are more stringent than the new 2012 Federal NSPS Requirements The 2012 promulgated NSPS requirements in 40 CFR 60 subparts Ja and OOOO do not implement requirements that are more stringe nt than those already implemented in District Rule 4311. Therefore, Rule 4311 satisfies the requirements of these NSPS requirements.

This thorough and comprehensive further study evalu ation has resulted in the District’s conclusion that operators of flares in the Valley a re subject to the most stringent emission requirements and are proactively taking measures ne cessary to minimize emissions from flaring in the Valley by implementing feasible alte rnatives to flaring and committing to perform activities to reduce flaring.

In light of these findings, the District recommends no rulemaking action for Rule 4311 at

this time.

II. BACKGROUND

The development of the District’s 2012 PM2.5 Plan involved extensive research and analyses of technologies for potential opportunities to furt her reduce emissions of particulate matter (PM) and oxides of nitrogen (NOx), which is a predo minant pollutant in the formation of fine particulate matter (particulate matter that is 2.5 microns or less in diameter, or PM2.5) and ozone. Although the results of the analyses for t his plan did not indicate that regulatory action to further reduce flaring emissions would ac celerate PM2.5 attainment, the District committed to continue evaluating flares through thi s further study measure. The 2009 rule amendments to Rule 4311, subjected facilities to ne w reporting requirements that require the submittal of annual flaring reports to the District every July beginning in 2012. While this did not provide adequate time for analysis and incorpor ation into the 2012 PM2.5 Plan , the District committed to perform a further study of th ese reports. Additionally, in 2012, EPA promulgated amendments to an existing New Source Pe rformance Standard (NSPS) and promulgated a new NSPS. The District’s 2013 Plan for the Revoked 1-Hour Ozone Standard also committed to further analyze these opportuniti es as a part of this Further Study effort. Specifically, the two state implementation plans commit the District to evaluate submitted Flare Minimization Plans, Annual Monitori ng Report data, Reportable Flaring Event data, and new NSPS requirements to identify and eva luate potential opportunities to further

reduce emissions from these sources. This further study analysis satisfies requirements in

both the 2012 PM2.5 Plan and the 2013 Plan for the Revoked 1-Hour Ozone Standard by presenting results of the aforementioned review and evaluations.Rule 4311 (Flares) Further Study

September 16, 2014

5 What is flaring? | SJVUAPCD III. WHAT IS FLARING?

Flares serve two basic functions: as an emission co ntrol device for VOC emissions, and as a safety device during unforeseeable and unpreventabl e emergency situations. Any unreasonable restrictions on flaring could potentia lly result in catastrophic consequences which may lead to explosions resulting in loss of p roperty, 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 destructio n efficiency of 98 percent or greater. During combustion, gaseous hydrocarbons react with atmospheric oxygen to form carbon dioxide (CO2) and water. Flares used for emergenc y situations generally have large flaring capacities to enable them to handle large volumes o f gas. Emergency situations, as defined in District Rule 4311, include any situation or con dition arising from a sudden and reasonably unforeseeable and unpreventable event be yond the control of the operator and requiring immediate corrective action to restore sa fe operation at the facility or site. Examples of emergency events include, but are not l imited to, equipment failure, natural disasters, external power curtailment, and acts of terrorism. Operators consider feasible alternatives to flaring because it is generally cos tly, 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, air- assisted, pressure-assisted, or non-assisted).

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 consists o f five components: a gas collection header (to collect gases from various process units); a pr oprietary seal; a water seal, or purge gas supply (to prevent flash back); a single or multipl e-burner unit in the flare stack; and gas pilots and an igniter. Figure 1, below, depicts a t ypical 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 enclosur es.Rule 4311 (Flares) Further Study

September 16, 2014

6 What is flaring? | SJVUAPCD Figure 1 Flare Diagram 2

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 combus tion zone. Fuel characteristics include the carbon-to-hydrogen ratio and the molecular stru cture of the gases to be burned. Soot is eliminated by adding steam or air; hence, most indu strial flares are steam-assisted and some are air-assisted. Flare gas 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 air is insufficient, the gases entering the base

2 EPA, “13.5 Industrial Flares”. 1995. http://www.epa.gov/ttnchie1/ap42/ch13/final/c13s05. pdfRule 4311 (Flares) Further Study

September 16, 2014

7 What is flaring? | SJVUAPCD of the flare are preheated by the combustion zone, and larger hydrocarbon molecules crack to form hydrogen, unsaturated hydrocarbons, and car bon. The carbon particles may escape further combustion and cool down to form soo t or smoke.

An external momentum force, such as steam injection , is used for turbulence and efficient mixing of air and waste gas, which promotes smokele ss flaring of heavy hydrocarbon waste. Other external forces may also be used, inc luding water spray, high velocity vortex action, or natural gas. External 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), an d turbulent mixing. Through combinations of these factors, flares have a destru ction efficiency of 98 percent or greater. Complete combustion converts all volatile organic c ompounds (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 fir ed, or endothermic flares. In some cases, even flaring gases with the necessary heat c ontent will require supplemental heat to ensure complete combustion.

Figure 2 A visual example of complete versus incom plete combustion 3

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 for flares to ha ve high volume capacities so that they may prevent injury and loss of property during unforese eable and unpreventable emergency situations. Emergency flaring occurs when necessar y, to prevent an accident, hazard, or release of vent gas directly into the atmosphere. Emergency events may occur because of process malfunctions, relief valve leakage, power o utages, and equipment breakdown.

3 Image retrieved February 2012 from: http://www2.epa.gov/sites/production/files/2013-09/ nei-air-toxicsflare-250.jpgRule 4311 (Flares) Further Study

September 16, 2014

8 Valley Flares | SJVUAPCD Consequently, flare gas volumes can vary from a few cubic feet per hour during regular operations up to several thousand cubic feet per ho ur under emergency conditions.

IV. VALLEY FLARES

The flare source category subject to Rule 4311 requ irements in the Valley is unique from other air districts in California because it incorp orates such a diverse group of industries while other air districts generally limit the appli cability of their analogous rules to petroleum refineries. There are approximately 235 flares in the Valley. Of those 235 flares, 126 are exempt from District Rule 4311 because they are subject to the requirements of District Rule 4642 (Solid Waste Disposal Sites), su bject 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 Guid elines and Compliance Times for Municipal Solid Waste Landfills), or are not operat ed at a major source facility. Stationary sources that emit a total of less than ten tons per year of VOC and NOx emissions from all operations at the facility (including any flares) a re not considered major sources, and are exempt from prohibitory requirements of the rule. However, all new or modified flares are subject to New Source Review (NSR) requirements inc luding Best Available Control Technology (BACT) requirements, meaning they may be required to implement even more stringent controls regardless of whether or not the y are subject to the requirements of Rule

4311.

The 109 flares in the Valley subject to the require ments in Rule 4311 are used by the following industries:

• Gas plants

• Heavy oil production / Thermally enhanced oil recov ery

• Light oil production

• Refinery operations

• Wastewater treatment plants

• Cheese production

• Wine

• Dairy operations

• Flat glass production

• Correctional facility

While much of flaring in the Valley occurs in the S outhern region (Tulare and Kern counties) of the Valley, flaring activity also occu rs in the Northern (San Joaquin, Stanislaus, and Merced counties) and Central (Madera, Fresno, a nd Kings counties) Valley. Of the 109 flares subject to Rule 4311 requirements, 7 operate in the Northern region, 5 in the Central region, and 97 in the Southern region.Rule 4311 (Flares) Further Study

September 16, 2014

9 Methodology | SJVUAPCD The emissions from all 235 flares operating in the Valley contributed 0.14% of the total annual NOx emitted from all stationary and area sou rces in 2012. Flares are a small contributor to overall Valley emissions throughout the year in part because properly operated flares achieve at least 98 percent combust ion efficiency 4 . The emissions represented in the table below represent emissions from all flaring activity in the Valley regardless of exemption status.

Table 1 Annual Average Flare Emission Inventory (t ons per day) 5

Pollutant 2012 2014 2015 2016 2017 2018 2019

PM2.5 0.13 0.13 0.13 0.14 0.14 0.14 0.14

NOx 0.38 0.39 0.39 0.39 0.39 0.39 0.39

SOx 0.25 0.26 0.26 0.26 0.26 0.26 0.27

District staff used reported volumes of gas flared to calculate an estimated emission inventory from Valley flaring and compared the calc ulations to the emission inventory for 2012 in Table 1 above. The data comparison verifie d that the emissions inventory is representative of the actual flaring activity.

V. METHODOLOGY

This report is a culmination of the efforts of an i nterdepartmental team consisting of staff from Rule Development, Compliance, and Permits Serv ices spanning a four-year implementation period since the June 2009 amendment of Rule 4311. Some of the actions performed during this implementation period include :

• Working with facilities that operate flares to dete rmine which units are subject to
Rule 4311;

• Collecting Flare Minimization Plans (FMP), Annual M onitoring Reports (AMR), and Reportable Flaring Event (RFE) reports; and

• Review and determination of compliance with Rule 43 11 requirements for FMPs, AMRs, and RFE reports.

This further study report continues to build on pre vious efforts to examine this source category and identify and evaluate potential opport unities to reduce emissions by analyzing information collected during the previous ly described implementation period.

