Date: May 2, 2011

To: Docket ID No. EPA-HQ-OAR-2007-0011

From: Kristin Sroka

Subject: NSPS Subpart J Review: Meeting Minutes for June 29, 2010, Meeting Between the U.S. EPA and Representatives of Thermo Fisher Scientific

Introduction

On June 29, 2010, representatives of the U.S. Environmental Protection Agency (EPA) and their contractor (RTI In ternational) participated in a stakeholder meeting with representatives of Thermo Fisher Scientific (Thermo Fisher). The names and affiliations of the participants are included in Att achment 1. Attachment 2 is a c opy of the meeting invitation and meeting description. A copy of the product info rmation provided by Thermo Fisher is provided in Attachment 3. The purpose of the meeting was to discuss total sulfur monitoring for flares in NSPS subpart Ja.

Discussion

The Thermo Fisher representative began by noting that five of the seven refineries in the South Coast Air Quality Manageme nt District (SCAQMD) of Ca lifornia use the SOLA II Flare total sulfur analyzer to comply with the SCAQM D regulations, so they fully expect that the SOLA II Flare will meet the specifications in NSPS subpart Ja when it is finalized. However, he stated that sales have been slow because many re finery owners and operators are waiting for the final NSPS subpart Ja before purchasing their monitors.

In response to EPA questions, the Thermo Fi sher representative provided more details about the SOLA II Flare total sulfur analyzer. The SOLA II Flare total sulfur analyzer is a single analyzer system with two independent measur ement ranges. The analyzer calculates a 240- second rolling average, updating every second. Ther mo Fisher representative recommends that the sensor be placed afte r the flare’s water seal.

The Thermo Fisher representative noted that an external stimulus is needed to switch from the low range tube to the high range tube. If the system has a flow meter, a high flow rate reading will provide that stimulus; the water level in the water seal may also be used. Thermo Fisher has found that the pressure difference be tween a low flow and a high flow is not large enough to cause the switch. With dilution, the gas stream reaching the detector typically has a maximum sulfur concentration of 1 percent. Howe ver, if gas with a high sulfur content enters2

the system in the low measurement range, it will “peg” the detector. Once that happens, it will

take the detector about 6 to 10 minutes to recover (depending on the sulfur content of the gas stream that pegged it).

The Thermo Fisher representative noted that the analyzer can take samples during flaring events; however, he stated that refinery owners and operators that do so should be reheating the sample prior to analysis to make sure the su lfur compounds have not c ondensed in the water, which would bias the results low. Similarly, he noted that some refiners send their samples to a knockout drum to get a dry sample, but that ma y also bias the result s low if the sulfur compounds condensed in the water.

The Thermo Fisher representative stated th at typically, analyzer checks are conducted daily, while more comprehensive whole-system calib rations are less freque nt (usually quarterly or annually). Most of the time, three gas cylinders are used to ca librate the system. One cylinder

is used to test the lo w end of the low range ( e.g. , 50 ppm), one cylinder is used to test the high end of the high range ( e.g. , 500,000 ppm), and a third cylinder is us ed to test both the high end of the low range and the low end of the high range ( e.g. , 5,000 ppm). The Thermo Fisher representative also stated that at some refi neries in the SCAQMD, they tried using carbonyl sulfide (COS) in the cylinders as an alternative to hydrogen sulfide (H 2 S), but COS has to be maintained at 70 °F, so they went back to using H 2 S.

The Thermo Fisher representative stated that the SOLA II Flare anal yzer typically costs about $125,000. The company has heard estimates of $450,000 to 500,000 for the full shelter system and sampling line. A refiner would also in cur costs for site prepar ation, electrical work, and tapping the flare line, so the overall estimated cost for the system would be about $1 million.

Finally, the Thermo Fisher representative st ated they would be interested in an EPA certification process for analyz ers. He noted that the SC AQMD has a process to certify analyzers for use in complying with their regulat ions. The process requires the system to be tested with several standard compou nds to evaluate its performance.Attachment 1 Participants in June 29, 2010 Meeting

Thermo Fisher Representatives Greg Brumfield

Daniel Merriman

U.S. EPA Representatives

Jason Dewees

Brenda Shine

Peter Westlin

RTI International (EPA contractor)

Jeff Coburn

Kristin SrokaAttachment 2

Meeting Invitation and DescriptionThermoFisher: Total Sulfur Analyzer for Refinery Flare Gas
Tue 06/29/2010 9:00 AM - 10:30 AM

Chair: Peter Westlin/RTP/USEPA/US

Rooms: Conf. Rm. E101/RTP-Bldg E@EPA

Required: Barrett Parker/RTP/USEPA/US@EPA, Brenda Shine/RTP/USEPA/US@EPA, Dan Bivins/RTP/USEPA/US@EPA, daniel.merriman@thermofisher.com , Foston Curtis/RTP/USEPA/US@EPA, greg.brumfield@thermofisher.com , Jason Dewees/RTP/USEPA/US@EPA, Robin Segall/RTP/USEPA/US@EPA

Optional: Rachel Agnew/RTP/USEPA/US@E PA, Ron Myers/RTP/USEPA/US@EPA, Tom
Driscoll/RTP/USEPA/US@EPA

Presentation led by Greg Brumfield - ThermoFisher Scientific manufactures the majority of Total Sulfur Analyzers for SCAQMD's Rule 1118 in Southern California. The latest analyzer can accurately measure from 15 ppm to 100% total su lfur. The latest SOLA Flare Analyzer removes the need for the refinery to do "Engineering Calculations.” This analyzer monitors ALL of the sulfur in the flare gas, not just MOST (which is what TRS is), or SOME (which is what H2S is). Every sulfur compound from light mercaptans to heavy sulfur compounds are efficiently and effectively converted to SO2 (Total Sulfur).