PASSIVE FOURIER TRANSFORM INFRARED TECHNOLOGY (FTIR) 

EVALUATION OF POOl PROCESS CONTROL DEVICE 

AT THE 

INEOS ABS (USA) CORPORATION 

ADDYSTON, OHIO FACILITY 

July 2010 
Section 

Table of Contents 

Table of Appendices 

List of Figures 

List ofTables 

1.0 Summary of Evaluation Program 

2.0 Source Description 

2.1 Process Description 

TABLE OF CONTENTS 

2.2 Control Equipment Description 

2.3 Sampling Location 

3.0 Evaluation Program Summary and Results 

3.1 Objectives and Test Matrix 

3.2 Field Test Changes and Problems 

3.3 Summary of Results 

4.0 Sampling and Analytical Procedures 

4.1 Evaluation Methods 

4.2 Process Data 

5.0 QAIQC Activities 

LIST OF FIGURES 

Figure Name 

Figure 2-4 Sampling Location 

LIST OFT ABLES 

Table Name 

Table 3-3 Data Summary Table 

LIST OF APPENDICES 

Appendix Name 

Appendix A Confidential Figures and Tables 

Figure 2-1 POO 1 Process Flow 

Figure 2-2 POOl Process Vent Overview 

Figure 2-3 Flare Layout 

Table 3-1 Proposed Sampling Evaluation Matrix 

Table 3-2 Actual Sampling Evaluation Matrix 

Appendix B Results and Calculations 

Appendix C Raw Field Data and Calibration Sheets 

Appendix D Flare Monitoring Data and Meteorological Data 

Appendix E QAIQC Audit Data Sheets 

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1.0 SUMMARY OF EVALUATION PROGRAM 

Pursuant to the Consent Decree (Civil Action No. 1 :09-CV-545) between U.S. Environmental 

Protection Agency (EPA) vs. INEOS ABS (USA) Corporation (INEOS ABS) and LANXESS 

Corporation, INEOS ABS perfom1ed a Passive FTIR evaluation on the POO 1 Process control device 

at the INEOS ABS Addyston, Ohio facility. The purpose of the evaluation was to determine the 

appropriate Net Heating Value of Flare Gas (NHVFG) limit to be used to operate the control device 

to ensure 99% control efficiency. 

The Passive FTIR (PFTIR) evaluation was performed on the POOl process air pollution control 

device (the Flare). The PFTIR method was used to estimate emissions from the Flare by measuring 

carbon dioxide (C02), carbon monoxide (CO) and total hydrocarbons (THC) in the Flare output 

stream (the area above the flame ofthe Flare) at varying operating conditions and NHVFG values. 

The PFTIR evaluation was a comparative test only as it is still a developing technology for 

measuring flare emissions. 

The EPA has proposed that a NHVFG of 200 British Thermal Units per standard cubic feet 

(BTU/scf) yields a control efficiency of 99%. This PFTIR evaluation compared environmental 

perfom1ance at different NHVFG values so as to detennine the range ofNHVFG that provides 

optimum environmental perfonnance for operation of the Addyston Flare. 

INEOS ABS contracted with Industrial Monitor and Control Corporation (IMACC) to perform the 

PFTIR evaluation of the Flare. The test was perfonned in a timely manner on November 3 through 

November 5, 2009. The following personnel from EPA and Hamilton County Department of 

Environmental Services (HCDES) observed the evaluation: 

Cary Secrest, EPA Headquarters (Washington, D.C.) 

Brian Dickens, EPA Region V (Chicago) 

Mike Kramer, HCDES 

The evaluation pursuant to the Consent Decree was only being used to provide information to the 

EPA Office of Enforcement and Compliance Assurance (OECA), Director of Air Enforcement of the 

Office of Civil Enforcement (OCE) to aid in his/her decision in the establishment of a newly defined 

lower NHVFG limit to be used to control the POO 1 Process Flare. This evaluation was not used as a 

means to determine compliance with the facility's Title V Pem1it. 

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2.0 SOURCE DESCRIPTION 

2.1 PROCESS DESCRIPTION 

Figure 2-1 illustrates the basic processing steps in the POO I Process. The general steps in the process 

include: 

Reacting 1.3-butadiene with other ingredients in kettles to produce a rubber latex; 

Cooling the intem1ediate latex; and 

Holding the intem1ediate latex in preparation for further processing. 

