# Performance Test of a Steam-Assisted Elevated Flare With Passive FTIR

FINAL REPORT May 2010
Marathon Petroleum Company, LLC Texas Refining Division

502 10th Street South Texas City, Texas 77590

Testing Conducted September 15 - 24, 2009

Prepared by Clean Air Engineering, Inc. Project No: 10810Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page i 

## Table of Contents

1.0 Background & Summary.......................................................................................... 1-1
2.0 Introduction............................................................................................................... 2-1 2.1 Objectives of Test Program ..................................................................................................... ... 2-1 2.2 Testing Organization ........................................................................................................... ....... 2-1 2.3 Flare System Components ........................................................................................................ .. 2-2 2.3.1 Purpose........................................................................................................................ ...... 2-2 2.3.2 Flare Tip...................................................................................................................... ...... 2-2 Table 2.3-1: Texas City Main Flare Summary of Description and Design Specifications 2-2 2.3.3 Flare Automatic Steam Control Sy stem............................................................................ 2-3 Table 2.3-2: Automatic Steam C ontrol System Components............................................ 2-3 2.4 Mikron IR Cameras .............................................................................................................. ...... 2-4 2.4.1 Background on IR Sm oke Monitors.................................................................................. 2-4 2.4.2 Use of IR Cameras during Marath on Texas City Te st Project .......................................... 2-5 2.5 Video Cameras .................................................................................................................. ......... 2-6 Figure 2.5-1: Image from PFTIR Aiming Camera............................................................ 2-6 Figure 2.5-2: Image from FLIR A320 IR Camera ............................................................ 2-7 Figure 2.5-3: Image from FLIR GasFind IR LW Camera................................................. 2-7 Figure 2.5-4: Image from Axis Q1755 Camera................................................................. 2-8 2.6 Passive FTIR ................................................................................................................... ........... 2-8 2.7 Flare Test Program ............................................................................................................. ........ 2-9 2.7.1 Steam Demand and API 521 ............................................................................................. 2-9 Figure 2.7-1: API 521 Table 11 Suggested Stea m Rates ................................................ 2-10 2.7.2 Test Cond itions ............................................................................................................... 2 -12 Figure 2.7-3: S/VG vs. Conditio n ................................................................................... 2-13 Figure 2.7-4: S/HC vs. Condition.................................................................................... 2-13
3.0 Summary of Results ..................................................................................................3-1 3.1 Summary and Key Data Tren ds by Test Series .......................................................................... 3-1 3.1.1 Combustion Efficiency with Increasing Stea m Rates ....................................................... 3-1 3.1.1.1 Test Series A – Typical Base Load C onditions ......................................................... 3-1 Figure 3.1-1: CE vs. S/VG for Base Load Cond itions ...................................................... 3-2 Figure 3.1-2: X-Axis Zoom of Base Conditions, CE vs. S/VG......................................... 3-3 Figure 3.1-3: CE vs . S/S521 for Base Load Conditions.................................................... 3-4 3.1.1.2 Test Series B – Refi nery Fuel Gas............................................................................. 3-6 Figure 3.1-4: Re finery Fuel Gas CE vs. S/VG .................................................................. 3-6 Figure 3.1-5: Refi nery Fuel Gas S/S521 with Combustion Efficiency ............................. 3-7 3.1.1.3 Test Series C – Propane............................................................................................. 3-8 Figure 3.1-6: Propane Test Series CE vs. S/VG................................................................ 3-8 Figure 3.1-7: Propane Test Series CE vs. S/S521 ............................................................. 3-9 3.1.1.4 Test Series D & E – Propyle ne/Butylene Ol efins .................................................... 3-10 Figure 3.1-8: Olefin Test Series CE vs. S/VG................................................................. 3-10 Figure 3.1-9: Olef in Test Series CE vs. S/S521 .............................................................. 3-11 3.1.2 Observed Impacts of Hydrogen....................................................................................... 3-12 3.1.2.1 Test Series F – Increasin g Hydrogen Co ntent ......................................................... 3-13 Figure 3.1-10: Combustion Efficiency as Hydrogen Cont ent Increases ......................... 3-13 3.1.2.2 Test Series G – Increasin g Nitrogen Co ntent........................................................... 3-14Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page ii Figure 3.1-11: Combustion Efficiency with Decreasing NHV VG .................................... 3-14 3.2 Summary and Key Data Trends of Whole Data Set ................................................................. 3-15 3.2.1 Composite of All Hydr ocarbons Tested.......................................................................... 3-15 Figure 3.2-1: Combustion Effi ciency vs. S/VG Composite of All Materials Tested ...... 3-15 Figure 3.2-2: Combustion Effi ciency vs. S/S521 Composite of All Materials Tested.... 3-16 3.2.2 Combustion Zone Gas Net Heating Value...................................................................... 3-17 Figure 3.2-3: CZG NHV vs. CE for All Material s Tested .............................................. 3-17 3.2.3 Visible Emissions and Co mbustion Effi ciency ............................................................... 3-18 Table 3.2-1: Visual Flam e Rating Descriptions .............................................................. 3-18 Figure 3.2-4: Combustion Efficiency vs. Visible Emissions Ratings for All Materials Tested......................................................................................................................... ..... 3-19 3.2.4 Comparisons to API 521 Table 11 .................................................................................. 3-20 Figure 3.2-5: Incipient Smoke Point vs. API 521 Table 11 Predictions.......................... 3-20 Figure 3.2-6: Incipient Smoke Po int Varies with Mass Load ......................................... 3-21 Table 3.2-2: Runs with Visible Emissions Ratings 4.5 – 5.5 .......................................... 3-22 3.3 Factors Influenci ng Test Results............................................................................................... 3-23 3.3.1 Mechanical Damage of Flare Tip.................................................................................... 3-23 Figure 3.3-1: Steam Leak at Shaping St eam Ring .......................................................... 3-23 3.3.2 Wind Effects ................................................................................................................... 3-25 Figure 3.3-3: Example of Good Plume Alignment w ith PFTIR...................................... 3-25 Figure 3.3-4: Example of Poor Plume Alignment w ith PFTIR....................................... 3-26 Figure 3.3-5: Comparative View from PFTIR Aiming Camera...................................... 3-26 Figure 3.3-6: Wind Fl agging Algorithm ......................................................................... 3-27 Figure 3.3-7: Day by Day Wind Roses ........................................................................... 3-28 3.3.3 PFTIR Aiming Issues...................................................................................................... 3-29 Figure 3.3-8: Aiming Te st: Video Stills from E ach Test Po int....................................... 3-30 Figure 3.3-9: Aiming Test: Measured Components........................................................ 3-31 Figure 3.3-10: Aiming Test: Meas ured Components - Zoomed ..................................... 3-31 Figure 3.3-11: Aiming Test: CO 2 /CO and CO 2 /THC Ratio s........................................... 3-32 Figure 3.3-12: Aiming Test: Combustion Effi ciency...................................................... 3-33 Figure 3.3-13: Aiming Te st: Steam Ra tios...................................................................... 3-33 Figure 3.3-14: Aiming Te st: Flow an d CZG................................................................... 3-34 Figure 3.3-15: Aiming Te st: VG Com position ............................................................... 3-34 3.3.4 Overall Test Variability ................................................................................................... 3-35 3.3.4.1 PFTIR Precision Assessment................................................................................... 3-35 Figure 3.3-17: Long Term Stab ility Run by Run Variability .......................................... 3-37 Figure 3.3-18: Confidence Interval Determination from LTS Data................................ 3-38 3.3.4.2 Dilution Assu mption................................................................................................ 3-39 Figure 3.3-19: CO 2 /CO Ratio Comparison on LTS Runs ............................................... 3-39 3.3.5 PFTIR Calibra tion........................................................................................................... 3-4 0 3.3.5.1 Radiance Calib rations.............................................................................................. 3-40 Figure 3.3-20: PFTIR Ra diance Calibra tions.................................................................. 3-40 3.3.5.2 Hot Cell Calib ration................................................................................................. 3-41 Figure 3.3-21: PFTIR Hot Cell Calibration Curve – CO 2 ............................................... 3-41 Figure 3.3-22: PFTIR Hot Ce ll Calibration Cu rve - CO ................................................. 3-42 Figure 3.3-23: PFTIR Hot Cell Ca libration Curve – Methane ........................................ 3-42 3.3.6 Methane and Heavy Hydrocarbon s ................................................................................. 3-43 3.3.7 PFTIR Component Errors ............................................................................................... 3-43 3.3.8 Lack of Integrat ed Sampling........................................................................................... 3-44Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page iii 3.4 Conclusions .................................................................................................................... .......... 3-45 3.5 Recommendations for Further Study........................................................................................ 3-45
4.0 PFTIR Testing Method and Procedure.................................................................... 4-1 4.1 Description and Principles of Passive FTIR ............................................................................... 4-1 4.2 PFTIR Siting Co nfigura tion ..................................................................................................... .. 4-2 Figure 4.2-1: Location of PFTIR Camera, Flare, and Cameras ........................................ 4-2 Figure 4.2-2: View of Main Flare from PFTIR Location.................................................. 4-3 Figure 4.2-3: Marathon Texas City Plot Plan (Area shown in Figure 4.2-1 shown in red)4-4 4.3 Background..................................................................................................................... ............ 4-5 4.4 PFTIR Operation ................................................................................................................ ........ 4-5 Figure 4.4-1: PFTIR Trailer .............................................................................................. 4-6 Figure 4.4-2: The PFTIR Instrument................................................................................. 4-6 Figure 4.4-3: Schematic of PFTIR set-up ......................................................................... 4-7 4.5 PFTIR Data Reduction ........................................................................................................... .... 4-9 Figure 4.5-1: Contributions to Total Radiance.................................................................. 4-9 Figure 4.5-2: PFTIR Data Analysis Prog ression............................................................. 4-13 4.6 Q-Branch Su btraction ........................................................................................................... .... 4-14
