COf\ITININTAL RFFINING C{}MPANY

May 8,2013

VIA CERTIFIED MAIL

Kentucky Department for Environmental Protection

Secretary of the Energy and Environment Cabinet

300 Fair Oaks Lane

Frankfort, KY 40601

U.S. Environmental Protection Agency

Office of Air Qualrty Planning and Standards

Sector Policies and Programs Division

U.S. EPA Mailroom (E143-01)

Attention: Refinery Sector Lead

109 T.W. Alexander Drive

Research Triangle Park, NC 27711

refiner:tnsps@epa.gov

Re: Continental Refining Gompanv ("GRG"I- NSPS Subpart Ja "Flare Manaqement Flan"

501 Refinerv Road. Somerset. KY 4250f

To whom it may concern:

ln accordance with 40 C.F.R. 60.103a(b), please find enclosed the written flare management plan for CRC's

petroleum refinery in Somerset, Kentucky. CRC previously submitted the enclosed plan with its Title V permit

application, transmitted to KDEP on September 20, 2412.

lf you have any questions please contact me at 606-679-6301, x1005.

Sincerely,

Floyd @%J. Hoffer

Environmental Compliance Manager

cc: File

/ Attachments

3AO REFINERY RAAD SOMERSET, KY 42547 TELEPHONE 606.679"6301
1

FLARE MANAGEMENT PLAN

501 REFINERY ROAD, SOMERSET, KY 42501

SEPTEMBER 18, 2012

Connected Equipment and Systems          (Figure 1)

(1) Relief from Crude Desalter SD‐4001

(2) Relief from Crude Distillation Tower T‐4001

(3) Relief from Hydrotreater Sulfur Guard Bed V‐2009

(4) Relief from Naphtha Desulfurization Reflux Drum V‐2002  

(5) Relief from Naphtha Splitter T‐2001

(6) Relief from Stabilizer Reflux Drum V‐1002

(7) Relief from Stabilizer T‐1001

(8) Relief from Kerosene Reflux Drum V‐3003

(9) Relief from Kerosene Stripper T‐3001

(10) Relief from Kerosene High Pressure Drum V‐3002

(11) Relief from Separator V‐1001

(12) Relief from Hydrogen Compressor  [inherently low sulfur]

(13) Relief from Naphtha Desulfurizer High Pressure Drum V‐2001

(14) Relief from Sour Fuel FG Drum V‐9001

(15) Relief from Sweet Fuel Gas Drum V‐9002

(16) Relief from NAHS Reactor R‐9001

(17) Relief from Crude Gas Trap V‐9006

(18) Vapor from Vapor Recovery Unit Compressor  

Source Reduction / Minimization

The refinery has been in idle status since February 10, 2010.  Following ownership and name change in

December 2011, C & I Engineering of Louisville, Kentucky was commissioned to review and assess the

facility for optimum operation in its current configuration and to provide for future expansion.  The

process started with a complete review of the current systems and generation of updated Process and

Instrumentation Diagrams (P&ID’s).  Concurrent with this activity, inspections of tanks, process vessels,
2

and process piping were conducted.  Only limited modeling and process operation optimization was

possible from operating data available during the brief operational period from June 2009 to February

2010.   

Relief valves from all sources were removed for inspection, repair, set point verification, and functional

integrity.  They will be re‐installed prior to startup.

Written procedures are followed to minimize gas routed to flare during operational startup and

shutdown.

One outcome of the C&I assessment was a recommendation to replace the relief header and flare

system to provide adequate capacity for the anticipated relief scenarios in the plant’s current

configuration, and to provide for possible expansion in the future. Key elements of the project scope

include:  

(a) Elimination of three process reliefs to the atmosphere (from the Crude Unit Desalter, the Crude

Unit Fractionator, and the Naphtha Desulfurizer’s Naphtha Splitter tower).  The discharge for

these three relief valves will be connected to the plant’s redesigned relief header and flare

system.  

(b) Installation of new, higher capacity relief headers throughout the system  

(c) Installation of a new, larger knock‐out drum upstream of the flare

(d) Installation of a new, larger capacity air‐assisted flare  

(e) Demolition of the existing relief headers and the existing flare

Although the new relief headers and flare system will have greater capacity than the existing system,

crude oil throughput will not exceed the 5500 BPD specified in our current Title V operating permit. In

fact, we expect the plant to operate at about 1500‐2000 BPD for the first month of operation, and

gradually increase as operating experience is gained and operating data becomes available to support

optimization efforts. If plant optimization or future projects indicate that the plant would be capable of

processing more than 5500 BPD, we will apply for a revision to our Title V permit to accommodate the

higher throughput.

