Be Aware of Your Flares

Recent events have escalated our meticulousness in our oversight of flare compliance. The addition of the “alternative work practice” in 60.18(g) provided a means for both industry and the regulatory community to ensure compliance. The steady increase in availability of infrared camera technology amongst the regulatory community, as well as environmental interest groups, further increases the need for proper diligence. Also, there has been a steady increase in media attention compounded with resulting heightened awareness from regulatory agencies in the form of both aerial and ground-level investigations.

Some key aspects spelled out in 40 CFR §60.18 that come to mind are: 

?      60.18 (c)(1): Flares shall be designed for and operated with no visible emissions as determined by the methods specified in paragraph (f), except for periods not to exceed a total of 5 minutes during any 2 consecutive hours.

?      60.18 (c)(2): Flares shall be operated with a flame present at all times, as determined by the methods specified in paragraph (f)

?      60.18 (f): References EPA Method 22 that uses the human eye to determine the total time an industrial activity causes visible emissions.

?      60.18(g)(4): Optical gas imaging instrument means an instrument that makes visible emissions that may otherwise be invisible to the naked eye.

?      60.18 (d) Owners or operators of flares used to comply with the provisions of this subpart shall monitor these control devices to ensure that they are operated and maintained in conformance with their designs.

Proactive internal management is integral to the demonstration of compliance and includes such strategies as:

·        Maintaining an accurate daily flare operations log

·        Routine infrared camera inspections

·        Flare operations training for field personnel

·        Maintenance program

In short, we need to be “aware of our flares”.