5.0 Data Tables................................................................................................................ 5-1 5.1 Data Summary Tables............................................................................................................ ..... 5-1 Table 5.1-1: Condition A19 Test Result Summary ........................................................... 5-3 Table 5.1-2: Condition A11 Test Result Summary ........................................................... 5-3 Table 5.1-3: Condition A8 Test Result Summary............................................................. 5-3 Table 5.1-4: Condition B Test Result Summary ............................................................... 5-4 Table 5.1-5: Condition C Test Result Summary ............................................................... 5-4 Table 5.1-6: Condition D Test Result Summary ............................................................... 5-4 Table 5.1-7: Condition E Test Result Summary ............................................................... 5-5 Table 5.1-8: Condition F Test Result Summary ................................................................ 5-5 Table 5.1-9: Condition G Test Result Summary ............................................................... 5-5 Table 5.1-10: LTS Test Result Summary.......................................................................... 5-5 5.2 Test Cond ition A1 9 ............................................................................................................. ....... 5-6 5.2.1 Process Co nditions............................................................................................................ 5 -6 Figure 5.2-1: Condition A19 Flow and CZG Heat Content .............................................. 5-6 Figure 5.2-2: Condition A19 Vent Gas Com position........................................................ 5-6 5.2.2 Steam Ratios ................................................................................................................... .. 5-7 Table 5.2-1: Condition A19 Steam Ra tios ........................................................................ 5-7 5.2.3 Wind Cond itions ............................................................................................................... 5 -7 Figure 5.2-3: Condition A19. Wind Speed and Directio n during Test.............................. 5-7 5.2.4 Results........................................................................................................................ ....... 5-8 5.3 Test Cond ition A1 1 ............................................................................................................. ....... 5-9 5.3.1 Process Co nditions............................................................................................................ 5 -9 Figure 5.3-1: Condition A11 Flow and CZG Heat Content .............................................. 5-9 5.3.2 Steam Ratios ................................................................................................................... 5-10 Table 5.3-1: Condition A11 Steam Ra tios ...................................................................... 5-10 5.3.3 Wind Cond itions ............................................................................................................. 5-1 0 Figure 5.3-3: Condition A11. Wind Speed and Directio n during Test............................ 5-11 5.3.4 Results........................................................................................................................ ..... 5-12 5.4 Test Cond ition A8 .............................................................................................................. ...... 5-13Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page iv 5.4.1 Process Cond itions.......................................................................................................... 5-1 3 Figure 5.4-1: Condition A8 Flow and CZG Heat Content .............................................. 5-13 Figure 5.4-2: Condition A8 Vent Gas Com position........................................................ 5-13 5.4.2 Steam Ratios ................................................................................................................... 5-14 Table 5.4-1: Condition A8 Steam Ra tios ........................................................................ 5-14 5.4.3 Wind Cond itions ............................................................................................................. 5-1 4 Figure 5.4-3: Condition A8. Wind Sp eed and Direction During Te st............................. 5-14 5.4.4 Results........................................................................................................................ ..... 5-15 5.5 Test Cond ition B............................................................................................................... ........ 5-16 5.5.1 Process Cond itions.......................................................................................................... 5-1 6 Figure 5.5-1: Condition B Flow and CZG Heat Content ................................................ 5-16 Figure 5.5-2: Condition B Vent Gas Comp osition .......................................................... 5-16 5.5.2 Steam Ratios ................................................................................................................... 5-17 Table 5.5-1: Condition B Steam Ra tios........................................................................... 5-17 5.5.3 Wind Cond itions ............................................................................................................. 5-1 7 Figure 5.5-3: Condition B. Wind Sp eed and Direction During Test............................... 5-17 5.5.4 Results........................................................................................................................ ..... 5-18 5.6 Test Cond ition C............................................................................................................... ........ 5-19 5.6.1 Process Cond itions.......................................................................................................... 5-1 9 Figure 5.6-1: Condition C Flow and CGZ Heat Content ................................................ 5-19 Figure 5.6-2: Condition C Vent Gas Comp osition .......................................................... 5-19 5.6.2 Steam Ratios ................................................................................................................... 5-20 Table 5.6-1: Condition C Steam Ra tios........................................................................... 5-20 5.6.3 Wind Cond itions ............................................................................................................. 5-2 0 Figure 5.6-3: Condition C. Wind Sp eed and Direction during Test................................ 5-20 5.6.4 Results........................................................................................................................ ..... 5-21 5.7 Test Cond ition D ............................................................................................................... ....... 5-22 5.7.1 Process Cond itions.......................................................................................................... 5-2 2 Figure 5.7-1: Condition D Flow and CZG Heat Content ................................................ 5-22 Figure 5.7-2: Condition D Vent Gas Comp osition .......................................................... 5-22 5.7.2 Steam Ratios ................................................................................................................... 5-23 Table 5.7-1: Condition D Steam Ra tios .......................................................................... 5-23 5.7.3 Wind Cond itions ............................................................................................................. 5-2 3 Figure 5.7-3: Condition D. Wind Sp eed and Direction during Test................................ 5-23 5.7.4 Results........................................................................................................................ ..... 5-24 5.8 Test Cond ition E............................................................................................................... ........ 5-25 5.8.1 Process Cond itions.......................................................................................................... 5-2 5 Figure 5.8-1: Condition E Flow and CZG Heat Content................................................. 5-25 Figure 5.8-2: Condition E Vent Gas Com position .......................................................... 5-25 5.8.2 Steam Ratios ................................................................................................................... 5-26 Table 5.8-1: Condition E Steam Ra tios........................................................................... 5-26 5.8.3 Wind Cond itions ............................................................................................................. 5-2 6 Figure 5.8-3: Condition E. Wind Sp eed and Direction during Test ................................ 5-26 5.8.4 Results........................................................................................................................ ..... 5-27 5.9 Test Cond ition F ............................................................................................................... ........ 5-28 5.9.1 Process Cond itions.......................................................................................................... 5-2 8 Figure 5.9-1: Condition F Flow and CZG Heat Content................................................. 5-28 Figure 5.9-2: Condition F Vent Gas Com position .......................................................... 5-29 5.9.2 Steam Ratios ................................................................................................................... 5-29Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page v Table 5.9-1: Condition F Steam Ra tios........................................................................... 5-29 5.9.3 Wind Cond itions ............................................................................................................. 5-3 0 Figure 5.9-3: Condition F. Wind Sp eed and Direction during Test ................................ 5-30 5.9.4 Results........................................................................................................................ ..... 5-31 5.10 Test Cond ition G ............................................................................................................... ....... 5-32 5.10.1 Process Cond itions ..................................................................................................... 5-32 Figure 5.10-1: Condition G Flow and CZG Heat Content .............................................. 5-32 Figure 5.10-2: Co ndition G Vent Gas Composition........................................................ 5-33 5.10.2 Steam Ratio s............................................................................................................... 5-33 Table 5.10-1: Condition G Steam Ra tios ........................................................................ 5-33 5.10.3 Wind Cond itions ........................................................................................................ 5-34 Figure 5.10-3: Condition G. Wind Speed and Dir ection during Test.............................. 5-34 5.10.4 Results........................................................................................................................ 5-35 5.11 Long Term St ability Test....................................................................................................... ... 5-36 5.11.1 Process Cond itions ..................................................................................................... 5-36 Figure 5.11-1: Long Term Stability Flow and CZG Heat Content.................................. 5-36 Figure 5.11-2: Long Term Stab ility Vent Gas Co mposition........................................... 5-37 5.11.2 Steam Ratio s............................................................................................................... 5-37 Table 5.11-1: Long Term Stability Steam Ratios............................................................ 5-37 5.11.3 Wind Cond itions ........................................................................................................ 5-38 Figure 5.11-3: Long Term Stability. Wind Speed and Directio n during Te st................. 5-38 5.11.4 Results........................................................................................................................ 5-39
6.0 Appendix.................................................................................................................... 6-1 A.1 Calcula tions ................................................................................................................... ............. 6-1 A.2 PFTIR Calibration an d Operation............................................................................................... 6 -1 A.3 VOC Emission Ca lculations...................................................................................................... . 6-1 A.4 Personnel Involved with Fl are Performan ce Test....................................................................... 6-1Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page vi 