Valid assessment of opportunities and measures to reduce, minimize, or eliminate discharges from

connected sources can be effectively accomplished with availability of real time operating information.  

Assessment of installation of a flare gas recovery system is not possible at this time for the same reason.  

As operating data is obtained, cost / benefit determinations of improvement opportunities can be

quantified.  The Flare Management Plan will be updated / revised accordingly.   

Flare Description

The existing flare, designated as Source ID 4 and KyEIS ID #04, will be demolished.  The existing flare

system will be replaced by construction of a new 10” header, 5.67’ dia. x 23’ long knockout drum, 60’

overall high x 24” dia. outer riser x 10” dia. inner riser flare stack, triple pilots, automatic ignition,
3

thermocouple, and control system.  Design of the header system is provided by C & I Engineering and

the flare and control system is provided by HERO Flare, Bastrop, Texas.

(1) The flare is elevated.  (2) The flare is air assisted.  (3) The flare tip is simple. (4) The flare is

primary, is not part of a cascaded system, and is not a backup to another flare.  (5) The flare

functions in a non‐emergency capacity to combust excess plant generated fuel gas, excess gas

generated during plant startup and shutdown, and gas generated by equipment malfunctions

and process upsets.  (6) The flare will not, initially, be equipped with a flare gas recovery system.

(2) The flare header is designed with a 1 degree slope to avoid liquids accumulation and to minimize

sweep gas requirements.  A velocity seal, shown as VS‐10 in the flare tip detail drawing, coupled

with purge gas serves to prevent air and / or flame from being pulled into the flare stack or

header.

Figures 1, 2, 3, 4, 5, and 6 provide details of the new flare system as follows:  

Figure 1: Block Flow Diagram of 10” header, relief header connections, knock out drum, metering,

and flare.  

Figure 2: Knockout Drum V‐8003 connection schematic

Figure 3: Flare Stack diagram

Figure 4: Air Assist Flare Tip [ 10’ high x 26” dia. plenum x 10” internal riser ]

Figure 5: Flare Ignition Equipment [ Control Panel and Mounting Rack ]

Figure 6: Flare design specifications

        

Pilot and purge gas to the flare is natural gas purchased from the City of Somerset and is inherently low

sulfur with an average heating value of 1250 Btu/scf.  Aggregate natural gas flow to supply the three

pilots is 6.12 Mscf/day.  Design purge gas rate is 50 scf/hr (1.2 Mscf/day).  Plant generated fuel gas is

monitored for H2S content at a single point downstream of the NAHS unit and prior to routing to

process combustion units in the facility.  Excess fuel gas routed to the flare is therefore, monitored.

Gas discharged to flare is measured and monitored downstream of the flare knockout drum V‐8003.  A

Panametric flowmeter is used to measure total flow.  Analyzers will monitor H2S concentration and

Total Reduced Sulfur in accordance with 40 CFR 60.107a (f)(1), (e)(1), and (e)(2).  

Baseline Flow to the Flare

Baseline gas routed to flare is estimated from the operating period June 24, 2009 through December 31,

2009.  During this period the current flare operated for a total of 5004 hours and combusted a total of

1.77 MMscf (pilot and sweep gas excluded).  Crude throughput during this period varied considerably,

from 1200 bpd to 3000 bpd, and exact correlations of throughput rates to flared volumes at this low
4

volume would have little value.  Initial baseline for plan use is, therefore, the average gas to flare over

this period – 8.5 Mscf per day.  We have, at this time, no special conditions for which alternative

baseline(s) are warranted or can be established.

Procedures for Planned Startup and Shutdown

Written procedures for planned startup and shutdown of plant process and ancillary equipment are

undergoing review prior to restart of operations.  Any identified improvements which will result in

reduction or elimination of gas routed to flare will be implemented immediately.  Procedural reviews

conducted subsequently, as driven by process changes or engineering recommendations, may result in

additional reductions in gas routed to flare.

