Presentation Profile
EMACT (Chemical Sector Rule) - Lessons Learned from Refinery Sector Rule Implementations for Flares
Currently Scheduled: 10/16/2019 - 8:50 AM - 9:15 AM
Room: Wisteria Room
Main Author
Andy Shurtleff - Airgas, an Air Liquide company
Abstract:
A Top 10 Run Down plus a few Bonus topics to ease the transition to the new Requirements Refineries trying to adhere to the new Refinery Sector Rule (RSR) implemented January 30, 2019 found interpretation of the guidelines and related compliance to be no easy feat. Fortunately for those in the Chemical Sector, the path to compliance is mostly paved due to significant overlaps in the RSR and proposed CSR (EMACT) rules. Examples includes the requirement for documenting proof of compliance with the requirement for 98% destruction of Hazardous Air Pollutants (HAPs), frequency of measurement and overall monitoring systems uptime for reporting. While most U.S. refineries have taken the necessary steps to install instrumentation and implement calibration/validation regimens to meet these requirements, others are still working toward compliance with deadline date extensions The process of gaining needed capabilities has generated some experiential education related to calibration/validation (Cal) gases. At the top is the reminder that all is subject to change via EPA or other regulatory authority requirements or approval of Alternative Monitoring Plans (AMPs). Variables can be general, regional, localized, site specific or company by company among others. This session is focused on an active vendor observation of Top Ten common RSR lessons learned and sharing some of the strategies employed for RSR compliance as a boost forward toward CSR compliance. This is intended to be a conversational session and there will be time throughout and following for Q&A.