## Acknowledgements

The Primary Authors for this report were:

Ruth Cade – Marathon Petroleum Company

Scott Evans – Clean Air Engineering

This report would not have been possible withou t extensive input and feedback from others involved with this project. We wish to acknow ledge the following people for their invaluable contributions to this project and this report.

Brian Wilt – Marathon Petroleum Company
Alejandro Acuna – Marathon Petroleum Company
Dr. Robert Spellicy – Industrial Monitor and Control Corporation

Dr. Jim Seebold – Chevron (Ret.)

Dr. Laura Kinner – Emission Monitoring

Jim Franklin – John Zink Company, LLC

Peter Kaufmann – Clean Air Engineering

Daniel Roesler – Clean Air Engineering

Nadia Lazzar – Clean Air EngineeringPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 1-1 

# 1.0 BACKGROUND & SUMMARY
As required by a Clean Air Act Section 114 requ est requiring testing of a refinery steamassisted flare, Marathon Petroleum Company (“ Marathon”) conducted performance testing of its main flare in Texas City, Texas. The main objective of the test was to better understand the impacts of steam on the overall emissions performance of the flare in terms of combustion efficiency (CE). Marathon has implemented an automatic steam control system for this flare designed to mitigate periods of flare over-steaming. The performance test was conducted using a Passive Fourier Transfor m Infrared (PFTIR) Spectroscopy instrument developed and operated by Industrial Mon itor and Control Corporation (IMACC).
The purpose and major benefit of a steam injection system is to significantly reduce the amount of smoke that would otherwise be created by combustion. In a typical system, steam is injected into the flare combustion zone to deliver educted air as well as mixing energy. Over-steaming is a generic description of an undesirableoperating condition possible in steamassisted flare systems. In an over-steaming scenario, it is possibl e that the amount of steam and educted air introduced into the combustion reaction zone diminishes, rather than promotes, the efficiency of the combustion process if introduced in large enough quantities.
A flare’s operating envelope should be bounded by excess visibl e emissions (i.e. too little steam) and excess emissions of volatile organi c compounds (“VOCs”) (i.e. too much steam). The efficiency of any particular steam injecti on system with respect to smoke suppression is easily measured by monitoring steam rates a nd visually observing smoking performance. However, the ability to measure or even id entify excess emissions caused by over-steaming is a more difficult task. Standard emission es timation techniques have generally assumed a 98% combustion efficiency or higher when calculating VOC emissions from flares. 

## Figure 1-1

. Texas City Main FlarePerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 1-2 Regulatory requirements for flar es are contained in 40 CFR § 60.18 and § 63.11. These requirements were developed from a series of flare emissions tests led by the United Stated Environmental Protection Agen cy (US EPA) from 1983 – 1986. 1 The requirements include maintaining a flare pilot, operating with a mi nimum net heating value of 300 BTU/scf in the vent gas, operating at exit ve locities of less than 60 ft/s (o r 400 ft/s depending upon the vent gas net heating value) and opera ting with a limited amount of visible emissions. However, a flare can be operated in compliance with th ese requirements and st ill be over-steamed.
Previous tests of flare performance, including the US EPA tests in the mid-1980s, have been conducted on pilot-scale test flar es at moderate to high vent gas loads. However, a flare typically operates at low vent gas loads (i .e., high turndown) under normal conditions until a process upset or other operati ng condition requires the operator to flare waste gas. Thus, the flare normally operates at high turndown for th e majority of the operating year, a condition for which there is little to no available performance data.
In the past, measuring the combustion products from a flare was difficult and dangerous. Recent technological advances, however, have pr oduced remote sensing instruments capable of indicating the presence of combustion produ cts such as carbon dioxide, carbon monoxide and select hydrocarbons without the safety hazards introduce d by physically sampling a flare plume. One such instrument is the PFTIR, wh ich characterizes a plume’s chemical make-up (carbon dioxide, carbon monoxide , and total hydrocarbons) in units of concentration x pathlength. The absolute concentration cannot be determined, but the product (concentration x pathlength) measured in ppmv x meters, can be used in the combustion efficiency calculations. The PFTIR instrument is a new tool that has not yet been blind validated against extractive sampling results. The Texas Commission of Environmental Quality (TCEQ) evaluated the PFTIR ag ainst extractive FTIR in 2004 2 . Marathon’s Texas City main flare performance test was the first time the PFTIR was used on an operating industrial flare.

1 EVALUATION OF THE EFFICIENCY OF INDUST RIAL FLARES: TEST RESULTS, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, EPA-600/2-84-095, May 1984

EVALUATION OF THE EFFICIENCY OF INDU STRIAL FLARES: FLARE HEAD DESIGN AND GAS COMPOSITION,, United States Environmental Protectio n Agency, Office of Air Quality Planning and Standards, EPA-600/2-85-106, September 1985

EVALUATION OF THE EFFICIENCY OF INDUSTRIAL FLARES: H 2 S GAS MIXTURES AND PILOT ASSISTED FLARES, United States En vironmental Protection Agency, Office of Air Quality Planning and Standards, EPA-600/2-86-080, September 1986

2 PASSIVE FTIR PHASE 1 TESTING OF SIMULA TED AND CONTROLLED FLARE SYSTEMS, Texas Commission on Environmental Quality, June 2004Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 1-3 The PFTIR performance test conducted on Mara thon’s Texas City refinery’s main flare produced valuable insights into the flare’ s efficiency performance under a variety of conditions. Tests were conducte d while flaring gases containing saturates, olefins, nitrogen and hydrogen mixtures. For each Test Series, st eam was increased from the manufacturer’s recommended minimum cooling steam rate to the point of snuffing the flare. For the majority of tests conducted, combustion efficiency declined with increasing steam at constant vent gas mass loading and constant compositi on. High combustion efficiencies could be achieved at minimum cooling steam rates on the Texas City main flare.



## Figure 1-2

. Combustion Efficiency vs . S/VG: Composite of All Materials Tested

This data demonstrates that this flare can likely achieve 98% combustion efficiency during turndown operation with proper st eam delivery system design.
The performance test data also yielded insights into variables that could potentially be used as parametric monitoring points to ensure hi gh efficiency during stand-by operation. One variable is a calculate d term representing the net heati ng value (NHV) of the combustion zone gas (CZG). The combustion zone for an el evated steam-assisted flare is directly above the flare’s tip, and is the point in which a ll materials combine for combustion. The net heating value (NHV) of the combustion zone gas is therefore the resulting heat content of the mixture that is created by the vent gas from the flare header, the pilot gas, and the total steam, in this case including center, lower, and upper steam. The CZG NHV showed strong correlations to combustion efficiency regardle ss of vent gas compos ition, with efficiency declining between 200 – 250 BTU/scf. See Figure 1-3 below.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 1-4 The test data also showed that a visible flam e has higher combustion efficiency than a steaminduced transparent flame. Combustion effici ency becomes erratic and declines rapidly when enough steam is added to turn a visible yellow flame invisible. High combustion efficiencies were also observed while the ma in flare experienced unacceptable levels of visible emissions.
While not yet blind validated against extractiv e analysis techniques, the PFTIR instrument appears to be a good tool to identify general flar e performance trends. Additional research is needed to characterize the instrument’s overa ll precision and bias. The combustion reaction products measured by the PFTIR appeared to sh ow variability and scatter in terms of the carbon dioxide component, but less so in terms of combustion efficiency. There are many factors that could influence the efficiency perf ormance of a flare, including those associated with the flare operation and design. Other f actors contributing to component variability could also include atmospheric conditions, flame movement/plume tracking, instrument specific factors such as the specific detector us ed or the spectral wavelength used for plume component quantification as we ll as variability introduced by the measurement technique itself. Another potential cause of the observe d data variability could be flare plume inhomogeneity -- pockets of differing compositions exist within the plume resulting in a plume cross-section with vary ing composition. The PFTIR’s field of view is small relative to the plume size, which could enhance rather th an normalize these variations in plume composition. A single source of data variability was not determined as part of this test.



## Figure 1-3

. Combustion Zone Gas NHV vs. CE for All Materials TestedPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-1 

# 2.0 INTRODUCTION

2.1 Objectives of Test Program The overall objectives of the test program were as follows:

1. Implement a performance test program th at demonstrates compliance with 98% combustion efficiency requirements as determined by the PFTIR remote sensing analyzer, over a range of vent gas compositi ons and steam to vent gas (“S/VG”) ratios at turndown operating scenarios.
2. Evaluate key variables such as Com bustion Zone Gas Heat Content (“CZG ” ), actual steam to vent gas ratio (“S/VG”), and a comparison of S/VG ratios predicted by API 521 to actual ratios (“API 521 Multiplier (S/S521)”) as ke y performance indicators that may assist in maintaining flare operation at high e fficiency conditions.
3. Evaluate the viability and reliability of utilizing an infrared smoke detector to maintain flare operation at the “incipient smoke point”, a point that has been demonstrated through third-party pilot-scale test programs to be the highest point of combustion efficiency.
4. Conduct a flare performance test without incurring upsets or other malfunctions on refinery process equipment, which would generate additional sources of emissions.



### 2.2 Testing Organization
The test was conducted with the assistance of both Clean Air Engineering and Industrial Monitoring and Controls Corporation (IMACC).

Clean Air Engineering 500 W. Wood St. Palatine, Illinois 60067

Because the test required personnel from Marath on’s operations, maintenance, engineering, and environmental staff, a cross-functional team was formed between IMACC, Clean Air Engineering and Marathon in order to staff, monitor and record test results. A list of personnel present during the test is included in Appendix A.4. IMACC 800 Paloma, Suite 100 Round Rock, Texas 78645Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-2 

### 2.3 Flare System Components
2.3.1 Purpose A flare is one of the most important safety de vices in use at a refine ry. Its purpose is to safely combust gases generated by emergency or ups et conditions within a process unit. As a result, a flare must operate over a large and vari able range of operating scenarios. These vary from typical stand-by operation at minimum fl ow conditions to efficiently combusting gases generated from a full power outage or othe r process safety relief scenario.

Marathon’s flare test focuse d on the stand-by (i.e. high turn down) operating range. Not only does this range encompass the majority of a fl are’s operating time, but it is also the range where performance test data are scarce.



### 2.3.2 Flare Tip The Marathon Texas City main flare is an elev ated steam-assisted flare. The flare tip is manufactured by Callidus Technologies and was installed in December, 2000. The tip has three points of steam addition: center steam , a lower steam ring, and an upper steam ring. The lower steam ring manifold piping has a c onnection to a small sweep gas ring used for shaping at the tip exit.

A description of the Main Flare and key design specification are listed in Table 2.3-1 below.


