Saep 340 PDF
Saep 340 PDF
Saep 340 PDF
Contents
1 Scope................................................................. 2
2 Conflicts and Deviations .................................... 2
3 Applicable Documents ....................................... 2
4 Definitions, Abbreviations, and Acronyms .......... 5
5 Air Dispersion Modeling ................................... 12
6 Emission Inventory........................................... 18
Revision Summary................................................. 18
APPENDIX ............................................................................................................... 19
TABLE 1 - MEAN BACKGROUND CONCENTRATION DATA SHEET................................... 19
TABLE 2 - BUILDING DIMENSIONS INFORMATION
USED FOR BUILDING PROFILE INPUT PROGRAM, BPIP ............................ 19
TABLE 3 - STACK EMISSION ESTIMATION W ORKSHEET AND MODELING RESULTS.......... 20
TABLE 4 - FUGITIVE EMISSIONS ESTIMATION W ORKSHEET .......................................... 21
TABLE 5 - BULK LOADING EMISSIONS AND
PRODUCT TRANSFER EMISSIONS W ORKSHEET ....................................... 22
TABLE 6 - TANK EMISSIONS W ORKSHEETS ................................................................ 23
TABLE 7 - EMISSIONS INVENTORY FORMAT TABLE ..................................................... 26
TABLE 8 - VOC AND HAPS EMISSIONS
FROM GASOLINE TRANSFER AND DISPENSING OPERATIONS ..................... 27
TABLE 9 - MARINE VESSEL EMISSION FACTORS ......................................................... 28
TABLE 10 - MARINE FACILITY DATA SHEET................................................................ 29
1 Scope
This document, SAEP-340, contains technical procedures for ambient air dispersion
modeling and emissions inventory. This document also supports the design
requirements of SAES-A-102, “Ambient Air Quality and Source Emissions Standards.”
2.1 Any conflicts between this Procedure and other applicable Saudi Aramco
Engineering Procedures (SAEPs), Saudi Aramco Engineering Standards
(SAESs), Saudi Aramco Materials System Specifications (SAMSSs), Saudi
Aramco Standard Drawings (SASDs), or industry standards, codes, and forms
shall be resolved in writing through the Manager of Environmental Protection
Department of Saudi Aramco, Dhahran.
2.2 Direct all requests for deviations from this Procedure in writing in accordance
with SAEP-302 and forward such requests to the Manager of Environmental
Protection Department of Saudi Aramco, Dhahran.
3 Applicable Documents
Except as modified by this SAEP, applicable requirements in the latest issues of the
following industry Codes, Standards, and Practices shall be considered an integral part
of this procedure.
“Flaring & Venting in the Oil and Gas Exploration & Production Industry,”
International Association of Oil & Gas Producers (OGP), Report No. 2.79/288,
London, January 2000
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Page 3 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
“A User’s Guide for the CALPUFF Dispersion Model (Version 5).” Scire, J.S.,
D.G. Strimaitis, and R.J. Yamartino: Earth Tech, Inc. Concord, MA, 2000a
“Air Pollution Engineering Manual Second Edition,” Air & Waste Management
Association (A&WMA), edited by Wayne. T. Davis, April 2000
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
“Locating and Estimating Air Toxics Emissions from Organic Liquid Storage
Tanks,” Chapter 7.1 of AP-42, U.S. Environmental Protection Agency, Research
Triangle Park, N.C. updated November 2006
https://sourceforge.net/projects/epri-dispersion/files/SCICHEM/
http://www.epa.gov/scram001/dispersion_alt.htm
https://www3.epa.gov/ttn/scram/dispersion_related.htm#mmif
4.1 Definitions
Page 5 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Air Quality: Ambient air pollutant concentrations with temporal and spatial
distribution.
Air Pollutant: Any substance emitted to the atmosphere that causes or has the
potential to produce adverse impacts on human health or the environment.
Ambient Air: The portion of the atmosphere external to defined industrial areas
(facility plot limits).
24-Hour Average: computed as the daily average only and not as a running
24-hour average.
Annual Average: computed on a non-running 12-month Gregorian calendar
(January – December).
Calms: A term used in air dispersion modeling to indicate wind speeds of less
than 1.0 meters per second.
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Criteria Pollutant: An air pollutant for which an air quality standard with a
specific set of ambient air concentration limits has been established by the Saudi
Arabian government based on specific health criteria (i.e., SO2, O3, NO2, CO,
Particulates).
Downwash: This is a term used in air dispersion modeling to describe the effect
of turbulence from buildings and other structures on the laminar and dispersive
flow of stack emissions. Downwash considerations are important when
modeling sources in close proximity to buildings, hills, trees, and other
obstructions to air flow.
Emission Source: Any facility, process, or operation that releases air pollutants
to the atmosphere.
