THIS PAGE INTENTIONALLY LEFT BLANK

# Suncor Energy (U.S.A.) Inc.

Commerce City, Colorado

NSPS Subpart Ja Flare Management Plan

Gasoline Benzene Reduction Unit (GBR) Flare

5801 Brighton Boulevard
Commerce City, Colorado

Adams County

April 201 4Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan i 

## TABLE OF CONTENTS

Section 1 Introduction

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

- 1

1.1 Facility Description

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

- 1

1.2 NSPS Ja Applicability

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

- 1

1.3 Revisions to the Flare Management Plan

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

- 2

1.4 Flare Management Plan Contents

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

- 3

Section 2 Description of Flare Systems

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

- 1

2.1 Flare Type

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

- 1

2.2 Flare Tip

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

- 1

2.3 Flare Head er System

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

- 2

2.4 Knockout Drum

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

- 3

2.5 Flare Gas Recovery System

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

- 4

2.6 Water Seal

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

- 4

2.7 Assist System

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

- 4

2.8 Pilot Gas

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

- 5

2.9 Ignition System

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

- 5

2.10 Pur ge Gas

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

- 6

2.11 Sweep Gas

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

- 6

2.12 Supplemental Gas

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

- 7

2.13 Monitoring Instrumentation

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

- 7

2.13.1 Vent Gas Flow

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

- 8

2.13.2 Sulfur Content

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

- 9

Section 3 Flare Minimization

................................ ................................ .............................. 3

- 1

3.1 Description of Contributions to Flare Header

................................ .................... 3

- 1

3.2 Minimization Assessment

................................ ................................ ................... 3

- 1

3.3 Baseline Flow Evaluation

................................ ................................ ................... 3

- 3

3.4 Startup and Shutdown

................................ ................................ ......................... 3

- 6

3. 5 Fuel Gas Imbalance

................................ ................................ ............................ 3

- 7

3.6 Fuel Gas Recovery Outage

................................ ................................ ................. 3

- 7

Section 4 Root Cause Analysis and Corrective Action

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

- 1

4.1 Root Cause Analysis

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

- 1

4.1.1 RCA

– Flow Exceedance

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

- 2

4.1.2 RCA

– SO 2 Exceedance

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

- 2

4.2 Corrective Action Analyses

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

- 4Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan ii LIST OF APPENDICES

Appendix A Plan revision log Appendix B NSPS Ja Cross

- Reference Table Appendix C Process Flow Diagrams Appendix D Flare Tip Drawing Appendix E Alt. Test Method 099

- Approval of Optical Flow M eters for FlaresTHIS PAGE INTENTIONALLY LEFT BLANKSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 

## SECTION 1

INTRODUCTION

1.1 Facility Description

Suncor Energy ( U.S.A .) Inc. ( Suncor ) owns and operates a petroleum refinery in Commerce City, Colorado ( Commerce City refinery)

. The Commerce City refinery is a 98,000

- barrel

per

- day refinery that produces gasoline, distillate fuel s , and paving

- grade asphalt.

In 2012

, Suncor completed a project at the Commerce City refinery to construct a new process unit at Plant 1 of the refinery to saturate benzene in the reformate stream. The project, referred to as the Gasoline Benzene Reduction (GBR) Unit , was necessary in order
for Suncor to comply with Mobile Source Air Toxic rule (MSAT 2), which requires refiners to produce gasoline with low benzene content. The construction of the new GBR Unit
included the construction of the GBR flare.

1.2 NSPS Ja Applicability

The most recent promulgation of the petroleum refinery N ew S ource P erformance S tandard (NSPS) is contained within 40 CFR 60 Subpart Ja . NSPS Ja applies to fluid catalytic cracking units (FCCU), fluid coking units (FCU), delayed coking units, fuel gas combustion devices, flare s, and sulfur recovery plants.

According t o NSPS Ja 60.1 01a , the definition of a F lare is as follows :

“Flare means a combustion device that uses an uncontrolled volume of air to burn gases. The flare includes the foundation, flare tip, structural support, burner, igniter, flare controls ( including air injecti on or steam injection systems ) , flame arrestors

, an d the flare gas header system. In the case of an interconnected flare gas header system, the flare includes each individual flare serviced by the interconn ected flare gas header system.”

An affected flare under NSPS Ja is one for which construction, modification or reconstruction commenced after June 24, 2008. A modification to a flare occurs when a project that includes any of the following activities commences:

 Any new piping from a refinery process unit, ancillary equipment, or a fuel gas system is physically connected to the flare; or

 A flare is physically altered to increase the flow capacity of the flare

. However, the following activities do not, by themselves, constitute a modification:

 Connections made to install monitoring systems to the flare;

 Connections to install or enhance a flare gas recovery system;

 Connections made to replace or upgrade existing pressure relief or safety valves;Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 1

- 2  Connections made for flare gas sulfur removal;

 Con nections made to install redundant equipment associated with the flare, provided they do not increase the capacity of the flare;

 Replacement or relocation of pipe “in kind” ; or

 Connections that interconnect two or more flares.

The GBR Flare ( FLR

- 6 as it i s referenced in the facility Air Permit ) construction was

co mplete d in May 20 12 . Under the rule, the GBR Flare is subject to the requirements and compliance timeframes of a “ new flare ” since it was initially constructed after the NSPS proposal date of Jun e 24, 2008.

NSPS Ja contains work practice provisions that are applicable to refinery flares 1 . These work practice standards, as well as the applicability triggers for flares, were proposed to be changed in the Federal Register dated December 22, 2008 2

. On September 12, 2012, the
revised NSPS Ja standards were finalized and published in the Federal Register.

The work practice standards of 60.103a(a) require the prep aration of this F lare Management Plan (F MP )

. As the GBR flare system is considered to be a single

, new affected source that
is subject to the rule , the Commerce City refinery m ust develop and implement a FMP for the

GBR flare by no later than 60 days after the rule was published in the Federal Register, or November 13, 2012. The Commerce City refinery is required to submit a copy of this initial
FMP to the EPA and maintain a copy of the initial FMP until it is revised. See Section 1.3
for operational changes w hich t rigger a revision to t he FMP

.

1.3 Revisions to the Flare Management P lan

The FMP and all documents referenced herein should be internally reviewed and updated periodically to account for changes in the operation of the GBR flare system. These changes include, but are not limited to, adding new connections to the flare head er system or the
installation of a flare gas recovery system

. The Commerce City refinery is required to
maintain a copy of the current FMP

. I t is recommended that one copy be placed in a central,

easy

- to

- access location so that the FMP can be provided to agency inspectors in the event of

an agency visit

. It is important to note that n ot all events which trigger the need for an internal revision of the FMP require a re

- submission of the revised FMP to the United States Environmental

Prot ection Agency (US EPA ) Administrator. The rule requires the FMP to be re

- submitted to the Administrator for one of the following four reasons:

 A dd ition of an alternative baseline flow rate,

 R evis ion of an existing baseline,

 I nstall ation of a flare gas re covery system

, or

 C hange of flare designations and monitoring methods.

1 40 CFR 60.103a

2 73 FR78522, dated December 22, 2008Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 1

- 3 A Plan Revision History log is included in Appendix A . The log should be utilized to
document all periodic changes to the FMP

, both the internal revisions and the revisions that

are submitted to the Administrator

.

