### PASSIVE FOURIERTRANSFORM INFRAREDTECHNOLOGY (FTIR) EVALUATION OFPOOl PROCESS CONTROLDEVICE ATTHE INEOS ABS (USA) CORPORATION ADDYSTON, OHIOFACILITY July2010Section Table ofContents Table ofAppendices List ofFigures List ofTables 1.0 Summary ofEvaluation Program 2.0 Source Description 2.1 Process Description 

### TABLE OF CONTENTS

2.2 Control Equipment Description 2.3 SamplingLocation 3.0 Evaluation Program Summary and Results 3.1 Objectives and Test Matrix 3.2 Field Test Changes and Problems 3.3 Summary ofResults 4.0 Sampling and Analytical Procedures 4.1 Evaluation Methods 4.2 Process Data 5.0 QAIQC Activities



### LIST OF FIGURES
FigureName Figure 2-4 Sampling Location



### LIST OFT ABLES

TableName Table 3-3 Data Summary Table



### LIST OFAPPENDICES
Appendix Name Appendix A Confidential Figures and Tables Figure 2-1 POO1Process Flow Figure 2-2 POOl Process Vent Overview Figure 2-3 Flare Layout Table 3-1 Proposed SamplingEvaluation Matrix Table 3-2 Actual SamplingEvaluation Matrix Appendix B Results and Calculations Appendix C RawField Dataand Calibration Sheets Appendix D Flare MonitoringData and Meteorological Data Appendix E QAIQC Audit Data Sheets 1 2 2 2 3 5 5 

### 5 6 

### 8 8 11 12

Page 4

Page 7

July 6, 2010 0:\lnhcom\ENVIRONMENTAL\Consent Decree Actions\Fiare\FTIR\Report\FINAL PFTIR Report.doc1.0 SUMMARY OFEVALUATION 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 POO1Process control device at the INEOS ABS Addyston, Ohio facility. The purpose ofthe evaluation was to determine the appropriate Net Heating Value ofFlare Gas (NHVFG) limitto be used to operate the control device to ensure 99% control efficiency.

The Passive FTIR (PFTIR) evaluation was performed on the POOl process airpollution control device (the Flare). ThePFTIRmethod 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 oftheFlare) at varying operating conditions and NHVFG values. ThePFTIR evaluation was a comparative test only as it is still a developing technology for measuring flare emissions.

TheEPA has proposed that aNHVFG of200 British Thermal Units per standard cubic feet (BTU/scf) yields a control efficiency of99%. This PFTIR evaluation compared environmental perfom1ance at different NHVFG values so as to detenninethe range ofNHVFG that provides optimum environmental perfonnance for operation ofthe Addyston Flare.

INEOS ABS contracted with Industrial Monitorand Control Corporation (IMACC) to perform the PFTIRevaluation ofthe Flare. The test was perfonned in atimely 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 evaluationpursuantto the Consent Decree was only being used to provide information to the EPA Office ofEnforcement and Compliance Assurance (OECA), DirectorofAirEnforcementofthe Office ofCivil Enforcement (OCE) to aid in his/her decision in the establishment ofa newly defined lowerNHVFG limit to be used to control the POO1Process 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 POOI Process. The general steps in the process include: Reacting 1.3-butadiene with otheringredients in kettles to produce a rubberlatex; 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 orthe boilers for destruction. Process emissions are generated as the materials react, while materials are cooling in process tanks, orwhen materials are breathing while in storage tanks. Process emissions sent to the Flare are routed through the seal tank on the wayto the Flare (see Figure 2-2). Wastewaters from the process are routed to the chemical sewerfor further treatment at the facility's wastewatertreatmentplant.

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 bythe John Zink Company, LLC (Zink) (Model # EEF QS-16) and is equipped with a Zink airrestorpurge 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 ofsteam flow to theFlare tip and the amount ofnatural 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 molecularweight ofthe stream from the seal tank to the Flare. These measured values are used to calculatethe 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 lowerNHVFG.

