Overview of the Final NSPS Ja for Refinery Flares And the Latest Developments on Flare Consent Decrees

Transcription

1 Overview of the Final NSPS Ja for Refinery Flares And the Latest Developments on Flare Consent Decrees October 24, 2012 Troy Boley & Raymond Allen Sage Environmental Consulting Overview of Ja & Flare CDs 10/24/2012 1

2 Agenda Introductions Review of Final NSPS Ja for Flares Flare Consent Decree Comparisons Suggested Approach Questions Overview of Ja & Flare CDs 10/24/2012 2

3 An Abbreviated History of NSPS Ja May 14, 2007: NSPS Ja was first proposed in the Federal Register June 24, 2008: EPA promulgated FINAL amendments to NSPS Ja this ultimately established the flare applicability date because EPA made substantive changes to the flare provisions since the original proposal September 26, 2008: EPA published a final rule staying the effective date of certain provisions of NSPS Ja including those for flares until December 25, 2008 this stay was ultimately extended indefinitely December 22, 2008: EPA published proposed amendments to NSPS Ja which addressed certain stayed NSPS provisions including those for flares again the stay on all flare provisions was extended indefinitely September 12, 2012: EPA promulgated the FINAL NSPS Ja and lifted the 2008 stay on most rule provisions including the flare provisions November 13, 2012: FINAL effective date of NSPS Subpart Ja Overview of Ja & Flare CDs 10/24/2012 3

4 Flare Highlights in the Final NSPS Subpart Ja A flare is now a separate affected facility instead of a subcategory of Fuel Gas Combustion Devices Certain exemptions and alternatives available for infrequently-used flares Flares now must comply only with the short term H 2 S limit (162 ppmv 3-hr avg) no long-term H 2 S limit for flares The so-called flare special modification provisions are still present where a new flare connection triggers an NSPS Ja modification but a list of exempted connections added Stronger emphasis now given to the required Flare Management Plan Overview of Ja & Flare CDs 10/24/2012 4

5 Flare Highlights in the Final NSPS Subpart Ja NSPS Ja now introduces the concept of flare baseline flow final rule has no numerical flare flow rate limitation Must conduct a RCA and take CA when the flare gas flow rate exceeds 500,000 SCFD above baseline flow, or the flare gas SO 2 emissions exceed 500 lb on an absolute basis in any 24-hr period Affected flares must have TRS and flow monitors except in limited cases For infrequently used flares, NSPS Ja allows, as an alternative, the monitoring of the flare drum s water seal pressure NOTE: NSPS GP flare controls in not referenced or required by Ja Overview of Ja & Flare CDs 10/24/2012 5

6 Three NSPS Ja Flare Applicability Triggers 1. Construction Any brand new flare constructed after June 24, Modification Any existing flare modified after June 24, 2008 Pay special attention to the flare special modification provisions of NSPS Ja, which supersede the NSPS General Provision (GP) rules for modifications found at among other things this means the NSPS emissions increase test under 60.14(a) and the NSPS capital expenditure test under 60.14(e)(2) both become irrelevant 3. Reconstruction Any existing flare reconstructed after June 24, 2008 Generally consistent with the NSPS GPs at 60.15(b), flare reconstruction occurs when the current-day capital cost of all flarerelated capital projects over any 2-year period > 50% of the currentday capital cost to totally replace the flare with a comparable new flare IMPORTANT NOTE: It is critical to know which specific applicability trigger new, modified or reconstructed makes a flare subject to NSPS Ja because the required schedule to achieve compliance is much more stringent for new and reconstructed flares compared to modified flares NSPS Ja compliance deadlines are addressed later Overview of Ja & Flare CDs 10/24/2012 6

7 Defined Boundaries of the NSPS Ja Flare Facility 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 injection or steam injection systems, flame arrestors and the flare gas header system. In the case of an interconnected flare gas header system, the flare includes each individual flare serviced by the interconnected flare gas header system and the interconnected flare gas header system. IMPORTANT NOTE: It is crucial to understand the importance of NSPS facility boundaries for one thing, any applicability cost test, such as a reconstruction test, is performed within the confines of those boundaries. NSPS Ja defines a flare at a as shown above. Overview of Ja & Flare CDs 10/24/2012 7