1.4 Flare Management Plan Contents

This FMP fulfills the requirements of NSPS Ja regarding the development of a written FMP and has been prepared pursuant to the requirements and provisions of the rule. Appendix B
includes a table that cross

- references the specific requirements of NSPS Ja and their location
within this FMP. The following information is specifically required to be included in or referenced by this FMP :

 Listing of all process units, ancillary equipment , and fuel gas systems that are
connected to the flare header system ;

 Flare minimization a ssessment ;

 Descriptions of all flare components and design parameters ;

 Specifications for all required monitoring instrumentation ;

 Baseline flow evaluation ; and

 Procedures to reduce flaring during planned startup s and shutdown s , during

imbalances of the fuel gas system , and during outages of the fuel gas recovery

system

.

T his Plan also includes or references information which is not explicitly required to be

i ncluded in the FMP under NSPS Ja. The inclusion of this supplemental information enables

the FMP to fully document the management practices and flaring minimization measures and strategies that are in place. The following supplemental information is prov ided in or referenced by this FMP :



###  Description of triggering events and compliance timeframes for Root Cause Analys es (RCAs) and Corrective Action Analyses and Implementation ; and,

 Details of the required records, reports, and notifications.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 

## SECTION 2

DESCRIPTION OF FLARE SYSTEMS

This section outlines the details of the GBR flare system and its components. Appendix C includes process flow diagrams depicting this flare system.

2.1 Flare Type

The GBR fla re is an elevated flare. An elevated flare consists of a tip that is mounted on a
flare stack , which is raised high above grade

, and supports combustion at the upper end of a
vertical riser . T he combustion zone is elevated in order to separate the heat generated by combustion from people, equipment, or structures at grade level and to aid in air dispersion.

Per the definitions cont ained in the rule, this flare is a non

- emergency flare that is not cascaded and does not operate as a backup flare.

The GBR flare is a self

- supported elevated flare that stands 2 49 feet above the ground, with a

156 ” diameter base. The diameter of the flar e tip is 28 ”

. The flare has a m aximum design capacity of 491,018 pounds per hour ( lb/hr ) of hydrocarbon flow and has a smokeless capacity of 73,655 lb/hr of hydrocarbon flow

.
The flare includes a fixed velocity seal within the flare stack to limit the possibility of air infiltration through the flare tip into the flare stack and header . The velocity seal is located at the base of the flare tip and out of the flame zone.

2.2 Flare Tip

The function of the flare tip i s to mix the flare gas and assist gas at velocities, turbulence, and concentration required to establish and maintain proper ignition and stable combustion for the maximum specified relief gas flow rates at the system

- allowable pressure drop. Although
the GBR normally has a low base load of flare gas in the flare system during normal operations , the largest concern with respect to the flare system is its ability to handle the rare yet large emergency flaring events. The design of the flare tip is an integ ral part of the flare system because it enables the refinery to handle large variances in the volume, pressure drop, concentration, and temperature of the flare gas streams.

The GBR flare tip

, which was installed in April 201 2

, is a 28 ” diameter tip design ed by

Zeeco Inc.

, model number QFSC

- 24/28

. Based on a review of the flare tip drawings, the flare tip appears to be unobstructed by the steam ring and pilot assemblies; therefore the effective diameter of the tip is approximately 2 8 ”. It consists of a si ngle burner equipped with steam assist gas

. The upper s team is supplied through a single 4 ” steam supply pipe, radially

, using a 40 ” dia meter external steam ring with 18 star

- shaped steam diffusers arranged outside of the flare stack circumference. The center steam injection includes a single internal steam injection nozzle using a 1.5 ” supply pipe centered inside the stack and just above the velocity seal , but below the plane of the flare tip, thus causing no decrease ofSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 2

- 2 the effective tip area

. There a re no lower steam nozzles inside the effective area of the flare tip. Each of the two steam supply lines can be controlled independently

. The minimum tip
and center steam requirement for continuous cooling and protection of the tip is 630 lb/hr and
350 l b/hr, respectively

. A drawing of the tip is included in Appendix D

. Further information on the steam assist system can be found in Section 2.7

.

2.3 Flare Header System

According to the definitions promulgated in Subpart Ja, the flare gas header system is
defined as :
“all piping and knockout pots, including those in a subheader system, used to collect and transport gas to a flare either from a process unit or a pressure relief valve from the fuel gas system, regardless of whether or not a flare gas recovery system draws gas from the flare gas header system. The flare gas header system includes piping inside the battery limits of a process unit if the purpose of the piping is to transport gas to a flare or knockout pot that is part of the flare.”

The primary function of the flare gas header is to safel y accumulate and transfer gases to the
flare for combustion. In addition to hard

- piped connections for normal operating conditions,
the flare gas header also has connections for equipment depressurization and p urging for maintenance activities, such as startup, shutdown, and turnaround.

The flare gas header provides the process units with a controlled low

- pressure outlet for any excess vapor flow that originates with high

- pressure operations within the refinery . Nearly
all refinery vapors are flammable, making the flare gas header an essential safety feature of every refinery. The flare gas header relieves the pressure and lowers the temperature of the gas, rendering the gas safe to both equipment and surround ing personnel.

In the GBR flare gas header system there are currently 2 9 process connections to th is
dedicated flare header. These process connections are made utilizing continuous vents, manually operated valves, control valves, relief valves ( R Vs) , and sample connections . The
connections are detailed in Table 2

- 1 below.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 2

- 3 Table 2

- 1. PSV Connections to GBR Flare Header System

Type Description Quantity

Continuous Vented Pump Seal Pots 12

Sample Analyzer Building 1

Sample Sample Port Purges 3

RV Overhead OF 1

RV Fuel Gas to KO Drum * 1

RV Splitter Overhead Drum 2

RV Light Reformate Guard Beds 2

RV BERT Tower Overhead Drum 1

RV BERT Tower 1

RV H2 Guard Beds 1

Manual Light Reformate Guard Beds 1

Manual Fuel Gas to KO Drum Drain * 1

Control
Valve From BERT Overhead 1

Control
Valve From PC 1108 1

*These sources originate outside of the GBR unit battery limits.

2.4 Knockout Drum

The hydrocarbon liquid knockout (KO) drum removes any potential liquid hydrocarbons from the flare gas prior to combustion. Generally, liquid hydrocarbons cannot be safely or completely burned in most flare systems. KO drums contain a specified amount of liquid
that is monitored and mainta ined to ensure proper operation

. Most KO drums utilize a mist eliminator, located upstream of the gas outlet, to enhance the knockout drum’s performance by removing suspended water droplets that are entrained in the vapor streams.

The GBR K nockout D rum , D

- 3924, is a horizontal vessel that is located on the main flare gas header upstream of the flare stack. The inner diameter of the vessel is 1 26 inches and the length, from tangent to tangent , is 34 feet. The Maximum Allowable Working Pressure ( MAWP ) i s 50 psig and the Maximum Allowable Working Temperature ( MAWT ) is 500° F.

The flare gas continues to the flare stack, while the liquid that accumulates in the boot of the

KO vessel is pumped to the Sour Water Collection Drum (D

- 260) by pumps P

- 3914 and P

3915 (in

- line spare) . The level in the boot is controlled with a high level switch, L SH

- 2310

, which provides a high level alarm to trigger pumps P

- 3914 and /or P

- 3915 to start to lower
the water level in the KO Drum. P ump P

- 3924 is connected to the KO Drum to remove any
accumulated hydrocarbons by pumping the material to crude tank T

- 58. L evel transmitter s LT

- 2300A and LT

- 2300B monitor the hydrocarbon liquid level in the vessel and trigger pump P

- 3924 to start to remove the hydrocarbon layer in the KO Drum.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 2

- 4 2.5 Flare Gas Recovery System

According to the definitions promulgated in Subpart Ja, flare gas recovery system is

“a system of one or more compressors, piping and the associated water seal, rupture disk or similar device used to divert gas from the flare and direct the gas to the fuel gas system or to a fuel gas combustion device.”