4 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

. 5 Retrieved from the District’s 2012 PM2.5 Plan ( http://www.valleyair.org/Air_Quality_Plans/PM25Plan s2012.htm )Rule 4311 (Flares) Further Study

September 16, 2014

10 Methodology | SJVUAPCD To begin, District staff analyzed the 235 flare per mits to determine which flares are subject to Rule 4311 requirements and how the facility oper ators are complying with applicable requirements. Based on information gathered, staff compiled all relevant data into the following categories:

• Facility name

• Facility description

• Major source of NOx emissions (true or false)

• Major source of VOC emissions (true or false)

• Region (South, Central, or North)

• Facility ID

• Permit Number

• Facility City

• District inspection area

• Equipment description

• Subject to Rule 4311 requirements, other than recor dkeeping (yes or no)

• Flare rating (capacity)

• Permit conditions that limit flaring (yes or now; i f yes, description)

• Flare type (emergency, standby, primary disposal

• Greater than 5 MMBtu/hr (yes or no)

• Summary of stated flare uses in FMP

• Actions identified in FMP to minimize flaring

• 2012 Annual Monitoring Report received (yes or no)

• 2012 Reportable Flaring Events report received (yes or no)

• 2012 Reportable Flaring Event analysis (number of e vents, number planned, and number unplanned)

• Reportable Flaring Event link for more information

• 2010 emissions inventory (MMscf)

• 2010 annual gas flared from inspection reports

• 2011 emissions inventory (MMscf)

• Annual gas flared from AMR (7/11 – 6/12)

• 2012 emissions inventory (MMscf)

• Annual gas flared from annual monitoring report (7/ 12 – 6/13)

Organizing, sorting, and consolidating the vast col lection of data presented a significant challenge throughout this study, and a significant amount of staff resources were expended to thoroughly evaluate this information. As patter ns and outlying data points were identified, staff began to sort the information int o smaller, more manageable compilations that were used to answer specific questions about v arious Rule 4311 requirements and search for more patterns and outliers, all with the intent to identify additional opportunities to reduce emissions.Rule 4311 (Flares) Further Study

September 16, 2014

11 Methodology | SJVUAPCD The District began with the determination that out of the 235 flares being evaluated, 126 flares are exempt from Rule 4311 requirements other than basic recordkeeping requirements due to one of the following reasons: n on-major source, subject to other rules regulating landfills, or are not stationary. The r emaining 109 flares in the Valley were determined to be subject to Rule 4311 requirements. Facilities subject to Rule 4311 requirements were further categorized by whether or not they are subject to Flare Minimization Plans (FMP), Annual Monitoring Reports (AMR), or Reportable Flaring Event (RFE) submission requirements

District staff determined that 95 facilities are su bject to Flare Minimization Plan requirements and every flare permit was examined to determine whether an FMP had been submitted and approved by the District. If a facil ity did not submit an FMP for approval, staff investigated whether or not they were require d to. When this study began, all facilities were in compliance with FMP requirements

.

The submitted FMPs were analyzed for patterns or ir regularities, and evaluated whether:

• FMPs account for all rule-required elements

• Operators are identifying and evaluating opportunit ies to reduce flaring

activities

• Operators are incorporating identified opportunitie s that are determined to be

feasible

• Operators are not missing opportunities to further reduce flaring

FMP review also focused on determining if there wer e common actions or best management practices identified in the FMPs that co uld be required for all facilities. As discussed further in the FMP section of this report (Section VI), actions identified in the FMPs are typically dependent on the facility and op eration type, as well as the quality of gas being flared. Due to the variability of each facil ity’s needs, staff found no additional feasible actions/practices that could be added to Rule 4311 requirements.

The next major analysis determined that 40 faciliti es were not subject to the requirements to submit Annual Monitoring Reports. Certain facil ities were too small or had not utilized their flares, while the majority had accepted speci fic limiting conditions on their permits to operate (PTOs) which limited the amount of flaring the facility could conduct. This analysis also determined that 55 facilities are subject to A MR submittal requirements. Similar to the FMP analysis, staff began evaluating if the fac ility had submitted an AMR for the reporting period and, for the facilities that had n ot, District staff contacted the facilities to explain deficiencies and collect the missing inform ation.

The submitted AMRs were examined for the following information:

• Percentages of total gas flared from each facility

• Patterns of high or irregular flaringRule 4311 (Flares) Further Study

September 16, 2014

12 Methodology | SJVUAPCD • Flaring in excess of limits committed to

• Reasons for flaring

Information gathered from the Annual Monitoring Rep orts allowed staff to gain a better understanding of how each facility was utilizing th eir flares, the measures taken to reduce flaring, and the amounts of gases being flared. Ad ditionally, staff was able to use reported flaring volumes from the AMR to estimate emissions from reported flaring and compare those calculations to verify the accuracy of the em issions inventories.

The final portion of the analysis evaluated data fr om facilities that experienced Reportable Flaring Events (RFEs) during this reporting period. District staff used the same comprehensive methods as were used for FMPs and AMR s to analyze the RFE reports for the following data:

• Percentage of total volume flared from reportable e vents for each facility

• Salable gas flared

o Total volume

o Total value

o Average value

• Total volume and percentage of non-salable gas flar ed

• Causes of events (planned, unplanned, maintenance, new equipment installation, etc.)

• Percentage of events due to each main type of cause

District staff conducted case studies of two facili ties during the RFE analysis to gain a deeper understanding of how specific operations and events at those facilities affected their flaring activity. The two facilities were se lected because they both experienced periods of abnormally high reportable flaring, and because one was representative of oil field flares, which include the majority of Valley flares. Staff analyzed the following

information:

• Type of facility

• Operations performed at the facility

• Reasons for flaring in general

• Causes of reportable flaring events

• Amount of flaring during the periods in question

• Possible prevention measures

• Additional opportunities to reduce flaring at the f acility

District staff also performed a regulatory evaluati on that compared the requirements of

Rule 4311 to those of NSPS and flare rules in other air districts. To understand the

differences and similarities between Rule 4311 and NSPS, staff looked at fact sheets, guidance documents, and the actual NSPS text. Simi larly, because the different rules for other air district have minor language and administ rative differences, staff created a tableRule 4311 (Flares) Further Study

September 16, 2014

13 Flare Minimization Plans | SJVUAPCD (see Attachment) to organize and compare the main r equirements of each district’s flare rules. Additionally, staff compared total numbers of flares, flare types, and flare capacities between the District and other major air districts in California.

The following sections provide more details and exp lain the results of the further study as

committed to in the 2012 PM2.5 Plan

.

VI. FLARE MINIMIZATION PLANS

Rule 4311 Flare Minimization Plan (FMP) Requirement s 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 flar e or any flare with a flaring capacity greater than or equal to 5.0 MMBtu/hr. The rule pr ohibits facilities subject to FMP requirements from flaring unless it is consistent w ith a District-approved FMP and all

commitments in that FMP have been met. To ensure F MPs are up-to-date without undue redundancy in paperwork requirements from stakehold ers, FMPs are to be updated every five years. Updates to the FMP are also required t o address any new or modified equipment that requires an Authority to Construct p ermit and impacts emissions from the

flare.

An FMP submitted to the District pursuant to Sectio n 6.5 of Rule 4311 shall include at least the following information:

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

• Process flow diagrams of upstream equipment and pro cess units venting to each flare (with identification of type and location of control equipment)

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

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

and shutdown

• Evaluation of preventative measures to reduce flari ng that may be expected to occur due to issues of gas quantity and quality. This in cludes an audit of vent gas recovery capacity of each flare system, storage capacity for excess vent gas, and scrubbing capacity available for vent gas for use as a fuel; and shall determine the feasibility of reducing flaring through the recovery, treatment an d use of the gas.

• Evaluation of preventative measures to reduce flari ng caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Evaluation sh all determine adequacy ofRule 4311 (Flares) Further Study

September 16, 2014

14 Flare Minimization Plans | SJVUAPCD existing maintenance schedules and protocols for su ch equipment. (A failure is recurrent if it occurs more than twice during any f ive year period as a result of the same cause)

Further Study Commitment:

Evaluate Flare Minimization Plans

Summary of Facilities Required to Submit FMPs B.

Of the 109 flares in the Valley subject to Rule 431 1 requirements, 95 are subject to FMP requirements, all of which have been submitted by t he time of this further study report. The remaining 14 flares are not required to submit FMPs to the District because they have a flaring capacity less than 5.0 MMBtu/hr and are o perated at facilities other than petroleum refineries.

To further illustrate the wide applicability of Rul e 4311, a summary of the 95 submitted FMPs is presented in table 2 and is organized by in dustry type.Rule 4311 (Flares) Further Study

September 16, 2014

15 Flare Minimization Plans | SJVUAPCD

Table 2 Submitted FMPs Summarized by Industry

Industry Summary Qty

Cheese production 1

Wine 2

Correctional Facility 1
Crude oil and natural gas production 14

Crude oil production 1

Crude petroleum and natural gas production 2

Gas plant 2
Light oil production 5

Natural gas processing 4
Natural gas production 2
Natural gas transmission 2

Oil and gas production 13
Oil and natural gas production 29
Petroleum and natural gas production 1

Petroleum production 1
Petroleum refinery 7

Dairy 1

Flat glass 1

Wastewater 6

Total 95

Pursuant to Section 6.5.1 of rule requirements, ope rators are required to evaluate preventative measures to reduce flaring during plan ned major maintenance activities, flaring due to issues of gas quantity or quality, a nd flaring caused by recurrent failure of equipment.

Each operator of the facilities described above per formed such evaluations and presented findings in the FMPs they submitted to the District . Table 3 includes a summary of actions identified in FMPs to minimize flaring, along with the facility types that committed to the actions. The actions identified are a sampling fro m multiple facilities within each category, and not every facility in the category committed to all of the FMP actions shown.Rule 4311 (Flares) Further Study

September 16, 2014

16 Flare Minimization Plans | SJVUAPCD

Table 3 Summary of FMP Measures

FACILITY

CATEGORY ACTIONS IDENTIFIED IN FMP TO MINIMIZE FLARING*

Oil and Gas

Production

and

Transmission Include permit limit on gas flared daily and annual ly

Streamline startup, shutdown, and maintenance proce dures to minimize equipment downtime, thereby minimizing flaring

Hydrogen sulfide scrubbing of flare gases to condit ion for sale 6

Inject flare gas in DOGGR-approved wells

Use other combustion devices such as glycol re-boil er/thermal oxidizer

Wastewater Treatment/

Reclamation Install new equipment to combust digester gas in in ternal combustion

engines, fuel cells, and process heaters

Install equipment to allow digester gas storage and conditioning for greater use in turbines (additional storage is mini mal and only capable of handling excess gas during minor process upsets)

Wine

Production Burn flare gas in steam generation boilers; coordin ate plant operations

that generate the flare gas with production operati ons requiring steam

Cheese

Production Modify boiler to combust a natural gas/digester gas blend

Flat Glass Manufacturing Reduce idle time during calibration and purge test to reduce necessary

flaring

Dairy Farming Install additional gensets (electricity generation equipment located near

the end user) to combust more produced biogas

Depending on the facility type, and the quality of flare gas produced, some of the above measures may not be feasible for all facilities.

For oil and gas production, the flare gas produced is often in excess of what could be used onsite to power equipment. For these facilities, f lares are generally used only under abnormal conditions, as the flare gas is usually hi gh enough quality to sell for use at other

facilities.