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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 ofthe Flare (labeled "E" KETTLE on Figure 2-4). This location gave a direct line ofsight to the Flare tip and plume and helped to minimize interferences from surrounding buildings and process equipment. However, one limitation this created was experienced wheneverthe wind direction was blowingthe plumetowards oraway from the FTIR camera. This made it more difticult to keep the camera focused on the best part of the plumeto give a good indication ofcomposition.

The PFTIR measurements were intended to be taken in the centerline oftheplume with the plume filling the entire field ofviewofthe FTIR equipment. A thermal imaging camera was used to aid the technicians in making constant manual adjustments oftheposition ofthe FTIRcameraby attempting to locate the hottest area above the flame in the Flare plumethat would allowfor a full field ofvision for the FTIRequipment. The zone monitored was intended to be above the combustion zone so the majority ofcombustion was complete, yet low enough so the temperature
was above 200°C to allowdetection (within two meters ofthe flame).

3 July 6, 2010 0:\lnhcom\ENVIRONMENTAL\Consent Decree Actions\Fiare\FTIR\Report\FINAL PFTIR Report.docFigure 2-4 Sampling Location



# FLARE**.~** 

# STACK B.9

4 

# "E" ·KETTLE ]

July 6, 2010 0:\Inhcom\ENVIRONMENTAL\Consent Decree Actions\Flare\FTIR\Report\FINAL PFTIR Report.doc3.0 EVALUATION PROGRAM SlJMMARYAND RESULTS

3.1 OBJECTIVES AND TESTMATRIX

The purpose ofthe PFTIR evaluation was to determine the appropriate lowerNHVFG limit to be used to operate the POOl Process Flare. The PFTIR method was used to estimatethe emissions from the Flare by measuring C02• CO and THC in the Flare output stream (the area above the flame ofthe Flare) at varying operating conditions and NHVFG values.
During the evaluation, operating scenarios ofthe Flare were varied in orderto determine which lowerNHVFG limit is the most appropriate, i.e. most efficient. Operating scenarios involved varying the flow rates and composition ofthe 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/scfscenarios would be considered to be representative ofcontrol efficiency higherthan 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 lowerNHVFG limit. The runs were divided into four different flow rates of 1,3-butadiene. DifferentNHVFG were proposed within each ofthese flow rates.

3.2 FIELD TEST CHANGES AND PROBLEMS

At the beginning ofthe evaluation. it became apparent that achieving and keeping steady flows to the Flare would be challenging. Dueto these complications. several runs were modified and not performed in the orderthat was proposed. These runs were modified after consulting and receiving the approval oftheEPA 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 sometest runs, 1 ,3-butadiene flows were modified (lower orhigherthan proposed). As a consequence, the exit velocities were also eitherlowerorhigherthan proposed. However, the target NHVFG for the test runs was not impacted as this was the value that was the controllingparameterto 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 ofsampling 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 usingthe black body source. IMACC is working on technology to do calibration tests for the primary gas ofconcem (1.3-butadiene in the case ofthese 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 ofthe evaluation.

5 July 6, 2010 0:\lnhcom\ENVIRONMENTAL\Consent Decree Actions\Flare\FTIR\Report\FINAL PFTIR Report.docInitial instrument set-up was perfom1ed on November3. 2010 and shots ofthe sky were made during calibration. Problems with the sensorbecoming saturated were experienced when the sensorwas exposed to too much sunlight and a different sensortube had to be installed.

On the night ofNovember 3. 2010. the instrument got too cold and difficulties were experienced with sluggish movement ofsensor elements which influenced analyzercapabilitythe next day. Theseproblems were minimized by providing a heat source for the sensorhousing for subsequent
runs.



### 3.3 SUMMARY OF RESULTS
Upon review ofthe PFTIR test data. it was discovered that there was a problem with some ofthe data generated bythe Panametrics monitoring system. After a great deal ofinvestigation and extensive discussions with the manufacturerofthe Panametrics monitoring system, it was discovered that a fixed (80%) nitrogen concentration value differed greatly from actual concentrations and hence impacted the resulting molecularweight calculation perfonned bythe 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 manufacturerofthe monitoring system (GE Sensing) had developed an algorithm to correct this problem, but the manufacturer initially refused to providethis 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 oftime to make the necessary corrections to the data. INEOS ABS is in the process ofconve11ing the test data in orderto evaluate the appropriateNHVFG limit to be used to operate the POO 1Process Flare.