The POOl process is a batch process. Process emissions from the POOl process are routed to the 

Flare or the boilers for destruction. Process emissions are generated as the materials react, while 

materials are cooling in process tanks, or when materials are breathing while in storage tanks. 

Process emissions sent to the Flare are routed through the seal tank on the way to the Flare (see 

Figure 2-2). Wastewaters from the process are routed to the chemical sewer for further treatment at 

the facility's wastewater treatment plant. 

2.2 CONTROL EQUIPMENT DESCRIPTION 

The Flare is the control device that was evaluated during this test. The Flare's steam-assisted tip was 

manufactured by the John Zink Company, LLC (Zink) (Model # EEF QS-16) and is equipped with a 

Zink airrestor purge reduction device (Model# EEF-AR-16). Figure 2-2 shows the POOl process 

vent overview and Figure 2-3 shows the Flare layout. 

Several monitoring instruments are used to calculate parameters that have been identified as 

influencing flare efficiency. The amount of steam flow to the Flare tip and the amount of natural gas 

added to the Vent Gas are direct measurements from flow meters in the field. A GE Sensing 

DigitalFlow Panametrics Ultrasonic Flowmeter (Panametrics Model # GF868) is located in the Flare 

system to measure velocity and molecular weight of the stream from the seal tank to the Flare. 

These measured values are used to calculate the amount of 1 ,3-butadiene in the stream, total Vent 

Gas flow rate and subsequent heat value ofthe Vent Gas going to the Flare. In addition, these values 

can be used to calculate the steam-to-Vent Gas ratio and the lower NHVFG. 

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2.3 SAMPLING LOCATION 

The PFTIR evaluation was performed on the POOl Process Flare. The location ofthe FTIR 

equipment was on an elevated platform 165 feet to the east of the Flare (labeled "E" KETTLE on 

Figure 2-4). This location gave a direct line of sight to the Flare tip and plume and helped to 

minimize interferences from surrounding buildings and process equipment. However, one limitation 

this created was experienced whenever the wind direction was blowing the plume towards or away 

from the FTIR camera. This made it more difticult to keep the camera focused on the best part of 

the plume to give a good indication of composition. 

The PFTIR measurements were intended to be taken in the centerline ofthe plume with the plume 

filling the entire field of view of the FTIR equipment. A thermal imaging camera was used to aid 

the technicians in making constant manual adjustments of the position of the FTIR camera by 

attempting to locate the hottest area above the flame in the Flare plume that would allow for a full 

field of vision for the FTIR equipment. The zone monitored was intended to be above the 

combustion zone so the majority of combustion was complete, yet low enough so the temperature 

was above 200°C to allow detection (within two meters of the flame). 

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Figure 2-4 Sampling Location 

FLARE .~ 

STACK 

B.9 

4 

"E" 

·KETTLE ] 

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3.0 EVALUATION PROGRAM SlJMMARY AND RESULTS 

3.1 OBJECTIVES AND TEST MATRIX 

The purpose of the PFTIR evaluation was to determine the appropriate lower NHVFG limit to be 

used to operate the POOl Process Flare. The PFTIR method was used to estimate the emissions from 

the Flare by measuring C02• CO and THC in the Flare output stream (the area above the flame of the 

Flare) at varying operating conditions and NHVFG values. 

During the evaluation, operating scenarios of the Flare were varied in order to determine which 

lower NHVFG limit is the most appropriate, i.e. most efficient. Operating scenarios involved 

varying the flow rates and composition of the steam and the Vent Gas stream. The purpose ofthis 

evaluation program was to run scenarios to bracket conditions and to compare emissions at different 

scenarios. The ultimate goal was to compare the emissions at different scenarios and recommend the 

future lower limit ofNHVFG. It is proposed that any scenarios with lower emissions than those 

seen at the 200 BTU/scf scenarios would be considered to be representative of control efficiency 

higher than 99% as the EPA has stated that a 200 BTU/scfNHVFG would achieve a 99% efficiency. 

Table 3-1 presents the sampling and analytical evaluation matrix that was proposed to be used to 

help establish the appropriate lower NHVFG limit. The runs were divided into four different flow 

rates of 1 ,3-butadiene. Different NHVFG were proposed within each of these flow rates. 