For facilities other than oil and gas production, t he gas produced is usually a much lower heating value and requires conditioning if combuste d for electrical generation or process

6 BioPath, LLC. (2013). Hydrogen Sulfide H2S Scrubber . Retrieved from http://biopathfps.com/hydrogensulfide-h2s-scrubber/Rule 4311 (Flares) Further Study

September 16, 2014

17 Flare Minimization Plans | SJVUAPCD heating. Expensive modifications or new equipment is often required to allow said combustion activities, and the flare gas is sometim es of too low quality or quantity to make these installations cost effective. Additionally, depending on the combustion equipment used, there is no guarantee that emissions will be lower because flares are already effective

control devices.

The majority of the operators are already performin g all activities possible to reduce flaring at their facilities, as confirmed in the FM P submittals. As such, most operators were not able to identify additional actions above and b eyond those already implemented at their facilities to further minimize flaring, and t hose that did identify feasible alternatives

committed to them in the FMPs submitted to the Dist rict.

What was learned from collected FMPs C.

The majority of the 95 Valley flares with FMPs are standby flares, which means they are only utilized when needed such as during maintenanc e or to dispose of excess flare gas, and are not used as a method of primary disposal for wa ste gases. Twelve of the 95 flares are permitted specifically for emergency use only and a nother three serve a primary purpose as both an emergency flare and a standby flare. Se e figure 3 for a summary of the primary uses of flares with FMPs in the Valley.

Only three flares in the Valley are permitted to be used as primary disposal devices. Two of the three flares are used at an oil and natural gas production facility as a VOC control device for vapors displaced from trucks during load -out operations pursuant to requirements in District Rule 2201 (New and Modifie d Stationary Source Review Rule). The facility minimizes flaring by limiting use of t he flares to comply with Rule 2201 and not using them for planned major maintenance, start up or shut down activities, or for control of emissions caused by equipment failure or process malfunctions. The third flare is used at a cheese making facility for primary disposal of methane gas generated by the wastewater anaerobic digester at the facility. How ever, the cheese making facility committed to modify an on-site boiler to combust a natural gas/digester gas blend to reduce flaring in the facility’s FMP.Rule 4311 (Flares) Further Study

September 16, 2014

18 Annual Monitoring Reports | SJVUAPCD

Figure 3 Primary Purpose of Valley Flares

Review of the information in the FMPs verified that operators are performing actions to reduce flaring at their facilities including not us ing the flares, permitting them for emergency use only, not using them for major mainte nance as a standard practice, burning gases in alternative devices when possible, and lim iting gas flow to the flares.

VII. ANNUAL MONITORING REPORTS

Rule 4311 Annual Monitoring Report Requirements A.

The operator of a petroleum refinery flare or any f lare with a flaring capacity equal to or greater than 50 MMBtu/hr (§5.10, 6.6, 6.7, 6.8, 6.9 , 6.10), as appropriate, is required to submit an annual monitoring report to the District no later than July 31 st of each calendar year (§6.2.3).

Pursuant to Rule 4311 Section 6.2.3, the annual mon itoring report submitted to the District shall contain the following information:

• Total volumetric flow of vent gas (§6.2.3.1)

• Hydrogen sulfide content, methane content, and hydr ocarbon content of vent gas (§6.2.3.2)

• If vent gas composition is monitored by a continuou s analyzer(s): average total hydrocarbon content by volume, average methane cont ent by volume, and depending upon the analytical method used, total re duced sulfur content by volume or hydrogen sulfide content by volume of vent gas f lared for each hour of the month (§6.2.3.3)Rule 4311 (Flares) Further Study

September 16, 2014

19 Annual Monitoring Reports | SJVUAPCD • If the flow monitor measures molecular weight, the average molecular weight for each hour of each month (§6.2.3.4)

• For any pilot and purge gas used, the type of gas u sed, the volumetric flow for each day and for each month, and the means used to deter mine flow (§6.2.3.5)

• Flare monitoring system downtime periods, including dates and times (§6.2.3.6)

• For each day and each month provide calculated sulf ur dioxide emissions (§6.2.3.7)

• A flow verification report for each flare (§6.2.3.8 )

Further Study Commitment: Evaluate Annual Monitoring Report Data

Submitted 2012 Annual Monitoring Reports B.

Flares are subject to the annual monitoring report requirements if the flare is subject to flare minimization plan requirements and can produc e a reportable flare event; however, many Valley operators of flares are proactive in re ducing flaring by having specific limiting conditions added to their District permits that lim it the amount of flaring. As a result, many of the 95 flares subject to FMP requirements do not produce reportable flare events and are not required to submit annual monitoring report s. At the time of this further study effort, 55 annual monitoring reports have been subm itted to the District. The following table is a summary of annual monitoring reports sor ted by industry type.Rule 4311 (Flares) Further Study

September 16, 2014

20 Annual Monitoring Reports | SJVUAPCD Table 4 Submitted Annual Monitoring Reports Summar ized by Industry

Industry Summary Qty

Correctional Facility 1

Cheese Production 1

Winery 1

Oil and Gas Production 6

Crude Petroleum and Natural Gas 1

Crude Oil and Natural Gas Production 7

Oil and Natural Gas Production 15

Natural Gas Transmission 2

Waste Water Reclamation 1

Gas Plant 2

Petroleum and Natural Gas production 1

Petroleum refining 7
Natural Gas Production or Processing 6
Light Oil Production 4

Total 55

What was learned from submitted Annual Monitoring R eports C.

As committed to, the District collected and analyze d Annual Monitoring Reports.

Information from these AMRs allowed the District to evaluate the total amount of vent gases combusted and their compositions from each of the 55 flares. This information

allowed the District to calculate the amount of emi ssions from the reported flaring and compare those values to verify the accuracy of the emissions inventory for flares.

As can be seen above, the annual monitoring reports represent a variety of industries in the Valley. Of the flares summarized in the 55 annual monitoring reports, only one is used as a primary disposal device, one is dormant, and eleven are designated for emergency use only. The remaining flares are standby flares. Ma ny facilities have specific limiting conditions in their permits that limit the amount o f flaring allowed to less than the threshold for reportable flaring events; another ex ample of operators committing to keep flaring at their operations reduced. Operators of all of the flares with annual monitoring reports are also actively taking measures pursuant to their FMPs to reduce flaring at their facilities; a few examples include having the flare s permitted for emergency use only, rendering flares dormant, and coordinating efforts at the facility to reduce flaring. Annual monitoring reports are a valuable resource for unde rstanding the activities of Valley flares.

The information in these reports offers additional evidence that flaring is generally a last

resort for facilities. The District will continue to collect and analyze these reports annually.Rule 4311 (Flares) Further Study

September 16, 2014

21 Reportable Flaring Event | SJVUAPCD VIII. REPORTABLE FLARING EVENT

Rule 4311 Reportable Flaring Event Requirements A.

What is a Reportable Flaring Event? A flaring event is considered a “Reportable Flaring Event” if more than 500,000 standard cubic feet (scf) of vent gas is flared per calendar day, or where sulfur oxide emissions are greater than 500 pounds per calendar day. A report able flaring event ends when it can be demonstrated that the integrity of the water seal h as been maintained sufficiently to prevent vent gas to the flare tip, or when the rate of flow of vent gas falls below 0.12 feet per second (§3.31). Assuming an estimated heating value for flare gas of 1,000 Btu/scf, a flare must have a capacity greater than or equal to 20.8 MMBtu/hr to achieve a reportable flaring event, although most flares commonly operat e at a small fraction of maximum capacity. Additionally, some low quality waste gas es can have heating values of 200-300 Btu/scf, which would lower the minimum capacity for reportable flaring events. Reportable Flaring Event requirements are applicabl e to the operator of a flare subject to FMP requirements with the exception of flares that the operator can verify are not capable of producing reportable flare events (§5.10). Annu al reports summarizing all Reportable Flaring Events shall be submitted to the District n o later than July 31 st of each year (§6.2.2).

What data are required to be reported to the Distri ct in the Reportable Flaring Event report? The report shall summarize all Reportable Flaring E vents that occurred during the previous 12 month period (§6.2.2). The report shal l include, but is not limited to the following:

• The results of an investigation to determine the pr imary cause and contributing factors of the flaring event (§6.2.2.1)

• Any prevention measures considered or implemented t o prevent recurrence together with a justification for rejecting any mea sures that were considered but not implemented (§6.2.2.2)

• If appropriate, an explanation of why the flaring w as an emergency and necessary to prevent accident, hazard or release of vent gas to the atmosphere, or where, due to a regulatory mandate to vent a flare, it cannot be re covered, treated and used as a fuel at the facility (§6.2.2.3)

• The date, time, and duration of the flaring event ( §6.2.2.4)Rule 4311 (Flares) Further Study

September 16, 2014

22 Reportable Flaring Event | SJVUAPCD Further Study Commitment: Evaluate Reportable Flare Event Data

Reportable Flaring Events B.

The reportable flaring events data presented in thi s report are from the 2011-2012 fiscal year. While 2012-2013 reportable flare event repor ts and data have been submitted to the District at the time of this further study, a compl ete analysis of these more recent reports has not been incorporated into this further study b ecause doing so would require an additional year of District analysis. However, the District analyzed 2012-2013 reportable flaring events data for the two case studies presen ted below.

Of the 109 flares subject to Rule 4311, 21 flares g enerated 395 reportable flaring events. The following table summarizes the amount of gas fl ared during reportable flaring events. This information is organized by industry type.

Table 5 Summary of Total Reportable Flare Events (M SCF)

Industry Summary Qty of

Flares Reportable Flare

Events – Total (MMscf) Crude Oil and natural gas production 3 27.8

Gas plant 2 12.0
Light oil production 3 7.7

Natural gas processing and production 5 42.8

Oil and natural gas production 4 52.5

Petroleum and NG production 1 20.9

Petroleum refining 2 59.4

Wastewater reclamation facility 1 124.2

Total 21 347.4

Case Studies C.

Two case studies were performed to provide a more i n-depth evaluation of flaring activities in the Valley. As the oil and gas relat ed industries represent a majority of the operations in the Valley performing flaring activit ies, the first case study focuses on an oil field flare. The second case study is of flaring a ctivities at a wastewater treatment plant; this facility was selected because it had an unusua l amount of flaring during the reporting period.Rule 4311 (Flares) Further Study

September 16, 2014

23 Reportable Flaring Event | SJVUAPCD LIGHT OIL PRODUCTION

Vintage Production California LLC operates as a sub sidiary for Occidental Petroleum Corporation at several facilities in California. O ne facility located in North Shafter (VPC North Shafter) was selected for a case study becaus e it is representative of oil field flares in the Valley and because it experienced a period of a bnormally high flaring activity during the reporting period.

