Flare Gas Regulation and Monitoring Technologies …

1 Flare Gas Regulations and Monitoring Technologies Lorenzo Nirchi Thursday, December 18, 2014. Overview Why we measure Flare gas Flare gas regulations Technologies used to monitor Flare gas Dealing with carbon dioxide Open forum for Q&A. 2. Why measure Flare gas flow ACCOUNTABILITY STEAM CONTROL. > Flare Base Load Steam Injection Typically unknown Complete burning >Mass Balance Smokeless operation Steam Consumption Complete balance Expensive Drive flaring reduction Flow rate controlled Molecular weight CRUDE Flare proportion steam RECOVERY COMPRESSION. Flare Gas as fuel PRODUCT PRODUCT PRODUCT.

2 A B C. Waste Gas ENVIRONMENTAL. Process Unit Furnace >Mandatory Reporting >Avoidance of Penalties LEAK DETECTION. EPA, TCEQ, SCAQMD, EU, Kyoto, Molecular Weight BOEM, 40 CFR Part 98 (GHG), 1 2. Identification of more source Leaky Valves 3 4. Potentially 1000's in plant 3. What the Rule Covers NSPS Ja applies to Flare systems as follows: New Flares Modification of existing flares (after June 24th 2008). Reconstructed flares (after June 24th 2008). It is probably fair to say that the vast majority of flares in NA will be required to comply because they have been modified during the past few years 4.

3 How many flares are affected? The EPA estimates that there are approximately 400 flares in the USA of which 70% will be subject to Monitoring under these regulations. That's 280 flares that will need attention .. Deadline to comply November 11th 2015. 5. Flare Management Plan Operators are required to: Establish baseline Flare flow (not including pilot and purge flows). based upon all inputs into the Flare header system Implement Root Cause Analysis and Corrective Action Methods for unplanned Flare events Establish maintenance procedures and routines 6. Monitoring of emissions and operations for fuel gas combustion devices and flares.

4 (i) Locate the monitor in a position that provides a representative measurement of the total gas flow rate. (ii) Use a flow sensor with a measurement sensitivity of no more than 5. percent of the flow rate or 10 cubic feet per minute, whichever is greater. (iii) Use a flow monitor that is maintainable online, is able to continuously correct for temperature and pressure and is able to record flow in standard conditions (as defined in ) over one-minute averages. (iv) At least quarterly, perform a visual inspection of all components of the monitor for physical and operational integrity and all electrical connections for oxidation and galvanic corrosion if the flow monitor is not equipped with a redundant flow sensor.

5 (v) Recalibrate the flow monitor in accordance with the manufacturer's procedures and specifications biennially (every two years) or at the frequency specified by the manufacturer. 7. Flow Meter Performance Under Ja What are the requirements for flow metering? (f)(1)(i) Locate the monitor in a position that provides a representative measurement of the total gas flow rate. In other words: Meter must be positioned in the pipeline between all sources of gas and the Flare Meter itself Gas goes here Pilot Gas can be included as it Sources is considered a constant flow 1 2.

6 And is part of the Flare baseline flow but this is not necessary 3 4. 8. Flow Meter Performance Under Ja What are the requirements for flow metering? (f)(1)(ii) Flare gas flow meters must have a measurement sensitivity of +/-5% of flow rate or 10cfm, whichever is greater. In other words: Flow rates at or above 200cfm must be sensitive to +/-5%. Flow rates below 200cfm must be sensitive to +/-10cfm On a 24 pipe size 200cfm flow rate~ 1ft/sec On a 72 pipe size, 200 cfm flow rates ~ Measurement of Flare flow rate requires performance across a wide range of flow rates.

7 A careful assessment of operating conditions should be carried out to estimate performance over the 9. flow range of the meter Flow Meter Performance Under Ja What are the requirements for flow metering? (f)(1)(iii) Use a flow monitor that is maintainable online, is able to continuously correct for temperature and pressure and is able to record flow in standard conditions (as defined in ) over one-minute averages. In other words: Electronic units must have the ability to calculate volume flow at standard conditions and to either read line pressure and temperature directly or have input capability for values from external devices 10.

8 Flare Gas: Why Measure Ultrasonically? Conventional Technologies all Flare GAS. have problems with one or more > Variable Flow Rates of these characteristics of Flare Low flow = normal Flare gas operation, resulting in Moderate flow = inadvertent Flare inaccuracy, High flow = emergency Flare poor reliability and high cost of > Variable Composition ownership. Range of hydrocarbons The required turn-down ratio H2 to C6 + (typical) and low-end sensitivity > Corrosive Environment far exceeds conventional H2S, HF etc. flow measurement Technologies Liquid dropout > Low Pressure 1 2.

9 Atmospheric (slightly negative to slightly positive). > Wide Temperature Range From 150C to 280C overall 3 4. 11. Flare Gas Flowmeter: Hardware Overview Model GF868 Flare Gas Ultrasonic Flowmeter: 12. The Flare Gas Flowmeter: Transducers Configurations 13. Low Flow Method and Solution Installed system with a dual diagonal TD45 path arrangement. New T17 high power Solutions: transducer 3 times more Full Diameter Path Length signal energy than existing Longer paths with high power transducers capture a full cross designs section of the flow in the pipe. Apply Two Cross Paths Look at flow in two directions - cancel/reduce cross Flow 14.

10 Flare Gas Flowmeter: Low Flow Rate Cross flow-demonstration test FAN Cross flow Verification Results GENERATES. CROSS FLOW. Channel 1. Channel 2. Two channel GF for two crossed paths. Log flow for both channels with and without cross flow. Each channel sees a different slice of the cross flow currents. When averaged together, 15. net result is zero. Low Flow / Cross Flow Field Performance CFD Models used to define issue and recommend path configuration for best 1' performance 2. T17 high power transducer allows long path length in big pipes increased tolerance to non-perfect flow profile 2' 1.