Historically, imbalance of fuel gas needs at our facility has varied seasonally and with variations in crude

oil received and processed.  Following startup and as progression occurs with time and throughput

rates, assessments will be conducted to identify opportunities to reduce excess fuel gas routing to the

flare.  Real time operational data is necessary to make these assessments and to implement procedural

or operating parameter solutions.  We plan to conduct the first such assessment upon reaching a crude

oil throughput rate of 4000 bpd and make use of operating date obtained at each preceding rate.

Investigation of Abnormal Incidents or Conditions  

Formal investigation of an operating condition or process upset resulting in a discharge to the flare of

500,000 scf over baseline volume in a 24 hour period or combustion generated emission of 500 lb. or

more SO2 will be conducted to determine the root cause of the occurrence and to identify

implementable corrective actions.  Threshold flared volume necessary for generation of 500 lb. of SO2

will be determined from flow and monitoring data.

Plan Amendments, Revisions, and Updates

As a minimum, plan reviews will be conducted on an annual basis.  Reviews will be conducted more

frequently following startup as crude throughput rates are ramped up and operating data is obtained.  

Reviews will be conducted in conjunction with planning and design of equipment changes,  for

modifications, for plant process expansions, and in follow up to change implementations.  Revised or

amended plans will be submitted per Subpart Ja requirements.




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PLENUM DETAIL 1. FAERICATION PER AISC

2. FULL PENETRATION AND PIPE WELDS TO BE PER ASME BJI.3

3, WELDING PER AUIS 01.1

FI.ARE TIP INLET CONNECTION - 1" PI.AIE

30" 0D y{/12 3/+6 AN 28" BoLT CTRCLE

FI.ARE RISER, 10", SCH IO, WEL.DED, 31655

ArR PLENUM, 26' RolLtD PLAIE, l/+',, 316SS/CS

PILOT, AUTO SPARK IGNI1ED WTH THERMOCOUPLT

P|LoT GAS, 3/8'TUBTNG, MAN|Fo|"D T0 CoMMoN Po|NT

coNoutT FoR tcNmoN & Tc UR|NG (oNE pER prloT)

l-i ero Flc re

704 Hwy 71 West St 0400 Bostrop, TX 78602

Tel: (512) 772-5744 www.heroflore.com

AA1 OX26

AIR ASSIST TIP

THE INFORMATION ON THIS DRAWNG 

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THE PROPERTY

OT HERO FARE. UNAUIHORIZED USE 

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Qualrtl'flarer that wnrk er'€ry time.

704 Hwy 71 West, Suite D400

Bastrop, Texas 78602

September 1.,20L2

To: Continental Refining

Attn: Mr. Demetrios Haseotes

Reference: A2005-F-002 HI2I45 Rev 1

Air Assisted Flare for Continental Refining

Are you looking for a high quality flare for a reasonable price? HERO Flare specializes in high

quality flares for gas plants and storage facilities. Our staff includes three engineers with over 40

years of combined flare design experience. We perform the process and mechanical engineering.

Our fabricators have designed and built flares for many yea.rs. Every design is independently

checked for process and mechanical accuracy. Field technicians are available for installation,

startup assistance and training.

The proposed flare meets the inquiry specifications and data sheets. The stainless steel flare tip

will resist heat damage and corrosion. An oversized flare tip allows the maximum flare flow

without exceeding EPA regulations. The electronic ignition pilots can be easily accessed by a

manlift. The flare tip and pilots meet all EPA regulations including destruction efficiency.

There are many advantages to these gas flare including:

. We guarantee that the flare tips will prevent flame instability.

o The flare tip will prevent smoke formation.

o The capacity, pressure drop and emissions will not exceed guaranteed values.

. The flare tip will meet EPA regulations for tip velocity and pilot monitoring.

r The flare pilots are fully automatic, electric spark design with flame monitoring.

o We can deliver the flare quickly. We have recently built two other fast track, nearly identical

flares.

We look forward to working with you as this project progresses.

Best regards,

Da^ri^d, G'dzry

HERO Flare

David Giles

David. giles@herofl are. com

713 5420925

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C&I / Continental Refining

9i I i 1l R*i,: I

Data Sheet

Design Basis

Inlet Nozzle 10" 150# RF (CS) with 10" riser

Flare Height 60 ft

Number of Pilots Three Fixed, Spark Ignited

Design Flowrate NDS HP: 0 - i5430lblhr of 6.8 MW gas

Kerosene Stripper: 0-17560 lblfu of 92 MW gas

Cases are not simultaneous.