8 Flare Special Modification Provisions in Subpart Ja 60.14(f) Special provisions set forth under an applicable subpart of this part shall supersede any conflicting provisions of this section [on modifications] a(c) - As provided in 60.14(f), the special provisions set forth under this subpart shall supersede the provisions in with respect to flares. For the purposes of this subpart, a modification to a flare occurs as provided in paragraphs (c)(1) or (2) of this section. (1) Any new piping from a refinery process unit, including ancillary equipment, or a fuel gas system is physically connected to the flare (e.g., for direct emergency relief or some form of continuous or intermittent venting). However, the connections described in paragraphs (c)(1)(i) through (vii) of this section are not considered modifications of a flare.. [see next slide for exceptions], or (2) A flare is physically altered to increase the flow capacity of the flare. Overview of Ja & Flare CDs 10/24/2012 8

9 Flare Special Modification Provisions in Subpart Ja Flare Piping Changes Allowed Without Triggering a Modification Connections made to install or upgrade flare monitoring systems Connections made to install or upgrade flare gas recovery systems Like-kind connections made to replace or upgrade SRVs Replacing piping or moving an existing connection from a refinery process unit to a new location in the same flare, provided the new pipe diameter is less than or equal to the diameter of the pipe/connection being replaced/moved Connections between flares Connections for flare gas sulfur removal Connections made to install redundant flare equipment (such as a back-up compressor) HOT ISSUE! This major change to NSPS Ja was a surprise bombshell to refiners in the 2008 Ja rule the 2012 final version of NSPS Ja has added these generally un-helpful exceptions AND NOW THE BAD NEWS Overview of Ja & Flare CDs 10/24/2012 9

10 The Sad Bottom Line on the Final NSPS Ja Flare Special Modification Provisions Sage Commentary: The new limited list of exceptions to flare piping changes that trigger a modification in the final NSPS Ja are simply EPA s attempt to add window dressing to a burdensome regulation that, in fact, will cover almost all U.S. refinery flares by November The bottom line is over a relatively short period of time all active U.S. refineries will have to make flare piping connections that are likely outside of the list of exceptions provided in the final NSPS Ja. QUESTION: Between June 2008 and the present day, has your refinery added any flare piping connections outside of the limited list of allowed exceptions? If yes, then your flare has been modified and must achieve compliance with all NSPS Ja flare requirements by November 2015! Overview of Ja & Flare CDs 10/24/

11 Flare Changes from Original to Final NSPS Ja Affected Source Aspect Original NSPS Ja (June 2008) Flares Applicability New, reconstructed or modified flare systems - adding new connections to or physically altering a flare to increase flow constitutes a modification FINAL NSPS Ja (September 2012) Similar, except specific list of connections that do not trigger applicability. Flares H 2 S Concentration Limit in Flare Gas 162 ppmv H 2 S (3-hour average) 60 ppmv H 2 S (annual rolling average) 162 ppmv H 2 S (3-hour average) No 60 ppmv H 2 S long term limit for flares! Flares Compliance date for modified flares. Comply with H 2 S limit at start-up, and all other requirements within 1 year. Comply with H 2 S limit at startup (see rule for exceptions) and all other requirements by November yr leeway Overview of Ja & Flare CDs 10/24/

12 Flare Changes from Original to Final NSPS Ja Affected Source Aspect Original NSPS Ja (June 2008) FINAL NSPS Ja (September 2012) Flares Flow Rate Limits Flare system-wide flow limit of 250,000 SCFD No flare flow rate limits! Flares Root Cause Analysis & Corrective Action (RCA/CA) Flare RCA/CA required for upsets/malfunctions exceeding: EITHER : 500,000 SCFD (based on absolute flow) Flare RCA/CA required for events exceeding EITHER : 500,000 SCFD (above baseline flow) OR: 500 lbs/day SO 2 (regardless of flare SO 2 emissions limit) OR: 500 lbs SO 2 (in any 24-hr period regardless of flare SO 2 emissions limit) Flares Flow Monitoring Continuous Continuous except for emergency flares Flares Sulfur Monitoring Continuous Total Reduced Sulfur (TRS) with H 2 S Option Continuous TRS, using reference method 15A (Total S) with certain exemptions and alternatives provided Overview of Ja & Flare CDs 10/24/

13 NSPS Ja Flares Exempt from TRS Monitoring Flares that receive only fuel gas streams that are inherently low in sulfur content, as defined in NSPS Ja. Emergency flares (which receive flows < 4 times/yr) that comply with water seal monitoring. (No seal? NOT an Emergency Flare) Flares equipped with flare gas recovery systems designed, sized and operated to capture all flows except those from startup and shut down must comply with water seal monitoring Secondary flares that receive gas diverted from the primary flare If discharge from the secondary flare, the sulfur content measured by the sulfur monitor on the primary flare should be used to calculate SO 2 emissions If flare is exempt from TRS monitoring, Ja says use engineering calculations to estimate SO 2 emissions from flare discharges Overview of Ja & Flare CDs 10/24/

