Date: January 11, 2010 

To: Docket ID No. EPA-HQ-OAR-2007-0011 

From: Kristin Parrish Sroka 

Subject: NSPS Subpart J Review: Meeting Minutes for July 16, 2009, Conference Call 

Between the U.S. EPA and Representatives of Lion Oil 

Introduction

On June 30, 2009, representatives of the U.S. Environmental Protection Agency (EPA) 

and their contractor (RTI International) participated in a stakeholder conference call with 

representatives of Lion Oil Company (Lion Oil). The names and affiliations of the participants 

are included in Attachment 1. Attachment 2 contains the background information provided by 

the Lion Oil representatives prior to the conference call. Attachment 3 contains more detailed 

information regarding flare sampling provided by Lion Oil in response to the EPA’s request 

during the call. The purpose of the conference call was to discuss the requirements for 

monitoring flares in NSPS subpart Ja, particularly for flares with flare gas recovery systems. 

Discussion

The Lion Oil representatives noted that they have safety concerns with testing and 

Relative Accuracy Test Audit (RATA) requirements that would require operators to be close to a 

flare. They noted that, for safety reasons, personnel must stay a certain distance from the flare at 

all times and must wear protective clothing before they can approach any closer. No one is 

allowed to climb up to the flare tip because flares cannot be isolated and there is no way to be 

sure that no gas will be flared while a worker is close to the flare. They noted that to comply 

with safety requirements, a monitor would have to be located at least 125 feet from base of flare, 

and depending on the height of the flare, that could be 200 feet from the flare tip. 

In addition, the Lion Oil representatives noted that the sulfur concentration can range 

from less than 10 ppmv up to 50,000 ppmv. They stated that it is difficult to span a monitor to 

accurately measure that range of concentrations. For the above reasons, the Lion Oil 

representatives asserted that for flares that rarely experience flaring events, there are better ways 

to quantify emissions than monitoring. 

The Lion Oil representatives stated that the flares at their refinery are used mostly as 

control devices, and they usually collect more than 99 percent of the gas sent to the flare. 

Although they try to use excess fuel gas in the hydrogen plant as much as possible, the refinery 
 

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occasionally has more fuel gas than needed for current operations (i.e., is long on fuel gas) and 

must flare the excess. 

The Lion Oil representatives then described their flare gas recovery system 

configurations and their emissions estimation procedures. Both the high pressure flare and low 

pressure flare at the refinery have flare gas recovery systems with a knockout drum and water 

seal. Each system has staged compressors, one of which is always running. The pressure is 

monitored so that additional compressors can start up when needed. Regarding the location of 

the water seal (see diagram in Attachment 2), the Lion Oil representatives noted that their 

configuration was designed by John Zink Company and they are not sure how many other flare 

gas recovery systems in the petroleum refining industry might be designed with the water seal in 

the same location. 

The differential pressure is monitored at the water seal, and a pressure exceedance that 

breaks the water seal is considered a flaring event. Lion Oil calculates flaring event emissions 

using the monitoring results for pressure, flow rate, and composition of the flare gas. The flow 

rate is monitored by a Panametrics flow meter between the knockout drum and flare. During a 

flaring event, a sample of the flare gas is collected and analyzed using gas chromatography (GC). 

The GC analysis is typically measuring hydrogen sulfide (H2S) and organic compounds; the Lion 

Oil representatives noted that it may be possible to measure total reduced sulfur if necessary. 

The Lion Oil representatives then identified specific issues with the EPA’s proposed 

monitoring provisions for subpart Ja. First, although the compressors in their flare gas recovery 

system are closely calibrated, the second and third compressor cannot start up instantaneously 

without burning out the motor. Instead, it takes about 1 to 5 minutes for the additional 

compressor to be fully operational. Lion Oil is reporting all of these “burps” because the H2S 

concentration is above 160 ppmv. The Lion Oil representatives noted that these “burps” are 

likely exempt from the 160 ppmv H2S limit because they are process upsets, but they choose to 

report all of them as emissions exceedances rather than having to prove that each exceedance is 

caused by an upset. However, the Lion Oil representatives did note that this practice increases 

the amount of time needed to prepare semiannual reports. In addition, they are worried that this 

practice, although environmentally conservative, opens them up to accusations of violations. 

