RECEIVED 

AUG 0 9 2010 

AIR ENFORCEMENT BRANCH 

U.S. EPA REGION 5 

PASSIVE FOURIER TRANSFORM INFRARED TECHNOLOGY (FTIR) 

EVALUATION OF POOl PROCESS CONTROL DEVICE 

AT THE 

INEOS ABS (USA) CORPORATION 

ADDYSTON, OHIO FACILITY 

SUPPLEMENTAL REPORT 

August 2010 
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 performed a Passive FTIR evaluation on the POOl 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 of the 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 

performance at different NHVFG values so as to determine the range of NHVFG that provides 

optimum environmental performance for operation of the 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 of the Flare. The test was performed in a timely manner on November 3 through 

November 5, 2009. 

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 Permit. 

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 stream and the Vent Gas stream. The purpose of this 

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 of NHVFG. It is proposed that any scenarios with lower 

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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/scf NHVFG 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 of these flow 

rates. 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 representatives of the 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 of molecular weight of the stream and the corrected 

calculation of mass flow rate of 1 ,3-butadiene by the percent mass method. The nitrogen content 

compensation was completed using a propriety algorithm provided by GE Sensing. 

SUMMARY OF RESULTS 

The graph in Figure 1 depicts the relationship that was determined between NHVFG and estimated 

relative efficiency as determined by PFTIR analysis. The individual data points represent the 

averages of all data collected for each test condition. The solid curve represents a polynomial curve 

fit with a R2 confidence of 0.98, which indicates an excellent mathematical model of the data set. 

Data summary of the exit velocity of the Flare Gas, 1 ,3-butadiene flow to the Flare, NHVFG of the 

Flare gas, and the relative efficiency for each test run is summarized in Table 3-3. The raw field 

data and the calculated NHVFG of each 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 

<1> 85%. 

'(3 

:E 

w 80% -

y = -2E-13x6 + 3E-10x5 - 2E.07x4 + 6E-05x3 - 0.0103x2 + 0.9939x - 38.26 

R2 = 0.9778 

<1> 

> 

:;:; 75%-

ctl 

Q5 

a: 70% -

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 of the 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 of the Heating Value of the 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 of Flares" 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 minimum heating 

value at a given velocity by using the lower 95 percent confidence interval of Figure 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 of the flame is thought to be caused by the difficulty of 

operating a flame near the stability limit." 

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100 

96 .... 

c:: 

41 0 u 0 .. 

41 

0. 

~ 

~ 94 c:: 

41 6 

u 

~ .... ...., 92 c:: 

0 

.... 

.... 

"' ::J 

.0 

a 90 (.) 

0 3-in;, EER 

6 6-in., EER 

0 12-in., EER 

C::. 12-in., Conmercial A 

0 12-in., Commercial B 

0 12-in., Commercial C 

Heating Value/Minimum Heating Value for Stability 

FIGURE 8 Combustion efficiency near the limits of name stability. 

N 

.... 

0 

~ 

;t 

2l 

:z: 

r 

~ 

"' ,.... 

The EPA has proposed that the lower limit for the new NHVFG limit should be 200 BTU/scf in 

order to assure the required control efficiency. The relative efficiency determined from the 

polynomial curve fit for the PFTIR data of the Addyston Flare is equivalent from NHVFG values of 

169 through 200 BTU/scf. Below a NHVFG of 169 BTU/scf, the model predicts declining 

efficiency. The EPA study referred to above identified that operation at a level of 110% of the 

minimum stable Heating Value provided confidence that high combustion efficiencies would be 

observed. INEOS ABS proposes that a value of 110% of the NHVFG value of 169 BTU/scf, or 

186 BTU/scf, is the most appropriate lower NHVFG limit to operate the POOl Process Flare. 

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Test 

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 Data Summary Table 

INEOS ABS - Addyston, Ohio 

Proposed Actual Proposed 

Butadiene Butadiene NHVFG 

Flow (lb/hr) Flow During (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 of 5 

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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