Flare gas at oil production facilities is mostly co mposed of high quality, high energy content compounds like methane, ethane, propane, and butane , and typically transmitted either to a sales gas line or to a gas plant pipeline where i t is treated prior to use or sale. With an estimated heating value of 1000 Btu/scf for this ga s, it is a valuable commodity. The facilities producing this gas generally try to use or sell as much as possible, but must sometimes flare for various reasons, most commonly for safety during emergency and process upset situations. Other reasons for flarin g include gas produced in excess of

commercial demand or in excess to what can be burne d as process gas, vapors collected from the tops of tanks as they are filled, process upsets, equipment changeover or maintenance, well tests, production shut-down, gas of insufficient volume to financially warrant treatment prior to sending to a pipeline, o r when there is not a gas plant pipeline

available.

VPC North Shafter operates a 41.7 MMBtu/hr Coanda t ip flare with liquid knockout and sulfur knockout vessels. It is permitted at a gas rate of no more than 4.0 MMscf/day and 438 MMscf per year. The emission rates (lb/MMscf) are not to exceed 20 for PM10, 68 for NOx, 33 for VOC, or 38 for CO.

Of the 395 reportable flaring events in 2011-2012 i n the Valley, nine were at VPC North Shafter, all of which were planned maintenance. In contrast, the facility performed 157 reportable flaring events in 2012-2013; all of whic h were for planned shutdown for repair and maintenance because Chevron, which normally pip es the flare gas to its Kern River oil field after purchasing it from VPC North Shafter, w as repairing a pipeline. 7 The total volume flared during reportable events at VPC North Shafter in 2011-2012 was 13.1 MMscf, compared to 283.3 MMscf in 2012-2013.

During the 2012-2013 reporting period, there were f our months of nearly constant flaring. Despite the abnormally high flaring activity, NOx e missions from these reportable flaring events were 9.6 tons for the entire reporting perio d, an average of 0.06 tons per day. The total value flared during the 2012-2013 reportable events was an estimated $1.4M. The

7 The Bakersfield Californian, “The Sound and the Fur y”. 2012 http://www.bakersfieldcalifornian.com/business/x871 558971/The-sound-and-the-fury-Gas-flare-wears-onShafter-area-residentsRule 4311 (Flares) Further Study

September 16, 2014

24 Reportable Flaring Event | SJVUAPCD sales transmission line was closed due to condition s beyond the control of the facility. Therefore, flaring activities conducted in 2012-201 3 at VPC North Shafter were extremely abnormal and unlikely to occur in the future.

Internal combustion engines (IC engines) can combus t low-sulfur well vapors typical of light oil production sources such as the VPC North Shafter facility. Increased use of IC engines, where available and feasible, can reduce f laring activities; however, it would not decrease emissions beyond what would be reduced by the flare. Flares are emission control devices that operate at 98% control efficie ncy. The use of IC engines in the Valley is regulated through District Rule 4702 (Internal Comb ustion Engines). Depending on the size, type, and total hours of usage of the engine, using IC engines in place of flaring could actually increase emissions. Furthermore, the addi tion of IC engines to a facility requires additional controls (Best Available Control Technol ogy), monitoring, and reporting thus increasing the cost of using the waste gas in this type of equipment.

Measures listed in the VPC North Shafter FMP includ e:

• Flaring frequency and gas volume flared is insuffic ient to economically justify installation of redundant equipment

• In the event of a planned shut down by end user, an d/or major maintenance activities to the sales gas compressor, gas product ion will be curtailed to the extent possible without hampering oil production

• The gas process equipment is operated in a manner t o minimize disruptions from repair and/or maintenance

• Sales gas compressor has a thorough, regular mainte nance schedule to prevent major malfunctions that result in longer periods of flaring

• VPC cooperates with end user to minimize down time and flaring

The VPC case study offers evidence that oil product ion facilities take actions to minimize flaring and instead attempt to transmit the gas for sale or use in other locations. Occasional installation, maintenance, or repair of critical it ems such as transmission lines can cause abnormally high flaring activity, but these are typ ically one-time events. Because light oil production facilities already sell or utilize as mu ch flare gas as possible, no feasible

alternatives are available.

WASTE WATER TREATMENT PLANT—Fresno/Clovis Regional Wastewater Treatment Plant, South Fresno

The Fresno/Clovis Regional Wastewater Treatment Pla nt (WWTP), located in south Fresno, was selected for this case study because it experienced an abnormally high amount of flaring and is not a part of the petroleum and n atural gas industry.Rule 4311 (Flares) Further Study

September 16, 2014

25 Reportable Flaring Event | SJVUAPCD The 80 million gallon per day (MGD) facility treats wastewater through primary treatment, secondary treatment, and anaerobic digestion. Dige ster gas from the WWTP is produced during anaerobic digestion, a process that exploits a variety of bacteria in an oxygen-free environment to reduce organic matter in bio-solids 8 . Anaerobic digesters are capable of producing high-quality, high energy content methane that can be used for electricity generation or to supply heat needed to complete the digestion process. However, digester gas requires treatment to remove hydrogen sulfide ( H 2 S) and sometimes requires dehydration, filtering, or CO 2 removal. Digester gas, which usually has a methan e content of greater than 60%, can be a suitable natural gas fuel substitute for use in boilers, hot water heaters, reciprocating engines, turbines, and fuel cells. 9

According to the District-approved FMP for this fac ility, digester gas is consumed to create electricity and provide heat for the digesters. Th e WWTP uses two 3.4 Megawatt (MW) turbine engines and one 16.7 MMBtu/hr process boile r that are almost completely fueled by digester gas. Because there is no significant g as storage capacity, any excess digester gas or gas produced during interruptions to the tur bines or boiler must be flared.

Flaring at the WWTP is performed by a 36.3 MMBtu/hr John Zink waste gas flare that was installed to replace three older, less efficient fl ares. The fully automated, enclosed ground flare is designed to burn digester gas without auxi liary fuel at a maximum flow rate of 1,100 cubic feet per minute (CFM). NOx emissions a re less than 0.06 lb/MMBtu, and SOx is controlled by reducing H 2 S concentrations in the digester gas. To fulfill c ommitments in the FMP, the facility installed a small digester ga s storage tank, installed additional digester gas conditioning, and increased the allowable diges ter gas fuel for the turbines from 50% to 100%. The storage tank is capable of holding ga s for small periods, such as during switchover between turbines, and the gas conditioni ng allows the use of selective catalytic reduction (SCR) on the turbines.

The WWTP has reduced the volume of gas flared from 174.7 MMscf in 2004 to 50.4 MMscf in 2013; however, the 2011-2012 reporting period in cluded abnormally high flaring activity. During this period, the turbines were ou t of service to allow installation of selective catalytic reduction (SCR) control devices for compliance with District Rule 4703 (Stationary Gas Turbines). As a result, a large po rtion of the digester gas was flared. Out of 395 total reportable flaring events in the Valley d uring the 2011-2012 reporting period,

164 occurred at the WWTP. Those events accounted f or 36 percent of the total volume of gas flared during reportable events, more than thre e times the next highest volume at any

8 City of Fresno Wastewater Management Division. Retr ieved from http://www.fresno.gov/Government/DepartmentDirector y/PublicUtilities/Wastewater/default.htm on 1/26/14.

9 DOE, “Wastewater Digester Gas can Produce High Qua lity Methane Fuel for Federal Facilities.” 2005. http://www1.eere.energy.gov/femp/news/news_detail.h tml?news_id=8961Rule 4311 (Flares) Further Study

September 16, 2014

26 Reportable Flaring Event | SJVUAPCD facility. The graph below shows the percent of tot al volume flared from each source that experienced reportable flaring events during the re porting period.

Figure 4 Percent of Reportable Flaring from All Sou rces

All of the events were planned, and the majority (1 27 events) was for the installation of the SCR units. The remaining 37 events were due to mai ntenance or excess digester gas production. By contrast, the 2012-2013 reporting p eriod showed only 46 reportable flaring events, all of which were for regular activ ities except one due to failure of a turbine. Because the majority of flaring events during the 2 011-2012 reporting period were due to installations and are therefore one-time events, th ey are not part of normal facility operations.

The WWTP case study offers further evidence that fa cilities in the Valley are already implementing feasible measures to reduce flaring. The digester biogas is a valuable resource that the WWTP uses to provide a significan t portion of its electricity demands and process heating input. The facility implemented me asures identified in the FMP to increase digester gas usage onsite, install a gas storage ta nk, and further condition the gas to allow for additional air pollution control equipment to b e operated.

0 5 10 15 20 25 30 35 40

A B C D E F G H I J K L MPercent of Total Volume Flared fromReportable Flaring Events

Facility (Facility 'A' is Fresno/Clovis Regional WW TP)Rule 4311 (Flares) Further Study

September 16, 2014

27 Reportable Flaring Event | SJVUAPCD What was learned from collected Reportable Flaring Event reports D.

The majority of reportable flaring events during th e 2011-2012 reporting period were planned (82.5%) and only 20% involved salable flare gas. This shows that measures have already been implemented to reduce the number of em ergency events. Over half of the reportable flaring events were due to new installat ions, and as such are unlikely to be repeated. The figure below shows the percent of ev ents due to the different reasons for reportable flaring events.

Figure 5 Reasons for Reportable Flaring Events

The total value of all reportable flaring events wa s estimated at $560,000, of which only $190,000 occurred due to planned events. Facilitie s in the Valley are already implementing feasible alternatives to flaring because flare gas is a valuable commodity for sale or use

onsite.