Going forward, the Lion Oil representatives noted that they would continue to quantify 

emissions for compressor staging “burps,” but they would like to avoid having to do a root cause 

analysis for each exceedance, particularly because there is not much they can do to prevent the 

“burps.” They requested that the EPA add a provision to subpart Ja that states if the water seal 

breaks but emissions are below 500 pounds of sulfur dioxide (SO2) per day, a root cause analysis 

is not needed. They also noted that it would help if the EPA could clarify whether the “burps” 

are really violations. 

Another issue the Lion Oil representatives noted with the subpart Ja standard as it applies 

to flares with flare gas recovery systems is the format of the concentration limit and how 

averages are calculated. Even one minute of flare gas with a concentration of 50,000 ppmv 

(5 percent) H2S causes the flare to exceed the 3-hour 160 ppmv concentration limit. However, 

because their recovery system is state-of-the-art and highly efficient, the Lion Oil representatives 
 

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feel they would be better able to meet a percent reduction target. The Lion Oil representatives 

suggested that the EPA should provide an option to consider a flare with a flare gas recovery 

system to be a control device required to meet a percent reduction emission limit. They also 

noted that a de minimis bright line would help define gray areas. The Lion Oil representatives 

noted that they would be happy to meet with the EPA again to further discuss their recovery 

system and their specific requests. 

The EPA representatives agreed that it would be ideal for the provisions of subpart Ja to 

be written such that installation of flare gas recovery systems is encouraged. They noted that the 

monitoring systems on the flare gas recovery system at the Lion Oil refinery seem to be good for 

quantifying emissions, and they noted that sampling during a flaring event is a good compromise 

between continuously monitoring the sulfur content of flare gas and no monitoring at all. 

Regarding root cause analyses, the EPA representatives noted they would consider allowing 

facility to explain upfront that “burps” are the result of compressor staging. Regarding the de 

minimis bright line, the EPA representatives noted that it is difficult to draw a bright line because 

other recovery systems are not as good as the one at Lion Oil, particularly regarding the 

quantification of SO2 emissions. The EPA representatives requested a description of the 

monitoring system for the record, including cost estimates for sampling and laboratory labor. 

(The information provided by Lion Oil following the call is included in Attachment 3.) 

Finally, the EPA representatives and Lion Oil representatives discussed the answers to 

the questions posed in Attachment 2. For Item 1, the EPA representatives noted that if the H2S 

concentration of a gas stream is being continuously monitored to ensure compliance with the 

160 ppmv concentration limit, the facility could use the H2S-to-sulfur ratio option to determine 

the total reduced sulfur concentration in that stream. The Lion Oil representatives then noted 

that they have one fuel gas system providing fuel gas to the flares as well as other combustion 

devices. They asked, assuming that all the gas being flared is from the fuel gas system, whether 

they would be permitted to use the information obtained from a boiler’s SO2 continuous 

emissions monitoring system (CEMS) to estimate SO2 emissions from the flare (rather than 

determining the H2S-to-sulfur ratio). The EPA representatives noted they would consider 

whether to provide that option. 

The EPA representatives agreed with Items 2 and 6. They also agreed with Item 3, with 

the caveat that their response to Item 1 would have to be taken into account. For Item 5, they 

agreed that continuous monitoring is meaningless when there is no flow, but they noted they had 

not yet decided how to handle that issue. According to 40 CFR part 60, a source is required to 

have valid data for four quadrants of an hour, but they recognize that is not always likely to 

happen. 
Attachment 1 

Participants in July 16, 2009, Conference Call 

Industry Representatives

Ray Callahan, Ergon 

George Garten, Lion Oil Company 

Chuck Hammock, Lion Oil Company 

U.S. EPA Representatives

Bob Lucas 

Brenda Shine 

RTI International (EPA contractor)

Jeff Coburn 

Kristin Parrish 
Attachment 2 

Background Information 

Flare Monitoring Questions 
Conference Call to Discuss Questions about Flare Monitoring under proposed 40 

CFR 60, Subpart Ja 

Thu 07/16/2009 10:00 AM - 12:00 PM 

Chair: George.Garten@lionoil.com 

Location: Conference Call 

Required: Bob Lucas/RTP/USEPA/US, Chuck.Hammock@lionoil.com, Paul.Young@ergon.com 

Time zones: This entry was created in a different time zone. The time in that time zone is: Thu 07/16/2009 

9:00 AM CDT11:00 AM CDT 

Mr. Lucas 

Please find the call in information below. I have also attached a copy of the questions we submitted for 

those on the meeting invitation who may not have a copy. 