Please see the timeline ofevents below. As such, this report will be amended to include theresults ofthe evaluation by August 6, 2010.

Date 3/22/10

4115110

Week of 04/12/10 4/21/10

4/22/10

5/3/10 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 regardingthe Panametrics with regards to nitrogen concentrations and molecularweight. Began discussion with GE Sensing to obtain algorithm to correct molecularweight.

Conference call between EPA. HCDES, and INEOS ABS continuing discussion on correctmethod to calculate 1 J-butadiene flow and the Panametrics with regards to nitrogen concentrations and molecularweight. GE Sensing agreed that it may bepossible to supply an algorithm to correct molecular weight. Conference call between EPA, HCDES, and INEOS ABS continuingdiscussion on


### 6 July 6, 2010 0:\lnhcom\ENVIRONMENTAL\Consent Decree Actions\Flare\FTIR\Report\FINAL PFTIR Report.doc5/6110

5/10/10

5/13/10 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 molecularweight. 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 Sensingto supplyproposal 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 Orderto GE Sensing. INEOS ABS received algorithm from GE Sensing.

Table 3-3 Data SummaryTable 

### 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



### 7 July 6, 2010 0:\lnhcom\ENVIRONMENTAL\Consenl Decree Actions\Flare\FTIR\Report\FINAL PFTIR Report.doc4.0 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 ofhot water followed by liquid 1.3-butadiene was sent to a rubberkettle at the beginning ofthe evaluation. Thejacket on the kettle heated the contents and caused the 1.3-butadieneto go into the vaporphase 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 orderto record any visible emissions (soot generation) from the plume during each scenario. Visible emissions can negatively impact the quality ofdata 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, ambientpressure. and wind speed) during the duration ofeach run for all the operating scenarios. This data was used to detennine ifa steam contribution factor should be applied to a particulartest run.
TheNHVFG value is the measure ofenthalpy (.6.H/98) ofthe 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 molecularweight(s) bythe molarvolume at STP conditions (14.696 psia and 60°F, resulting in a STPmolarvolume of379.48 ft3llb-mol. References for these STP conditions include Perry's Handbook gth Edition Table 1-4 Conversion Factors. as well as Crane's Technical PaperNo. 410 on Flow ofFluids).

The molecular weight ofeach 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

8 July 6, 2010 0:\lnhcom\ENVIRONMENTAL\Consent Decree Actions\Fiare\FTIR\Report\FINAL PFTIR Report.docThe enthalpy ofeach component (using a referencepoint of298.15 K for 1"\Ht) is as follows: 1,3-butadiene (Perry's Handbook 8111 Edition)= 19,160 BTU/lb Natural Gas (NASA Polynomials; DukeEnergy 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+steamflow included [lbslhr] * 131 BTU/lb) I (lb-moles/hroftotal Flare Gas * 379.48 scf/lb-mole)

When exit velocities from the Flare are less than 75 feet perminute (ft/min), a steam contribution factor was applied when calculatingthe 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 ofthe steamparticipates in combustion withthe Flare Gasjustafterthe exit ofthe Flaretip. The EPA concluded thatthe steam contribution factor onlyincludes 37.5% ofthe steam when exit velocities are below75 ft/min. However, INEOS ABS believes that the appropriate exitvelocityto apply a steam contribution factor is I00 ft/min. This exitvelocity threshold is underappeal at the time ofthewriting ofthis report. The adjusted exitvelocities using the steam contribution factor at exit velocities below75 ft/min are shown in Tables 3-1 and 3-2.

ThePFTIR evaluation measured the concentrations ofC02, CO, and THC which was used to estimate emissions ofthe Flare. The efficiency estimation was based onthe following equation:

where: [C02] = C02concentration [CO]=CO concentration [THC] = THC concentration 

### E11_ C02
:JJ 

### C02+C0+THC

NOTE: The above equation does not measure control orcombustion efficiency. An actual efficiency calculation would include componentsthat the FTIR equipment cannotdetect (for example I,3-butadiene, NOx, H2. etc.)