The GBR flare at Suncor Commerce Ci ty does not utilize a flare gas recovery system.

2.6 Water Seal

Water seals , if present, are generally located downstream of the knockout drum or at the base
of each flare. Liquid (typically water) is maintained at a certain level in the seal drum to create a barrier which seals the flare gas header from the flare stack and burner tip . The maximum height of liquid in the seal must be determined by the maximum exit back pressure
allowable in the flar e gas header

. For this specific case, t he GBR flare does not utilize a water seal. The addition of a water seal would require the facility to perform an engineering and safety study to re

- evaluate the pressure settings for the in

- process RVs to ensure pro per function as safety release devices.

2.7 Assist System

A ssist gas is added to the flare tip to encourage additional flame zone turbulence, improved air entrainment, and thus, improved combustion efficiency and the reduction of smoke
formation . Care must be taken to ensure the combustible mixture of the combined gases is not diluted by excess use of assist gas.

The GBR flare is a steam assisted flare. The flare receives both tip steam and center steam

, which are both provided at approximately 175 psig

. Ste am is delivered to the flare tip by
means of two parallel control valve s ( FV

- 2401 A and FV

- 2401B )

. The tip steam line is
reduced from 6

- inches to 4

- inches to feed into the external steam ring

. The tip steam flow is
monitor ed by two flow transmitter s (FT

- 2401A and FT

- 2401B ) and viewed in the Light Oil control room. Steam supply to the tip is adjus ted by a flow control device s ( FC

- 2401 A/B ).

Once FC

- 2401A, which controls the low flow range steam, is opened to 100%, then FC

2401B is automatically opened to control the high flow range steam to supply any additional
steam needed. The flare tip is monitored by a video camera fixed on to the flare line of sight and is monitored on a color display located in the Light Oil control room. If smoke is observed, the steam is manually increased by remote operation from within the control room to stop the smoking. The m aximum tip steam flow rate is 28,976 lb/h r

. Center steam is
del ivered to the flare stack just above the velocity seal by means of 1.5 inch piping. The center steam flow is monitored by a flow transmitter (FT

- 2402 ) and viewed in the Light Oil control room. The center steam supply line has a manual 0.5 inch globe valve that is sized
for continuous minimum flow of 350 lb/hr. The center steam valve cannot be remotely operated and can be manually adjusted only in the field. It is not adjusted to respond toSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 2

- 5 smoking events. The minimum steam additions for thermal conditioning of the flare tip is 350 lb/hr of center steam and 630 lb/hr of ring steam.

2.8 Pilot G as

Pilot gas is introduced through the pilot tip s of a flare in order to provide a flame to reliably ignite the flare. If the pilot is unreliable, the potential for unburned hydrocarbons and/or toxic gases releasing to the atmosphere increases drastically and may result undesirable
health e ffects, vapor

- cloud explosion, and/or odor problems. Since the flare must be removed from service to maintain or replace a pilot, pilot system s are designed to operate for extended period s without requir ing maintenance.

The GBR flare has three natural gas fueled pilot lights that are paired with redundant thermocouples (TE

- 2401

– 2406 ) , which are operational at all times

. If the temperature on those thermocouples drops below 350 ° F, the automatic ignition system (see Se ction 2.9) immediately attempts to re

- ignite the inactive pilot

. The pilot lights are spaced at 120 degree intervals around the flare tip. The pilot gas flow rate is adjusted by a 1

- inch Pilot Gas Regulator ( PCV

- 2407 ) to a design flow rate of 186 scf/hr total (61.9 scf/hr per pilot)

. PCV

2407 has a maximum design rating of 250 scf/hr

. The design heat release for each pilot is 58,678 Btu/hr

. The pilot gas flow rate is maintained at all times and spread evenly to all three pilots. The flow is regulated by a n orifice with a 3/64” bore size . The pilot orifice drilling is based on 947.34 B tu/scf gas with 0.62 specific gravity.

The pilot lights at all three flares are fueled by purchased , pipeline quality, natural gas . The

NSPS Ja rule in 60.107a(b) explic itly allows all pilot gas lines associated with the GBR flare to be exempt from sulfur content monitoring as they are considered inherently low in sulfur

content . Therefore, an analysis of the H 2 S concentration in the pilot gas is not required.

2.9 Ignition System

Pilot ignition is a critical concern because without a flame, there will be no flare gas
combustion

, and a pilot light is required to ensure that a flame remains always present.

The ignition equipment functions to reliably light the pilot. The t wo ignition types described
below are used for the GBR flare:

1. Automatic

- Spark ignition at the pilot tip is easy and simple to automate. Spark generation is located so that it is exposed to the combustible flare gas stream that exits the tip. T his is the primary ignition system for each of the pilots.

2. Flame

- Front Generator (FFG) System

- The compressed

- air flame

- front generator ignition system is the most widely

- used flare ignition system and is utilized as backup for each of the existing pilots

. Co mpressed air and fu el are introduced through a sparking device located downstream of the mixing chamber with the pilot tip. A flame front that ignites the pilot is sent through the piping when the flare gas stream is ignited by the sparking device. The pr imary advantage of the compressed

- air flame

- front generator is that both the sparking device and flow controls are located at ground level and can be maintained andSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 2

- 6 repaired without removing the flare from service. However, the primary disadvantage of thi s ignition system is with its propensity for moisture formation in the piping leading to the pilot, which, if corrosive, may potentially render the ignition system useless. Therefore, it is common to flush each ignition line after
use to reduce the moistu re problem.

The GBR flare ignition system consists of three pilot lights, all of which are continuous. All three pilots have an automated high energy ignit ion (HEI) system with a manual FFG system as backup. Ignition gas is supplied through the Pilot Gas Regulator, PCV

- 2407

, when the HEI system is used. When the FFG system is used, ignition gas is supplied through a 1

- inch control valve, PCV

- 2401

. When the HEI system is activated, the ignition sequence takes place for 1 minute to light the pilot

. If the pilot cannot be lit, an alarm alerts the operator to manually start the flame using the FFG System. When the FFG system is used, an operator standing at the ignition panel within proxi mity to the base of the flare manually closes the gas valve once the pilot flame has been visually detected through the control panel sight glass

. Ignition at the pilot tip can take 1

- 2 minutes.

2.10 Purge Gas

According to the definitions promulgated in Subpart Ja, purge gas is

“ G as introduced between a flare’s water seal and a fl are’s tip to prevent oxygen infiltration (backflow) into the flare tip. For flares with no water seals, the function of purge gas is performed by sweep gas (i.e., flares without water seals do not use purge

gas ) ”

. All flare systems have the propensity for flashback, in

- line detonation, and potential explosion in the flare stack if oxygen enters through the flare burner and travels dow n the flare stack. A continuous purge is therefore necessary to prevent atmospheric oxygen from entering down through the flare burners

. The purge is an injected gas designed to provide a minimum continuous momentum flux upward thru the flare ti p ensurin g no reversal of flow
and so that no intrusion of air that could create an ignitable mixture.

For flares with no water seals, such as the GBR flare, the function of purge gas is performed by sweep gas. See Section 2.11 for information regarding sweep gas

. The GBR Flare does not utilize any purge gas.

2.11 Sweep Gas

Sweep gas is defined as:

“ G as introduced in a flare gas header system to maintain a constant flow of gas to prevent oxygen buildup in the flare header. For flares with no water seals, sweep gas
al so performs the function of preventing oxygen infiltration (backflow) into the flare tip”.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 2

- 7 The GBR flare was put in place using the philosophy to install natural gas sweep s for major collection headers in the flare system. The volume of each sweep shall be adequate for a velocity of 0.1 feet per second in the header. The total volume of sweep gas required will depend on flare tip requirements, type of fl are seal, and control systems.