14 NSPS Ja Alternative Monitoring Option for Infrequently-Used Flares An alternative NSPS Ja flare monitoring option is available where the water seal height and pressure in the flare header just upstream of the water seal is continuously monitored for: Emergency flares Secondary flares Flares equipped with a Flare Gas Recovery System (FGRS) designed, sized and operated to capture all flows (except flows resulting from planned startups and shutdowns that are addressed in the Flare Management Plan) If this alternative NSPS Ja flare monitoring option is selected, then any instance where the pressure upstream of the water seal exceeds the water seal height triggers a RCA/CA, unless the event is related to FGRS compressor cycling or a planned startup or shutdown conducted in accordance with the Flare Management Plan. Overview of Ja & Flare CDs 10/24/

15 Does the Final NSPS Ja Require a Flare Gas Recovery System? a: Flare gas recovery system means 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 NO! there is still no explicit requirement in the final NSPS Ja to install a flare gas recovery system. However, in the rule preamble EPA states that the required flare monitoring, FMP, and RCAs will likely demonstrate that a flare gas recovery system is economical. Overview of Ja & Flare CDs 10/24/

16 Ja Flare RCA/CA Triggers & Requirements RCA/CA Trigger: Any time the SO 2 emissions exceed 500 lb in any 24- hour period: The final NSPS Ja is clear that the 500 lb SO 2 limit is an absolute limit, with no regard to flare s SO 2 permitted emissions limit RCA/CA Trigger: Any discharge to the flare in excess of 500,000 SCFD above the baseline flow in any 24-hour period. RCA/CA Trigger: Blown water seals for infrequently-used flares that claim the Ja alternative monitoring option, unless the event is related to FGRS compressor cycling or a planned startup or shutdown conducted in accordance with the Flare Management Plan RCA/CA Deadline: All the requirements for determining when and how to conduct a RCA and CA analysis, and the requirements for when and how to implement a CA, have been expanded normally the RCA and CA must be completed within 45 days of the triggering event A RCA is not required for any flare discharges from planned startups or shut downs if the Flare Management Plan (FMP) was followed. Overview of Ja & Flare CDs 10/24/

17 NSPS Ja Flare Management Plan a(a) Elements of the Flare Management Plan (FMP): (1) A listing of all refinery process units and fuel gas systems connected to each affected flare (2) Assessment of whether discharges to affected flares can be minimized; (3) A description of each affected flare (4) Evaluation of the baseline flow to the flare (5) Procedures to minimize or eliminate discharges to the flare during planned startups and shutdowns (6) Procedures to reduce flaring in cases of fuel gas imbalance (i.e., excess fuel gas for the refinery's energy needs) (7) If equipped with flare gas recovery systems, procedures to a) minimize the frequency and duration of outages of the flare gas recovery system and b) minimize the volume of gas flared during such outages Overview of Ja & Flare CDs 10/24/

18 NSPS Ja FMP: Baseline Flow Evaluation Determined after implementing minimization assessment Do not include pilot or purge flow (gas introduced after the flare s water seal) if constant Separate baseline flows allowed for special operating conditions if FMP includes: Primary baseline as the default Special condition description (including rationale, duration, daily flow) Procedures to minimize discharges during each special condition Overview of Ja & Flare CDs 10/24/

19 NSPS Ja Flare Compliance Deadlines Modified Flares Generally Given 3-yr Leeway Period 162 ppmv short-term H 2 S limit: comply by November 13, 2012 or upon startup of the modified flare, whichever is later applies only if the flare is already a FGCD under NSPS Subpart J Root Cause Analyses (RCAs): comply by November 11, 2015 or upon startup of the modified flare, whichever is later Flare Management Plan (FMP): develop and implement the FMP by November 11, 2015 or upon startup of the modified flare, whichever is later Flare Monitoring: comply by November 11, 2015 Quote from Rule Preamble: Compliance with the phased compliance schedule [for modified flares] constitutes compliance with the flare standards as of the effective date [November 13, 2012] Overview of Ja & Flare CDs 10/24/