## Table 2.3-1: Texas City Main Flare Summary of Description and Design Specifications Texas City Main Flare Flare Tip Details Flare Tip Manufacturer Callidus Technologies Flare Tip Installation Date December 2000 Flare Tip Size 24 in. diameter , 23.25 in. effective diameter Flare Tip Model Number BTZ-IS 3 /US-24-C Summary of Flare Design Information Parameter Value Units Design Purge Rate 108 scfh Pilot Rate 12 lb/hr Minimum Total Steam 1250 lb/hr Maximum Hydraulic Capacity (i.e. Max Vent Gas Rate) 500,000 lb/hr

Maximum Smokeless Capacity 165,000 lb/hr Height of Flare Tip 159 ft above gradePerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-3 The main flare serves as relief protection for nine process units. Typical flare operation is in stand-by mode at approximately 1100 to 2000 lb/hr of base load flow or less than 0.5% of the hydraulic capacity -- a 250:1 tur ndown factor. Base load incl udes flare header sweep gas, seal purges from rotating equipment, sample stat ions, and various proces s vents from refinery equipment. 

### 2.3.3 Flare Automatic Steam Control System Marathon implemented an automatic steam contro l system prior to the performance test. This system consists of flow instruments for both the total steam rate and vent gas rate, as well as a smaller trim steam control valve for the lower steam ring. An instrument that detects visible emissions (i.e. smoke) using an infrared signal was also installed and tested for viability (see Section 2.4 for details). The existing flare header gas chromatograph installed pursuant to Texas HRVOC rules (30 TAC Chapter 115 Subchapter H, Division 1) was used to characterize vent gas composition.
Specific components of the steam control system are summarized in Table 2.3-2 with details below.


## Table 2.3-2: Automatic Steam Control System Components

Parameter Technique Vendor Model

Flare Gas Volumetric/ Mass Flow Ultrasonic Time of Flight GE Panametrics DigitalFlow GM868

Steam Mass Flow Ultrasonic Time of Flight GE Panametrics DigitalFlow GS868

Flare Gas Composition and Net Heating Value Gas Chromatography Siemens Maxum II

Flare Gas Molecular Weight Ultrasonic Time of Flight GE Panametrics (same unit as above) DigitalFlow GM868

Incipient Smoke Point Infrared Camera Qty 2 Mikron / E 2 Technology Zoom TM 8100SM

Flare Gas Flow Rate, Temperature, and Molecular Weight A GE Panametrics ultrasonic flow meter meas ures flare gas flow rate, temperature and molecular weight. It is impor tant to note that this instru ment cannot distinguish between components of like molecular weight. For in stance, it cannot disti nguish propane from carbon dioxide (both having a molecular weight of 44 lb/lbmole). Since the steam controlPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-4 requirements would be very different fo r the two compounds, the molecular weight measurement was not used independ ently in the control logic.
Note that the ultrasonic meter is spanned fo r the full flow range of the flare system. Manufacturer’s specifications indicate reasonab le accuracy at low flow conditions. Prior to testing, the ultrasonic flow meter was field ca librated by manufacturer representatives.
Flare Gas Composition A Siemens Maxum II Gas Chromatograph monito rs the flare gas compositions and heat content (BTU/scf). This analyz er provides an analytical data point approximately once every ten minutes.

Steam Flow Parameters Steam flow is measured by a GE Panametrics ul trasonic flow meter. Prior to testing, steam control valve positioners were calibra ted and checked for proper operation.
Incipient Smoke Point The ZoomTM infrared smoke detectors we re supplied by John Zink Company, but manufactured by Mikron/E 2 Technology. The ZoomTM is an IR sensor that monitors the flare flame to detect the presence of soot precursors. Two units were inst alled at approximately perpendicular points of view to accommodate at mospheric effects at the facility. Both detectors were calibrated and ad justed prior to testing.


### 2.4 Mikron IR Cameras
Two Mikron IR Cameras were installed for this test. The cameras, which are typically used for smoke detection, were tested for their ab ility to detect over-st eaming in addition to smoke. This section discusses some of th e background of using IR cameras for smoke detection as well as the details of the performan ce of the cameras during this test program. It should be noted that these “cameras” do not provi de a visual image but data only. The IR cameras were included as part of this test progr am to evaluate its pote ntial to be used as a trim control instrument to maintain flar e operation near the incipient smoke point automatically, and not based upon empirical or pa rametric variables. As discussed below, the IR cameras were determined to not be tec hnically feasible to prot ect the flare from oversteaming as part of an automatic control scheme.



### 2.4.1 Background on IR Smoke Monitors Infrared smoke monitors have been used for many years to assist in smoke control for flares. Infrared energy from the flare flame is collec ted by means of a focusing optical lens that concentrates the energy on a sensitive infrared de tector. The design tested uses two filters at separate wavelengths to allow the electronics to selectively amplify the infrared energy in the range of interest. These filters are on a continuously rotating “chopper wheel” which creates a pulsating “on/off” signal as each filter crosse s the view path between the optical lens andPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-5 the detector. The electronic circuitry is sync hronized with the chopper to provide the desired output based on the infrared energy levels passing through the two different filters.

A key parameter in the success of this technology is not only the circuitry and detector, but also the selection of the filters. The filters must be able to detect infrared energy in the range of interest while filtering out backgro und, weather conditions, and other potentially interfering infrared energy. Inte rferences include the sun, so the detectors must be oriented so the sun is not in the line of view at any time of the year. The actual filters chosen are proprietary to the manufacturer. The intent is to select filters that wi ll produce an increased level of infrared energy as the flame begins to smoke, a reduced level when the flame is not smoking, and an even lower or zero level when the flame is clear.

As smoke control was the primary driver for th e development of these monitors, successful operation was achieved if smoking was eliminated or at least signifi cantly reduced. The effects of over-steaming were not a major consid eration in the use of smoke monitors. This is particularly true when smoke monitors were first used many years ago when flares typically operated at higher flow rates on a c ontinuous basis. Flares operating at higher flow rates are harder to over-steam than flar es operating at high turndown rates.

Testing is not known to have been conducted to demonstrate if infrared smoke monitors had the accuracy and range of detection to not only prevent smoke but also prevent oversteaming. It is an even greater challenge to accomplish this task from a range from very high turndown (low flow) flare flow rates up to higher fl ow (low turndown) flare flow rates. If an infrared smoke monitor could provide this range of operation with a high level of accuracy, it was hoped that it could be tuned to assist in keeping the stea m at the incipient smoke point, as this point is believed to produce the highe st combustion efficiency for flare operation.



### 2.4.2 Use of IR Cameras during Marathon Texas City Test Project For this test, two Mikron / E 2 T M8100 Flare Smoke Monitors we re installed so at least one monitor would have a good view of the flame regardless of wind direction. Both were located so the sun would not directly interf ere with the infrared energy received by the detector.

The monitors were calibrated per the manufact urer’s instruct ions to obtain a midrange control signal when the flame was somewh at luminous, but not smoking. During these calibrations, the flare was operating in relativel y low flow, high turndown conditions. These were the main areas of interest for testing. Under these low flow conditions, the gain adjustment on both monitors had to be at almost full span to ge t the desired signal. However, high gain settings were found to produce erratic signals from the monitors.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-6 In some cases, the high gains resulted in “fal se” signals when the flame was clear. Under these conditions, the monitor would have been incorrectly calling for mo re steam instead of less steam. When the gain was adjusted to st op the erratic signals, th e output control could not produce enough signal strength to be used for flare control. The calibrations were adjusted several times during the testing and no calibration settings were found that could meet the requirements.

The conclusion is that the IR monitors cannot be used to keep a fl are near the incipient smoke point at low flow rates and, in fact, could increase th e chance of over-steaming. The monitors were not evaluated for performance at higher flow rates as all test were conducted at low flow conditions.



### 2.5 Video Cameras During this test program, a to tal of six video cameras record ed flare activity from various locations. Three of these were IR cameras a nd three were visible light cameras. The purpose and location of each camera are described below. The location of all cameras can be seen on the plot plan shown in Figure 4.2-3.
PFTIR Aiming Camera The PFTIR Aiming Camera is an IR camera mounted on the PFTIR telescope. The image from this camera is used by the PFTIR operato r to aim the instrument. An examination of this video stream gives an indication of PFTIR aiming accuracy. An image from this camera is shown in Figure 2.5-1. The red square (adde d for this report) show s the area analyzed by the PFTIR. This red area completely fills the field of view of the PFTIR telescope during testing and indicates the area of the plume being sampled.



## Figure 2.5-1: Image from PFTIR Aiming CameraPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-7 FLIR A320 Camera The FLIR A320 camera was used to obtain a genera l view of flare operation in the IR. It has a broad spectral range from 7.5 to 13 microns (1 333 to 769 wavenumbers). The temperature scale on the camera was not calib rated for this test and any temperature readings shown should be considered as relative indicators only. The camera was located approximately ninety degrees from the PFTIR siting location. An image from this camera is shown in Figure 2.5-2 below.



## Figure 2.5-2: Image from FLIR A320 IR Camera

FLIR GasFind IR LW Camera The FLIR GasFind IR LW camera was used to obtain a narrower spectral view of flare operation than that provided by the FLIR A320 camera. The GasFind LW camera operates in a spectral range of 10 to 11 microns (1000 to 909 wavenumbers). The camera was located approximately ninety degrees from the PFTIR si ting location for the test program. An image from this camera is shown in Figure 2.5-3 below.



