CleanAir Refinery Sector Rule

Refinery Sector Rule 2018 Amendments: Flare Impacts

Nov 20, 2018

On November 8, 2018, US EPA issued final amendments to the Refinery Sector Rule. These final amendments are based on EPA’s April 10, 2018 proposal. As November 19, this final rule has not been published in the Federal Register, so this analysis[…]

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Btu per SQUARE FOOT? What the heck is EPA’s Flare Dilution Factor?

Oct 12, 2018

OK… This is a long one.

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It’s Time to Rethink Flare Velocity Limits

Sep 26, 2018

US EPA’s flare velocity limits were originally issued in 1986. Since then, they have found their way into flare regulations around the world. They were developed following a series of EPA sponsored tests conducted in the 1980’s that examined how[…]

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EPA Proposes Refinery Sector Rule Amendments - Part 2

Mar 21, 2018

This is Part 2 of my blog post on EPA's proposed amendments to the Refinery Sector Rule (RSR). Part 1 covered changes to Subpart CC (MACT 1). Part 2 covers changes to Subpart UUU (MACT 2) and Subpart Ja.

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EPA Proposes Refinery Sector Rule Amendments - Part 1

Mar 20, 2018

On Monday, March 19, 2018, US EPA issued proposed amendments to the Refinery Sector Rule (RSR). These amendments are based on three petitions of reconsideration filed with the agency -- two of these were joint submissions by the American[…]

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EPA Allows Refineries to Measure Flare Vent Gas NHV with Mass Spectrometers

Feb 6, 2018

EPA has published a broadly applicable approved alternative test method (ALT-124) allowing refineries subject to 40 CFR 63, Subpart CC to use mass spectrometers to measure the net heating value of flare vent gas. The original language of the[…]

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