The GBR flare gas header utilizes a 3⁄4”

- inch natural gas supply line at the beginning of the flare header to provide the initial introduction of sweep gas. The sweep gas flow rate required to meet the design specification is 300 scf/hr. The sweep gas flow is monitored using flow indicator FI

- 1707. The sweep gas flow rate is generally not adjusted and remains

constant.

Downstream of the process connections to the GBR flare header

, the flare header diameter increases from 14 inches to 24 inches. At this point of diameter increase, a second sweep gas
line is connected to the header. This second sweep gas addition point is required

, in conjunction with the first, to maintain the appropriate continuous exit velocity of flare gases thru the velocity seal below the flare tip. This minimum flare exit velo city was determined by Zeeco to require an addition al minimum injection of 630 scf/hr of sweep gas.

Because natural gas, according to the rule, is inherently low in sulfur concentration, NSPS Ja offers provisions that allow gas lines that are exclusively natural gas to be exempted from sulfur content monitoring. Therefore, an analysis of the H 2 S concentration in the sweep gas to demonstrate compliance with the rule is not required.

2.12 Supplemental Gas

Supplemental gas is gas that is introduced to the flare in order to comply with the net heating
value (NHV) requirements of 40 CFR §60.18(b) and/or 40 CFR 63.11(b). Supplemental gas is used as a calorific boost to the vented gas to ensure optimal combustion. When combustible gases are used for sweep gas or pu rge gas, it simultaneously functions as supplemental gas.

T he GBR flare does not have a dedicated supplemental fuel gas line that is used to increase the heating value of the combusted flare gases . However, since natural gas is utilized for the

sweep gas , it simultaneously functions as supplemental gas

.

2.13 Monitoring Instrumentation

Monitoring of key parameters, such as flare performance, gas stream flow rate and composition, heating value, assist gas flow rate, pilot flare presence, and process unit perfo rmance, enables a facility to identify, respond to, and correct most flaring activities. Monitoring helps t o ensure proper flare operation and provide reliable data for emissions calculation. Without proper monitoring, it is impossible to know whether a flare is performing according to design specifications. Improving the reliability, completeness, and accuracy of flare data is expected to promote flare reduction activities and prioritize potential
future investments

. Reliable data is vital for effective and consistent enforcement of flaring regulations. It also informs operators of the potential economic losses resulting from flaring.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 2

- 8 Therefore, a rigorous flare monitoring and reporting pro gram is integral to a facility’s ability
to reduce fla ring to the maximum extent possible.

Flare monitoring devices do have specific limitations of accuracy and these limitations should be well understood by the operators and regulators. For example, flares potentially operate over a very wide range of flo w rates. Normal vent gas flow rates are typically a fraction of the overall maximum design capacity. In this example, flow meter technology should be assessed to provide the most accurate data within the range of most likely flow

rates. It is also impor tant that any recommendations regarding monitoring devices of a flare system will be based on prior analysis of reliable data derived from the actual monitoring of the system. This principle applies to all flare monitoring devices or equipment.

NSPS Ja id entifie s monitoring scheme s to demonstrate compliance with the rule

.

2.13.1 Vent Gas Flow

NSPS Ja requires the GBR flare to operate with a flare gas header flow meter that provides a representative measurement of the total flow rate discharged to each flare. The flow rate data that is collected will be used to determine if flaring events occur that exceed the Root Cause Analysis (RCA) thr eshold of 500,000 scf in a 24

- hour period above the established baseline. The following standards for the flow met er are required pursuant to the rule in 60.107a(f)(1) :

 Must be located in a position that is representative of the total gas flow rate,

 Must have a flow sensitivity of no more than 5% of the flow rate or 10 scfm, whichever is greater,

 M ust be maintainable online , and

 M ust continually correct for pressure and temperature and record flow in standard conditions,

The GBR flare use s a GE Panametrics GF868 Flare Gas Flow Meter System with T5
Ultrasonic Flow Transducers to measure the flow rate to each flare. Th e GF868 is manufactured according to the specifications in the rule , and the Suncor Commerce City refinery has ensured that the GBR flare flow meter is installed in a representative location

, thereby complying with the selection and installation of the flow meter . The following table
summarizes the specifications of the GF868 as provided by the manufacturer’s datasheet

.
Table 2

- 2 : Flow Meter Specifications

Required Information Monitor Information

Make General Electric

Model DigitalFlowTM GF868

- 1

- 11

- 20014

- FM

- 0

- 0

Type Panametrics Ultrasonic Flare Gas Mass Flow Meter

Range 0.1 fps to 328 fps

Precision Repeatability = ±1%
Accuracy ±2 .4 % to 5%Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 2

- 9 Maintenance and calibrations on the GF868 are conducted per manufacturer’s recommendations and are in compliance with the April 5, 2013 US EPA published
Alternative Test Method 099

– Approval of Optical Flow M eters for Flares. This alternative
test method is included as Appendix E

.
T he flow meter (F E

- 2301A/B , DCS tag No. FI

- 2301A/B ) is located downstream of flare KO Drum, D

- 3924. The meter configuration is a single

- channel bias

- 90 setup with temperature and pressure corrected readings. The pressure and temperature sensor s that are configured
with FT

- 9006 ar e PT

- 2302 (DCS tag No. PI

- 2302 ) and TT

- 2302 (DCS tag No. TI

- 2302 )

, respectively

. The pressure and temperature readings are used to automatically correct the raw flow meter reading to standard condition flow rates and are reported to the DCS

. Baseline flo w evaluation is discussed in Section 3.3

.

2.13.2 Sulfur Content

NSPS Ja requires th at a flare should operate a monitor ing device to measure the sulfur content of the gases combusted in the flare to demonstrate compliance with the H 2 S
concentration limit of 162 ppmvd and to determine if the SO 2 emissions have exceeded the threshold for conducting an RCA (500 pounds in a 24 hour period) . However

, if the gases combusted in the flare are inherently low in sulfur , the rule allows the Commerce City Refinery to apply for an exemption from sulfur monitoring

. The exemptions for sulfur monitoring are provided in §§ 60.107a(a)(3)(i) through (iv)

. The

process gases that constitute the feed to the GBR Unit meet the requirements of 60.107a(a)(3)(iii), which allows ga s streams that are produced in process units that are
intolerant to sulfur contamination to be considered inherently low in sulfur content

. Specific examples that are provided in the rule of units that are intolerant to sulfur include hydrogen plant s and catalytic reforming units, which are the very units at Suncor that generate the specific feed for the GBR u nit. Additionally, t he GBR unit utilizes guard beds that function

to remove sulfur, chlorides, and free water from the feed streams to further reduc e the
amount of sulfur fed to the GBR unit

. Therefore, because each of the gas streams that are
routed to the GBR flare header meets the requirements to be considered inherently low in sulfur, the Commerce City Refinery is not be required to monitor the s ulfur concentration of flare gas in the GBR flare header.

Although sulfur concentration analysis of the GBR flare header may not be required, t he Suncor Commerce City refinery voluntarily installed

, maintained , and certified an H 2 S
monitor on the GBR flare for operational purposes to ensure that there was negligible sulfur content generated from the GBR unit

. On February 7, 2014 Suncor submitted an Administrative Amendment (Administrative Amendment No. 9 to Title V Permit No. 96OPAD120) to the Colorad o Department of Public Health and the Environment (CDPHE) that proposed the decommissioning of the H 2 S monitor at the GBR flare. This Administrative Amendment was approved on the grounds that the flare streams generated by
the GBR unit are inherently low in sulfur.