Exceedance: A Ground Level Concentration (GLC) value greater than the limit
specified by the government for a specified averaging time (i.e., 1-hour, 3-hour,
8-hour, 24-hour, monthly, 3-month, or annual)
Good Engineering Practice (GEP) Stack: The stack height (as measured from
the ground-level elevation at the base of the stack) below which emissions from
the source are influenced by the aerodynamic downwash of nearby buildings or
other structures. The GEP stack height, HS, is calculated as follows: HS = H +
1.5L where H is the height of the nearby structure and L is the lesser dimension
of the height or width of the nearby structure. “Nearby” means that distance up
to 5 times “L” but not greater than 0.8 kilometer (½ mile). It should be noted
that compliance with this condition does not relieve the PMT or Facility from
ensuring ambient air quality standards are also met. For safety purposes, HS
must also meet the requirements of SAES-B-055, Appendix F-1 which states
that “the top of the furnace stack shall be at least 3 meters higher than any
working platform within 60 meters horizontally of the stack.”
Page 7 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Industrial Area: The area within the property line or recognized border limits
of a facility from which the public is restricted.
Insolation: The rate of delivery of all direct solar energy per unit of horizontal
surface, measured as solar radiation.
Load Capacity Factor: The output of a device (boiler, process heater, furnace,
etc.) expressed as a percentage of the maximum rated design capacity of the
device (Example: a 0.5 load capacity factor indicates the device is operating at
50% of the maximum rated capacity of the device).
Mixing Height: The depth at which atmospheric pollutants are typically mixed
by dispersive processes.
New Facility: Any facility designed and constructed as a wholly new facility.
All new facilities must be meet all current and anticipated environmental
standards and regulations.
Non-Criteria Pollutant: Any air pollutant that does not have a specific ambient
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Particulate Matter: Any finely divided solid or liquid material, other than
uncombined water, as measured by the USEPA reference or equivalent
measurement method.
Reid Vapor Pressure: The absolute vapor pressure of a volatile crude oil or
volatile non-viscous petroleum liquids (except liquefied petroleum gases) as
determined by the American Society for Testing and Materials (ASTM).
Royal Commission for Jubail (RCJ) and Yanbu (RCY): The jurisdictional
authority that administers activities within the Madinat Jubail Al-Sinaiyah and
Madinat Yanbu Al-Sinaiyah areas.
Sigma Theta (σθ): The standard deviation of the horizontal wind direction over
a 1-hour period, in degrees. A value used to determine the stability
classification of the atmosphere.
Stack Testing: The manual sampling of stack gases during normal operation to
determine the emission rates of specific pollutant. Stack testing is part of the
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
performance testing required at the initial start-up of a new process. Stack testing
may also be required periodically thereafter if mandated by the regulatory agency.
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
The Consultant performing the air dispersion modeling work shall demonstrate
sufficient knowledge and experience with the below recommended models and
projects of similar size. EPD reserves the right to evaluate the Consultant’s
capabilities and to reject any air dispersion modeling proposal, report, or
consultant.
The following models (latest regulatory version) can be used as detailed later:
SCIPUFF/ SCICHEM
CALPUFF
AERMOD
Before an air dispersion modeling study is conducted, EED shall review and
approve, within 15 business days of submittal, the following details:
a. Modeling Protocol detailing the modeling scope & objective; scenarios;
assumptions; data sources (ambient, emissions, site, etc.); report and
structure.
b. Meteorological and air quality data (latest 5 year data)
c. Background ambient air quality levels
d. Modeling assumptions & field parameters, i.e., meteorology coefficients, etc.
e. Dispersion model type and version
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
https://sourceforge.net/projects/epri-dispersion/files/SCICHEM/
CALPUFF, a refined three dimensional ‘non-steady state’ model shall be the
preferred model for complex meteorological conditions (i.e., non-steady) and/or
influences from geophysical factors such as ‘coastal areas’ (i.e., land and sea
breeze), recirculation, reversal flows and others conditions such as stagnation.
Where this section does not address specific modeling input requirements, the
model shall adhere to the procedures set forth in the USEPA document
"Guidelines on Air Quality Models" and 40 CFR, Chapter 1, Part 51,
Appendix W”.
http://www.epa.gov/scram001/dispersion_alt.htm
https://www3.epa.gov/ttn/scram/dispersion_related.htm#mmif
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
For modeling purposes, the maximum design load conditions shall be used to
predict the worst-case short-term ambient air quality impacts of 1-hour and
24-hour duration. Anticipated normal operating conditions shall be used for
assessing long-term impacts (annual or longer periods).
Good Engineering Practice (GEP) shall be applied to stacks for all project
designs. GEP definition is shown in Section 4. GEP guidelines shall be used
for modelling purposes, see Section 4.1.