## Figure 2.5-3: Image from FLIR GasFind IR LW CameraPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-8 Axis Q1755 Cameras The Axis Q1755 cameras were used at each of the three visible camera locations. These HD cameras provide a detailed visible light image of flare operation. One camera was co-located with the two FLIR IR cameras. The other two were located n ear the Mikron IR cameras at their installed locations. The purpose of these two cameras was to provide a visual image to correspond to the data produced by the Mikron ca meras. An image from the Axis camera located ninety degrees from the PFTIR s ite location is shown in Figure 2.5-4.



## Figure 2.5-4: Image from Axis Q1755 Camera

2.6 Passive FTIR The instrument used to determine the gas composition of the flare plume is the PFTIR analyzer. A detailed description of the inst rument and the testing procedure are found in Section 4 with further detail in Appendix A.2.
The PFTIR operates on the principle of spectral analysis of thermal radiation emitted by hot gases. Passive means that no “active” infrared light source is used. Instead, the hot gases of the flare are the infrared source. The spectro meter is a receiver onl y. This approach is possible because the infrared emission spectra of hot gases have the same patterns or “fingerprints” as their absorption spectra. C onsequently, observing a flare with an infrared instrument allows for identification and quantification of sp ecies through emission spectroscopy just as in absorption spectroscopy.
For this test program, the PFTIR operation a nd data analysis was overseen by Dr. Robert Spellicy of Industrial Monitor and Control Co rporation (IMACC). Th e instrument and the analytical software were both developed by IMACC.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-9 

### 2.7 Flare Test Program

2.7.1 Steam Demand and API 521 Marathon’s test program was designed to eval uate over-steaming under a variety of flaring conditions due to the wide operating range of the flare. Steam demand at a flare can vary for any number of reasons including:

 Compositional changes in vent gas – Saturated hydrocarbons such as methane and ethane require less steam for smokele ss combustion than olefinic hydrocarbons like propylene or butene. Non-hydrocarbons or inerts like hydrogen and nitrogen require little to no steam for smokeless combustion; however, the amounts present may influence a flare’s combus tion efficiency performance.

 Mixing – Well-mixed combustion reactants require less steam for smokeless performance.

 Steam Pressure at Tip Nozzles – Subsonic steam flow conditions, typical during standby operation, require more steam to produce the same smokeless capacity at given conditions. API 521 “Pressure-relieving and Depressuring Sy stems” is a design recommended practice issued by the American Petroleum Institute. API 521 suggests that a certain amount of steam is required for smokeless (Ringlemann 0) performance based upon the chemical composition of the hydrocarbons in the vent gas. Howeve r, the API 521 steam ratios are not related to combustion efficiency, but are utilized as a guide for the design of steam delivery systems for smoke suppression under worst-case design releas e scenarios. Proprietary commercial steam injection systems are of wi dely varying designs and ma y have differing degrees of effectiveness in smoke suppression than what is suggested by API 521.

One of the objectives of the Marathon Texas C ity test program was to determine if API 521 Table 11 (included below as Figur e 2.7-1) could also serve as an operational guide or target, which may provide adequate steam and smokeless operation. As the intent of API 521 Table 11 was to serve as a design guide under relief loads, it was unknown if the same ratios would hold true for low flow operation as for high fl ow operation. If so, then the amount of steam recommended by API 521 could serve as a “minim um” target, and represent the amount of steam necessary to provide smokeless flare ope ration under all operating ranges. A multiple above the minimum API 521 ratio could then be utilized to es tablish an upper bound preventing over-steaming. The mathematical re presentation of this concept is known as the “S/S521” Ratio, which represents the amount of actual steam applied in excess of the minimum recommended by API 521 Table 11.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-10 

## Figure 2.7-1: API 521 Table 11 Suggested Steam RatesPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-11 By plotting the API 521 predicted steam dema nd for saturates, olefins/aromatics, and diolefins based upon their molecular weight, a li near relationship emerged. Marathon’s test program uses the linear relationship of the olef in/aromatic curve as the basis representing the amount of minimum steam API 521 Table 11 would require to achieve smokeless combustion. This is represented mathematically as:

S 521 /VG = 0.0067 (MW) + 0.275



### API 521 Standard- Pressu re Relieving Systems Steam-to-Hydrocarbon Ratios

y = 0.0067x + 0.275

0.0 0.5 1.0 1.5 2.0

0 20 40 60 80 100 120 Molecular WeightSteam to Hydrocarbon Ratio (lb/lb) Parafins

Olefins/Aromatics

Di-Olefins



## Figure 2.7-2: API 521 Steam-to-Hydrocarbon Ratios

Another key parameter used in evaluating ove r-steaming is the net heating value of the combustion zone gas abbreviated as CZG in this report. The CZG is the Lower Heating Value, expressed in Btu per standard cubic foot (Btu/scf), of the mixture of gases introduced into the combustion zone of the fl are (i.e. at the flare tip). Th is value represents the resulting heat balance utilizing the inputs of vent gas, pilot gas, and steam. The CZG net heating value is a key parameter operators may use to optimize flare performance. The CZG is discussed further in Section 3.2.2.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-12 

### 2.7.2 Test Conditions The following test series (A through G) was conducted with a different test gas composition or flow rate. Within each test, the steam flow was varied to ach ieve a range of S/VG ratios. The rationale for each test series is as follows: Test A To simulate plant normal base load -- this is the typical flow condition for the flare and represents day-to-day operati on. Actual testing fo r this condition was conducted at three vent gas mass flow rate s: 1,900 lb/hr, 1,100 lb /hr and 800 lb/hr. These flow rates are analyzed separately in this report and are designated as A19, A11 and A8 respectively. A19 and A11 are typical historic vent gas flow rates as measured by the vent gas flow meter. A8 was achieved by minimizing normal refinery fuel gas sweep for the sole purpose of achieving low heating value conditions suitable for Test G. Test A8 conditions are not representative of normal operating conditions of the Texas City main flare. Test B To evaluate flare performance with a higher flow rate of hydrocarbons by adding gas (refinery fuel gas) that has a low S/VG ratio for smokeless operation. Test C To evaluate flare performance at flow rates similar to Test B with addition of a saturated gas (propane) that would re quire a higher S/VG ratio for smokeless operation than the gas added in Test B. Pr opane is also one of the materials most frequently used in independent-pilot scale test studies.
Test D Similar to Test C but add unsaturates (olefins) to evaluate performance at an even higher S/VG ratio needed for smokeless operation than added in Test C. Test E Same as Test D but with a higher flow rate (and thus higher unsaturate mass flow) to see the performance at higher flows for the unsaturate condition. Test F To evaluate performance when ope rating at higher levels of hydrogen than typically found in the base load. H ydrogen has been shown have exceptional combustion characteristics, but by nature has a low volumetric heat content (275 BTU/scf). Note that the base load may contain nominal amounts of hydrogen from 10 to 30% mole weight. Note that for the first part of this test, hydrogen was increased with the S/VG ratio held cons tant. For the last part of this test, a higher S/VG was used. Test G To evaluate performance with additio nal inerts (i.e. nitrogen) combined with hydrogen in the base load seeking an ove rall BTU/scf less than 300 (if possible) in vent gas or less than 200 in the co mbustion zone. In a ddition to the inert testing, this test provides a data point demonstrating the effect of the hydrogen benefit on a low BTU gas. With exception of Tests F and G, at each of th e conditions listed above several tests were performed at increasing steam rates. Steam wa s increased up to the po int of flame outage for each run. Once the flame was verified as ex tinguished, the test condition was halted. ForPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 2-13 each case, these are noted as “attempts” and are considered having zero combustion efficiency. Figures 2.7-3 and 2.7- 4 below show the range of S/ VG and S/HC ratios tested for each condition.



## Figure 2.7-3: S/VG vs. Condition

Figure 2.7-4: S/HC vs. ConditionPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-1 

# 3.0 SUMMARY OF RESULTS

3.1 Summary and Key Data Trends by Test Series Tests A through E were analyzed individually an d as a group to study the effect of steam on the combustion efficiency of a flare with hydrocarbon vent gases. Tests F and G were separately analyzed because they were primar ily performed to study the effect of hydrogen and inerts on the combustion efficiency of the flare. 

### 3.1.1 Combustion Efficiency with Increasing Steam Rates For each test series presented below, relati onships between combustion efficiency and at least two independent variables are presented: steam to vent gas ratio (S/VG) and actual steam to API 521 minimum (S/S521).

Condition A8 is not discussed since the sole purpo se of this condition was to prepare for Test Condition G. Condition A8 is not representative of normal flare operation for the Texas City main flare. Furthermore, the PFTIR data fo r Condition A8 is compromised due to adverse wind conditions on the day of testing and is not considered valid data.

3.1.1.1 Test Series A – Typical Base Load Conditions Test Series A represents typical base load conditions at the Texas City main flare. Both vent gas flow rates of 1,100 lb/hr (designated A11) and 1,900 lb/hr (designated A19) are grouped together on the figure below as they are repres entative of typical range of daily operation. The main flare header is partially swept with nitrogen as a sweep gas; therefore, this test series is a good comparator for increasing amounts of inerts in vent ga s as well as operating at a higher turndown factor. Detailed data ta bles for Test Series A19 are found in Section 5.2, and for Test Series A11 in Section 5.3. Aiming accuracy was greater for Test Series A11 than for A19. Five out of twelve data points in A19 were impacted by wind direction with respect to PFTIR view angle, whereas non e of the seventeen data points of A11 were impacted.

The point at which the flare was extinguished wa s much different from A Series to B Series conditions in terms of actual steam to vent gas ratios, but similar in te rms of total steam flow rate. For the A Series, the flare extinguished to a zero (0%) combusti on efficiency at S/VG ratios ranging from 3.5 to 7.5, or between 4,000 to 8,500 lb/hr total steam rate. The B TestPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-2 Series flame extinguished at ratios of 1.5 to 2, or between 5,700 to 8,300 lb/hr total steam rate. It is believed that a fa iled shaping ring on the flare tip, responsible for keeping the hot ball of gases together to fac ilitate combustion, contributed to early outages under certain wind directions.