3.2 FIELD TEST CHANGES AND PROBLEMS 

At the beginning of the evaluation. it became apparent that achieving and keeping steady flows to 

the Flare would be challenging. Due to these complications. several runs were modified and not 

performed in the order that was proposed. These runs were modified after consulting and receiving 

the approval of the EPA and HCDES who were observing the evaluation on site. The modified 

sampling and analytical evaluation matrix that was followed during the field test is shown in 

Table 3-2. 

In particular, during some test runs, 1 ,3-butadiene flows were modified (lower or higher than 

proposed). As a consequence, the exit velocities were also either lower or higher than proposed. 

However, the target NHVFG for the test runs was not impacted as this was the value that was the 

controlling parameter to start each test run. The flows of 1 ,3-butadiene, natural gas, and steam were 

modified for each test run to achieve the target NHVFG. Once the target NHVFG was achieved the 

test was begun. In addition, two test runs (Runs 1 B and 12) were shortened to less than twenty 

minutes of sampling time due to significant changes in 1 ,3-butadiene flow rates. Runs 6, 7, 9 and 

17 A were shortened under agreement with EPA and HCDES as good data was detem1ined to have 

been collected in less than 20 minutes. 

IMACC performed daily calibration checks using the black body source. IMACC is working on 

technology to do calibration tests for the primary gas of concem (1.3-butadiene in the case of these 

tests) by using a flow tube with that gas in it. This approach was not used for these tests as the 

technology was not available for 1,3-butadiene at the time of the evaluation. 

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Initial instrument set-up was perfom1ed on November 3. 2010 and shots of the sky were made during 

calibration. Problems with the sensor becoming saturated were experienced when the sensor was 

exposed to too much sunlight and a different sensor tube had to be installed. 

On the night of November 3. 2010. the instrument got too cold and difficulties were experienced 

with sluggish movement of sensor elements which influenced analyzer capability the next day. 

These problems were minimized by providing a heat source for the sensor housing for subsequent 

runs. 

3.3 SUMMARY OF RESULTS 

Upon review of the PFTIR test data. it was discovered that there was a problem with some of the 

data generated by the Panametrics monitoring system. After a great deal of investigation and 

extensive discussions with the manufacturer of the Panametrics monitoring system, it was 

discovered that a fixed (80%) nitrogen concentration value differed greatly from actual 

concentrations and hence impacted the resulting molecular weight calculation perfonned by the 

Panametrics. 

Upon this discovery. INEOS ABS acted promptly and diligently to detem1ine the nature ofthe 

problem and to seek a remedy. In this regard, it was discovered that the manufacturer of the 

monitoring system (GE Sensing) had developed an algorithm to correct this problem, but the 

manufacturer initially refused to provide this proprietary solution. Finally. in exchange for a fee and 

a confidentiality agreement. INEOS ABS obtained the algorithm. The algorithm is extremely 

complex and has taken a significant period of time to make the necessary corrections to the data. 

INEOS ABS is in the process of conve11ing the test data in order to evaluate the appropriate NHVFG 

limit to be used to operate the POO 1 Process Flare. 

Please see the timeline of events below. As such, this report will be amended to include the results 

of the evaluation by August 6, 201 0. 

Date 

3/22/10 

4115110 

Week of 

04/12/10 

4/21/10 

4/22/10 

5/3/1 0 

Event 

Conference call between EPA. HCDES. and INEOS ABS regarding correct method 

to calculate 1,3-butadiene flow. 

Conference call between EPA, HCDES, and INEOS ABS continuing discussion on 

correct method to calculate 1 ,3-butadiene flow and discussion regarding the 

Panametrics with regards to nitrogen concentrations and molecular weight. 

Began discussion with GE Sensing to obtain algorithm to correct molecular weight. 

Conference call between EPA. HCDES, and INEOS ABS continuing discussion on 

correct method to calculate 1 J-butadiene flow and the Panametrics with regards to 

nitrogen concentrations and molecular weight. 

GE Sensing agreed that it may be possible to supply an algorithm to correct molecular 

weight. 

Conference call between EPA, HCDES, and INEOS ABS continuing discussion on 

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5/6110 

5/10/10 

5/13/1 0 

5114/10 

5/25110 

Test 

Run 

l 

lA 

IB 

2 

3 

4 

5 

6 

7 

8 

9 

10 

I I 

12 

13 

14 

15 

16 

17 

17A 

18 

correct method to calculate 1.3-butadiene flow and the Panametrics with regards to 

nitrogen concentrations and molecular weight. Agreed that % mass verses % mol 

would be used to calculate 1.3-butadiene flow. 