The two case studies of typical Valley facilities s how that most facilities attempt to sell or use as much flare gas as possible. The greatest fl aring during the 2011-2012 period was from a wastewater treatment plant, where the option to curtail operations does not exist, due to the necessary nature of the facility. The e xcessive flaring at that facility was required to install more air pollution control equi pment, and was therefore a one-time event that will benefit Valley air in the long term

. Maintenance/ Repair

19%

Equipment
Installations

51% Startup/

Shutdown

13% Equipment
Failure

8% Power Outage

5% Reason Unkown

4%Rule 4311 (Flares) Further Study

September 16, 2014

28 Regulatory Evaluation | SJVUAPCD IX. REGULATORY EVALUATION

In evaluating District Rule 4311, the U.S. Environm ental Protection Agency (EPA) identified three core requirements needed to satisfy RACT for flares:

• Flare minimization plans

• Monitoring and reporting flare events

• Causal analysis for large flare events 10

Upon comparing District Rule 4311 to analogous rule s for these criteria, EPA deemed the District rule as being at least as stringent as RAC T and finalized approval of the District’s 2009 amendments to Rule 4311 on November 3, 2011. 11 Additionally, EPA finalized a partial approval of the 2009 RACT demonstration rep ort on January 10, 2012 and confirmed this rule as still being at least as stri ngent as established RACT requirements. 12 For purposes of this further study, the regulatory evaluation will consist of actions occurring after January 2012.

Federal Requirements A.

Rule 4311 is as stringent as, or more stringent tha n the applicable federal NSPS (40 Code of federal Regulations (CFR) 60.18 – General Control D evice Requirements) 13 and the flares section of the Consolidated Federal Air Rule (40 CF R 65.147 – Flares) 14 , and the applicable

federal National Emission Standards for Hazardous A ir Pollutants (40 CFR 63, Subpart SS – National Emission Standards for Closed Vent Systems , Control Devices, Recovery Devices and Routing to a Fuel Gas System or a Process) 15 . There are no applicable Control Techniques Guidelines, Alternative Control Techniqu es, or Maximum Achievable Control Technology requirements for flares.

In 2012, EPA modified an existing NSPS for flares ( 40 CFR 60 Subpart Ja) 16 and added a new NSPS (40 CFR 60 Subpart OOOO) 17 , both of which are applicable to this source

10 EPA TSD (Analysis of SJVUAPCD’s Rule 4311), http://www.regulations.gov/#!documentDetail;D=EPA-R 09-

OAR-2011-0601-0022

11 76 FR 68106, http://www.gpo.gov/fdsys/pkg/FR-2011-11-03/pdf/2011 -28391.pdf EPA Proposed approval 76 FR 52623, http://www.gpo.g ov/fdsys/pkg/FR-2011-08-23/pdf/2011-21368.pdf TSD: http://www.regulations.gov/#!documentDetail;D= EPA-R09-OAR-2011-0601-0022

12 77 FR 1417, http://www.gpo.gov/fdsys/pkg/FR-2012-01-10/pdf/2012 -139.pdf

13 40 CFR 60.18. http://www.gpo.gov/fdsys/pkg/CFR-2010-title40-vol6/ pdf/CFR-2010-title40-vol6-sec60- 18.pdf

14 40 CFR 65.147. http://www.gpo.gov/fdsys/pkg/CFR-2010-title40-vol15 /pdf/CFR-2010-title40-vol15- sec65-147.pdf

15 40 CFR 63, subpart SS. http://www.ecfr.gov/cgibin/retrieveECFR?gp=&SID=1a65b68f3f3a44dbf44870e8ae c64884&r=SUBPART&n=40y11.0.1.1.1.18

16 40 CFR 60, subpart Ja http://www.law.cornell.edu/cfr/text/40/part-60/subp art-JaRule 4311 (Flares) Further Study

September 16, 2014

29 Regulatory Evaluation | SJVUAPCD category. The District’s Permit Services Departmen t already evaluates NSPSs on a case-bycase basis to ensure the relevant flares comply wit h all federal requirements as they are promulgated, therefore, adding any requirements fro m subparts Ja and OOOO would not

achieve additional emission reductions from this so urce category.

40 CFR 60 Subpart J The NSPS for refinery flares constructed or modifie d after June 11, 1973 are regulated in 40 CFR Part 60, Subparts A and J. Subpart A applies t o flares as general control devices, specifying design and operational criteria for new and modified flares. Requirements include operating the flare with no visible emissio ns, monitoring the presence of the pilot flame with a thermocouple or equivalent device, and meeting heat content and maximum tip exit velocity specifications. Rule 4311 is as stringent as Subpart A.

40 CFR 60, subpart J - NSPS for petroleum refinerie s applies to the affected facilities at a refinery including flares that commence constructio n, reconstruction or modification after June 11, 1973, but on or before May 14, 2007. Subp art J applies to flares at petroleum refineries, where flares are defined as fuel gas co mbustion devices, and are limited to burning fuel gas for maintenance of the pilot flame if the fuel gas contains hydrogen sulfide (H 2 S) in excess of 0.10 gr/dscf. This limitation does not apply during process upsets, relief valve leakage, or other emergency malfunctions, whe re vent gases or fuel gas are released to the flare. This subpart also requires that a co ntinuous monitoring and recording device

be installed to track emissions of SO 2 or H 2 S from the flare, in addition to the installation o f an oxygen monitor for correcting the emissions data for excess air.

Amendments to Subpart J add a new paragraph to 40 C FR 60.100 to allow sources affected by 40 CFR part 60, subpart J to comply by following the requirements in 40 CFR part 60, subpart Ja. Other amendments were administrative i n nature and provided additional clarity to existing standards.

17 40 CFR 60, subpart OOOO http://www.ecfr.gov/cgibin/retrieveECFR?gp=&SID=5c050fac63d930ea5bc5c11716 888545&r=SUBPART&n=40y7.0.1.1.1.102Rule 4311 (Flares) Further Study

September 16, 2014

30 Regulatory Evaluation | SJVUAPCD Further Study Commitment: Evaluate New NSPS Requirements for Flares

40 CFR 60 Subpart Ja NSPS for petroleum refineries (40 CFR 60, subpart J a) apply to flares that commence construction, reconstruction or modification after June 24, 2008, and other affected facilities at petroleum refineries that commence co nstruction, reconstruction, or modification after May 14, 2007. Subpart Ja contai ns requirements for monitoring systems for certain flares, but does not specify any emissi on limits or technology requirements.

EPA amended 40 CFR 60 Subpart Ja on September 12, 2 012 18 . Amendments clarified existing requirements and applicability including w hat is considered and what is not considered a flare modification, clarification of s econdary flares, and of the records that must be maintained by the operator.

The September 2012 amendments to Subpart Ja include d new requirements for flarerelated unit and process descriptions, assessments and evaluations, analyses of causes and corrective actions for reportable flaring events, a nd sulfur limits for petroleum refineries. The NSPS subpart Ja does not implement more stringe nt requirements than Rule 4311. While there may be some minor differences in termin ology or requirements, making direct comparisons is not possible. The same level of con trols and emission reductions are achieved through District regulations as through th is NSPS. Additionally, as previously stated, the District’s Permit Services Department c ontinuously evaluates NSPSs on a caseby-case basis to ensure the relevant flares comply with all federal requirements as they are promulgated.

Subpart Ja has one new exemption for continuous mon itoring which allows for fewer requirements, than previously required in the NSPS, and therefore, is not more stringent than current rule language.

40 CFR 60 Subpart OOOO EPA finalized approval of a new NSPS requirement 40 CFR 60 Subpart OOOO on August 16,

2012 19 . This NSPS may indirectly affect some Valley flar es since there is a possibility that a flare is exempt from the majority of Rule 4311 and is used as a control device for a vapor controlled tank that is subject to Subpart OOOO.

Affected facilities under this subpart that may use flares as an approved control device include centrifugal compressors, storage vessels, a nd onshore natural gas processing

18 77 FR 56422, http://www.gpo.gov/fdsys/pkg/FR-2012-09-12/pdf/2012 -20866.pdf

19 77 FR 49490, http://www.gpo.gov/fdsys/pkg/FR-2012-08-16/pdf/2012 -16806.pdfRule 4311 (Flares) Further Study

September 16, 2014

31 Regulatory Evaluation | SJVUAPCD plants. If the facility chooses to meet the contro l requirements, then the flare must be designed and operated in accordance with §60.18(b) and must conduct the compliance determination using Method 22 at 40 CFR part 60, ap pendix A-7, to determine visible emissions. §60.18(b) was last amended Dec. 22, 200 8, which is after the last amendment for District Rule 4311 (June 18, 2009). Therefore, Subpart OOOO has no new requirements for flares after Rule 4311 rule adoption.

State Requirements B.

There are no California state Air Resources Board ( ARB) requirements specific to flaring

activities in California because flares are located at stationary sources, and the emissions are therefore under the jurisdiction of California’ s local air districts.

Local Requirements at Other Air Districts C.

As mentioned above, flares are under the jurisdicti on of local regulatory agencies because they are located at stationary sources. In Califor nia, local regulatory agencies include air pollution control districts (APCD) and air quality management districts (AQMD). District Rule 4311 is unique from all other air districts’ f lare rules in California in that it has a broader applicability. The Rule 4311 source catego ry currently includes flares associated with oil and gas production, combustion, sewage tre atment, incinerators, petroleum refining, and VOC control. Flare rules in other ai r districts in California are generally limited in applicability to flares at petroleum ref ining operations, or the use of flares at oil and gas or natural gas sources. As previously stat ed, EPA analysis of Rule 4311 resulted in the 2012 determination that Rule 4311 is as stringe nt as requirements in other air districts in California (76 FR 68106).

The following is a brief summary of the regulatory comparisons, for the complete review of rule requirement comparisons, refer to the attachme nt (Rule Requirement Comparisons) at the end of this report.

SCAQMD Rule 1118 (Emissions from Refinery Flares) 20 SCAQMD adopted Rule 1118 (Emissions from Refinery F lares) in February of 1998. The emissions data collected as a product of Rule 1118, between 1999 and 2003, was analyzed and resulted in recommendations to further strength en emissions monitoring and reporting procedures, which led to the adoption of amendments on November 4, 2005.

The 2005 amendments prohibit the flaring of vent ga ses except in emergency situations, or during operational needs, including activities such as startups, shutdowns, and

turnarounds. The 2005 amendments also established annual SO 2 performance targets, the

20 SCAQMD Rule 1118. Retrieved from https://www.aqmd.gov/rules/reg/reg11/r1118.pdf on 12/15/13.Rule 4311 (Flares) Further Study

September 16, 2014

32 Regulatory Evaluation | SJVUAPCD requirement that flares operate in a smokeless mann er, and the requirement for annual inspections of pressure relief devices directly con nected to flares. Any refinery that does

not meet SO 2 performance targets is required to have a FMP. Th e rule also contains provisions for refineries to give 24-hour advance n otice for each large planned flaring activity, to notify SCAQMD within 1-hour of unexpec ted flaring events, and to submit quarterly reports detailing flow, emissions, and ca use of each flaring event.