Combustion Efficiency with Increasing Steam / Total Vent Gas Ratios Base Load Conditions (Runs A19, A11)

0.60 0.65 0.70 0.75 0.80 0.85 0.90 0.95 1.00

0.00 1.00 2.00 3.00 4.00 5.00 6.00 7.00 8.00 Actual Steam to Vent Gas (lb/lb)Combustion Efficiency (%)

Vent Gas: 1100 - 1900 lb/hr MW = 22 lb/lbmole

53 mol% THC 16 mol% H2 31 mol% N2

S521/VG = 0.45
Incipient SP = 1.45

Snuff S/VG max = 7.5



## Figure 3.1-1: CE vs. S/VG for Base Load Conditions

The A11 Test series reached the highest S/VG ra tios before extinguishment of any other test series conducted. Zooming in to a smaller X-ax is scale below in Figur e 3.1-2, it is seen that the combustion efficiency declines around a S/VG ratio of 2.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-3 Combustion Efficiency with Increasing Steam / Total Vent Gas Ratios Base Load Conditions (Runs A19, A11)

0.76 0.78 0.80 0.82 0.84 0.86 0.88 0.90 0.92 0.94 0.96 0.98 1.00

0.00 0.50 1.00 1.50 2.00 2.50 3.00 Actual Steam to Vent Gas (lb/lb)Combustion Efficiency (%)

Vent Gas: 1100 - 1900 lb/hr MW = 22 lb/lbmole

53 mol% THC 16 mol% H2 31 mol% N2

S521/VG = 0.45
Incipient SP = 1.45

Snuff S/VG max = 7.5



## Figure 3.1-2: X-Axis Zoom of Base Conditions, CE vs. S/VG

Visible emissions were observed during Test Se ries A from 0.9 – 1.5 S/VG, or in terms of S/S521 at ratios of 2.2 – 3.2. As noted in Fi gure 3.1-3, the A Series Test runs have the tightest operating envelope be tween visible emissions and over-steaming. An S/S521 operating envelope of 3.5 lb/lb to 4.6 lb/lb is required to k eep the flare between smoking and combustion efficiencies between 96% - 99%.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-4 Combustion Efficiency with Increasing Actual Steam / Steam via API 521 Ratios Base Load Conditions (Runs A19, A11)

0.82 0.84 0.86 0.88 0.90 0.92 0.94 0.96 0.98 1.00

0.00 1.00 2.00 3.00 4.00 5.00 6.00 7.00 8.00 9.00 10.00 S/S521 (lb/lb)Combustion Efficiency (%) Visible Emissions > 5.5

Vent Gas: 1100 - 1900 lb/hr MW = 22 lb/lbmole

53 mol% THC 16 mol% H2 31 mol% N2



## Figure 3.1-3: CE vs. S/S521 for Base Load Conditions

Variability in the combustion efficiency data is more pronounced in the A Series data than with other test conditions. This may be due to several factors:

1. Less stability of flare header composition – Since the test was conducted on an operating flare rather than a pilot test, th e ability to maintain steady conditions was challenging throughout the test. Th e A Series runs are normal base load conditions, which have some natural vari ation that is more pronounced at low total flow rates. Nitrogen content vari ed from 16 to 41 mol%, total hydrocarbon content varied from 42 to 66 mol%, while molecular weight stayed relatively stable at 21 to 22 lb/lb-mole.

2. Higher concentration of inerts – Due to the low gas flow rates, the nitrogen content was more pronounced in this series . Of all the hydrocar bon test series, the A Series had the smallest amount of to tal hydrocarbons in the vent gas flow.

3. PFTIR signal strength – Achievement of a strong, steady signal on the PFTIR was more difficult at low vent gas flow rates.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-5 4. PFTIR aiming accuracy – Several test condi tions were severely impacted by wind direction and ability of the PFTIR to vi ew a representative cr oss-section of the flare plume. This external influence is discussed in more detail in Section 3.2.2 below.

5. Turndown factor – The A series had the lowe st total waste gas flow rate and was, therefore, more affected by wind a nd other external influences.

6. Inadequate mixing - Visually, it was appare nt that the vent gas and steam was not well-mixed, as sections of the flare tip cross-section consisted of steam only rather than a mixture of vent gas and steam.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-6 3.1.1.2 Test Series B – Refinery Fuel Gas Test Series B was the most stable test series with the least degree of external influences to the test results. In this series, re finery fuel gas was added to th e flare header to approximately double normal base load flow conditions. Vent gas composition was held to a very constant level throughout this test series. Aiming accuracy of the PFTIR instrument was also consistently high, with very few conditions where PFTIR view angle was compromised by wind direction. Detailed data tables for th is test series are found in Section 5.5.
As can be seen in Figure 3.1-4 below, combustion efficiency remains relatively flat and then begins to decline rapidly ar ound 1.75 S/VG ratio. The flame became transparent at S/VG ratios above 1.9.

Combustion Efficiency with Increasing Steam / Total Vent Gas Ratios Refinery Fuel Gas (B Test Series)

0.82 0.84 0.86 0.88 0.90 0.92 0.94 0.96 0.98 1.00

0.00 0.20 0.40 0.60 0.80 1.00 1.20 1.40 1.60 1.80 2.00 Actual Steam to Vent Gas (lb/lb)Combustion Efficiency (%)

VG: 4200 lb/hr (Avg) MW = 21 lb/lbmole

65 mol% THC 18 mol% H2 17 mol% N2

S521/VG = 0.41
Incipient SP = 1.0

Snuff S/V max = 2.0



## Figure 3.1-4: Refinery Fuel Gas CE vs. S/VGPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-7 Visible emissions were observed during Test Se ries B from 0.9 – 1.5 S/VG, or in terms of S/S521 at ratios of 2.2 – 3.2. As noted in Fi gure 3.1-5, the B Series Test runs have an operating envelope between visible emissions and over-steaming in terms of S/S521 of 1.9 lb/lb to 4.3 lb/lb to keep the flare between smoking and combustion efficiencies between 96% - 99%.

Combustion Efficiency with Increasing Actual Steam / Steam via API 521 Ratios Refinery Fuel Gas (B Test Series)

0.82 0.84 0.86 0.88 0.90 0.92 0.94 0.96 0.98 1.00

0.00 0.50 1.00 1.50 2.00 2.50 3.00 3.50 4.00 4.50 5.00 S/S521 (lb/lb)Combustion Efficiency (%) Visible Emissions > 5.5

VG: 4200 lb/hr (Avg) MW = 21 lb/lbmole

65 mol% THC 18 mol% H2 17 mol% N2



## Figure 3.1-5: Refinery Fuel Gas S/ S521 with Combustion EfficiencyPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-8 3.1.1.3 Test Series C – Propane Propane was one of the primary materials of choice used during previous pilot-scale extractive sampling performance tests of flares. Propane is readily avai lable on the market in pure liquefied petroleum gas (LPG) form, and therefore used routinely as the hydrocarbon species to benchmark flare performance against. Detailed data tables for this test series are found in Section 5.6.

Flare combustion efficiency results remained flat until flame extinguishment for the propane test series. The combustion effi ciency did not decline with increasing steam rates as seen in the other test materials. The incipient smoke point occurred at a 1.0 S/VG ratio and the flame was extinguished at 1.2 to 1.7 S/VG ratio with a total st eam flow ranging from 7,000 to 10,000 lb/hr.

Combustion Efficiency with Increasing Steam / Total Vent Gas Ratios Propane (C Test Series)

0.82 0.84 0.86 0.88 0.90 0.92 0.94 0.96 0.98 1.00

0.00 0.20 0.40 0.60 0.80 1.00 1.20 Actual Steam to Vent Gas (lb/lb)Combustion Efficiency (%)

VG: 5250 lb/hr (Avg) MW = 36 lb/lbmole

77 mol% THC

7 mol% H2 16 mol% N2

S521/VG = 0.52
Incipient SP = 1.0

Snuff S/VG max = 1.7



## Figure 3.1-6: Propane Test Series CE vs. S/VGPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-9 Visible emissions were observed during Test Se ries C from 0.3 – 0.5 S/VG, or in terms of S/S521 at ratios of 0.6 – 0.96 lb/lb. As noted in Figure 3.1-7, the C Series Test runs have an operating envelope between visible emissions and over-steaming in terms of S/S521 of 1.0 lb/lb to 2.5 lb/lb is required to keep the fl are between smoking and combustion efficiencies above 98%.

It is believed that the flare tip shaping ri ng damage caused premature extinguishments of the flare within this Test Series. When wind di rection pushed the flame toward the area of the shaping steam line leak, the fl are would shear off and go out.

