# RECEIVED AUG 09 

## 2010 AIR ENFORCEMENT BRANCH U.S. EPA REGION 5



### PASSIVE FOURIERTRANSFORMINFRARED TECHNOLOGY (FTIR) EVALUATION OFPOOl PROCESS CONTROLDEVICE AT THE INEOS ABS (USA) CORPORATION ADDYSTON, OHIOFACILITY

SUPPLEMENTAL REPORT August 2010SUMMARY 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 performed a Passive FTIR evaluation on the POOl Process control device at the INEOS ABS Addyston, Ohio facility. The purpose ofthe evaluation was to determine the appropriate Net Heating Value ofFlare 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 of200 British Thermal Units per standard cubic feet (BTU/scf) yields a control efficiency of99%. This PFTIR evaluation compared environmental performance at different NHVFG values so as to determine the range ofNHVFG that provides optimum environmental performance for operation ofthe Addyston Flare. The Facility's Title V Permit requires the Process POOl Flare to operate at 99% control efficiency.

INEOS ABS contracted with Industrial Monitor and Control Corporation (IMACC) to perform the PFTIR evaluation ofthe Flare. The test was performed in a timely manner on November 3 through November 5, 2009.

The evaluation pursuant to the Consent Decree was onlybeing used to provide information to the EPA Office ofEnforcement and Compliance Assurance (OECA), Director ofAir Enforcement ofthe Office ofCivil Enforcement (OCE) to aid in his/her decision in the establishment ofa newly defined lower NHVFG 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 Permit.

OBJECTIVES AND TEST MATRIX

The purpose ofthe PFTIR evaluation was to determine the appropriate lower NHVFG limit to be used to operate the POOl Process Flare. ThePFTIR method was used to estimate the emissions from the Flare bymeasuring 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 order to determine which lower NHVFG limit is the most appropriate, i.e. most efficient. Operating scenarios involved varying the flow rates and composition ofthe stream and the Vent Gas stream. The purpose ofthis evaluation program was to run multiple 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 Page 1of5 August 6, 2010 0:\Inhcom\ENVIRONMENTAL\Consent Decree Actions\Flare\FTIR\Report\FINAL PFTIR Report FINAL Supplement Report.doc

### emissions than those seen at the 200 BTU/scfscenarios 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 in Appendix A 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 ofthese flow rates. At the beginning ofthe 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 ofrepresentatives ofthe EPA and Hamilton County Department of Environmental Services 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 Appendix A. All values presented in Tables 3-2 have been corrected to account for the nitrogen content compensation in the calculation ofmolecular weight ofthe stream and the corrected calculation ofmass flow rate of 1

### ,3-butadiene bythe percent mass method. The nitrogen content compensation was completed using a propriety algorithm provided by GE Sensing.

SUMMARY OF RESULTS



### The graph in Figure 1depicts the relationship that was determined between NHVFG and estimated relative efficiency as determined by PFTIR analysis. The individual data points represent the averages ofall data collected for each test condition. The solid curve represents a polynomial curve fit with a R2 

### confidence of0.98, which indicates an excellent mathematical model ofthe data set. Data summary ofthe exit velocity ofthe Flare Gas, 1,3-butadiene flow to the Flare, NHVFG ofthe Flare gas, and the relative efficiency for each test run is summarized in Table 3-3. The raw field data and the calculated NHVFG ofeach test run are included in Appendix B; the flare monitoring data during the test runs is included in Appendix D.

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### Figure 1

PFTIR Relative Efficiency vs. Net Heating Value of Flare Gas

100%

95%

>. 90%
(..) c 85%. <1> '(3 :E 80%

- 

### w y =-2E-13x6 + 3E-10x5

- 2E.07x4 +6E

-05x3

- 0

.0103x2 +0.9939x

- 38.26 R2

### =0

.9778

<1> > 75%- :;:; ctl Q5 70%

- 

### a: a: 1- 65%- 

### u.. 

### a.. 60%
55%

- 50%100 150 200 250 300 350 400 Net Heating Value of Flare Gas in Btu/scf

The shape ofthe curve in Figure 1 is very similar to the relationships between Lower Heating Values and combustion efficiency established by previous EPA flare studies. These previous EPA flare studies identified that there is a lower limit ofthe Heating Value ofthe flare gas that below that value a rapid decline in flare combustion efficiency would occur. Excerpt from an Article in Combustion Science and Technology (50:4, pp. 217-231) titled "Combustion Efficiency ofFlares" by John H. Pohl; Joannes Lee; Roy Payne; Bruce A. Tichenor:
"The conditions which may lead to inefficient combustion in flare flames are graphically shown in Figure 8. The figure was constructed by determining the relative minimumheating value at a given velocity by using the lower 95 percent confidence interval ofFigure 5. Figure 8 shows that only one flare flame, operated at a heating value more than 10 percent above the minimum, resulted in combustion efficiencies less than 98 percent. The scatter in the data near the stability limit ofthe flame is thought to be caused by the difficulty of operating a flame near the stability limit."

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96

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Heating Value/Minimum Heating Value for Stability

FIGURE 8 Combustion efficiency near the limits ofname stability. N

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### The EPA has proposed that the lower limit for the new NHVFG limit should be 200 BTU/scfin order to assure the required control efficiency. The relative efficiency determined from the polynomial curve fit for the PFTIR data ofthe Addyston Flare is equivalent from NHVFG values of 169 through 200 BTU/scf. Below aNHVFG of 169 BTU/scf, the model predicts declining efficiency. The EPA study referred to above identified that operation at a level of 110% ofthe minimum stable Heating Value provided confidence that high combustion efficiencies would be observed. INEOS ABS proposes that a value of 110% ofthe NHVFG value of 169 BTU/scf, or 186 BTU/scf, is the most appropriate lower NHVFG limit to operate the POOl Process Flare.

Page 4 of5 August 6, 2010 0:\lnhcom\ENVIRONMENTAL\Consent Decree Actions\Flare\Ff!R\Report\FINAL PFTIR Report FINAL Supplement Report.docTest Run

I lA IB 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 17A 18 Proposed Actual Exit Exit Velocity Velocity During Test (ft/min) Run (ftlmin)

110 81 NA 102 NA 119 120 135 110 123 160 160 110 121 180 152 270 212 250 177 250 172 75 105 90 115 40 64 90 101 80 87 80 84 90 98 50 60 NA 54 60 81 

### Table 3-3 DataSummary Table 

### INEOS ABS

- Addyston, Ohio

Proposed Actual Proposed Butadiene Butadiene NHVFG Flow (lb/hr) FlowDuring (BTU/scf) Test Run

(lb/hr)
300 295 120 NA 325 NA NA 297 NA 300 540 200 300 488 150 300 543 180 300 509 230 600 640 !50 600 763 210 600 787 190 600 729 230 50 41 120 50 63 200 50 !59 200 50 73 140 50 202 160 50 44 180 50 171 220 10 21 140 NA 49 NA 10 26 200

Page 5 of5 Actual PFTIR NHVFG Estimated During Test Relative Run Efficiency (BTU/scf) (%) 183 96.1% 122 59.3% 147 89.9% 258 99.6% 198 95.3% 226 99.2% 305 99.8% 198 98.8% 270 99.8% 249 99.8% 285 99.9% 165 98.8% 227 99.2% 295 96.7% 183 98.3% 167 98.3% 156 98.1% 287 99.8% 283 98.2% 368 99.7% 296 99.8%

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