Inlet Pressure Per specification.

Gas Temperature Per Specification

Smokeless Flow 12,000 lb/hr Kerosene Stripper

100% flowNDS HP Case

Max Tip Velocity Not to exceed EPA regulations.

Max Radiation (API) less than 500 Btu/hrlSF normal.

Less than 1500 Btu/hrlSF at peak rate.

Emission Guarantees

1. The flare will operate without smoke at the design conditions.

2. HERO Flare guarantees a 987o or greater hydrocarbon destruction efficiency when operating

at the incipient smoke point (per TCEQ test data).

3. HERO Flare guarantees that the flare will be stable over the entire operating range.

4. The flare will meet EPA requirements for pilot operation, lower heating value and tip

velocity.

Utilities

Pilot Gas (per pilot) 85 scth at 5 psig. Clean, dry natural gas.

Ignition Gas None required.

Plant Air None required. (except for panel purge system)

Electricity Control Panel: l20Yl 1 Ph - 2 arnps

Blower: 480V I 3ph I 60}{z - 25 BHP

Purge Gas 50 scfh natural gas (normal flow exceeds purge rate)

Mechanical

Design Wind Speed 100 MPH

Corrosion Allowance I/16" on outer stack.

Ambient Temperature -5 to 105oF

Site Elevation 1000 ft

Electrical Area Class 1, Div 2, Gr C&D

Control Panel Tlpe Nema 4X (Stainless steel with Bebco Zpurge)

Motor Rating TEFC, Premium Duty suitable for VFD
C&I / Continental Refining

9'' I I i: ilrrj I

Equipment Description

Air Assisted Flare System

The air assisted flare mixes low pressure blower air with the flare gas at the tip to prevent smoke

formation. The tip design is well proven and has lasted well in previous applications. This

design has been used on hundreds of gas flares with good success. The flare gas is ignited by a

continuously sparking pilot. The flare pilots will withstand high winds without going out. The

flare system includes:

o The flare height will minimizethermalradiation and SO2 ground level emissions.

o Self supported stack complete with chair base ring (CS).

o The air riser is the main support structure. Initial design is 36" diameter base with24"

upper stack / air plenum.

. The main flare gas line is supported inside the stack. 10" std wall. A53B CS.

o Flare stack and tip will be shipped as one piece (if possible due to shipping regulations).

o The flare will be ready to lift and set upon arrival at site.

o Lifting lugs. Single piece lift design. No elevated field welds required.

o Tailing lugs.

. Complete stress analysis and NDT on lifting lugs. Lifting calculations included.

o One Air Assist Flare Tip with internal gas distributor. 316 stainless steel for temperature

resistance.

r Velocity seal for purge gas reduction.

o Air blower for smokeless operation. Blower is mounted on client foundation.

o Blower includes inlet slide control damper.

o The blower includes a TEFC motor, premium duty suitable for a client supplied VFD

drive and motor controls.

o Three Flare Pilot Model SP8 pilots to light the flare gases. The pilot is stable in all wind

conditions. Stainless steel construction for long life.

. The pilot is lit by an electric spark ignitor which continuously sparks every 2-3 seconds

whenever the panel power is turned on.

o Pilot flame monitoring system. A thermocouple continuously monitors the pilot flame

status. Dry contacts are included for remote indication of pilot status.

o Nema 4X (stainless) control panels mounted on structural rack.

o Bebco Z purge system to meet Div 2 area classification

o Pilot gas valve train mounted on control rack.

o Pilot gas lines along with thermocouple and ignition cable to grade.

. Mechanical drawings and operating manual.

t API 537 datasheets completed to matchflare equipment.
C&I / Continental Refining

9iiil2 Rev I

Optional Items

Delivery

HERO normally contracts with a local company to deliver the flare systems. Fabrication shop

would be an Austin, TX shop (Skotz Welding).

Our clients are welcome to pickup the equipment at the fabrication facility or use their prefered

freight service.

Onsite Field Installation Advisor

A freld technician can assist and advise your local contractor on installing the flare and panel.