GE Sensing agreed to supply INEOS ABS with the algorithm for a fee and a 

Confidentiality agreement. GE Sensing to supply proposal to INEOS ABS. 

Conference call between EPA, HCDES. and INEOS ABS continuing discussion on 

the Panametrics with regards to nitrogen concentrations and molecular weight. 

INEOS ABS received proposal from GE Sensing. 

INEOS ABS submitted Purchase Order to GE Sensing. 

INEOS ABS received algorithm from GE Sensing. 

Table 3-3 Data Summary Table 

INEOS ABS -Addyston, Ohio 

Proposed Actual Exit Proposed Actual Proposed Actual PFTIR 

Exit Velocity Butadiene Butadiene NHVFG NHVFG Estimated 

Velocity During Test Flow (lb/hr) Flow During (BTU/scf) (BTU/scf) Efficiency 

(ft/min) Run (ft/min) Test Run (%) 

(lb/hr) 

110 TO 300 TO 120 TO TO 

NA BE NA BE NA BE BE 

NA PROVIDED NA PROVIDED NA PROVIDED PROVIDED 

120 AFTER 300 AFTER 200 AFTER AFTER 

110 THE 300 THE 150 THE THE 

160 TEST 300 TEST 180 TEST TEST 

110 DATA 300 DATA 230 DATA DATA 

180 IS 600 IS 150 IS IS 

270 CONVERTED 600 CONVERTED 210 CONVERTED CONVERTED 

250 600 190 

250 600 230 

75 50 120 

90 50 200 

40 50 200 

90 50 140 

80 50 160 

80 50 180 

90 50 220 

50 10 140 

NA NA NA 

60 10 200 

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4.0 SAMPLING AND ANALYTICAL PROCEDURES 

4.1 EVALUATION METHODS 

The PFTJR evaluation was performed on the POOl Process Flare at varying operating scenarios as 

shown in Table 3-2. Control instrumentation was used to measure and vary the operating conditions 

and included: 

Flow meters and valves for natural gas. steam. and nitrogen streams: 

Process valves from C kettle for the 1.3-butadiene stream: and 

Panametrics for the stream from the seal tank. 

A charge of hot water followed by liquid 1 .3-butadiene was sent to a rubber kettle at the beginning 

of the evaluation. The jacket on the kettle heated the contents and caused the 1.3-butadiene to go 

into the vapor phase and flow to the Flare system. The vapors were sent to the Flare through the 

reflux vent valves for the low flows ( ~ 10 and 50 lbs/hr 1 J-butadiene flow) and through the fourinch vent header for the large :flows ( ~300 and 600 lbs/hr 1 .3-butadiene :flow). The composition was 

measured by the Panametrics and flows were adjusted to get the desired 1 .]-butadiene flow. Once 

the 1.3-butadiene flow was established, the nitrogen, natural gas. and steam flows were adjusted as 

necessary to get the desired NHVFG level. 

During the evaluation. the INEOS ABS video camera recorded the plume in order to record any 

visible emissions (soot generation) from the plume during each scenario. Visible emissions can 

negatively impact the quality of data generated by the FTIR equipment and would prevent the ability 

to complete evaluations at specific operating scenarios. There were no test runs where visible 

emissions negatively impacted the results. 

In addition, the INEOS ABS weather station was used to collect data (ambient temperature, relative 

humidity, ambient pressure. and wind speed) during the duration of each run for all the operating 

scenarios. This data was used to detennine if a steam contribution factor should be applied to a 

particular test run. 

The NHVFG value is the measure of enthalpy (.6.H/98

) of the components that comprise the Flare 

Gas. Flare Gas is the sum ofthe entire stream measured by the Panametrics plus the supplemental 

natural gas sent to the Flare stack, plus the natural gas sent to the pilot burners, plus the steam 

detennined to participate in the reaction zone. The density ofthe Flare Gas is determined by 

dividing the component molecular weight(s) by the molar volume at STP conditions (14.696 psia 

and 60°F, resulting in a STP molar volume of 379.48 ft3 llb-mol. References for these STP 

conditions include Perry's Handbook gth Edition Table 1-4 Conversion Factors. as well as Crane's 

Technical Paper No. 410 on Flow of Fluids). 