Combustion Efficiency with Increasing Actual Steam / Steam via API 521 Ratio Propane (C Test Series)

0.82 0.84 0.86 0.88 0.90 0.92 0.94 0.96 0.98 1.00

0.00 0.50 1.00 1.50 2.00 2.50 Actual Steam to API 521 Steam (S/S521) (lb/lb)Combustion Efficiency (%) Visible Emissions > 5.5

VG: 5250 lb/hr (Avg) MW = 36 lb/lbmole

77 mol% THC

7 mol% H2 16 mol% N2



## Figure 3.1-7: Propane Test Series CE vs. S/S521

It should also be noted that for generally all Test C runs, the amount of carbon dioxide detected by the PFTIR (in units of concen tration x pathlength) was unusually high, and exceeded predictions of expected carbon di oxide present based upon a gross heat and material balance. As the quantity of carbon di oxide drives the combustion efficiency result, it is expected that this may have had an influence on the flat nature of the propane performance test curve.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-10 3.1.1.4 Test Series D & E – Propylene/Butylene Olefins Olefins require more steam for smokeless com bustion due to unsaturat ed hydrocarbons. The primary purpose of Test Series D and E was to evaluate the incipient smoke point at turndown in comparison to the 0.55 lb steam per lb hydrocarbon predicted by API 521 Table 11. In addition, the 1983 CMA study trend that is primarily refere nced when discussing flare over-steaming was conducted on propylene. It predicted a decline in flare combustion efficiency at steam to hydrocarbon ratios above 3. 5 lb/lb. As noted below, the lower values achieved in the Marathon Texas City flare test could possibly be due to testing under a lower flow condition, or testing with a remote sensing technology versus extractive sampling of the composite flare plume.

Combustion Efficiency with Increasing Steam / Total Vent Gas Ratios Olefin Test Series (D and E Test Series)

0.82 0.84 0.86 0.88 0.90 0.92 0.94 0.96 0.98 1.00

0.00 0.50 1.00 1.50 2.00 2.50 Actual Steam to Vent Gas (lb/lb)Combustion Efficiency (%)

D (Low Flow) E (Hi Flow) E Series VG: 9030 lb/hr (Avg) MW = 43 lb/lbmole

87 mol% THC

3 mol% H2 10 mol% N2

S521/VG = 0.56
Incipient SP = 0.7

Snuff S/VGmax = 1.4 D Series VG: 4200 lb/hr (Avg) MW = 39 lb/lbmole

77 mol% THC

6 mol% H2 17 mol% N2

S521/VG = 0.53
Incipient SP = 1.3

Snuff S/VG max = 2.1



## Figure 3.1-8: Olefin Test Series CE vs. S/VGPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-11 Visible emissions were observed during Test Se ries D & E from 0.4 – 0.9 S/VG. Test Series D was tested at a lower mass loading (approxi mately 4200 lb/hr vent gas flow rate), and resulted in an S/S521 operating envelope between visible emissi ons and over-steaming between 1.0 lb/lb to 2.1 lb/lb to keep the flar e between smoking and combustion efficiencies above 98% as noted in Figure 3.1- 9 below. Test Series E, tested at approximately 9030 lb/hr vent gas flow rate, resulted in an S/S 521 operating envelope between 1.1 and 2.1 lb/lb.

Combustion Efficiency with Increasing Steam / Total Vent Gas Ratios Olefin Test Series (D and E Test Series)

0.82 0.84 0.86 0.88 0.90 0.92 0.94 0.96 0.98 1.00 1.02

0.00 0.50 1.00 1.50 2.00 2.50 3.00 3.50 4.00 4.50 Actual Steam to API 521 Predicted Steam (S/S521) (lb/lb)Combustion Efficiency (%)

D (Low Flow) E (Hi Flow) E Series VG: 9030 lb/he (Avg) MW = 43 lb/lbmole

87 mol% THC

3 mol% H2 10 mol% N2 D Series VG: 4200 lb/hr (Avg) MW = 39 lb/lbmole

77 mol% THC

6 mol% H2 17 mol% N2 D Visible Emissions > 5.5

E Visible Emissions > 5.5



## Figure 3.1-9: Olefin Test Series CE vs. S/S521Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-12 

### 3.1.2 Observed Impacts of Hydrogen
Conditions F and G were intended to evaluate whether the hydrogen content of the vent gas had an effect on combustion efficiency. With both Test Series F and G, an issue with the sampling technique was identified upon review of the infrared video recordings from the PFTIR aiming camera. Tests conducted on two part icular days of the test series, September 23 and 24, experienced wind conditions out of the north-northeast, which pushed the flame plume direction directly away from the PFTIR field of view. During these days, the PFTIR was not able to sample the plume cross-sec tion, but was only able to sample the boundary layer surrounding the flame perimeter closest to the PFTIR instrument’s line of sight.

The boundary layer of the flame perimeter may or may not be consistent with the results observed from a plume cross-section. There is not enough information to conclusively make an assertion either way. Howeve r, it could be theorized that, although the absolute values of combustion efficiency may potentially not be the same, the trend behavior of the flame boundary layer and plume cross-section ma y directionally track together.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-13 3.1.2.1 Test Series F – Increasing Hydrogen Content For Test Series F, the influence of increasing hydrogen content was tested as shown in Figure 3.1-10. For this condition, steam rates were he ld relatively constant at minimum conditions, with the exception of one run at 81 mol % hydrogen, in which steam rates were increased to a 4.0 S/VG ratio or an 8.0 S/HC ratio. Hydr ogen compositions above 30 mol% consistently produce high combustion efficienci es regardless of steam rate.

In a petroleum refinery, there may be relief and/or operational scenarios that would divert highly concentrated hydrogen to a flare. For th ese cases, hydrogen is not expected to have a negative impact on combustion efficiency, but result in consistently high efficiencies regardless of steam rate. As noted above, all data presented below as well as in Section 5 were impacted by PFTIR view angle with respec t to wind direction, therefore are reported for completeness, but should be limited in interp retation to general trend behavior only.



## Figure 3.1-10: Combustion Effi ciency as Hydrogen Content IncreasesPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-14 3.1.2.2 Test Series G – Increasing Nitrogen Content Test Series G was designed to test whether hydro gen and nitrogen mixtures that create a vent gas net heating value of less than 300 BTU/sc f would achieve high combustion efficiencies. Operating in this manner is not a normal condition for the Texas City main flare and required many operational changes. Sources of refinery fuel gas used to sweep flare headers were turned off and additional nitrogen purge lines we re added to the flare. Hydrogen was also added in increments until the net heating value of the vent gas began to change. Combustion efficiency appears to decline as the net heating value of vent gas drops below 300 BTU/scf. As noted above, all data presented below as well as in Section 5 were impacted by PFTIR view angle with respect to wi nd direction, therefore are report ed for completeness, but should be limited in interpretation to general trend behavior only.



## Figure 3.1-11: Combustion Effi ciency with Decreasing NHV VGPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-15 

### 3.2 Summary and Key Data Tr ends of Whole Data Set 3.2.1 Composite of All Hydrocarbons Tested When comparing the combustion efficiency curve of all conditions tested during the Marathon Texas City test program, it is intere sting to note that an overall trend emerges as shown in Figure 3.2-1.



## Figure 3.2-1: Combustion Efficien cy vs. S/VG Composite of All Materials Tested

For some test conditions, it was not possible to achieve an S/VG ratio less than 1.0 due to the minimum steam requirements at the flare tip. A certain amount of steam is required to be injected into the tip to maintain mechanical integrity and preserve the reliability of the tip. When the flare was being operated at mini mum cooling steam only, an “M” denotes the condition on the chart above. Minimum cooling steam rates are set by the manufacturer and are specific for each flare tip design. For the base case Te st Series A19 and A11, the minimum steam rates were reached at S/VG ratios of 0.9 and 1.4 lb steam per lb vent gas, respectively.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-16 As steam cannot be reduced any further, the on ly mechanism to reduce the S/VG ratio is to increase the denominator (VG) and flare additiona l gas. The test program showed that even for base case conditions, the flare can be ope rated at high combusti on efficiencies at minimum steam rates. The operating window under these conditions may be small between the point of visible emissions and the deflect ion point on combustion efficiency; however, minimum steam rates (or rates slightly above minimum) achieved good combustion and no visible emissions for Marathon’s Texas City main flare.

Figure 3.2-2 shows the relationship between com bustion efficiency and S/S521 ratio for all components tested.



## Figure 3.2-2: Combustion Efficien cy vs. S/S521 Composite of All Materials TestedPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-17 

### 3.2.2 Combustion Zone Gas Net Heating Value The Combustion Zone Gas (CZG) is located at the mixing zone at the flare tip. It represents the resulting net heating valu e of the mixture containing a ll materials under combustion, and is the resultant heat balance of all inputs to the mixing zone and incl udes the vent gas flow, vent gas net heating value, pilo t flow and heating value, as we ll as the total steam flow. As steam does not have a heat of combustion, its corresponding heat content is zero. CZG is represented in units of BTU/scf. The detailed calculation is presented in Appendix A.1. It has been suggested that net heating value of the mixture can reveal additional information about expected combustion efficiency and may se rve as a key performan ce indicator of flare combustion.

One benefit of the CZG is that it is the only variable that accounts for all components under control of the flare operator. As a result, the CZG can be adju sted based upon more than one independent action. If too low, the CZG can be raised by reducing steam, changing the flare header composition by reducing nitrogen and/ or adding a high-heating content hydrocarbon, or increasing total vent gas. No other key performance indicator has this many degrees of freedom under which to operate the flare.
As seen in Figure 3.2-3 below, CZG appears to have a strong correlation to flare combustion efficiency. CZG does not appear to be heavily influenced by material molecular weight or composition. In general, the deflection point of the CZG curve appears to occur just around 225 - 240 BTU/scf.



## Figure 3.2-3: CZG NHV vs. CE for All Materials TestedPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-18 

### 3.2.3 Visible Emissions and Combustion Efficiency Visible emissions play a key ro le in environmental compliance for refinery flares. New Source Performance Standards (“NSPS”) and Maximum Achievable Control Technology (“MACT”) standards 3 contain time limits for allowable visi ble emissions or “smoke”, as any five minutes in a two-hour period. As such, the point at which visible emissions begin to form is the primary basis for the lower operating bound.