Based on an analysis of the GBR H 2 S data, Suncor and the CDPHE agreed to use a constant

H 2 S value of 0.07 ppm to estimate emissions from flared gas. This information was incorporated into Appendix H of the above

- referenced Title V Permit. T he H 2 S monitor hasSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 2

- 10 been decommissioned and is no longer being used to demonstrate compliance, nor is it being maintained per 40 CFR 60 Appendix F.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 

## SECTION 3

FLARE MINIMIZATION

3.1 Description of Contributions to Flare Header

As detailed in Se ction 2.3, the process connections to the GBR header consist of RVs, pump seal vents, sample points, and manual service valves. The process contributions from each type of connection are as follows:

 Relief valves are utilized in the process as emergency r elief device s that will release gases into the flare header to prevent an unsafe pressure buildup in a process vessel ;

 Pump seal vents are used to discharge any gases that accumulate in the pump seal pots of the liquid seal pumps ;

 Sample points are connect ed to the flare header to allow the sample line to be purged
to ensure that a representative sample to be obtained.

 Manual valves are generally used to remove process gases that have condensed out of process gas lines and have been collected in condensate collection pots, such as KO
drums or demisters. While the material is a liquid at the time of accumulation, it immediately vaporize s when the valve is opened to route it to the flare.

This contributions analysis was reviewed in detail during t he design of the new process and each contribution/point of entry was deemed critical and necessary. In addition, each source was assessed for minimization alternatives during engineering design. In addition to the process contributions, the GBR flare he ader includes the contributions of two sweep gas inject ion points

. See Section 2.11 for further information on the sweep gas contributions

.

3.2 Minimization Assessment

A ccording to the NSPS Ja

, the Suncor refinery must conduct a further assessment of whether discharges to the new flare from the process units, from associated equipment, and from the fuel gas system can be minimized. The assessment must include the following items:

 Elimination of process gas discharge to the flare through process operating changes or gas recovery at the source;

 Reduction of the volume of process gas to the flare through process operating changes;

 Installation of a flare gas recovery system*; and,

 Minimization of sweep and purge gas flow rates, if applicable.

* If a facility is fuel rich, a flare gas recovery system and a co

- generation unit or combined heat and power unit would also need to be considered.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 3

- 2 For each of the items above, the minimization assessment must provide rationale in terms of the following consider ations :

 C osts, including capital and annual operating;

 Natural gas offset credits, if applicable;

 Technical feasibility;

 Secondary environmental impacts , and,

 Safety considerations.

If a reduction in flow cannot be achieved, a statement must be made justifying why the
minimization could not occur.

Suncor reviewed the various connections to the GBR flare header during detailed design phase of the new unit, and it assessed each type of connection for the potential for
minimization. The contributions and the rational e for minimization from each type of
connection are as follows:

 Relief valves are utilized in the process as an emergency relief device. Emergency conditions within a process vessel are an undesired condition that process controls are constantly attemptin g to minimize. Therefore, releases through an RV to the GBR flare header are currently minimized through process controls. Additionally, the RVs are serviced every five years as part of Suncor’s preventative maintenance program (removal and visual inspec tion plus pressure testing) . This maintenance reduces the potential for routine minor leakage through the RVs. Acoustic leak surveys of RVs

are also performed as indicated or on an as needed basis to identify sources of flow

outside of the normal operating ranges. Currently, there are only 9 PRVs routed to this GBR flare. Their contribution towards routine flow is negligible.

 Pump seal vents d ischarge any gases that accumulate in the pump seal pots of the liquid seal pumps. These pump seal pots are equipped with pressure transmitters that provide an indication of the performance of the pump seal. When the pressure of the pump seal pot reaches an undesirable level, the pump is taken out of service for maintenance, thereby minimizing the flow to t he GBR flare header. Currently, the DCS system will alarm when the pressure transmitters on each pump seal pot reach es 7 psig.

 Sample points are connected to the flare header to allow the sample line s to be purged prior to obtaining a sample. The sample lines associated with each sample point consist of 1⁄2 inch piping or tubing . Additionally, the sample points are located in close proximity to the process vessel to be sampled. Therefore, the volume of gas required to be purged prior to sampling has been minimized by design to the extent possible.

 Manual valves are generally used to remove process gases that have condensed and been accumulated in condensate collection pots. These liquids must be removed from the vessels to ensure proper operation. When t he liquids are released to the flareSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 3

- 3 header, due to the change in conditions, the liquids vaporize and are combusted in the flare as gases. Based on operational knowledge, the frequency of contributions to the GBR flare header can range from approximately once per day to once per year depending on the type of vessel and service . The volumes released through these
valves are minimal and are not likely to correlate to increased flaring events. See
Section 3.3 for a discussion of the baseline flow evaluatio n. Currently, it is not possible to route these liquids to another location within the refinery for beneficial use. If these contributions are observed to increase in frequency and volume in the future, Suncor will utilize the RCA procedure to investigat e whether redirecting these
flows is warranted.

 Control valves are generally used during startup conditions. These valves are opened during the startup of a unit when out of specification materials are being processed/produced. By directing these initial startup materials towards the flare, operations can prevent potentially excessive disturbances to the fuel gas system, which has the potential to upset other units causing additional flaring. Control valves
will be discussed further in Section 3.4.

 Sweep gas contributions occur at two distinct points at the GBR flare header

. The first addition point is located upstream of all contributions to the flare header. During the design of the GBR flare system, it was determined that the GBR flare header require s a minimum flow of 0.1 feet per second (fps). Based on the size of the flare header, the flow required to meet the 0.1 fps flow is approximately 300 scf/hr. At a point after the process connections to the GBR flare header have been made, the flare
heade r diameter increases from 14 inches to 24 inches. At this point of diameter increase, a second sweep gas addition point is made. This addition point is required to maintain the appropriate exit velocity of flare gases from the flare tip. This
minimum fl are velocity was determined to require the addition of a minimum of 6 3 0 scf/hr of sweep gas. As these sweep gas flow addition s were determined to be the
lowest flow rates required for proper operation of the GBR flare system, these flows
have been minimized.

Based on the flare minimization assessment performed, the Commerce City refinery has
determined that the current contributions to the GBR flare header have been minimized by proper engineering design . This minimization is consistent with Suncor’s operational philosophy which attempts to minimize losses of material as they represent lost products and
lost revenue.

3.3 Baseline Flow Evaluation

NSPS Ja specifies in 60.103a(4) that a baseline flow evaluation must be conducted after the minimization assessment has been completed. The determination of the baseline flow does not include pilot gas or purge gas, provided that these flow rates remain relatively constan t. See Sections 2.8 and 2.10 for further information on pilot gas and purge gas, respectively.
The numeric value of the baseline flow is the sum of all flows that the minimizationSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 3

- 4 assessment determined could not be further minimized. See Section 3.2 for further
information on the Minimization Assessment.

Alternative baseline flow rates can be established for different operating conditions provided that the following information is included with the development of separate baseline flow

rates:

 Identific ation of a primary baseline that will b e used as the default baseline;

 Description of each operating condition for which a separate baseline is established;
and

 Procedures to minimize discharges to the flare during each operating condition for which a sep arate baseline is established.

As the GBR Flare has been operational since May of 2012, Suncor reviewed the approximate
twelve months of available flare gas header flow rate data , which is presented as Figure 3

- 1
below.

Figure 3

- 1. Available Flow Rat e Data for Baseline Analysis

The available flow rate data illustrates that the majority of the flows to the GBR flare are of a relatively constant

, low flow. The period of increased flaring at the beginning of the time period is associated with the startup of the GBR unit. The spike in the middle of the char t is 0.00 50.00 100.00 150.00 200.00 250.00 300.00 350.00 

## GBR Flare Flow (Mscf/hr)Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 3

- 5 associated to a planned shutdown resulting in excess h ydrogen having to be sent to the GBR
Flare. These non

- routine episodes were not included within the normal baseline assessment.

