refinery flare sector rule update rsr 40 cfr part 63 - subpart cc mact cc

©2016 Wunderlich-Malec All rights reserved. 600 Corporate Cir | Golden, CO 80401 page | 1

RSR Flare Compliance Services Overview

EPA’s Refinery Sector Rule (RSR) requires enhanced flare controls to minimize emissions of hazardous air pollutants during flaring events. Continuous Parameter Monitoring Systems (CPMS) are required to demonstrate continuous compliance and report semi-annual deviations. Root cause analysis and corrective action programs incentivize refineries to prevent releases and avoid violations of the MACT. The required Flare Management Plan (FMP) must include a flaring minimization assessment to address startup, shutdown, and malfunction (SSM) procedures, pressure relief device (PRD) leakage prevention measures, and the feasibility of incorporating flare gas recovery. The FMP must document flare modifications and controls along with monitoring, recordkeeping, and compliance reporting procedures.

◊ Wunderlich-Malec Business Unit Capabilities

Wunderlich-Malec (WM) offers a wide range of services to help refineries address RSR rule compliance gaps by January 2019.

WM has refinery and flare expertise in its process controls, automation and environmental business units located in Golden CO, Wilmington NC, and other locations. WM has previously assisted refineries with EPA-compliant CPMS/CEMS monitoring and data collection for Flare Management Plans and Subpart Ja compliance. WM can provide solutions and resources for distributed control systems, field instrumentation, measurement devices and controllers, flare analysis, pressure relief device optimization, panel manufacturing at Eden Prairie MN, and Modular Integrated Control Shelter design and manufacturing at Winslow ME.

Portions of the RSR rule affecting flares in Part 63 Subpart CC require enhancements to flare design, instrumentation, controls, and data management.

WM brings refining and flare-specific experience to implement a refinery’s RSR solution.

WM has expertise to perform a monitoring system gap analysis, and implement a highly reliable compliance solution to meet your refinery’s sustainability goals.


◊ WM Integrated Environmental Solutions

WM’s Cirrus Business Unit in Golden, CO deploys data acquisition and control systems for environmental compliance. WM has installed and supported hundreds of environmental data systems in the power and industrial sectors. WM’s Cirrus EIS™ allows users to scale from a single unit continuous emissions monitoring system (CEMS), to networks of CEMS, predictive systems and CPMS, to facility-wide Title V compliance solutions, with ancillary NPDES, GHG, and air inventory reporting.

Our staff has worked on turnkey solutions and stand-alone systems with many CEMS integrators and analyzer vendors such as Cemtek, ThermoFisher, Siemens, Sick, Control Analytics, Horiba, and Ametek to implement air emissions data systems, compliant with the rules and policies of 40CFR Parts 60, 63, 75, and many state/local variations.

WM provides staff to evaluate various environmental regulatory and permit regimes with the goal of providing customers with regulation-specific compliant data and accurate reports. WM designs systems with proactive features to enhance unit operational efficiency and help avoid deviations and fines. Every source is documented with a unique Environmental Data Flow Diagram, which illustrates sample acquisition, data reduction, and archiving at each regulatory timing interval, complete with permit limitations.

WM also offers PowerEMSTM, which combines a powerful Predictive Emissions Monitoring System (PEMS) with compliance reporting. It provides refineries with a low cost alternative to CEMS, compliant with Part 60 Appendix B, Performance Specification 16, for combustion units such as gas and liquid fired heaters, package boilers, and turbines.

These product offerings are supplemented by valuable services to deploy and maintain a regulatory compliance program for a refinery’s process and regulatory staff.

PLC programming on multiple platforms, such as Allen Bradley, GE, Modicon, and Siemens to support CEMS control and related process parameters

DCS configuration and HMI integration on Honeywell Experion, Emerson DeltaV, and other platforms

Instrumentation, process, and electrical design services, including P&ID development

Configuration and data system interfaces to PI, PHD, and other historians

Refineries must be able to demonstrate continuous data compliance with flare operating limits.