EPA analysis of District Rule 4311 resulted in the 2012 determination that Rule 4311 is as stringent as requirements in SCAQMD Rule 1118, in t erms of core RACT requirements 21

. Additionally, SCAQMD recently identified the need t o evaluate flare emissions from sources other than refineries, sulfur recovery plants, and hydrogen production plants since District Rule 4311 regulates these flares and SCAQMD Rule 11 18 does not. 22

BAAQMD Regulation 12 Rule 11 (Flare Monitoring at P etroleum Refineries) 23 and Regulation 12 Rule 12 (Flares at Petroleum Refineri es) 24 On June 4, 2003, BAAQMD adopted Rule 12-11 (Flare M onitoring at Petroleum Refineries), which requires operators to monitor and record emis sions data for flares at petroleum

refineries. This rule facilitated the collection o f emissions data from refineries and resulted in the adoption of Regulation 12 Rule 12.

Regulation 12 Rule 12 (Rule 12-12) (Flares at Petro leum Refineries) was adopted on July 20, 2005 to prohibit the use of refinery flares wit hout the refinery first creating, following, and annually updating an FMP for each flare. Facil ities are required to submit flaring reports when a flare at that facility releases more than 500,000 standard cubic feet of gas per calendar day (scf/day). The flaring report mus t identify the cause, take actions if possible to avoid future flaring from that cause, a nd explain actions that will be taken. The rule also requires continuous monitoring of the fla re system’s knock-out drum water seal for leaks, and the submittal of annual reports to B AAQMD evaluating flaring events that released less than 500,000 scf/day, but emitted mor e than 500 lbs SO 2

.

21 EPA TSD (Analysis of SJVUAPCD’s Rule 4311), http://www.regulations.gov/#!documentDetail;D=EPA-R 09-

OAR-2011-0601-0022

22 SCAQMD (Board Meeting Date June 6, 2014 – Adopt the 2016 AQMP Reasonably Available Control Technology Demonstration). Retrieved from http://www.aqmd.gov/docs/defaultsource/Agendas/Governing-Board/2014/2014-jun6-031.p df?sfvrsn=2 [Page 3 of RACT Demonstration, 13th page of the PDF]

23 BAAQMD Regulation 12 Rule 11. Retrieved from http://www.baaqmd.gov/~/media/Files/Planning%20and% 20Research/Rules%20and%20Regs/reg%201 2/rg1211.ashx?la=en on 12/15/13.

24 BAAQMD Regulation 12 Rule 12. Retrieved from http://www.baaqmd.gov/~/media/Files/Planning%20and% 20Research/Rules%20and%20Regs/reg%201 2/rg1212.ashx?la=en on 12/15/13.Rule 4311 (Flares) Further Study

September 16, 2014

33 Regulatory Evaluation | SJVUAPCD EPA analysis of Rule 4311 resulted in the 2012 dete rmination that Rule 4311 is as stringent as requirements in both BAAQMD flare rules in terms of core RACT requirements.

VCAPCD Rule 54 (Sulfur Compounds) 25 VCAPCD Rule 54 (Sulfur Compounds) was adopted July 2, 1968, and last amended June 14, 1994. Rule 54 has very limited applicability in th at it is specific to sulfur compounds only. Rule 54 prohibits the discharge of sulfur compounds from any source, including flares that would exist as a liquid or gas at standard conditio ns in excess of the specified concentrations. Rule language also specifies sever al scenarios that are exempt from rule requirements including unplanned flaring, and plann ed flaring provided certain circumstances are met. Unplanned flaring is exempt from rule requirements as long as the unplanned burning of gas is for emergency or safety concerns. Planned Flaring Events are exempt from rule requirements provided specific con ditions are met. Each operator is required to submit a Flaring Management Plan to the VCAPCD that includes descriptions of measures implemented to decrease flare gas volume a nd reduce sulfur emissions, planned operational or maintenance procedures that may caus e flaring, design features of each flare system, and measures to be implemented to reduce th e number of planned flaring events.

EPA analysis of Rule 4311 resulted in the 2012 dete rmination that Rule 4311 is as stringent as requirements in VCAPCD Rule 54 in terms of core RACT requirements.

SBCAPCD Rule 359 (Flares and Thermal Oxidizers) 26 SBCAPCD adopted Rule 359 (Flares and Thermal Oxidiz ers) on June 28, 1994. Provisions of this rule apply to the use of flares and thermal oxidizers at oil and gas production sources, petroleum refinery and related sources, an d natural gas services.

Rule 359 sets specific requirements for the sulfur content in gaseous fuels, technology based standards, flare minimization plans, emergenc y events, and emission and operational limits.

Section D.3 of Rule 359 requires a FMP be submitted by any source subject to this rule that operates a flare rated at 15 MMBtu/hour or greater. For planned flaring, the FMP for all sources subject to this rule shall list a targeted maximum monthly flared gas volume, which shall not exceed 5% of the average monthly gas hand led/produced/treated at the source unless the operator demonstrates such a maximum vol ume to be infeasible based on safety, engineering or cost constraints and proposes a diff erent percentage. Any flaring that

causes an exceedance of the emission limits or stan dards of Rule 359 shall not be a violation if the operator demonstrates that the exc eedance resulted from an emergency

event.

25 VCAPCD Rule 54. Retrieved from http://www.vcapcd.org/Rulebook/Reg4/RULE%2054.pdf on 12/15/13.

26 SBCAPCD Rule 359. Retrieved from http://www.sbcapcd.org/rules/download/rule359.pdf on 12/15/13.Rule 4311 (Flares) Further Study

September 16, 2014

34 Valley Flaring Compared to Other Air Districts | SJ VUAPCD Rule 359 does not apply to the burning of sulfur co mpounds in the manufacturing of sulfur compounds. For oil and gas sources that recover sul fur as a by-product of gas treating/sweetening processes, the exemption for ma nufacturing shall apply to those specific processes (e.g., sulfur recovery plant). Additionally, flares whose flaring operations solely consist of planned, continuous flaring due t o the non-availability of a produced gas pipeline outlet are exempt from FMP requirements.

During the development of the District’s 2012 PM2.5 Plan and the 2013 Plan for the Revoked 1-Hour Ozone Standard, certain environmenta l interest groups claimed that District Rule 4311 was not as stringent as the SBCA PCD Rule 359, citing the specific flare minimization target of five percent of the total ga s produced/handled/treated. However, the comments failed to point out the second part of the requirement that states that if an operator demonstrates such a maximum volume (5%) is infeasible due to engineering, safety, or cost constraints, the facility could obt ain approval of a higher percentage. The District performed a thorough analysis of flare rul es in other air districts in California during the development of the two plans, and during the rule amendment project in 2009. The District found that while the SBCAPCD rule appe ars to include a performance standard restricting the use of flaring, it actually allows flaring under broad conditions, and Rule 4311 is at least as stringent. EPA concurs with th is assessment as illustrated by the approval of the rule as a SIP revision in 2011 27 . Therefore, EPA analysis of Rule 4311

resulted in the 2012 determination that Rule 4311 i s as stringent as requirements in SBCAPCD Rule 359 in terms of core RACT requirements

.

X. VALLEY FLARING COMPARED TO OTHER AIR DISTRICTS

The following discussion compares Valley flares to flares regulated by other air districts in California. Major differences include the types of facilities operating the flares, the capacities of the flares, and the emissions from th e flares.

Operations and Capacities A.

One major difference between Valley flares and flar es regulated in other air districts is the type of facility that employs them. Rule 4311 regu lates flaring from a variety of sources, as discussed in Section IV above (Valley Flares). Fac ility types include wastewater treatment, oil and natural gas production and processing, chee se and wine production, flat glass manufacturing, dairy operations, and a correctional facility. In contrast, flares regulated by SCAQMD, BAAQMD, VCAPCD, and SBCAPCD are employed on ly at oil and natural gas production and processing facilities. Because over 88% of flares in the Valley are operated

27 76 FR 68106, http://www.gpo.gov/fdsys/pkg/FR-2011-11-03/pdf/2011 -28391.pdfRule 4311 (Flares) Further Study

September 16, 2014

35 Valley Flaring Compared to Other Air Districts | SJ VUAPCD at oil and natural gas production facilities as wel l, it is useful to compare these facilities

between districts.

Flares in the Valley and other air districts are pr imarily engineered for emergency operation during process upsets and emergency situa tions. While they can be used during maintenance, new equipment installations, and start up/shut-down, the main concern is safety. In this regard, Valley flares are similar to those in other districts, the difference being that the facilities in SCAQMD, BAAQMD, and SB CAPCD are much larger. The facilities in those districts are mostly operated at massive o il and gas refineries, with significantly higher throughputs than those in the Valley. Tempe ratures and pressures are higher, cracking regularly occurs, and flares must be engin eering to control emergencies and process upsets on a larger scale. Flare gas is typ ically sent to a flare header, where it is distributed to multiple large flares. The flares a t these facilities are much larger in physical size, as well as capacity, as shown in the table be low.

Table 6 Flaring Capacity Comparisons (MMBtu/hr)

Air District Total Flares Median Mean Largest

District 235 33 663 40,000
SCAQMD 29 10,234 14,328 72,751
BAAQMD 23 108 14,442 246,612

VCAPCD 55 34 284 7,100

SBCAPCD 75 17 1,242 18,200

Flaring capacities of the flares in the SCAQMD, BAA QMD, and SBCAPCD are all significantly higher than the flaring capacities of flares in the Valley, while those in VCAPCD are similar size to Valley flares. Flares in BAAQMD have a wid e range of capacities, while those in SCAQMD are all greater than 1,000 MMBtu/hr. Figure 6 shows the average capacity of flares in the District, SCAQMD, BAAQMD, VCAPCD, and SBCAPCD.Rule 4311 (Flares) Further Study

September 16, 2014

36 Valley Flaring Compared to Other Air Districts | SJ VUAPCD Figure 6 Average Flare Capacities in the Different Air Districts

The size and capacity of flares in other districts explains why the San Joaquin Valley Air District with roughly ten times the number of flare s has NOx emissions nearly two times lower than BAAQMD and three times lower than SCAQMD , as illustrated in the emission inventory tables below.

Comparison of Emission Inventories B.