The data was organized into a histogram and analyzed to determine the flow rates at which the majority of normal operations occur . The distribution of low fl o ws is illustrated in Figure

3

- 2 below.

Figure 3

- 2. Distribution of Flow Rates to the GBR Flare

The distribution of the average hourly flow rate data illustrates a decreasing trend in occurrences and sharp decrease in flow rates greater than 2 ,000 scf/h r and again after 3 ,000
scf/hr. The flow rate data presented includes the sweep gas as the flow meter is located downstream of both of the sweep injection points. The number of average hourly data points
for the 12 months evaluated that were less than 3

, 000 s cf/hr represent s approximately 7 6 % of the operating hours analyzed. Because t he number of data points available for analysis is limited to only twelve months of data

, this baseline will likely need to be revised as
additional data becomes available. Based on the distribution of flow rates and the limited time that the GBR unit has been operati onal, Suncor plans to utilize 3 ,000 scf/hr less the

necessary 9 30 scf

/ h r of established sweep gas flow

, as the normal baseline flow to the GBR
flare

, which corresponds to 2
, 0 70 scf / h r

. This is for normal operating conditions. During startups, shutdowns, and periods of excess h ydrogen a different baseline is required. See sections below for detailed description of the baseline limit during abnormal operation.

0 1000 2000 3000 4000 5000 6000 7000

>1 >2 >3 > 5 >10 >20 >30 >50 >75 >100 >125 Number

GBR Flare Flow Rates (Mscf/hr) Distribution of Flow Rates to GBR FlareSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 3

- 6 3.4 Startup and Shutdown

The Commerce City refinery reviewed the procedures that detail its planned shutdown s and
startup s. These procedures elaborate upon the specific steps taken by operators of the GBR unit to startup and shutdown the unit in a planned, step

- wise manner , while maintaining safe
conditions within the unit

. T he operational philosophy at Suncor works to minimize losses to flaring through the use of their procedures as flaring represents lost raw materials and products. Therefore, S uncor believes it has minimized the potential for excessive flaring during planned startups and shutdowns through the use of the standard operating procedures.

Two control valves were identified that were utilized primarily during startup conditions of
th e GBR:

 The BERT overhead system connection utilizes a startup line for the overhead gases to go to the GBR flare during startup instead of the plant’s fuel system. During startup, if the BERT overhead gases were allowed to be sent to the fuel gas system, the fuel gas system would experience excessive pressure fluctuations that have the potential to disrupt the operation of additional units. When the GBR is in steady operation, the control value is closed and the control directing the gases to the fuel

gas system is opened.

 Control valve PC1108 is utilized during startups and emergency trips of the No. 3/ No. 4 HDS units to direct hydrogen to the GBR flare. During startup of the GBR unit, the hydrogen will be released to the GBR flare only until the H 2 guard bed system is in steady operation. As the No. 3/ No. 4HDS units start to accept the hydrogen, the control valve will slowly close to minimi ze disturbances to the system.

Additionally, if the No. 3/ No. 4 HDS units have an emergency trip causing the

p ressure in the line to build , the control valve PC1108 will automatically open to
redirect the hydrogen to the GBR flare until the operato rs can manage the hydrogen in the fuel system or reduce the hydrogen plant production until the hydrogen flows are

ret urned to normal

.

Because the number of data points available for analysis is limited to only twelve months of data, this startup/shutdown baseline will likely need to be revised as additional data becomes
available after additional startups and shutdowns h ave occurred . Based on the distribution of flow rates and the limited time that the GBR unit has been operational, Suncor plans to
utilize a 125 ,000 scf/hr less the necessary 930 scf/hr of established sweep gas flow, as the startup/shutdown baseline flow to the GBR flare, which corresponds to 124
, 07 0 scf/hr

.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 3

- 7 3.5 Fuel Gas & Hydrogen Imbalance

After reviewing the various scenarios regarding the fuel gas and hydrogen system that c ould result in flaring at the GBR flare , Suncor identified two scenarios that are d iscussed in detail
below:

 Over

- pressuring of the fuel gas KO Drum;

 Shutdown of any of the h ydrodesulfurization (HDS) units; and

 Various operating scenarios that could require additional Hydrogen to be sent to the
GBR flare for destruction.

Because t he fuel gas KO drum is connected to the GBR flare header via a n RV connection

, this vessel only vents to the flare header during emergency situations (a manual valve is also present to bypass the PRV during infrequent maintenance events)

. As discussed ear lier, releases from each RV are minimized by operations and maintenance personnel through continual process control.

The refinery’s two reformers and the hydrogen plant feed the new GBR unit. Approximately 14% of the material produced by the reformers a nd hydrogen plant pass through the guard beds at the GBR unit. The remaining 86% is sent to the fuel gas system. The material sent through the guard beds is then split between the GBR unit and the HDS units. When the HDS units trip or are shutdown, the pressure in the line to the HDS units experiences an increase in pressure. This increase in pressure triggers a control valve to open, sending hydrogen rich material to the GBR flare. If the amount of time required to bring the HDS

units back into operat ion is minimal , the facility will continue to flare the excess material until the HDS units are brought back online. If the amount of time required to bring the HDS
units back into operation is significant , the facility will reduce the production of the

r eformers and the hydrogen plant which has the ability to stop flaring at the GBR flare. As a refinery is a complex system of interconnected unit s , this decision to reduce production of
the reformers and the hydrogen plant will be unique for each episode a nd will be dependent on the available resources at the facility. During periods of excess fuel gas and/or hydrogen as outlined above Suncor plans to utilize a 125,000 scf/hr less the necessary 930 scf/hr of established sweep gas flow, as the baseline flow during periods of excess fuel gas and/or Hydrogen to the GBR flare, which corresponds to 124,070 scf/hr

.

3.6 Fuel Gas Recovery Outage

Suncor does not utilize fuel gas recovery within the GBR unit; therefore Section 3.6 does not apply to the GBR flare

.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 4

- 1 

## SECTION 4

ROOT CAUSE ANALYSIS AND CORRECTIVE ACTIO N

This section provides a discussion on Root Cause Analysis (RCA) and Corrective Action Analysis that are required by NSPS Ja. These analyses are not specifically required to be a part of the FMP; however, the monitoring systems that provide the data for the RCA threshold
determinations are detailed in the FMP and the conclusions obtained from the RCA and Corrective Action analyses will potentially require changes to be made to the FMP. Therefore, the RCA and Corrective Action Analysis requirements have been included in the FMP. Suncor currently is required to perform RCAs for sulfur and flow exceedances as part of their Global Refinery Initiative Consent Decree (CD) dated 2005

. Suncor will perform RCAs to comply with the requirements of both the Consent Decree and NSPS Ja.

4.1 Root Cause Analysi s

As defined in NSPS Ja, an RCA is

“ an assessment conducted through a process of investigation to determine the primary cause, and any other contr ibuting cause(s), of a discharge of gases in excess of specified
thresholds. ”

The Rule specifies two thresholds for flares that trigger an RCA in 60.103a(c)(i) and (ii) . An RCA must be completed as soon as possible, but no later than 45 days after a dis charge that exceeds one or both of the specified thresholds. The two thresholds which trigger an RCA are as follows :

 Anytime the SO 2 emissions exceed 500 lb in any 24

- hour period, or

 Any discharge to one or more flares in excess of 500,000 scf above an es tablished
baseline in a 24

- hour period.