All Saudi Aramco modelling projects shall use the latest USEPA executable
code version listed on SCRAM website or EPRI sourceforge. All modelling
codes are freely downloadable from:
USEPA (http://www.epa.gov/scram001/dispersionindex.htm) and from
Sourceforge (http://sourceforge.net/projects/epri-dispersion/).
All modelling files, associated codes, etc., including pre & post-processors and
utility packages shall be of non-proprietary nature when submitted to EPD for
project reviewing. All modelling file extensions and its formats shall adhere to
original USEPA file formatting to avoid any incompatibility issues during
reviewing process. All modelling related files and executable codes shall be
provided to EPD in structured format on external hard drives for EPD reviewing
at 30% project proposal or at FEL2 (DBSP phase) for project following the new
Capital Management System. All screen and refined air dispersion models, not
limited to AERMOD, CALPUFF, SCIPUFF/SCICHEM , respectively can be
downloaded freely from the USEPA SCRAM website or from SOURCEFORGE.
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Where possible, EPD will provide appropriate datasets for the modeling and/or
the technical guidance for conducting a proper technical modelling study.
Where there are missing hours in the meteorological data, the following USEPA
recommended options shall be applied to the missing data, but not limited to;
“Guideline on Air Quality Models” and “On-Site Meteorological Program
Guidance for Regulatory Modeling Applications.” Alternatives for filling
missing upper air data can be substituted by using prognostic data (i.e., WRF)
for the same year is preferred.
Modelling results shall include background ambient air quality pollution levels
that are based on a minimum of one year ambient air quality data collected from
the nearest monitoring station that is representative of the local area modeled,
preferably those collected by the Saudi Aramco Air Quality and Meteorology
Monitoring Network (AMMNET) program. Any other non-AMMNET data can
be used provided that proper data collection and QA/QC procedures are
implemented and presented to EPD (calibration and maintenance records,
QA/QC reports, etc.).
Building Profile Input Program (BPIP) shall be used and information tabulated
as listed in the Appendix Table 2. BPIP or Prime BPIP building down wash
algorithms shall be used in all modelling applications, where appropriate.
The Appendix Table 4 shall be used to record the input and output data for the
air dispersion modeling study.
Page 16 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
The final report shall include the following, but not limited to:
Clear digital maps detailing the area(s) modelled (axis scale in km) and
information of datum used;
Tabulate existing and proposed facility emission sources;
Locations of other significant emissions sources that emit the same
pollutants within 50 km radius; UTM coordinates shall also be tabulated;
Plots showing sensitive receptors, dense discrete receptors, emissions
sources presented on separate plots;
Typical preferred grid spacing of discrete receptors are; at fence-line, i.e.,
50 m, expanding to surrounding areas with appropriate spacing, such as
100 m, 250 m, 500 m, 1 km spacing;
Tabulate all emissions inventory of the facility;
List location(s), names and UTM coordinates of dimensions of any
significant obstacles, such as buildings or hills that could affect dispersion of
the air pollutants under study;
Tabulate and report any sensitive receptors and population groups within
50 km radius of the facility (including local residents, offices, service
stations and schools, farming area, sensitive), along with the locations of
these groups. UTM coordinates and population statistics, should be
provided where possible;
Tabulate and provide predicted ground-level concentrations (GLC) summaries
for; i.e., 1 and 24 hour AAQS pollutant with the highest, 2nd-highest, and
3rd-highest values (i.e., UTM coordinates, concentration values, wind speed,
wind direction) and corresponding date/hour for these values;
Provide clear plot(s) of predicted GLC isopleths superimposed on a current
area map of the facility and its environs, showing all emission sources and
identified sensitive and discrete receptors;
All modelling field option(s) used for modeling shall be presented, and
examples of modelling input files, control and listing files shall be provided;
Process flow diagram(s) showing existing facilities and proposed changes,
additions, modifications.
Evaluate engineering and design information (Technology details, Licensor
guarantees, and design documents) to support and demonstrate effectiveness
of the proposed mitigation measures. Such an evaluation shall be part of the
ADM report.
Page 17 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
6 Emission Inventory
6.1 General
An emission inventory can be used as a basis for air dispersion modeling studies,
demonstrate compliance with environmental standards, and minimize waste.
Tables are provided in the Appendix as an aid in developing a comprehensive air
emission inventory. EPD shall receive all emissions inventory data prior to any
modelling work for approval. The emissions data shall be provided in excel
spreadsheet with appropriate footnote and references. The excel spreadsheet shall
contain open-access calculation cells and include all the details of the calculations
and assumptions (separate Tabulations). Any hard-wired numbers shall be duly
explained and referenced.
