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{longname} Q702. If a startup, shutdown, or malfunction (SSM) event lasts for several days, should the flare flow term in Equation Y-3 include the cumulative flow for the entire event or only the cumulative flow for the day(s) for which the 500,000 scf/day threshold was exceeded?
{longname}

A702.While the threshold is assessed on a per day basis, the flare flow term, (FlareSSM)pFlare{~}SSM~){~}p~, in Equation Y-­3 is defined on a per "event" basis. If a SSM flaring event exceeds 500,000 scf in any "day" then the cumulative flare gas flow due to the entire SSM event should be included in the flare flow term, (FlareSSM)pFlare{~}SSM~){~}p~. For example, if a SSM event spanned two separate days and the flow due to the event was 1,000,000 scf on Day 1 and 400,000 scf on Day 2, this event would exceed the reporting threshold because it had at least one consistently designated 24-hour period ("day") in which the cumulative flow exceeded 500,000 scf. This would be reported as one event in Equation Y-3 and the entire 1,400,000 scf flow for the event would be used for the (FlareSSM)pFlare{~}SSM~){~}p~ term for this event. See the table below for some additional examples.
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Source: A. McKittrick, 11/27/2012 (Subpart Y_Flare SSM FAQ_final_2.docx)

Approval / Publishing History: Version 1

Expiration: none

Relevant Subparts: Subpart Y
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