Most installations are much less than one day. A typical flare installation includes:

o Install ground anchors for guy wire support.

o Set flare stack, attached guy wires, tension and plumb stack.

o Set control panel.

o Wire between pilot and control panel.

o Connect natural gas or propane with stainless tubing.

o Test pilot spark ignitor. confirm pilot flame if fuel gas is available.
C&I / Continental Refining

Q"i.1I Rrl l

Flare Manufacturing Standards

The fabrication shop maintains quality control documentation and welder's qualifications which

are available for our client's review. Inspectors have access to the facility upon short notice.

General Industry Standards

Welding - Structural: ANSI 83i.3

AWS D1.1

Pipe Flange:

Pipe Threads:

150 Lb ANSI

NPT

Weld Inspection: ASME V Electrical Wirine: NEC

Drawing Dimensions: Enslish Structural Design: ASCE latest version

Materials of Construction

Component Size Material Connection End Termination

Flare Stack 36/24" A53B Pipe / ,4.36 Buttweld 150# RF

Flare Gas Riser 10" A53B/A106 Buttweld 150# RF

Flare Tip 10" 316 SS Full oenetr. 150# RF

Pilot Gas Pioine 3t8" Stainless tubine Swagelok Swaeelok

Conduit 314" std salv risid NPT

Non-Destructive Testing

Dimensional Check: All exterior and mounting dimensions

All We1ds: 100% Visual lnspection

RadioeraphyA{DT: As requested bv client at cost.

Hvdrostatic testins: Not applicable.

Material certificates: All stainless steel.

Painting

Comoonent Sandblast Shop Paint

Carbon Steel Stack SSPC-SP6/10 Hero Standard Paint Spec

Valves and Control Panel Manuf. Std. Manufacturers Standard

Stainless steel None None
C&t / Continental Refining

9,'I' il {i;:r. !

Pricing and Commercial Terms

Pricing

60ft air flare, self supported with three automatic pilots, blower/motor $300,000

To release engineering through drawing completion. This will also

cover the long lead item purchase orders.

$50,000 included in

eqt Price

Optional Items

Base rins temolate of steel $4.500

Comolete spare pilot and key control panel intemals $8,000

Delivery is Prepay and Add. We expect delivery to cost less than

$5000. The blower/motor freight will be about $1000. Template

hotshot is around $1000.

Field Service Rates

Base rate including travel time

Lodging and subsistence (overnight stay)

Vehicle mileage

Air Fare / Rent Car (if anv)

$1200/day

$150/day

$1/mile

Cost+20Vo

Terms & Conditions

o We normally accept the standard terms and conditions contained with our client's purchase

order. We can not accept unlimited liability or consequential damages.

o Prices are quoted in US funds, FOB point of manufacture. Pricing does not include any state,

federal or locai taxes. Shipping costs will be charged at cost and added to the last invoice.

o Prices quoted are valid for 30 days.

. Terms of payment: 25o/o down I 65% upon completion and inspection that the flare

meets proposal specs / 5olo upon receipt of all engineered drawings / 5o/o upon successful

startup.

o Invoices are due I00% net 30 days after invoice. Downpayment is wire transfer upon order.

Schedule u Standardda Deli e

Drawing Package 0-1 week after order or release to begin engineering

Fabrication Complete 4-5 weeks after order

The blower, controls will be ordered on Day 2. The flare stack

will be released for fabrication on Day 3. All vendors have

committed to shipping before Sept 30, 2012. Guaranteed

delivery date is October 5,2012.

Cancellation

If the work is canceled for any reason, we shall invoice for all work completed or in progress at

the time of cancellation. A project cancellation fee equal to 20Yo of the remaining project work

at the cancellation date will be charged.

Warranty - Mechanical

We warrant all equipment to be free from material or workmanship defects for 18 months after

shipment or 12 months after first operation, whichevel occurs first. We shall require all

equipment vendors to pass through their standard warranty to the end user. The equipment
C&I / Continental Refining

9llll2 Rev i

warranty covers replacement parts, but excludes freight, freld labor or backcharges. We can

supply the formal warranty statement upon request.

Warranty - Process

The flare will match the specifications of this (and previous) proposals and will perform to the

process requirements in the original client specifications, including EPA compliance

specifications.

Contact Information

HERO Equipment LLC

704Hv'ry 71 West, Suite D400

Bastrop, Texas 78602

Direct: 512 772 5744

Fax: 5127725743

Federal Tax ID: 45-3861476

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