<<Lion Oil Company Subpart Ja Flare Monitoring Questions.pdf>> 

Call in Information Below: 

(888) 472-4293; 7994380 
Flare Monitoring Questions

Background Information

Lion Oil Company ("Lion Oil") installed flare gas recovery units ("FGRU's") on the two flare systems at

its refinery in EI Dorado, Arkansas. The FGRU's at Lion Oil are adequately sized and have not one but

two back up compressors in parallel for each flare. The FGRU withdraws gas from the flare header

upstream ofthe liquid seal drum and recovers gas that would normally be burned in the flare. The recovery

system operates to maintain a slight positive pressure on the flare header upstream ofthe liquid seal drum,

which ensures that air is not drawn into the flare system or the FGRU. When gas is relieved to the flare

system, the compressors automatically stage up to handle the increase in volume to the flare system. This

process is not instantaneous and Lion Oil often experiences very small flaring releases, even though the

cono'ol system is a state-of-the-art design.

When the refinery is fuel rich excess sweet or NSPS fuel gas is introduced into the flare above the water

seal as shown in the attached diagram. This excess fuel gas is monitored by the refinery fuel gas H2S

monitor as required by Subpart J-Ja. The additional natural gas purge streams indicated on the drawing are

used for flare safety purposes and are exempt from monitoring under the inherently low sulfur exemption.

Discussion

40 CFR 60.1 07a, Monitoring of emissions and operations for fuel gas combustion devices, states in

60.107a (d) that the owner or operator of an affected flare subject to §60.1 03a (b) shall install, operate,

calibrate, and maintain an instrument for continuously monitoring and recording the concentration of

reduced sulfur in flare gas. The owner or operator of a modified flare shall install this instrument by no

later than 1 year after the flare becomes an affected flare subject to this subpart.

(I) The owner or operator shall install, operate, and maintain each reduced sulfur CEMS according to

Performance Specification 5 of appendix B to part 60.

(2) The owner or operator shall conduct performance evaluations of each reduced sulfur monitor according

to the requirements in §60.13(c) and Performance Specification 5 of appendix B to part 60. The owner or

operator shall use Methods 15 or 15A of appendix A-5 to part 60 for conducting the relative accuracy

evaluations. The method ANSlIASME PTC 19.10-1981, "Flue and Exhaust Gas Analyses," (incorporated

by reference-see §60.17) is an acceptable alternative to EPA Method 15A of appendix A-5 to part 60.

(3) The owner or operator shall comply with the applicable quality assurance procedures in appendix F to

part 60 for each reduced sulfur monitor.

Based on the required monitoring in 60.107a (d) Lion Oil Company has several questions and areas of

concern.

Safety Issues

Thermal radiation exposure during a flaring event is a concern for Lion Company. Locating a probelsample

line system in the flare stack and a CEMS building in close proximity presents an opportunity for thermal

exposure for refinery and testing personnel. ANSlIAPl Standard 521 recommends that flare system design

and plant equipment layout should minimize the need for operator exposure when at all possible.

Conducting routine maintenance, RATAs would require personnel to be in danger ofthermal exposure.
Flare Monitoring

I. The attached diagram shows the relative location of each gas stream entering into the flare. The drawing

shows that when the refinery is fuel rich, which is defined as having excess refinery fuel gas, this gas is

introduced into the flare above the water seal in a separate line. This excess fuel gas is part ofthe refinery

common fuel gas system and is less than 160 ppm H2S and is monitored by the refinery fuel H2S gas

analyzers.

a) Lion Oil Company's interpretation is that since the excess refinery fuel gas meets all ofthe

Subpart J fuel gas requirements and has previously been monitored it would not have to be

monitored for TRS. Does EPA agree?

2. Also you will notice on the diagram some natural gas streams that are introduced to the flare for safety

purposes.

b) Based on Lion Oil Company's interpretation these streams are exempt from TRS monitoring

based on the fact that purchased Natural Gas is inherently low sulfur.. Does EPA agree?

3. Based on the fact that Lion Oil Company has interpreted that both the natural gas and the excess refinery

fuel gas is exempt from TRS monitoring that would leave monitoring just the sour gas for TRS during the

times when the water seal is broken during a flaring event.

c) Does EPA agree?

4. Assuming that the sour gas line is the only line that needs to be monitored for TRS then a better

approach from a safety standpoint would be to monitor the horizontal line coming to the flare. This

approach would limit the likelihood ofthermal exposure by refinery personnel. Monitoring in the

horizontal will also reduce the CEMS sample system length allowing for a more reliable system.

d) Does EPA agree with the monitoring approach in the horizontal?