The flaring data in the tables below is from all fl aring activities in each air district’s jurisdiction and is provided in the ARB-maintained 2012 CEPAM: NORCAL 2012 PM2.5 SIP Baseline Emission Projection Tool.

0 2000 4000 6000 8000 10000 12000 14000 16000

District SBCAPCD VCAPCD SCAQMD BAAQMDMean Capacity (MMBtu/hr)Rule 4311 (Flares) Further Study

September 16, 2014

37 Conclusion | SJVUAPCD

Table 7 NOx Emission Inventories (tons per day)

Air

District 2012 2013 2014 2015 2016 2017 2018 2019

SJVAPCD 0.38 0.39 0.39 0.39 0.39 0.39 0.39 0.39
SCAQMD 1.19 1.20 1.20 1.21 1.22 1.22 1.23 1.23
BAAQMD 0.64 0.64 0.64 0.64 0.64 0.64 0.64 0.65

VCAPCD 0.12 0.12 0.12 0.12 0.12 0.13 0.13 0.13

SBCAPCD 0.09 0.09 0.09 0.08 0.08 0.08 0.08 0.08

Table 8 VOC Emission Inventories (tons per day)

Air

District 2012 2013 2014 2015 2016 2017 2018 2019

SJVAPCD 0.16 0.16 0.16 0.16 0.16 0.16 0.16 0.16
SCAQMD 0.40 0.41 0.41 0.41 0.41 0.41 0.41 0.41
BAAQMD 1.32 1.33 1.33 1.33 1.33 1.33 1.33 1.33

VCAPCD 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05

SBCAPCD 0.06 0.06 0.05 0.05 0.05 0.05 0.05 0.05

Table 9 SOx Emission Inventories (tons per day)

Air

District 2012 2013 2014 2015 2016 2017 2018 2019

SJVAPCD 0.25 0.26 0.26 0.26 0.26 0.26 0.26 0.27
SCAQMD 3.27 3.27 3.27 3.27 3.28 3.28 3.28 3.28
BAAQMD 0.58 0.58 0.58 0.58 0.58 0.58 0.58 0.58

VCAPCD 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08

SBCAPCD 0.18 0.17 0.17 0.17 0.16 0.16 0.16 0.15

In summary, emissions in SCAQMD, BAAQMD, and SBCAPC D are much higher per flare than in the Valley. Far less volume is flared at Valley facilities, and each facility contributes only

a small fraction of emissions. Emissions are effec tively controlled at these facilities, and the remaining flaring activity is necessary for safety. Consequently, these facilities cannot reasonably be expected to further reduce flaring.

XI. CONCLUSION

District Rule 4311 limits the emissions from flarin g activities while offering flexibility to affected industries by allowing a variety of option s to control emissions. Flaring is itself is a highly effective control technology with a 98 perce nt or greater destruction efficiency.Rule 4311 (Flares) Further Study

September 16, 2014

38 Conclusion | SJVUAPCD Additionally, flares are necessary for safety durin g unforeseeable and unpreventable emergency situations. Any unreasonable restriction s on flaring have the potential to result in catastrophic consequences which may lead to expl osions and other dangers.

This further study report was committed to as a par t of the District’s 2012 and 2013 attainment plans to allow the District sufficient t ime to review and analyze information submitted to the District by operators of flares in July 2012 pursuant to Rule 4311 requirements. Specifically, the District committed to evaluate FMPs, data from annual monitoring reports, reportable flaring event data, and two new NSPS requirements promulgated by EPA in 2012.

This thorough and comprehensive further study evalu ation has resulted in the District’s conclusion that operators of flares in the Valley a re doing their due diligence to reduce emissions from flaring in the Valley by implementin g alternatives to flaring and committing to perform activities to reduce flaring. As such, the District recommends no rulemaking