The molecular weight of each component is as follows: 

The stream exiting the seal tank = Detem1ined by the Panametrics 

Natural gas (based upon compositions from Duke Energy)= 16.40 

Steam= 18.015 

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The enthalpy of each component (using a reference point of 298.15 K for 1"\Ht) is as follows: 

1,3-butadiene (Perry's Handbook 8111 Edition)= 19,160 BTU/lb 

Natural Gas (NASA Polynomials; Duke Energy gas composition)= 915 BTU/scf 

Steam (NASA Polynomials)= 131 BTU/lb (steam supplied to the tips at 458.7 K) 

The NHVFG value was determined using the following equation and agreed upon by the EPA in 

August 2007: 

(1,3-butadiene flow [lbs/hr] * 19,160 BTU/lb +natural gas (supplemental+ pilots) flow [seth]* 915 

BTU/scf +steam flow included [lbslhr] * 131 BTU/lb) I (lb-moles/hr of total Flare Gas * 3 79.48 

scf/lb-mole) 

When exit velocities from the Flare are less than 75 feet per minute (ft/min), a steam contribution 

factor was applied when calculating the NHVFG and steam-to-Vent Gas ratio. It has been agreed to 

by the EPA and INEOS ABS during Consent Decree negotiations that at certain velocities only a 

portion of the steam participates in combustion with the Flare Gas just after the exit of the Flare tip. 

The EPA concluded that the steam contribution factor only includes 3 7.5% of the steam when exit 

velocities are below 75 ft/min. However, INEOS ABS believes that the appropriate exit velocity to 

apply a steam contribution factor is I 00 ft/min. This exit velocity threshold is under appeal at the 

time ofthe writing of this report. The adjusted exit velocities using the steam contribution factor at 

exit velocities below 75 ft/min are shown in Tables 3-1 and 3-2. 

The PFTIR evaluation measured the concentrations of C02, CO, and THC which was used to 

estimate emissions of the Flare. The efficiency estimation was based on the following equation: 

where: 

[C02] = C02 concentration 

[CO]= CO concentration 

[THC] = THC concentration 

E11 _ C02 

:JJ C02+C0+THC 

NOTE: The above equation does not measure control or combustion efficiency. An actual efficiency 

calculation would include components that the FTIR equipment cannot detect (for example I ,3-butadiene, NOx, 

H2. etc.) 

In order to complete these calculations the background concentrations of CO, C02 , and HC must be 

compensated. The procedure used to make these compensations is documented in "Combustion 

Efficiency of Flares" by Pohl, John H., Lee, Joannes, Payne, Roy and Tichenor, Bruce A., 

Combustion Science and Technology, (1986), 50:4, pp. 217- 231 and in "Evaluation of the 

Efficiency oflndustrial Flares: Test Results", EPA document EPA-600/2-84-095. 

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IMACC provided the following calculations that were used to estimate errors in efficiency with 

respect to each term in the PFTIR measurements. The variation in efficiency with each term is given 

by its partial derivative with respect to each term. This gives: 

5E.ff li(CO) = - C02 li(CO) 

5CO (C02+C0+THC) 2 

<JEff ii(THC) = -C02 ii(THC) 

5THC (C02+C0+THC) 2 

5Ejf li(C02) (CO+ THC) li(C02) 

5C02 = (C02+C0+THC) 2 

In each term the li (x) is the error for compound x. Once these tem1s are evaluated the total error in 

the efficiency is given by: 

( <JEff liC0)

2 

+ ( <JEff iiC02)

2 

+ ( <JEff liTHC)

2 

5CO 5C02 5THC 

The efficiency as estimated by the PFTIR method was detennined using the Classical Least Square 

method of analysis to two significant figures. 

Measurements from the FTIR equipment were taken every second and averaged over a five minute 

period; an efficiency value was generated every five minutes. The samples taken at each operating 

scenario were averaged to get a representative efficiency for that particular operating scenario. 