A detailed discussion regarding each threshold is provided below.

The rule delineates three special circumstances that affect the nu mber of RCAs that the Commerce City refinery must perform following an RCA threshol d exceedance:

 If a single discharge event last s for two or more consecutive 24

- hour periods, only one RCA must be performed;

 If a single discharge event triggers an RCA based on both of the specified thresholds, only one RCA must be performed;

 If a dischar ge that triggers an RCA is the result of a planned startup or shutdown during which the Planned Startup & Shutdown procedures referenced in Section 3.4 were f ollowed, an RCA is not required; and

 If multiple flares in a cascaded flare system each trigger an RCA in the same 24

- hour period, only one RCA must be performed.

As the GBR unit is intolerant to sulfur, sulfur monitoring is not required. Additionally, due to the inherently low sulfur requirements of the unit, exceedances of the flow threshold will li kelySuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 4

- 2 occur prior to exceedances of the sulfur threshold. However, for completeness, this FMP details the RCA requirements for both flow exceedances and SO 2 exceedances.

4.1.1 RCA

– Flow Exceedance

The specified flow threshold which triggers an RCA is the discha rge to a flare of greater than 500,000 scf above the established baseline flow s in a 24

- hour period to the flare.

When performing a n RCA for a flow exceedance at the Commerce City refinery , there are several key parameters that should be documented as part of the investigation:

 the connections that were contributing to the header,

 the duration of the flaring event,

 what was occurring in the process that led to the flaring event, and, if possible,

 the sequence of events t hat lead to the flaring event.

Once these items have been investigated and documented, a determination of potential actions that could have prevented the flaring event or reduced the volume or duration of the flaring even t
should be evaluated and documented.

Once the investigation has been completed, the key information and data gathered during the process should be assembled into an RCA Report to be retained in internal records. Because the rule specifies that certain items must be recorded for each RCA, each internal report should, at minimum, include the following:

 A description of the discharge.

 Date and time of when the discharge was first identified and the duration of the discharge.

 The measured quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the quantity for each 24

- hour period.

 The steps taken to limit the emissions during the discharge.

 Stat ement as to whether the discharge resulted from the same root cause(s) identified in previous RCAs.

 Description of the recommended corrective action(s) or an explanation of why corrective action is not necessary.

 If the discharge was a result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that an RCA is not necessary because the facility followed the FMP. For further information on the procedures to minimize flaring during pla nned startup and shutdown, see Section 3.4.

4.1.2 RCA

– SO 2 Exceedance

The specified sulfur content threshold which triggers an RCA is the emission from the flare of
more than 500 lbs of SO 2 in any 24

- hour period. In contrast to the RCA flow threshold, there is no reference baseline upon which to compare SO 2 emissions. The SO 2 emissions ar e determined by monitoring the H 2 S concentrations in the gases sent to the flare for combustion. Pilot gas is specifically exempt from sulfur monitoring. The GBR flare is cu rrently equipped with an H 2 SSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 4

- 3 monitor that is utilized to determine total daily SO 2 emissions; however, this monitor does not currently meet the upper span requirements of NSPS Ja and is not being used to show compliance with the Rule.

When performing an RC A for a n SO 2 exceedance at the Suncor refinery , there are several key parameters that should be documented as part of the investigation:

 the connections that were contributing to the header,

 the duration of the flaring event,

 what was occurring in the p rocess that lead to the flaring event, and, if possible,

 the sequence of events led to the flaring event.

Once these items have been investigated and documented, a determination of potential actions that could have prevented the flaring event or reduced the volume or duration of the flaring event
should be evaluated and documented.

Once the investigation has been completed, the key information and data gathered during the process should be assembled into an RCA Report to be retained in internal records. Because the rule specifies that certain items must be recorded for each RCA, each internal report should, at a minimum, include the following:

 A description of the discharge.

 Date and time of when the discharge was first identified and the duration of the discharge.

 The measured quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the quantity for each 24

- hour period.

 The measured total sulfur concentrations in the fuel gas at a representative location in the
flare inlet.

 The cumulative quantity of H 2 S and SO 2 released into the atmosphere. For releases controlled by flares, assume 99 % conversion of TRS to SO 2

.

 The steps taken to limit the emissions during the discharge.

 Statement as to whether the discharge resulted from the same root cause(s) identified in previous RCAs.

 Description of the recommended corrective action(s) or an explanation of why corrective action is not necessary.

 If the discharge was a result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that an RCA is not necessary because the facility followed the FMP. For further information on the procedures to minimize flaring during planned startup and shutdow n, see Section 3.4.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 4

- 4 4.2 Corrective Action Analyses

As defined in the NSPS Ja 60.101a , a Corrective Action is

“the design, operation and maintenance changes that one takes consistent with good engineering practice to reduce or eliminate the likelihood of the recurrence of the primary cause and any other contributing cause(s) of an event identified by a root cause anal ysis as having resulted in a discharge of gases to an affected flare in excess of specified
thresholds”

An identification of corrective action(s) must be performed as the final step of an RCA per 60.103a(d) . The purpose of documenting the corrective actio n(s) in the internal RCA Report is to systematically identify changes that could be made to reduce or, if possible, eliminate the possibility of the recurrence of the causes of the flaring event that caused an exceedance of one
or both of the RCA threshold s. The identification of corrective actions should incorporate rationale regarding economic or technical feasibility or other potential limiting factors. The purpose of identifying corrective actions is to determine, based upon good engineering practices

, potential changes that could rectify the cause(s) of the flaring event that was/were identified by
the RCA.

According to the rule, a Corrective A ction A nalysis is

“a description of all reasonable interim and long

- term measures, if any, that are availab le, and an explanation of why the selected corrective action(s) is/are the best alternative(s), including, but not limited to, considerations of cost effectiveness, technical feasibility, safety and secondary impacts.”

The Corrective Action Analysis is the process to determine which of the identified corrective actions presents the most plausible argument for implementation. It is during this analysis that rationale regarding economic and technical feasibility, along with other potential limiting factors, are taken into consideration. If the facility concludes that a corrective action should not be conducted, the facility must document the decision and include the basis for the conclusion.

All corrective actions must be implemented within 45 days of the di scharge for which the RCA and corrective action analyses were required or as soon as practicable. If it is determined that a corrective action should not be implemented, the explanation of the basis of that decision must be recorded no later than 45 days following the discharge. Because the Corrective Action Analysis is a consequence of the RCA, it is imperative to commence the RCA as soon after the discharge as possible in order to allow for the maximum amount of time to be allotted to the
determination and implementation of the most beneficial corrective action. However, if a corrective action cannot be fully implemented within 45 days, the facility must develop an implementation schedule to complete the corrective action as soon as feasible

.
Once the 4 5

- day period following the discharge has passed, the rule specifies that certain items must be included in the internal RCA Report for each Correct Action Analysis. At minimum, each internal report must include the following items:

 If it is determined tha t a corrective action should not be implemented, an explanation of
the basis of that decision

.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 4

- 5  A description of the corrective action(s) completed within the first 45 days following the discharge.

 For corrective actions not completed within 45 days, a sc hedule for implementation, including proposed commencement and completion dates.

According to 60.103a(d)(3), i f the discharge was a result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a Corrective Action Analysis is not necessary because the facility followed the FMP. For further information on the procedures to minimize flaring during planned startup and shutdown, see Section 3.4.Suncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 

## APPENDIX A
PLAN REVI SION LOGTHIS PAGE INTENTIONALLY LEFT BLANKSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 

### Revision Log

Suncor Energy (U.S.A.) Inc. Commerce City, Colorado NSPS Subpart Ja

– GBR Flare Management Plan

This Flare Management Plan (FMP) fulfills the requirements for NSPS Subpart Ja for the GBR Flare at the Commerce City Refinery. Any changes to the original plant should be
documented in the table below.

