Industrial Flare Consulting

For some facilities, enforcement scrutiny is not a matter of if, but when. If your facility has escaped scrutiny, but you are concerned you could be next, understanding what information could be requested and how compliance will be judged can be crucial. Spectrum works with facilities to review flare systems and existing data to assess a facility to determine how enforcement could view a facility. These assessments also help environmental departments assemble the required information to allow for more timely responses.

Receiving a Section 114 request and formulating a response can be a large undertaking. It will take coordination between legal, environmental, engineering, and operations in order to put all the required pieces together. Spectrum has helped refineries, chemical plants, and petrochemical plants to assemble the data and provide narrative responses to the questions. Spectrum understands what should be included vs. what is not pertinent to the request.

Once the flurry of activity has ended and the Section 114 response has been submitted, now you want to know how the response will be viewed by enforcement. Will they take issue with alleged poor combustion? Is sufficient data available to make a determination? Spectrum reviews the data and provides insight into how regulators will view the status of the flare vs. existing regulation and future expectation.

The path from Section 114 request to signing a CD is a lengthy process. Just because you are in the process, doesn’t mean enforcement doesn’t expect changes to be made during the process. Spectrum works with facilities to implement activities that show movement in the right direction to show active engagement by the facility.

One thing Spectrum believes strongly is, THE WORDS MATTER! Poorly or ambiguously worded CDs lead to potential future enforcement risk and headaches for implementation. Spectrum reviews CD language to identify areas for clarification to ensure compliance with the strategy implemented. This avoids costly changes to designed systems at the last minute.

Implementation with a CD starts before the CD is signed!  Most facilities need to have monitoring and control systems installed before the CD is in effect.  Spectrum’s experience with CD implementation allows us to guide engineering to design systems that can ensure compliance even with changes during negotiations, which includes setting up the data systems to readily provide the required reporting requirements.

The CDs typically include multiple reports that will require annual/semi-annual updates:

• Data and Monitoring Systems (DMS) Protocol Report
• Waste Gas Minimization Plan (WGMP) Report
• Semi-Annual Report