Authorization Process for Pressure Assisted MultiPoint Ground Flares

Transcription

1 Authorization Process for Pressure Assisted Anne Inman, P.E. Technical Specialist Operational Support Section Air Permits Division Texas Commission on Environmental Quality 3/7/16 Page 1

2 Overview of Regulatory Authorization Process for MPGF Federal Regulation Applicability AMEL Introduction and Streamline Framework Project Scope and Background Performance Demonstration Monitoring and Operating Conditions Public Notice Proposal and Final Decision by EPA State/Regional Parallel Authorizations 3/7/16 Page 2

3 Federal Regulatory Applicability 40 CFR 60, Standards of Performance for New Stationary Sources (NSPS) 88 Subparts A-OOOO 40 CFR 61, National Emission Standards for Hazardous Air Pollutants (NESHAPs) - 22 Subparts A-FF 40 CFR 63, National Emission Standards for Hazardous Air Pollutants Source Categories (a.k.a. Maximum Achievable Control Technology) (MACT) 134 Subparts A - HHHHHHH 3/7/16 Page 3

4 Federal Regulatory Applicability NSPS, NESHAPs, MACT regulate sources and mandate emission limitations Flares are a common control with design & operating specifications 40 CFR and 40 CFR Continuous Pilot Net Heating Value Flare Tip Velocity Smokeless 3/7/16 Page 4

5 Pressure Assisted Multi-Point Ground Flares (MPGF) Flare systems: Characterized by one or more flare headers and groupings Operate at high pressures Varying stream characteristics and flows 99%+ Destruction Rate Effectiveness (DRE) for VOCs and HAPs Cannot meet flare tip velocity requirements in federal regulations 60.18(c) or 63.11(c) 3/7/16 Page 5

6 Alternate Means of Emission Limitations AMEL Introduction FCAA 111(h)(3) Alternative Means of Emission Limitation (AMEL) Satisfy Administrator (EPA not delegated) Achieve equivalent emission reduction Each regulated air pollutant and subpart Notice and opportunity for public hearing EPA Authorization 3/7/16 Page 6

7 MPGF AMELs by EPA Docket EPA-HQ-OAR Proposal Dow and Exxon 2/13/2015 FR pgs Approval Dow and Exxon, Proposal OCC 8/31/2015 FR pgs Streamline Framework Proposal 8/31/2015 FR pgs Pending Actions at EPA: OCC (1), CPCHEM (2), R&H (2) 3/7/16 Page 7

8 AMELs Streamline Framework Submit AMEL request to EPA Copy corresponding state/tribal/local permitting programs and agencies Each request stands-alone (documentation) Must have all needed information to satisfy EPA Administrator 3/7/16 Page 8

9 AMEL Project Scope and Background Identify site, company, permits, reference IDs Describe processes and operational conditions which generate emissions Details of typical and worst-case waste gas compositions, flows, profiles Anticipated start of construction and operation 3/7/16 Page 9

10 AMEL Project Scope and Background MPGF utilization (routine operations, planned MSS, upsets, etc.) Applicable NSPS, NESHAPs, MACT standards Authority to request AMEL (FCAA plus subparts) 3/7/16 Page 10

11 AMEL MPGF Identify burner manufacturer, design, specifications (type, geometry, size) Describe operational scenarios (low pressure, high pressure) Details on capacity, rows/stages, burners, pilots per stage, staging curve Include any unique design or operational details 3/7/16 Page 11

12 AMEL MPGF Performance Must achieve equivalent control (DRE) Most stringent applicable standard VOC HAPs Individual constituents Demonstration options Test Engineering assessment 3/7/16 Page 12

13 AMEL MPGF Performance Demonstration Testing Test PFTIR and Extractive Specific manufacturer and design Representative fuel/waste gas OR Worst-case substitute Minimum 3 runs Report 3/7/16 Page 13

14 AMEL MPGF Performance Demonstration Test Report Contents Test description Protocols and methodologies Quality assurance/quality control Raw field and laboratory data Summary report sheets Calibration standards and curves Date, time, duration 3/7/16 Page 14

15 AMEL MPGF Performance Demonstration Test Report Contents Fuel/waste gas composition and justification Highest operating pressure/sonic velocity conditions Visible emissions observation forms Calculate average DRE and combustion efficiency Flowrates and velocity of gas Calculate NHVcz and/or LFLcz of gas 3/7/16 Page 15

16 Gas Net Heating Value in Combustion Zone (NHVcz) + NHV %& = ( x * NHV * *,- Based on compositional analysis data NHVcz = Net heating value of flare vent gas (Btu/scf). i = Individual component in flare vent gas & n = Number of components in vent gas xi = Concentration of component i in flare vent gas, volume percent. NHVi = Net heating value of component i 3/7/16 Page 16