Anomalies in the data were evaluated before inclusion or exclusion in any analysis, e.g. efficiency 

values not consistent with other efficiency values in that test run. All of the concentration data 

reported by the PFTIR analysis has corresponding error measurements. These error values reflect 

how well the software is able to match the features in the infrared spectrum. By subtracting the 

scaled reference from the data, this ideally would result in a straight line. Deviations reflect 

inaccuracy in the measurement. The error bar is a root mean squared residual that can be converted 

to concentrations using library reference standards. If the data is not at least 2.5 times the value then 

the data is suspect. For example, IMACC stated that the measurement reported for C3H6 

concentration of 9.393 ppm on 11103/09 at I 0:46:47 AM is suspect because this value is less than 

2.5 times the reported error for that measurement of 4.518 ppm. 

IMACC also provided data that estimated the actual temperature at the point of the FTIR focus. This 

data was used to assess how successful the technicians were in keeping the point of focus of the 

FTIR sensor at the optimum location in the plume. The calculations employed by the FTIR 

computer assume the sensor is measuring the plume at 200°C. Therefore, deviations of that 

temperature from 200°C (used as a basis for the PFTIR analysis) lead to increased magnitude of 

error in the PFTIR test results. These temperature estimates are located in Appendix C. 

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4.2 PROCESS DATA 

During the evaluation, the following parameters were measured and/or calculated using the existing 

steam and natural gas flow meters and the Panametrics and stored in the facility's data historian: 

Vent Gas sent to the Flare (in lbs/hr) 

1 ,3-butadiene in the Vent Gas sent to the Flare (in lbs/hr) 

Steam flow sent to the Flare (in lbs/hr) 

Net Heating Value of the Vent Gas sent to the Flare (in BTU/scf) 

Natural gas in the vent stream sent to the Flare (in scfh) 

Steam-to-Vent Gas ratio 

NHVFG (in BTU/scf) 

In addition, meteorological data and video of the Flare flame were collected and stored on the 

facility's computer network. 

Copies of the monitoring parameters and meteorological data are included in Appendix D. 

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5.0 QA/QC ACTIVITIES 

IMACC calibrated the PFTIR equipment prior to and at the end of each evaluation day. Calibration 

of the FTIR equipment included instrumental radiance calibration (calibration with a cold target), 

radiance calibration (calibration with an infrared black body source), and background radiance 

calibration (sky background). QA/QC audit data sheets are included in Appendix E. 

The calibration parameters for the Panametrics (signal strength, etc.) was verified as being within 

proper ranges prior to, during, and after the PFTIR test period. During discussions between EPA 

and INEOS ABS concerning the methods used to detern1ine 1 ,3-butadiene flow rates from the 

Panametrics data, a couple of problems were identified with the use ofthe Panametrics data that has 

led to a re-evaluation of the algorithm previously agreed to by INEOS ABS and the EPA in 

August 2007. This algorithm is being revised to address these problems. The revisions include 

development of logic to compensate for errors in the Panametrics estimate of Vent Gas molecular 

weight due to limitations in detecting nitrogen and the use of an assumed (i.e., constant) nitrogen 

concentration. GE Sensing has provided INEOS ABS an algorithm that can be used to estimate the 

errors in molecular weight measurements due to the use of an incorrect assumption for nitrogen 

composition in the stream. INEOS ABS is using this algorithm to develop a separate algorithm to 

correct the errors in the originally measured molecular weight. The INEOS ABS algorithm is 

currently being tested and INEOS ABS expects to complete corrections to the stream composition 

calculations for the period of the PFTIR by August 6, 2010. 

Supplemental natural gas is metered via a thermal gas meter directly into the Flare base. Prior to the 

PFTIR tests a secondary thermal gas meter was installed in this line. This secondary gas meter 

indicated a higher flow rate than the original meter at most flow conditions. After the PFTIR testing 

was completed the original thermal gas meter was removed and sent back to the factory for 

recalibration. While that meter was out, an additional gas meter of a different design (mass flow 

meter) was installed in place of the original thermal gas meter. This meter agreed more closely with 

the newer (secondary) thermal gas meter. Therefore, the supplemental gas flow measurement from 

the secondary gas meter is considered to be the more accurate of the two meters in use during the 

PFTIR test period and its values are used in the calculations. 

Steam flow to the Flare tip is metered via a vortex shedding meter. Prior to the PFTIR tests a 

secondary vortex meter was installed in the steam line. The readings from the secondary and the 

primary steam flow meters agree, therefore the primary steam flow indication is considered accurate 

for the PFTIR evaluation period. 

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