action for Rule 4311.Rule 4311 (Flares) Further Study

September 16, 2014

39 Conclusion | SJVUAPCD This page intentionally blank.Rule 4311 (Flares) Further StudySeptember 16, 2014A-1Rule Requirement Comparisons | SJVUAPCDAttachmentRule Requirement ComparisonsDistrict Rule 4311(Flares)SCAQMD Rule 1118(Control of Emissionsfrom RefineryFlares)BAAQMD Reg. 12Rule 11 (FlareMonitoring atPetroleumRefineries)BAAQMD Reg. 12Rule 12 (Flares atPetroleumRefineries)VCAPCD Rule 54(Sulfur Compounds)SBCAPCD Rule 359(Flares and ThermalOxidizers)DATES OF ADOPTION/ AMENDMENTAdopted Jun 20, 2002;Amended Jun 15,2006; Jun 18, 2009Adopted Feb 13, 1998;Amended Nov 4, 2005Adopted Jun 4, 2003 Adopted Jul 20, 2005Adopted Jul, 1968;Revised Oct 1968; Jun1969; May 1972; Jul1983; Jun 1994Adopted Jun 28, 1994APPLICABILITYAll flaresFlares used at:•Petroleum (petro.)refineries•Sulfur recoveryplants•Hydrogen productionplantsFlares used at petro.refineriesFlares used at petro.refineriesAny person whodischarges sulfurcompounds from anysourceFlares and thermaloxidizers used at:•Oil and gasproduction•Petro. refinery•Natural gas servicesand transportation•Wholesale trade inpetro./petro.productsEXEMPTIONS•Municipal solid wastelandfill flares subjectto Rule 4642•Flares subject to 40CFR 60 WWW or Cc•Stationary sourcesw/ potential to emit<10 tons VOC and<10 tons NOx perExempt from samplingand analyses forhigher heating valuesand sulfurconcentration for flareevent that:•Results fromcatastrophic event•Is safety hazard tosampling personnel;Flares and thermaloxidizers used for:•Emissions fromorganic liquid storagevessels (subj. to R. 8-5)•Emissions fromloading racks (subj. toR. 8-6, 8-33, or 8-39)Same as Rule 11(except last exemptionon list)Sulfur emission limitand avg. concentrationlimit don’t apply to:Unplanned flaring foremergency or safety if:•Not result ofintentional ornegligent act,omission, improperBurning of sulfur,hydrogen sulfide, acidsludge, or other sulfurcompounds inmanufacturing ofsulfur or sulfurcompoundsFor oil and gas sourcesthat recover sulfur asRule 4311 (Flares) Further StudySeptember 16, 2014A-2Rule Requirement Comparisons | SJVUAPCDDistrict Rule 4311(Flares)SCAQMD Rule 1118(Control of Emissionsfrom RefineryFlares)BAAQMD Reg. 12Rule 11 (FlareMonitoring atPetroleumRefineries)BAAQMD Reg. 12Rule 12 (Flares atPetroleumRefineries)VCAPCD Rule 54(Sulfur Compounds)SBCAPCD Rule 359(Flares and ThermalOxidizers)year(Not exempt fromrecordkeeping)Sulfur dioxide (SO2)emissions (emissions)from flaring eventscaused by:•External powercurtailment beyondoperator’s control•Natural disasters•Acts of war orterrorism(Not exempt from flaremonitoring systemrequirements)•Emissions frommarine vessel loadingterminals (subj. to R.8-44)Thermal oxidizersused for:•Emissions fromwastewatertreatment systems(subj. to R. 8-8)•Emissions from pumpseals (subj. to R. 8-18) (except whenemissions from pumpare routed to flareheader)Monitoring andreporting totalhydrocarbon (HC) ormethane compositiondoesn’t apply to flarethat burns flexicokergas if weekly samplingshows methane/nonmethane content ofvent gas flared is<2%/<1% by volumemaintenance orsetting of shut-insensors•Results fromoperational problems(emergencyblowdowns, processupsets, poweroutages, equipmentbreakdown)•Records of event kept•corrective measuresimmediately taken•Event lasts <24 hr.•Notify <4 hr. afterdetection and submitreport if event >1 hr.Planned flaring if:•Notice submitted >72hr. in advance,justifying work(reasons and steps tominimize sulfuremissions)•Notice can besubmitted <72 hr. ifhazardous situation,economic harm, orexcess emissions•Submit plannedby-product of gastreating/sweetening,manufacturingexemption appliesonly to those specificprocesses(Except technologybased std.) Burninggas w/ net heatingvalue <300 Btu/scf iffuel used to incinerategas has sulfurcompounds:•<15 grain/100 ft3 inSouthern Zone•<50 grain/100 ft3 inNorthern ZoneFlare and thermaloxidizer units rated<1.7 MMBtu/hr.,unless total cumulativerating of all such unitsat a source is >5MMBtu/hr. (Notexempt from sulfurcontent std.,technology std.,monitoring,recordkeeping, andRule 4311 (Flares) Further StudySeptember 16, 2014A-3Rule Requirement Comparisons | SJVUAPCDDistrict Rule 4311(Flares)SCAQMD Rule 1118(Control of Emissionsfrom RefineryFlares)BAAQMD Reg. 12Rule 11 (FlareMonitoring atPetroleumRefineries)BAAQMD Reg. 12Rule 12 (Flares atPetroleumRefineries)VCAPCD Rule 54(Sulfur Compounds)SBCAPCD Rule 359(Flares and ThermalOxidizers)flaring mgmt. plan•Records kept 2 yrs.•District notified whenwork complete•Sulfur emissions areminimized•Excess emissions feepaid to District eachyear ($5.00/lb. SO2emitted)recording.)Flares and thermaloxidizers exempt fromFMP:•Rated at <15MMBtu/hr, unlesscumulative rating >50MMBtu/hr.•Operations of onlyplanned, continuousflaring due to nonavailability of aproduced gas pipelineoutletFLARE MINIMIZATION PLAN (FMP) REQUIREMENTSFMP requirementsdon’t apply if flaringcaused by emergencyand necessary toprevent accident,hazard or release ofvent gas directly to theatmosphereFMP required forpetro. refinery flare orany flare w/ capacity>5.0 MMBtu/hr.:•Technical specs foreach flare, knock-outOwner/operator ofpetro. refineryexceedingperformance targetssubmit FMP:•<90 days from end ofyear w/ emissionsexceeding target•Plan is pursuant toRule 221 and feespursuant to Rule 306•List all actions to betaken to meet targets:oTechnical specs forflares, knock-outNoneFMP required forflares subject to ruleand 3-month statusreports required untilFMP completed:•Technicalinformation for eachflare•Upstream equipmentand processes (Sameas SJVAPCD andSCAQMD)•Equipment,processes, andproceduresEach operator submitsa planned flaringmanagement plan:•Measures to decreaseFG volume andreduce sulfuremissions•Description ofplanned operationalor maintenanceprocedures that maycause flaring•Description of eachflare systemincluding designSources subject to ruleand flares and thermaloxidizers rated at >15MMBtu/hr submitFMP:•Planned flaring:targeted maxmonthly FG volumeo<5% avg. monthlygas handled/produced/ treatedat source based on 3yearsoHigher limit may begranted by APCO ifRule 4311 (Flares) Further StudySeptember 16, 2014A-4Rule Requirement Comparisons | SJVUAPCDDistrict Rule 4311(Flares)SCAQMD Rule 1118(Control of Emissionsfrom RefineryFlares)BAAQMD Reg. 12Rule 11 (FlareMonitoring atPetroleumRefineries)BAAQMD Reg. 12Rule 12 (Flares atPetroleumRefineries)VCAPCD Rule 54(Sulfur Compounds)SBCAPCD Rule 359(Flares and ThermalOxidizers)pots, surge drum,water seal, and flaregas (FG) recoverysystem•Process flowdiagrams of upstreamequipment andprocess units ventingto each flare•Equipment,processes, orprocedures plannedto install orimplement tominimize flaring andplanned date•Evaluations ofpreventativemeasures to reduceflaring expected dueto planned majormaintenanceactivities, gasquantity and qualityissues, and recurrentfailure of equipmentor processes•Submit updated FMPevery 5 years and fornew or modifiedequipment prior topots, surge drums,water seals and FGrecovery systemsoProcess flowdiagrams ofupstreamequipment andprocess unitsventing to flaresoPolicies,procedures, andequipmentimprovements tominimize flaringand flare emissionsoFG recoveryequipment andtreatment systemsto be installed•FMPs available for60-day public reviewprior to approval•45 days allowed tocorrect deficiencies•Facility in violation ifFMP denied•Revised FMPsubmitted 90 daysafter end of year ifperformance targetsexceededimplemented in last 5years to reduceflaring and thoseplanned to beinstalled orimplemented•Prevention measures,including schedulefor implementationfor flaring:oThat has or willoccur duringplanned majormaintenanceoExpected to occurdue to issues of gasquantity and quality(include audits ofcapacities), orcaused by recurrentfailure of equipmentor processesfeatures•Description of anysulfur reductionsystem•Measures to beimplemented toreduce the number ofplanned flaringeventsdemonstrated to beinfeasible•Submit emissionsmitigation plan if:oVolume limit >10%of avg. monthly gasoSulfur content offlared gas >239ppmv/ >796 ppmvin Southern/Northern Zone•The emissionsmitigation plan mustachieve 50%reduction of greaterof actual or proposedavg. monthly FGvolume limit•Owner/operatorreimburses forreview and approvalof plansFMP includes:•Measures to decreasevolume of FG andplanned flaringevents•Measures to preventemergency flaringand unplannedRule 4311 (Flares) Further StudySeptember 16, 2014A-5Rule Requirement Comparisons | SJVUAPCDDistrict Rule 4311(Flares)SCAQMD Rule 1118(Control of Emissionsfrom RefineryFlares)BAAQMD Reg. 12Rule 11 (FlareMonitoring atPetroleumRefineries)BAAQMD Reg. 12Rule 12 (Flares atPetroleumRefineries)VCAPCD Rule 54(Sulfur Compounds)SBCAPCD Rule 359(Flares and ThermalOxidizers)installingflaring•Flare system•FG monitoring system•Design and operationfeatures of pilot andpurge gas system•Design features offlare to handlenominal and peak gasflows and range ofcompositions•Plans to reduceplanned flaringemissions•Schedules to reduceplanned shutdowns•Proposed study ofdifferent settings tominimize emissions•Summary ofscheduled/typicalplanned flaring•Review FMP every 5yearsANNUAL MONITORING REPORTSFor refinery flare orflare w/ flaringcapacity >50MMBtu/hr: Operatorsubmit annual reportSubmit quarterlyreport <30 days afterend of each quarterincluding:•Information requiredMonthly report:•Total volumetric floweach day and month•If gas compositionmonitored w/None NoneSubmitted annually, byMarch 1 of thefollowing calendaryear, including:•Monthly volumes ofRule 4311 (Flares) Further StudySeptember 16, 2014A-6Rule Requirement Comparisons | SJVUAPCDDistrict Rule 4311(Flares)SCAQMD Rule 1118(Control of Emissionsfrom RefineryFlares)BAAQMD Reg. 12Rule 11 (FlareMonitoring atPetroleumRefineries)BAAQMD Reg. 12Rule 12 (Flares atPetroleumRefineries)VCAPCD Rule 54(Sulfur Compounds)SBCAPCD Rule 359(Flares and ThermalOxidizers)<30 days after end ofeach 12 month periodincluding:•Total volumetric flowof vent gas (scf) foreach day•Contents of vent gascomposition:oHydrogen sulfideoMethaneoHC•If vent gascompositionmonitored bycontinuous analyzeror analyzers: thefollowing for eachhour of the month:oAvg. total HCcontent by volumeoAvg. methanecontent by volumeoTotal reduced sulfurcontent by volumeor hydrogen sulfidecontent by volume•Avg. molecularweight for each hourof each month (ifmeasured)•For pilot and purgeto be monitored:oTable of nineoperatingparameters, basedon flare type (cleanservice, emergencyservice, generalservice)oAlternative flarevent gas samplinginformationnecessary tocalculate flareemissionsoFlare monitoringsystem dataoImages of visibleemissionsoPresence of pilotflameoPilot gas and purgegas flow to eachflare•Total daily andquarterly emissionsof criteria pollutantsfrom each flare andeach flare event alongwith informationused to calculateemissionssampling, content byvolume for eachsample of total HC,methane, and H2S•If compositionmonitored w/continuous analyzer,avg. content byvolume of: total HC;methane; totalreduced sulfur; H2S•Avg. molecularweight for each hourof the month (ifmeasured)•For pilot & purge gasoType of gasoVolumetric flow foreach day and monthoMeans used todetermine flow•For any 24-hr periodwhen 1 million scfflared, description:oCauseoTime and durationoSourceoMeasures to reduceor eliminate flaring•Monitoring systemdowntime periodsgas flared perplanned continuousand plannedintermittent flaringcategories•Summary of total gasvolume releasedduring emergenciesand weightedaverage H2S contentfor the entire volume•Monthly reporting onany exceedance of theallowable monthlyvolume of gasesplanned for flaringRule 4311 (Flares) Further StudySeptember 16, 2014A-7Rule Requirement Comparisons | SJVUAPCDDistrict Rule 4311(Flares)SCAQMD Rule 1118(Control of Emissionsfrom RefineryFlares)BAAQMD Reg. 12Rule 11 (FlareMonitoring atPetroleumRefineries)BAAQMD Reg. 12Rule 12 (Flares atPetroleumRefineries)VCAPCD Rule 54(Sulfur Compounds)SBCAPCD Rule 359(Flares and ThermalOxidizers)gas:oType of gas usedoVolumetric flow foreach day and eachmonthoMeans used todetermine flow•Flare monitoringsystem downtime•SO2emissions foreach day and eachmonth•Flow verificationreport for each flare•Description of causeand category of eachflare event•Records of annualacoustical ortemperature leaksurvey•Flare monitoringsystem downtimeperiods•Copy of writtennotices for allreportable airreleases related toany flare event•Images recorded forthe month•Methane, nonmethane, and SO2emissions for eachday and for themonthSemi-annual flowverification report,comparing flowmeasured bymonitoring system andflow verification forsame period of timeREPORTABLE FLARING EVENT REPORTS•Definition:oFlaring event where>500,000 scf gasflared/day oroSO2 emissions >500lb/dayoEnds when waterseal integritydemonstrated oroFor flares w/owater seal, endswhen flow <0.12ft/s•Submit annual reportsummarizing allRequirements:•Notify by telephone<1 hr. of unplannedflare event w/emissions >100 lb.VOC, >500 lb. SO2, or>500,000 scf gas•Submit Specific CauseAnalysis w/in 30days – cause,duration, mitigation/corrective actionsFor any 24-hourperiod during which>1 million scf of ventgas was flared:•Cause•Time of occurrenceand duration•Source or equipmentof origin•Measures taken toreduce or eliminateflaringNotify if volume flared>500,000 scf per day:•Results of causeinvestigation•Measures to preventrecurrence•Justification forrejecting measures•Explanation whyconsistent with FMP•Explanation of whyemergency andcannot be recovered•Volume flaredFor unplanned flaring>1 hr. in duration:•Notify <4hr. afterdetection•Submit report:oDate, time, duration,volume of gas flaredoReasons for flaringoSettings pressurerelief valves andmax/min allowedsafety settingsoCorrectivemeasures andactions to preventExceedance not aviolation if emergency:•Inform <4 hr. afterstart of next businessday•Document eventoccurrence andcauses•Submit <7days afterend of event:oDescription of eventand mitigating andcorrective actionsimplementedoDemonstrationRule 4311 (Flares) Further StudySeptember 16, 2014A-8Rule Requirement Comparisons | SJVUAPCDDistrict Rule 4311(Flares)SCAQMD Rule 1118(Control of Emissionsfrom RefineryFlares)BAAQMD Reg. 12Rule 11 (FlareMonitoring atPetroleumRefineries)BAAQMD Reg. 12Rule 12 (Flares atPetroleumRefineries)VCAPCD Rule 54(Sulfur Compounds)SBCAPCD Rule 359(Flares and ThermalOxidizers)reportable flaringevents:oResults of causeinvestigationoMitigation/corrective actions toprevent recurrenceoJustification forrejecting measuresoExplanation of whyemergency andcannot be recoveredoDate, time, duration•Methane, nonmethane, HC, and SO2emissionsrecurrenceoSulfur emissionsoEquipment orcontrols that failedFor planned flaring:•Notice submitted >72hr. prior:oWork that requiresoDate and timeoExpected gasvolume and sulfuremissionsoSteps or equipmentto minimize sulfuremissionsreasonable stepstaken to minimizeexcess emissionsoDemonstration thatemergency notcaused byimproperlydesignedequipment; lack ofpreventativemaintenance;careless orimproper operation;operator error;willful misconductoDocument thatsource was properlyoperated at timeevent occurred