By: Mathew George and 

Michael Dudasko

Comparison of Two Flare Minimization ApproachesENV-09-25
OBJECTIVES

– Compare flare rules 

• One effects refineries in 

Northern California

• One effects refineries in 

Southern California 

– Have they both been effective ?– Does one prove to be a better 

approach ?

B
San Francisco Bay Area

– Bay Area Air Quality Management District (

• Five refineries• ~ 847,000 BPD

– Reg 12, Rule 11 – 6/4/2003

• Required flare monitoring

– Reg 12, Rule 12, Flare Minimization

• Required Flare Minimization Plans (FMPs) by 8/

 Comprehensive documents Subject to Public Review

• Prohibited flaring as of 11/1/2006 unless per FM
Los Angeles Area

– South Coast Air Quality Management District (SCAQ

• Seven refineries • ~ 1,070,000 BPD

– Rule 1118

• 1998 – required refineries to provide flare data• Emission reductions occurred

Year SOx (tons)2000 2,6332001 1,7932002 7542003 7352004 352
Los Angeles Area (cont.)

– Rule 1118 amended in November 2005

• Intended to reduce SOx emissions from 700 

150 tpy by 2012

• Established performance targets (tons SOx

 January 1, 2006 - 1.5 tons  January 1, 2008 - 1.0 ton  January 1, 2010 - 0.7 ton  January 1, 2012 - 0.5 ton 

• Also required basic flare process informatio

options to reduce flaring during SD / SU / TA

• If target exceeded, fees are paid, an FMP is 

subject to public review
BAAQMD and SCAQMD Comparison

BAAQMD Reg. 12, Rule 12 versus SCAQMD Rule 11. Target/Emissions Limits2. FMP Submittal Requirement 3. Basis for FMP4. Refiner Goals5. Incident Analysis6. Performance Standards7. Cost of Non-Compliance
BAAQMD and SCAQMD Comparison

BAAQMD Reg. 12, Rule 12 SCAQMD Rule No pre-determined quantity of allowable SO

2 emissions from 

a facility.

The District sdetermined qflare emissionfacility for eac

Targets/Emissions Limits
BAAQMD and SCAQMD Comparison

BAAQMD Reg. 12, Rule 12 SCAQMD Rule A FMP is submitted up front and refreshed on an annual basis (involves both District and public review). 

Submittal of binformation 2only required 

flaring events allowable for year.

FMP Submittal Requirement
BAAQMD and SCAQMD Comparison

BAAQMD Reg. 12, Rule 12 SCAQMD Rule FMP predicts events that could cause flaring of SO2.

FMP lists the flaring events preventative implemented

Basis for FMP
BAAQMD and SCAQMD Comparison

BAAQMD Reg. 12, Rule 12 SCAQMD Rule Refineries have an ability to predict their SO

2 emissions 

due to flaring and reduce to the lowest possible 

Refineries haSO

2 emission

district.

Refiner Goals
BAAQMD and SCAQMD Comparison

BAAQMD Reg. 12, Rule 12 SCAQMD Rule Root cause analysis of flaring incident greater than 500,000 SCF of vent gas and discussion of why it is consistent with the FMP (if applicable).

Relative causany other flarmore than 5,0cubic feet of vcombusted. Root cause afor flare incidthan 500 pou

500,000 SCF 

Incident Analysis
BAAQMD and SCAQMD Comparison

BAAQMD Reg. 12, Rule 12 SCAQMD Rule Relative to the operatorproposed FMP and comparison to the peer refiner FMPs

Absolute to thtarget

Performance Standards
BAAQMD and SCAQMD Comparison

BAAQMD Reg. 12, Rule 12 SCAQMD Rule None specified. Flaring is prohibited unless approved in FMP or deemed necessary in an emergency to prevent an accident, hazard or release of vent gas directly to the atmosphere. Would follow normal Notice of Violation process.

Public Reviewthe FMP and paid to Distric$25,000 to $1in excess of ttarget with a yearly cap of 

Costs of Non-Compliance
California Refinery Flare Emissions

Total Annual SOx Emissions

0

100200300400500600700800

2004 2005 2006 2007 

Year

Annual SO2 (Tons)SCAQ

BAAQ

2000 SCAQMD = 2,633 tons
Pounds per BPD (Nameplate)

0.000.200.400.600.801.001.201.401.601.80

2004 2005 2006 2007 

Year

Annual SO2 (Pounds/BPD) SC

BA

California Refinery Flare Emissions
Conclusions

– Flare emissions have reduced dramatically in both r– It appears that the SCAQMD performance targets c

San Francisco Bay area refineries to date

– The SCAQMD target (tons of SOx per MM Bbls 200

does not allow for capacity creep and for the accou

intermediate feedstock

– Current performance targets in SCAQMD managea

refinery to date required to submit a FMP

– One incident can be significant and obscure the imp

that refinery or even for the entire air basin (magnifiwith lower capacity basis)

– Too early to tell whether the SCAQMD and BAAQM

achieved greater reductions; further reductions in Sand 2012 will test the parallel District performance f
Questions ?

Mathew George (Long Beach)mathew.george@aecom.comMichael Dudasko (Oakland)michael.dudasko@aecom.com