Revision

No. Revision

Date Revision Author

(name, company) Reason for Revision Requires
Submission to the EPA? (See
section 1.3 o f FMP)

0 11/13/12 Sage Environmental

Consulting Original Submittal to EPA Yes

1 7/16/13 Craig Neuman

(Suncor) Updated baseline flow limits Yes

2 4/7/1 4 Bernd Haneke

(Suncor) Updates to Section 2.13.1 Updates to Section 2.13.2 YesTHIS PAGE INTENTIONALLY LEFT BLANKSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 

## APPENDIX B
NSPS J a CROSS

- REFERENCE TABLETHIS PAGE INTENTIONALLY LEFT BLANKFMP Manual Section
60.103a(a) Appendix D 1.1, Appendix D 1.1, Appendix D 60.103a(a)(2) 3.2 60.103a(a)(3)(i) Flare type 2.1 Assist system 2.7 Flare tip 2.2 Flare header system 2.3 Flare Gas Recovery System 2.5 60.103a(a)(3)(ii) Flare tip 2.2, Appendix D KO drum 2.4, Appendix D Flare header & subheader 2.3, Appendix D Assist system 2.7, Appendix D Ignition system 2.9, Appendix D 60.103a(a)(3)(iii) Maximum vent gas flow rate 2.1 Minimum sweep gas flow rate 2.11 Minimum purge gas flow rate N/A Maximum supplemental gas flow rate N/A Maximum pilot gas flow rate 2.8

Minimum total steam flow rate 2.2 60.103a(a)(3)(iv) Flare header 2.3, Appendix D Purge gas N/A Sweep gas 2.11, Appendix D Supplemental gas N/A Pilot gas 2.8, Appendix D

60.103a(a)(3)(v) 2.13

60.103a(a)(3)(vi)

Description of water seal N/A Designation of monitoring option N/A

60.103a(a)(3)(vii) N/A

60.103a(a)(4) 3.3

60.103a(a)(5) 3.4

60.103a(a)(6) 3.5

60.103a(a)(7) N/A

60.103a(b)(1) 1.2 60.103a(b)(2) 1.3 60.103a(c)(1) 4.1

60.103a(d) 4.1 60.103a(e) 4.2

60.103a(f) 4.2

60.103a(g) N/A

60.103a(h) 2.13.2 60.107a(a)(2) 2.13.2 60.107a(a)(3) 2.13.2

60.107a(b) 2.13.2

60.107a(e) 4.1.2 60.107a(f) 4.1.1 60.107a(g) 2.13, 4.1 60.108a(a) - (c) 1.2, Appendix A Monitoring of flow rates for RCA Monitoring alternatives for Sulfur Content and Flow Rate for RCA Required notifications and records Applicability of flares to < 162 ppmv H2S concentration limit in flare Requirements for monitoring flare gas H2S concentration Exemptions for flare gas H2S concentration monitoring

Procedures to exempt streams from flare gas H2S concentration monitoring Monitoring of sulfur content for RCA Procedures to minimize or eliminate discharges during planned shutdown and startup
Procedures to reduce flaring in cases of fuel gas imbalance

Submission timeline for initial FMP

Conditions which Trigger a Root Cause Analysis for a Flaring Event

Specific requirements for flares located in the BAAQMD and SCAQMD Design parameters

Description and simple PFD of flow meters and sulfur content

Manufacturer's specifications for each monitor/analyzer identified in 60.103a(a)(3)(iv)

Description of FGRU, FGRU monitoring parameters, and compressor system logistics

Baseline flow evaluation List of ancillary equipment List of fuel gas systems

Minimization assessment General description

Description and simple PFD NSPS Ja Cross-Reference Table

Events which trigger a re-submittal of the FMP

Timeline to conduct Root Cause Analysis and Corrective Action Records to be maintained for Corrective Action Implementation Timeframe for initial compliance for Root Cause Analysis and Corrective Action Implementation Programs For emergency flares, secondary flares, and flares with FGRUs that are designed to capture all normal flows

Procedures to minimize frequency and duration during FGRU outages and to minimize flaring during FGRU outages Regulatory Citation

60.103a(a)(1) Items to be included in the Flare Management Plan List of process unitsTHIS PAGE INTENTIONALLY LEFT BLANKSuncor Energy (U.S.A.) Inc. July 2013 GBR - Flare Management Plan 

## APPENDIX C
PROCESS FLOW DIAGRAMSTHIS PAGE INTENTIONALLY LEFT BLANKSealPots•24P2410B24P2410B•24P2420B24P2420A24TW2410Overhead•ReliefValve‐24RV2410

Swee p Gas (SealPots•24P2410B•24P2410B•24P2410A•24P2410A•24P2400B•24P2400A•P‐3924SealSump•24P2420B•24P2420A•24P2415B•24P2425A•24P2430A•24P2430BGuardBeds•LightReformate(LR) GuardBeds‐24D2420A/B•LRReliefValve‐24RV2420A•LRReliefValve‐24RV2420B•H2GuardBed ReliefValves‐24RV2412A/B24TW2410Overhead•ReliefValve‐24RV2410BAnalyzerBuilding•24AAX3002•PC1108 Pur g e Gas ( Sa m

s ( Cit y Gas ) S am p le Port )Vent Gas )BERT•Overhead•TowerOverheadDrumReliefValve‐24RV2430•TowerRefliefValve‐24RV2425FuelGasKnockOut Drum•Drain‐24D2405Splitter OverheadDrum•Drum‐24D2415•ReliefValve‐24RV2415 Swee p Gas ( Cit y Gas )FIGUREC1GBRFlFLR6H d•TowerOverheadDrumReliefValve‐24RV2430•TowerRefliefValve‐24RV2425•ReliefValve‐24RV2415 Sw eFIGUREC‐1.GBRFlareFLR‐6HeaderSuncorEnergy‐CommerceCity,ColoradoSuncorEnergy(U.S.A.)Inc.DATE:November2012PROJECTNUMBER:294‐1‐84THIS PAGE INTENTIONALLY LEFT BLANKGasMixHighFlowRangeLowFlowRange4"UpperRingSteamLineIgnitionTubesPCV2407PCV2401FlameFrontIgnitionChamberPCV24021 5"C tFuelGasLineVent GasFlareGasfromGBRUnitInstrument AirPilotsThermocouplesTE2401‐TE2406(2 /pilot)SweepGasGlobeValveFV2401AFV2401BFT2402FT2401AFT2401BFlareVentGasNaturalGasSteamInstrumentAir1.5"CenterSuncorEnergy(U.S.A.)Inc.DATE:November2012PROJECTNUMBER:294‐1‐84FIGUREC‐2.GBRFlareFLR‐6SuncorEnergy‐CommerceCity,ColoradoFlareDrawingColorLegendKnockOutDrumD‐3924SteamLineFlareGasfromGBRUnit6"175lbSteamHeaderFT2401BTHIS PAGE INTENTIONALLY LEFT BLANKSuncor Energy (U.S.A.) Inc. July 2013 GBR - Flare Management Plan 

## APPENDIX D
FLARE TIP DRAWINGTHIS PAGE INTENTIONALLY LEFT BLANKTHIS PAGE INTENTIONALLY LEFT BLANKSuncor Energy (U.S.A.) Inc.

April 2014 GBR

- Flare Management Plan 

## APPENDIX E
ALT. TEST METHOD 099THIS PAGE INTENTIONALLY LEFT BLANKTHIS PAGE INTENTIONALLY LEFT BLANK