17 Gas Lower Flammability Limit in Combustion Zone (LFLcz) LFL 01 = + *,- 1 χ * LFL * Based on compositional analysis data LFLcz = Lower flammability limit of flare vent gas, volume fraction i = Individual component in flare vent gas & n = Number of components in vent gas xi = Concentration of component i in flare vent gas, volume percent. LFLi = Lower flammability limit of component i 3/7/16 Page 17

18 AMEL MPGF Performance Demonstration Test Report Contents MPGF burner tip pressure Waste gas temperature Meteorological conditions Observed flameouts Results analysis and summary 3/7/16 Page 18

19 AMEL MPGF Performance Demonstration Engineering Assessment Demonstrate effectiveness by prior testing Similar equivalent burner Representative fuel/waste gas OR worst-case substitute Address all other factors Include supporting documentation/prior tests Persuasive conclusions 3/7/16 Page 19

20 AMEL MPGF Performance Demonstration Engineering Assessment Equivalent burner destruction/combustion effectiveness Design principles of burner type Burner size Burner geometry Air-fuel mixing Combustion principles to assure smokeless operation Spectrum and variety of operating conditions 3/7/16 Page 20

21 AMEL MPGF Performance Demonstration Stability Testing Key Importance Lit, Stable Flame and Smokeless Conduct long-term stability test Spectrum and range of operating conditions Representative or worst-case waste gas stream Smokeless operation Stable flame to flameout point 3/7/16 Page 21

22 AMEL MPGF Performance Demonstration Stability Testing Design and complete test Purpose to determine point of flame instability and flameout Stable minimum 5 minutes Highest operating pressure/sonic flow conditions Most challenging composition Document all relevant conditions and parameters 3/7/16 Page 22

23 AMEL MPGF Performance Demonstration Stability Testing Replicate results Minimum and maximum operating conditions At least 15 minutes at each condition At least 3 test runs At or above NHVcz or below LFLcz Highest operating pressure/sonic flow conditions Most challenging composition Document and report all relevant conditions and parameters 3/7/16 Page 23

24 AMEL MPGF Performance Demonstration Cross Lighting Design and complete test Purpose to show all stages will light under range of conditions Vary operating pressure / velocity Appropriate design and installation spacing and pilot locations Boundaries At least 3 test runs at each condition NHVcz or LFLcz Minimum of 3 burners must light in each stage 3/7/16 Page 24

25 AMEL MPGF Performance Demonstration Cross Lighting Report Contents Description of the testing Protocol of test methodology Test method QA/QC parameters Time, length, and duration of the test 3/7/16 Page 25

26 AMEL MPGF Performance Demonstration Cross Lighting Report continued.. Waste gas composition Waste gas temperature NHVcz and/or LFLcz of the gas tested Velocity (or Mach speed ratio) of the waste gas tested 3/7/16 Page 26

27 AMEL MPGF Performance Demonstration Cross Lighting Report continued.. Burner tip pressure Whether successful cross-light was observed over Length of time it took for the burners to cross-light Maintaining a stable flame after a successful cross-light Duration of stable flame observed all of the burners 3/7/16 Page 27

28 AMEL MPGF Performance Demonstration Other Reduction Considerations Alternatives to flaring or flare reduction measures Evaluate flare gas recovery Justify MPGF utilization 3/7/16 Page 28

29 AMEL MPGF Operating Conditions Each stage equipped with at least two (2) pilots No visible emissions when operating NHVcz 800 Btu/scf LFLcz 6.5 vol % 3/7/16 Page 29

30 AMEL MPGF Monitoring Install, operate, calibrate, maintain, record data, record downtime & out of compliance periods At all times: Pilot flames on each stage present (thermocouple) 3/7/16 Page 30

31 AMEL MPGF Monitoring Receiving material Downtime for maintenance, instrument adjustments, calibrations (max 5%) Component concentrations in vent gas (LFLcz) or measure, calculate and record heating value of vent gas (NHVcz) Monitor vent gas flow rate Pilot flame / opacity video camera Pressure monitors on main header, each staging valve 3/7/16 Page 31

32 AMEL MPGF Review EPA staff will review details of request Provide all documentation Request for Information respond promptly to avoid delays Draft site-specific AMEL approval or disapproval 3/7/16 Page 32

33 AMEL Notice and Action Publish proposal in Federal Register 30-day comment and hearing request period EPA evaluates all comments Publish final AMEL in Federal Register Approval or Disapproval Revisions to AMEL conditions as proposed Respond to comments 3/7/16 Page 33

34 State/Tribal/Regional Authorizations Each state/region/tribe/local government has different requirements Actions possible Amend or Revise New Source Review Permits Administrative Revision to Federal Operating Permits Alternate Method of Compliance or Control (AMOC) Requests Public notice and comment/hearing opportunities Plans may parallel or be different than EPA AMEL May process simultaneously or consecutively 3/7/16 Page 34

35 Anne Inman, P.E. Air Permits Division, TCEQ Mail Code 163 P.O. Box Austin, TX /7/16 Page 35