20 NSPS Ja Flare Compliance Deadlines New and Reconstructed Flares Very Little Compliance Schedule Slack Provided Per Rule Preamble: We note that the final rule does not provide a phased compliance schedule for new and reconstructed flares. The final rule requires owners and operators of new and reconstructed flares to meet all the flare requirements upon the effective date of the requirements or upon startup of the affected flare, whichever is later. The final NSPS Ja essentially locks in the rapidly-approaching compliance deadline of November 13, 2012 for flares that already qualify as being new or reconstructed under NSPS Ja (although a 60 to 180 day shakedown period applies to certain requirements as per 60.8(a) and 60.13(b) of the NSPS General Provisions) AGAIN THIS IMPORTANT NOTE: in order to identify the required schedule to achieve compliance, you must know which NSPS applicability trigger new, modified or reconstructed makes a flare subject to Ja Overview of Ja & Flare CDs 10/24/

21 Flare Consent Decrees Overview of Ja & Flare CDs 10/24/

22 NSPS Subpart Ja vs. Flare CDs Objective of NSPS Subpart Ja Flare Provisions: Minimize or eliminate vent gas flow to flares via flare gas recovery systems, FMPs and a robust RCA and corrective action program (but no numerical flow limitation) H 2 S/TRS limit in vent gases to minimize SO 2 emissions Objective of Flare CDs: In addition to existing NSPS Subpart A requirements, improve combustion efficiency by monitoring and controlling multiple parameters identified in recent flare studies. Overview of Ja & Flare CDs 10/24/

23 As Steam to Vent Gas (SVG) Ratio Increases, Combustion Efficiency Decreases Photo credit: September 2010 New Developments in Flaring presented by East Harris County Air Partners Overview of Ja & Flare CDs 10/24/

24 Flare Study History Early 1980s: EPA concluded that properly designed and operated flares can achieve >98% CE 1998: EPA promulgated current version of NSPS and NESHAP flare general provisions focus on vent gas heating value and tip exit velocity. Other studies identified other factors that impact CE. Some studies are listed below: EPA: May 1984 Evaluation of the Efficiency of Industrial Flares: Flare Head Design and Gas Composition MPC Detroit: November 2010 Performance Test of a Steam-Assisted Elevated Flare With PFTIR (other sites and companies too) TCEQ: August 2011 TCEQ 2010 Flare Study Final Report Overview of Ja & Flare CDs 10/24/

25 Revised NHV Basis under CDs *Drawing from May 2012 EPA Presentation by Brian Dickens Overview of Ja & Flare CDs 10/24/

26 Flare Consent Decrees Formalized negotiations between EPA / state environmental agencies, DOJ, and private corporations Flare CDs began with the National Petroleum Refinery Initiative (2000), then extended to multiple industries EPA Global Petroleum Refinery CD statistics: 31 settlements with U.S. companies Representing over 90% of U.S. petroleum refining capacity. Include 107 refineries in 32 states and territories Most already reference flaring of SO2 and acid gas events Include enhanced requirements for specific regulatory programs Flare CD Legal Basis Allegation is that. NSR Past projects may have may have been major modifications, especially if flare efficiency was low. Overview of Ja & Flare CDs 10/24/

27 Presented Flare Consent Decrees Equistar Chemicals July 2007 ($1.9 million penalty, 154 p) INEOS (Lanxess) July 2009 ($3.1 million penalty, 85 p) Marathon Petroleum April 2012 ($460,000 penalty, 196 p) BP, Whiting Refinery May 2012 ($8 million penalty, 325 p) Note: 40 CFR is only 3 pages in the regs and contains ~907 words compare to MPC s Flare CD which is 196 pages that contains 98 definitions. Overview of Ja & Flare CDs 10/24/

28 Flare CD Comparison Classification 1 Classification 2 Steam to Vent Gas Ratio (mass) Steam to Vent Gas Ratio (volume) Equistar 2007 INEOS Lanxess 2009 MPC 2012 BP Whiting :1 Auto 3.6:1 Max 3:1 Max 3:1 Max 2.7:1 Max Operating Parameters DCS Logic NHV FG (in the flare gas, at the tip) > 300 Btu/scf 385 Btu/scf (or >200), set by P-FTIR >300 Btu/scf > 300 Btu/scf (variable NHV) (variable NHV) Flaring Limitations (SSM included) X (by flare, by refinery) X (3.1MMscfd) Momentum Flux Ratio MFR (minimum) All > ; Detroit > > No Visible Emissions (SSM excepted) X X Exit Velocity (<60 fps) X X (with exceptions) X (with exceptions) Supplemental Fuel Addition X X X Steam Addition X X X For Equistar, NHV-FG includes pilot gas, and is LHV. MFR incorporated into the calculation for NHV. For BP, all Flare Provisions located in the CD s Appendix D (100 pages). Overview of Ja & Flare CDs 10/24/