5. Based on the above monitoring interpretations the sour gas stream would be exempt from the monitoring

requirement in 60.102a (g)(ii) for compliance with the 3-hour rolling average 160 ppm H2S standard. This

horizontal line is stagnant except during flaring events that break the water seal. Monitoring for the

purpose of developing a 3-hour rolling average for H2S is meaningless considering the majority offlaring

events are very short in duration and the next flaring event could potentially be several hours, days or

weeks later making it impossible to meet the valid data requirements of 40 CFR Part 60 and calculate a

valid 3-hour rolling average.

e) Does EPA agree with this approach as well?

QA/QC

6. The horizontal line to the flare from the FGRU is a stagnant line except during a flaring event. As

described above the flaring events are not long in duration or predicable making conducting a RATA on a

stagnant line virtually useless as far as 40 CFR Part 60 is concerned. Lion Oil Company proposes to

conduct 4 quarters ofCylinder Gas Audits in lieu of conducting an annual RATA.

f) Would EPA agree with this approach?

Attachment 3 

Follow-up Information 

Requested Flare Sampling Information 
From: "George Garten" <George.Garten@lionoil.com> 

To: Bob Lucas/RTP/USEPA/US@EPA 

Cc: Brenda Shine/RTP/USEPA/US@EPA, "Chuck Hammock" <Chuck.Hammock@lionoil.com>, 

"Ray Callahan" <Ramon.Callahan@ergon.com> 

Date: 07/24/2009 12:40 PM 

Subject: RE: Requested Flare Sampling Information - Lion Oil Company 

Mr. Lucas 

Please find the attached flare sampling description that was requested during our conference call on July 

16, 2009. Please contact me with any questions or additional information requests. We are available if 

you feel an additional conference call would be beneficial. Thanks again for your consideration 

concerning this matter and we look forward to hearing from you and your staff. 

Sincerely, 

George Garten 

Lion Oil Company 

mailto:george.garten@lionoil.com

870.864.1453 (voice) 

870.864.1165 (fax) 

<<Lion Oil Company Flare Gas Sampling Information .pdf>> 
Lion Oil Company ("Lion Oil") has installed flare gas recovery units ("FGRU's") on

the two flare systems at its refinery in EI Dorado, Arkansas. The FGRU's at Lion

Oil are adequately sized and have not one but two back up compressors in

parallel for each flare. The seal for each flare system consists of a 30 inch water

seal which is located at the base of each flare stack. (See Figure 1A)

The FGRU withdraws gas from the flare header upstream of the liquid seal drum

and recovers gas that would normally be burned in the flare. The recovery

system operates to maintain a slight positive pressure on the flare header

upstream of the liquid seal drum, which ensures that air is not drawn into the flare

system or the FGRU. When gas is relieved to the flare system, the compressors

automatically stage up to handle the increase in volume to the flare system. This

process is not instantaneous and Lion Oil often experiences small flaring

releases, even though the control system is a state-of-art design. There are other

process unit startups, shutdowns and malfunctions that also result in these micro

flaring events.

The above mentioned water seal is monitored on a continuous basis and when

the water seal is broken, which indicates a flaring event is occurring a signal is

sent to the sample collection system to begin the sampling sequence. There is a

delay in the sample collection in order to make sure the horizontal flare line has

been purged, which allows for collection of a representative sample. After

completion of the delay a solenoid opens allowing the flare gas sample pump to

fill the sample canister with a gas sample from the horizontal flare line.

When the water seal is broken, an automatic email is sent to Lab personnel,

Operations personnel and the Environmental department. The lab personnel then

collect and analyze the flare gas sample via GC and provide the results to the

Environmental Department for emissions quantification. The sample gathering

and analysis takes about 1 hour.

The emissions are quantified using the flare gas analysis and the monitored flow

during the flaring event. The flow is measured using a Panametrics measurement

system that corrects for temperature, pressure and also measures molecular

weight.

The flare gas sample collection system consists of a sample pump, heated

sample line, in-line filter, solenoids and sample canister. The sample system

currently utilized was designed in house at a cost of approximately $5000-10,000

(See Figure 1B). A similar type system has been developed by Texas Sampling

(www.TexasSampling.com) at an approximate cost of $26,000-$30,000. (See

Figure 1C)