The quantities of each pollutant emitted shall be based on one or more of the
following methods, and the method(s) used shall be stated in the inventory:
Measurements obtained by stack testing, continuous emission monitoring,
predictive emissions monitoring, or process gas sampling providing the
sample analyses are quality-assured;
Process-related engineering calculations;
Manufacturer’s emissions data - based on performance testing with the
installed equipment;
Emission factors based on the latest USEPA AP-42, API, CMA, or other
recognized governmental or industry source(s);
SAES-A-112 for meteorological conditions; and/or,
Saudi Aramco product specifications for hydrocarbon properties.
Revision Summary
5 June 2010 Revised the "Next Planned Update". Reaffirmed the contents of the document, and reissued
with other changes.
14 November 2016 Major revision as per the scheduled review cycle and updated to reflect the applicable new
air quality modeling and emissions estimation techniques.
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Appendix
Page 19 of 33
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Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Page 20 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Page 21 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Loading/Unloading of Product
From Storage Tanks Operations
Page 22 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Facility Name:
Environmental Coordinator:
Roof Characteristics:
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Facility Name:
Environmental Coordinator:
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Environmental Coordinator:
Tank ID#:______________________________________
Roof Characteristics
Breather Vent
Page 25 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
UTM (km, x, y)
Fuel
Stack ID #
(Gas/liquid) Potential
Actual Emissions Emissions
Emission Emissions
Factor
(Unit) Kg/hr MT/Yr Kg/hr MT/Yr (ng/Joule)
Page 26 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Table 8 - VOC and HAPs Emissions from Gasoline Transfer and Dispensing Operations
Emission Emission
Rate Rate Annual VOC Annual HAP Annual VOC Annual HAP
Throughput1
Emission Source (lb VOC / (lb HAPs / Emissions2 Emissions7 Emissions3 Emissions7
(gal)
1,000 gal 1,000 gal (lb/yr) (lb/yr) (tons/yr) (tons/yr)
throughput) throughput)
Tank Truck
Loading4
Aboveground
Tank Filling,
Breathing &
Emptying5
Vehicle
Refueling
Operations4
Displacement
Losses
Spillage6
Footnotes:
1- Assume annual throughput
2- VOC Emissions (lb / yr) = Emission Rate (lb VOC / 1,000 gal throughput) x Throughput (gal) / 1,000.
3- VOC Emissions (tons / yr) = VOC Emissions (lb/yr) / 2,000
4- Emission rate for tank truck loading, or loading loss (L1), calculated using the following equation:
Where;
Page 27 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Definitions
Page 28 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
As examples of vessel characterization, assume an ocean barge, previously filled with volatile material
which had been gas-freed, is being loaded:
Vessel Characterization is OVGL
Assume a Tanker, carrying gasoline, arrives in port with an Ullage of 3 meters:
Vessel Characterization is TD (3)
Note: For tankers that use main Diesel engine exhaust to inert their tanks, assume that the volume of
Diesel exhaust displaced by the product being loaded has a negligible impact on ambient air
quality.
Page 29 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Page 30 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
Ci LHVi
n
LHV = K i 1
Where,
LHV = Net heating value of the gas mixture (MJ/SCM)
Ci = Concentration of the ith sample gas component, ppm
LHVi = Net heat of combustion of the ith sample gas component at 25°C
and 760 mm Hg. pressure, kcal/g-mole
K = 1.74 x 10-7 g-mole MJ/ (ppm SCM kcal) (constant)
3. Calculating the Exit or Tip Velocity Limits of a Flare (for air dispersion modeling
purposes).
Note:
If the net heating value of the waste gas is over 37.3 MJ/scm, the maximum tip
velocity shall be determined from the applicable formulas below that calculate tip
velocities, subject to the absolute maximum of 122 m/s.
Page 31 of 33
Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
The tip velocity for an air-assisted flare shall be calculated based on the applicable
formula below, subject to the same absolute maximum velocity of 122 m/s.
To predict dispersion for flare type sources, the point source algorithm can be used
with arbitrary values assigned for stack exit velocity of 20 mps (65.6 ft/sec) and
stack exit temperature of 1,273°K (1,000°C).
A stack height equal to the height of the flare tip is recommended for flares.
The effective stack diameter, D, in meters, is determined using the following
equations:
D = (10 6 q n )
where
qn = q [1-0.048 MW ] and
q = gross heat release in cal/sec
Note:
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Document Responsibility: Environmental Standards Committee SAEP-340
Issue Date: 14 November 2016 Air Dispersion Modelling,
Next Planned Update: 14 November 2019 Emission Inventory, and Leak Detection and Repair
The diameter of the pipe leading to the flare tip is not considered a factor in
determining plume rise. Also note that qn accounts for heat loss due to
radiation. Enclosed vapor combustion units shall not be modeled with the
above parameters, but with stack parameters that reflect the physical
characteristics of the unit. For additional information, contact the Air
Quality Supervisor, EPD/EED/AMU.
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