29 Flare CD Comparison Classification 1 Classification 2 Equistar Lanxess MPC BP Whiting Monitoring (Most all to be in 5 minute block averages, GCs every 15 minutes.) Vent Gas Flow Rate X X X X Enhanced Vent Gas FR Monitoring (includes T and P correction) 1,3 Butadiene Flow X X (dual channel) X (dual channel) Steam Flow X X X Enhanced Steam FR Monitoring X X Supplemental Fuel Flow X Pilot Gas Flow X Optional Optional Vent Gas MW X X X Vent Gas Composition (by GC) Upstream of any Sweep or Purge Gas X X (thru C5+) X (thru C5+) Wind Speed (Met station high as possible ) X X X (if >5% in X (if >5% in manual mode; manual mode; Video Camera - Recording 4 fpm) 4 fpm) Exceptions allowed during SSM X X X Presence of Pilots X X Overview of Ja & Flare CDs 10/24/

30 Flare CD Comparison Classification 1 Classification 2 Equistar Lanxess MPC BP Whiting Flare Monitoring SOP X Report Development Enhanced Flare Monitoring Report X X Flare Minimization Plans X X Flaring Minimization Implement Specific Minimization Techniques Tailchase FGRS (4) X (to determine NHVFG) X (at Garysville GF) X (2 flares) Performance Test PFTIR Test Training Operators & Supervisors X X Survey all sweep/purge gas meters X Facility Survey Survey/Minimize Sweep/Purge Gases X Survey HP HC PRVs X Root Cause Analysis Perform RCA on Reportable Flaring Events X X X Flare Performance Maintain 98% combustion efficiency by compliance with NHV, S/VG, and MFR X X NHV means the NHV cz must be > NHV cz-limit NHV is variable. Overview of Ja & Flare CDs 10/24/

31 Flare CD Comparison Conclusions Very recent time tells an interesting story Quantity of provisions significantly increased with time. Similar provisions became much more detailed with time. Equistar (2007): very few monitoring requirements aside from existing GCs and vent gas flow meters (required per HRVOC program in Houston area) very few operating parameter requirements INEOS Lanxess (2009) no flare header contribution mapping requirement no minimization study report/requirement no MFR calculation requirement no explicit requirement to incorporate NHV, MFR or LFL to demonstrate proper flare combustion efficiency. Interest in S:VG only. Overview of Ja & Flare CDs 10/24/

32 Flare CD Comparison Conclusions Marathon (2012) Significant expansion of monitoring requirements (estimated at $1-2 MM per flare) Is this good air pollution control practice? OR Is this excellent air pollution control expectation? No mandatory Flare Gas Recovery, but max flow limitations now in place. Flare Minimization Plans will drive further progress. Explicit requirement to incorporate S/VG, MFR, NHV, and LFL to demonstrate proper flare combustion efficiency, even during SSM events. BP Products (2012) Very similar to Marathon; however, FGR compressors required (eventually 11 total). Has an air-assisted flare in the system (A:VG <10). Has more time to implement all the changes. Emphasis is on Waste Gas Minimization Overview of Ja & Flare CDs 10/24/

33 Overview of Ja & Flare CDs 10/24/

34 Flare CD Impressions EPA has quickly gained a sophisticated understanding of flare combustion issues. April 2012 Parameters for Properly Designed and Operated Flares from EPA to the Flare Review Panel. SR <7 and ratio NHV cz :NHV LFL > 6.54 The next flare rule will most likely incorporate many (all?) aspects of these latest flare CDs. Overview of Ja & Flare CDs 10/24/

35 Flare CD Impressions How much monitoring is necessary? What is my take-away for my flare? Good versus Excellent? Practice versus Expectation? Should my new Ja project incorporate SVG monitoring or control? Is there some incremental effort I can do now? What is that one holy grail parameter? NHV vg-lfl = NHV vg * LFL vg and then Ratio of NHV cz : NHV cz-limit >6.54 where limit uses variable Combustion Efficiency Multipliers and nitrogen equivalency factors. Can permitting and enforcement deal with a variable parameter deeply embedded into our DCS logic? Overview of Ja & Flare CDs 10/24/

36 Suggested Approach Evaluate NSPS Notification due dates Detailed Flare Systems Assessment Ja Requirements monitoring and data management Consideration of CD issues and options Baseline Flow Assessment data planning Minimization Assessment options for H2S, and flow Flare Management Plan Development Flare Systems network optimization, systems verification Overview of Ja & Flare CDs 10/24/