WM has implemented a facility-wide emissions compliance data system including CEMS for boilers, heaters, fuel gas systems, FCCU, SRUs, and Subpart Ja flares, at a major refinery, complete with integrated emissions management with Honeywell’s Experion DCS.


Environmental data flow design, configuration, and deployment from

the DCS through the data system

Network-knowledgeable staff to deploy data system solutions within the constraints of the refinery’s IT network infrastructure security standards

Standard report configuration and custom report programming

Data management services for periodic data quality maintenance, backups, and compliance reporting

Maintenance contracts for Cirrus EISTM and PowerEMSTM software support and PEMS model tuning

PEMS model development with initial certification and on-going quarterly and annual quality assurance audits

◊ WM Services for RSR Flare Provisions

Evaluate, recommend, and optimize existing vent flow and BTU related instrumentation and analyzers to meet flaring limits on a 15-min block basis with direct or feed-forward calculation methods

Modify the DCS to minimize supplemental fuel usage for compliance with the 270 Btu/scf NHZcz limit during flaring events

Evaluate flare drawings, P&IDs, instrument data sheets, and other detailed specifications to implement EPA-compliant RSR solutions

Specify and manufacture panels and integrated modular control enclosures (MICE) for new analyzer and instrumentation requirements

Enhance the DCS/HMI for operator awareness of 15-min operating limits for NHVcz, NHVdil, tip velocity, and pilot flame presence in each minute of a 15-min block

Inspect flare video camera placement/upgrades, archive 15-sec snapshots, and implement procedures to meet the flare visible emission limit of no more than 5 minutes of visible emissions in any 2-hr period

Prepare content for the refinery’s Flare Management Plan

Work with the flare manufacturer to develop an Alternative Monitoring Plan (AMP) to calculate perimeter assist air from steam flows

WM has worked with many CEMS vendors and can collaborate with your refinery’s instrumentation vendors to solve issues resulting from EPA’s RSR promulgationyour RSR issues.

WM has extensive documentation experience with CEMS monitoring and quality assurance plans and engineering assessments.

WM has worked with many CEMS vendors and can collaborate with your refinery’s instrumentation vendors to solve RSR issues.

WM provides CEMS monitoring and quality assurance plans and engineering assessments.


Ensure that EPA Continuous Parameter Monitoring System (CPMS)

(such as hydrocarbon concentration, flow, pressure, temperature monitors) accuracy requirements are met and prepare a CPMS Monitoring Plan

Provide a flare flow minimization analysis of current pressure relief devices (PRD), prevention measures (if any), and assess if additional preventions are technically and economically feasible

Provide a Cirrus EIS compliance data system configuration and programming to sample, quality-assure, calculate, record, and report CPMS averages, with automatic determination of deviations

◊ Robust Approaches to Avoid Violations and Monitoring Gaps

WM offers additional solutions and services to reduce environmental regulatory and financial risk –

Implement Integrated Emissions Management strategies between the Cirrus EIS HMI and the refinery’s DCS

WM’s Cirrus EIS™ Startup/Shutdown Questionnaire Module can assist operators follow flare flow minimization steps and document any exceptions to the procedures.

Record and report data useful for Root Cause Analyses of flaring events and pressure relief devices that vent to the atmosphere

Develop site-specific reports for continuous compliance

Minimize CEMS and CPMS downtime deviations by recommending enhanced work procedures, redundant monitoring, and robust electronic recordkeeping solutions

◊ Non-Flare RSR Compliance

The RSR addresses additional areas of the refinery including facility-level Benzene Fence Line Monitoring, controls for tanks and delayed coking units, and pressure relief devices. Typical services include:

Implement preventive measures, instrumentation, and controls to record details of venting events, and immediately alert operators for PRDs in organic HAP service that vent to the atmosphere

Ensure that process equipment openings following product purges meet procedural, parametric, emissions, and documentation requirements

Modify compliance reporting on FCCUs and SRUs for alternate emissions limitations during startup and shutdown

Evaluate EPA electronic reporting requirements

From field instruments to reports, WM knows how to get data into control/data systems, quality-assure and manage the data, and get data out with proactive alerts and compliance reports

WM can help your refinery with other aspects of the Refinery Sector Rule.