Compliance Date and Summary of Requirements
January 30, 2019, is rapidly approaching, and for those facilities with flares subject to the requirements in Subpart CC, that’s your compliance deadline for completing a Flare Management Plan (FMP). Flares that are subject to the requirements in §63.670 are also subject to the flare monitoring requirements in §63.671, which include developing a monitoring plan, operating a continuous parametric monitoring system (CPMS), and submitting periodic reports.
Many of the facilities subject to Subpart CC were already required to develop FMPs under 40 CFR Part 60 Ja; however, the additions to Subpart CC necessitate updates to the existing plans to ensure both regulations are met. Whereas Ja focused on minimizing overall flare volumes and emissions of pollutants such as sulfur dioxide (SO2), Subpart CC addresses minimizing hazardous air pollutant (HAP) emissions by placing enhanced monitoring and operational requirements on flare combustion such as:
- Continuous operation of a pilot flame
- Operation without visible emissions (VE)
- Maximum flare tip velocity
- Minimum combustion zone heat content (>270 Btu/scf) and proper steam or air assistance
In addition to the monitoring and operational requirements, facilities subject to Subpart CC must develop a CPMS monitoring plan that details quality control/quality assurance (QA/QC) requirements and procedures including, but not limited to:
- Identification of the specific flare being monitored and flare type
- Parameters monitored and type for each flare
- Description of the monitoring equipment
- Description of the data collection and reduction systems, including algorithms used to demonstrate compliance
- Routine QA/QC procedures with descriptions for calibrations, calibration drift, spare parts inventory, etc.
Additionally, facilities should use this time to conduct a thorough review of their FMPs and other monitoring plans to verify the plans are accurate and reflect the existing design and operation. Changes to existing flare minimization plans/strategies along with addressing modifications to the facility’s baseline or developing alternatives baselines should also be discussed during this time. This is also a good time for a facility to review its fence line monitoring program, which was first required to be implemented on January 30, 2018, since it will be coming up on a full years’ worth of data to analyze.
PPM has professionals with flare management plan experience who would be happy to discuss these required updates. Please give us a call at (251) 990-90000 if you need help or have any questions. Feel free to reach us by email: Isaac Smith (isaac.smith@ppmco.com), Ned Coleman (ned.coleman@ppmco.com).