37 Compliance Techniques Flare Monitoring Systems Reports Systematic approach to demonstrating compliance with monitoring requirements. Provides detailed instructions to collect data and maintain monitoring compliance. Crux of the flare compliance program. Flare Control System (automatically adjust NHV and SVG) Flare Gas Minimization Plan Unit by unit assessment SSM considerations Builds on data generated from monitoring, the DMAT, and other gap assessment tools Systematic approach to target contributions with high-reduction potentials Overview of Ja & Flare CDs 10/24/

38 Gap Assessment Tools Flare Mapping for Non-PRV sources. Detailed assessment during SSM activities. Contributions Flare Header Contributions Overview of Ja & Flare CDs 10/24/

39 Gap Assessment Tools Flare Header In-Line Leakage Surveys Acoustic Monitoring VPAC II Identifies leaking valves immediate ROI once a leaking valve is repaired. Correlation Equations developed by BP in the UK. May not be technically accurate but very good range of service. m Overview of Ja & Flare CDs 10/24/

40 Sage s Recent FLARE Activities International Benchmarking of Industrial Flaring Requirements USA, Canada, Europe IPPC, United Kingdom, Norway, and World Bank EU BREF Note s Review of new expectation for flares =Emergency Use Only? Flare Monitoring Assessments equipment viability for flow & composition, DCS logic for staged steaming, etc. Flare Contributions Analysis (detailed Flare Mapping) Flare Gas Recovery Compressors conceptual planning Development of the Flare DMAT (Documentation, Minimization and Analysis Tool) FLIR Camera Studies of Flare Activities Flare and PRV Surveys (acoustic monitoring) NSPS Ja Regulatory Assessments and FMP development Overview of Ja & Flare CDs 10/24/

41 Questions? Troy M. Boley, PhD. Phone: Raymond Allen Phone: Overview of Ja & Flare CDs 10/24/

42 Summary of Key NSPS Subpart Ja Deadlines Any flare built or reconstructed after June 24,2008 is NEW Flare Applicability Dates Any flare modified after June 24, 2008 is MODIFIED Rule Promulgation Date September 12, 2012 Rule Effective Date November 13, 2012 Subpart Ja Specific Deadlines (Modified flares are subject to a phased implementation schedule; new flares are not) Modified or Constructed AFTER Modified or Constructed AFTER rule June 24, 2008 and BEFORE rule promulgation (September promulgation (September 12, 2012) 12, 2012) Deadlines Citation Modified flare New flare Modified flare New flare Flare Management Plan Root Cause Analysis program a (b)(1) a (c)(6)(x) November 11, 2015 November 11, 2015 November 13, 2012 November 13, 2012 Startup or November 11, 2015 (whichever is later) Startup or November 11, 2015 (whichever is later) Upon Startup Upon Startup Flow and TRS/H 2 S Monitoring a(e) a(f) November 11, 2015 if not in place November 13, 2012 Startup or November 11, 2015 (whichever is later) Upon Startup 162 ppmv H 2 S limit in flare gas (relief valve leakage and emergencies are exempt) a(f) a(h) a(2)(vi) ( A) -IF Not subject to Subpart J prior to Ja: November 11, IF Subject to Subpart J prior to Ja: November 13, IF Subject to Subpart J prior to Ja (without continuous monitoring and recording): November 11, IF Subject to Subpart J prior to Ja but currently under a Consent Decree: November 11, 2015 November 13, 2012 IF Not subject to subpart J prior to Ja: Startup or November 11, 2015 (whichever is later) IF Subject to subpart J prior to Ja: Startup or November 13, 2012 (whichever is later) IF Subject to Subpart J prior to Ja but currently under CD: November 11, 2015 Upon Startup Overview of Ja & Flare CDs 10/24/

43 NSPS General Provisions Subpart A Deadlines Regulation Citation Construction Notification Due 30 days after construction of an affected facility commenced 60.7(a)(1) Startup Notification Agency Notification for Monitors Monitoring Performance Test Notification Performance Test Performance Test Report Actual date of affected facility startup within 15 days of startup Submitted with startup notification 30 days prior to the Monitor performance testing Within 60 days after maximum production rate but not later than 180 days after initial startup 60 days after completion of monitoring verification 60.7 (a) a (b) 60.7(a)(5, 6) 60.8(d) 60.8a 60.13c(2) Overview of Ja & Flare CDs 10/24/