In orderto complete these calculations the background concentrations ofCO, C02, and HC must be compensated. The procedure used to make these compensations is documented in "Combustion Efficiency ofFlares"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 ofthe Efficiency oflndustrial Flares: Test Results", EPA documentEPA-600/2-84-095.

9 July 6, 2010 0:\lnhcom\ENVIRONMENTAL\Consent Decree Actions\Fiare\FTIR\Report\F!NAL PFTIR Report.docIMACC 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 eachterm. 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. Oncethese tem1s are evaluated the total errorin the efficiency is given by:

( <JEff

### liC0)2

### + ( <JEff 

### iiC02)2

### + ( <JEff liTHC)2

5CO 5C02 5THC

The efficiency as estimated bythe PFTIR method was detennined using the Classical Least Square method ofanalysis to two significant figures.

Measurements from the FTIR equipment were taken every second and averaged overa 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 particularoperating scenario.

Anomalies in the data were evaluated before inclusion orexclusion in any analysis, e.g. efficiency values not consistent with otherefficiency values in that test run. All ofthe concentration data reported by the PFTIR analysis has corresponding errormeasurements. These errorvalues reflect how well the software is able to match the features in the infrared spectrum. By subtractingthe scaled reference from the data, this ideally would result in a straight line. Deviationsreflect inaccuracy in the measurement. The errorbaris a root mean squared residual that canbe converted to concentrations using library reference standards. Ifthe data is not at least 2.5 times the value then the data is suspect. Forexample, IMACC stated that the measurementreported for C3H6 concentration of9.393 ppm on 11103/09 at I0:46:47 AM is suspectbecause this value is less than 2.5 times the reported errorfor that measurement of4.518 ppm.
IMACC also provided data that estimated the actual temperature at the point ofthe FTIRfocus. This data was used to assess how successful the technicians were in keeping the point offocus ofthe FTIR sensor at the optimum location in the plume. The calculations employed bythe FTIR computerassume the sensoris measuringthe plume at 200°C. Therefore, deviations ofthat temperature from 200°C (used as a basis for the PFTIR analysis) lead to increased magnitude of
error in the PFTIR testresults. These temperature estimates are located in Appendix C.

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### 4.2 PROCESS DATA
Duringthe evaluation, the following parameters were measured and/orcalculated 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 ofthe Vent Gas sentto 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 ofthe Flare flame were collected and stored on the facility's computernetwork.
Copies ofthe monitoringparameters and meteorological data are included inAppendix D.

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### 5.0 QA/QC ACTIVITIES

IMACC calibrated the PFTIR equipmentpriorto and at the end ofeach evaluation day. Calibration ofthe 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 calibrationparameters for the Panametrics (signal strength, etc.) was verified as being within properranges priorto, during, and afterthe 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 ofproblems were identified with the use ofthe Panametrics data that has led to are-evaluation ofthe 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 oflogic to compensate for errors in the Panametrics estimate ofVent Gas molecular weight due to limitations in detecting nitrogen and the use ofan assumed (i.e., constant) nitrogen concentration. GE Sensing has provided INEOS ABS an algorithm that can be used to estimatethe
errors in molecular weight measurements due to the use ofan incorrect assumption for nitrogen composition in the stream. INEOS ABS is using this algorithm to develop a separate algorithm to correctthe errors in the originally measured molecularweight. The INEOS ABS algorithm is currently beingtested and INEOS ABS expects to complete corrections to the stream composition calculations for the period ofthe PFTIR byAugust 6, 2010. Supplemental natural gas is metered via a thermal gas meter directly into the Flare base. Priorto the PFTIRtests a secondary thermal gas meter was installed in this line. This secondary gas meter indicated a higher flow rate than the original meterat most flow conditions. Afterthe PFTIRtesting
was completed the original thermal gas meter was removed and sent back to the factory for recalibration. While that meterwas out, an additional gas meter ofa different design (mass flow meter) was installed in place ofthe 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 meteris considered to be the more accurate ofthe two meters in use during the PFTIRtestperiod and its values are used in the calculations.

Steam flow to the Flare tip is metered via a vortex shedding meter. Priorto the PFTIRtests a secondary vortex meterwas 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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