A visible emissions scale was de veloped and implemented as pa rt of the test program in order to quantitatively grade the visual flame characteristics. The s cale is shown in Table 3.2-1. The incipient smoke point was designated as the number 5 (the center of the scale), and represents the point at which the flare flam e displays a “marbley” texture, indicative of small carbon soot particles forming in the fl ame zone but quickly completing the combustion process. No visible soot particles were present outside of the flame boundary.
Flame ratings above 5 indicate an increasing amount of visible emissions extending beyond the flame boundary observed by increasing amounts of a trailing smoke plume. Flame ratings less than 5 indicate a visible flame decr easing in intensity until it becomes invisible. Ratings of 4 to 2 indicated a visible flame and a rating of 1 indicated a transparent or invisible flame. A flame rati ng of 0 indicated that the flar e was extinguished with steam visually present. 

## Table 3.2-1: Visual Flame Rating Descriptions
Flame Rating Flame Characteristic 0 Steam plume 1 Transparent 2 Mostly transparent, with occasional yellow flame 3 Mostly yellow flame, with occasional transparency 4 Yellow to orange flame.

5 Orange flame with some dark areas in the flame. (Incipient smoke point) 6 Orange flame with light smoke trail

7 Clear steam at the flare tip, with an orange flame and a light smoke trail 8 Orange flame with dark smoke trail leaving the flame 9 Orange flame with heavy dark smoke trail leaving the flame 10 Billowing black smoke

3 Code of Federal Regulations citations - 40 CFR 60.18 and 40 CFR 63.11Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-19 A flame’s visual characteristics appear to ha ve some influence on combustion efficiency. The most important correlation being that efficien cy declines rapidly as the flame starts to become transparent, with the exception of hi gh hydrogen-containing vent gas. See Figure 3.2-4.



## Figure 3.2-4: Combustion Efficiency vs. Visible Emissions Ratings for All Materials TestedPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-20 

### 3.2.4 Comparisons to API 521 Table 11 API 521 Table 11 presents design recommendati ons for steam to hydrocarbon ratios that result in smokeless combustion under relief load s cenarios. It has been suggested that Table 11 could also potentially serve as an operating guideline to develop lower operating targets for steam to hydrocarbon ratios during turndown operation of flare systems as well. One of the objectives of this test program was to eval uate whether the ratios in Table 11 could serve as a guide, that is, whether the guidance from design conditions at re lief conditions would also apply equally at turndown.

In Figure 3.2-5, the green diam onds represent the point of in cipient smoke for the various molecular weights of vent gas tested.



## Figure 3.2-5: Incipient Smoke Point vs. API 521 Table 11 Predictions

To the left of the above figure, Test Series A (Base Conditions) and B (Refinery Fuel Gas) are grouped together due to the similarity in molecular weights, ranging from 21 to 23 lb/lbmole, with predictions from API 521 ranging from 0.41 to 0.43 lb steam per lb vent gas.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-21 Similarly, Test Series C (Propane ) and D and E (Olefin Series) ar e grouped to the right of the figure having molecular weights between 37 to 42 lb/lbmole.

In all cases, the degree of closeness between the actual steam-to-vent gas achieved versus the value that API 521 predicted (S/S521 approachi ng 1.0) is directly pr oportional to the mass load to the flare as shown below in Figure 3.2- 6. For Test Series A, the flare was operating at a much lower mass load (i.e. higher turndown factor) than for Test Series C, D, and E. Therefore, the amount of steam needed for smokeless combustion was much higher, as compared to the higher mass loading tests. It is believed this phenomenon is likely due to inadequate mixing at the flare tip, and a cer tain amount of steam being present but not engaged within flame combustion.



## Figure 3.2-6: Incipient Smoke Po int Varies with Mass LoadPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-22 In summary, under high turndown conditions, the amount of steam needed for smokeless combustion was much greater than the value AP I 521 would have predicted. This could have been influenced by seve ral factors, including:

1. Mixing – lower vent gas rates create less turbulence in the mixing zone making it harder for the motive force gene rated by steam to get air intimately mixed with the vent gas. 2. Non-contact between steam and vent ga s – void areas between vent gas and steam resulting in not only no mixi ng but no contact between the two materials. 3. Turndown – runs with lower turndown f actors (higher vent gas flows) were closer to API 521 predictions than ones at lower vent gas flows.



## Table 3.2-2: Runs with Visible Emissions Ratings 4.5 – 5.5

Test Series Run
A11 1-1 A19 1-2. 3-1, 3-2

B 1-3, 2-3, 3-1, 3-3, 4-1, 4-2 C 2-2, 2-3 D 5-1 E 2-3Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-23 

### 3.3 Factors Influencing Test Results 3.3.1 Mechanical Damage of Flare Tip During the performance test of the Texas City main flare, mechanical damage was observed in two distinct areas, which are suspected of causing the premature flame extinguishment observed during the performance test. One ar ea was associated with the failure of the shaping steam ring, while the other was a steam leak observed around the muffler area. The most significant of these was the shaping steam ring failure.



## Figure 3.3-1: Steam Leak at Shaping Steam Ring

The shaping steam ring is connected to the lo wer steam ring, and injects a small amount of steam toward the center of the flare tip at an angle determined by the manufacturer. This steam is provided to supply a certain amount of pressure balance, that is, it shapes the flame from a concentric circle whose main function is to keep the hot ball of combustion gases together. The shaping steam is an annular ring, supplied from the lower steam ring at one location.

The shaping steam ring failure caused the shapin g pressure to be unbalanced, with one side of the concentric ring starved for steam. As the wind blew to wards the area of unbalance, the flame sheared off of the flare tip and was extingu ished. It is estimated that approximately 50 to 100 lb/hr of steam was leak ing from the shaping steam ri ng and muffler area during the test, and was not introduced into the flame combustion zone, although it was measured and accounted for in the total steam meter. At higher hydrocarbon mass flow rates (and thusPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-24 higher steam rates) it is thought th at the increased steam from the leak also interfered with the nearby pilot which may have been an addition al contributor to premature flame outages.

The shaping steam leak was on the east side of the flare; therefore, winds blowing towards the East / South East quadrant as noted in red in Figure 3.3-2 below exerted pressure towards the area of unbalance. Day to day wind roses for each day of testing are shown in Figure 3.3- 7. Winds blew towards the shaping steam l eak on 9/15, 9/16, 9/17, and 9/18. At least one series of runs were conducted on the main Te st Series for each of these days (A19, A11, B, C, D, and E), therefore it is suspected that the shaping steam leak may have caused premature flare outages for each of the Test Series.



## Figure 3.3-2: Wind Direction Impac ts to Flare Shaping Steam Leak

It should be noted that as the steam rates were increased during each test series, the flare was being forced into operating at an over-steamed condition near the instability point. This is neither a typical nor a normal operating regime . The requirements of the Clean Air Act 114 Request received by Marathon for this performan ce test stated that each test progression could only be stopped when the combustion effi ciency reached 60% or for other safety considerations. Not only is flame outage a safety concern, but each flame outage is considered to be zero (0 %) combustion efficiency.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-25 

### 3.3.2 Wind Effects During this test program, wind speed and di rection were recorded on a minute-by-minute basis from a meteorological stat ion located on-site at the Texas City refinery. These data are shown on the data summary tables in Section 5. The flare height (150 ft.) is much greater than the height of the met station (about 25 ft.) and winds at the flare tip are expected to be higher than those recorded.

Wind speed and direction play an important role in the quality of data collected by the PFTIR method. The alignment of the flare plume with the PFTIR must be optimal to have the best chance of obtaining a representative sample. The best opportunity for the PFTIR to obtain a representative sample of the flare plume is when:

1) The flame is buoyant and the plume is rising more or less vertically above the flame,

or 2) The flame is “bent over” by the wind and the plume is roughly perpendicular to the PFTIR field of view (see Figure 3.3-3)



## Figure 3.3-3: Example of Good Plume Alignment with PFTIR

The worst alignment occurs when the flame and plume are bent by the wind and blowing directly away from the PFTIR (see Figure 3.3-4). When this occurs, the flare blocks the view of the plume from the PFTIR, making it difficu lt or impossible to obt ain a representative sample (or even any sample) of the plume.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-26 

## Figure 3.3-4: Example of Poor Plume Alignment with PFTIR

This effect can be seen visually on the PFTIR aiming camera, as shown in Figure 3.3-5. The red square shows the PFTIR field of view. Image (a) shows good plume alignment. In image (b), the flame and plume are bent over and hidden behind the flare. In order to sample any of the plume, the PFTIR must be aimed very close to the flame re sulting in invalid data.

a b


## Figure 3.3-5: Comparative View from PFTIR Aiming Camera

During the entire test period, wind speed was 5 to 10 mph or more. For most of the test period, the flame was bent by the wind. During th e first week of testing, winds were in a favorable direction for testing. However, during the second week, winds shifted to an unfavorable direction and much of the data collected during th is time should be considered invalid.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-27 A data flagging algorithm was developed to in dicate which data points were collected when winds were unfavorable. This algorithm was implemented on the spreadsheets that are included in the electronic submittal for this project.
This algorithm takes both wind speed and direction into account. It firs t tests wind direction. If wind direction is between 165 and 225 degrees, a data flag is set to FALSE indicating a potentially suspect data point. This range is 30 degrees on eith er side of the PFTIR viewing axis. This is illustrated in Figure 3.3-6.



## Figure 3.3-6: Wind Flagging Algorithm

A value of 30 degrees was chosen because the da ta flagged using this value corresponds well to the data flagged during the video review (see Section 3.3.3) as being suspect due to aiming issues. Aiming and wind effects are closely related since it is diffi cult or impossible to properly aim the PFTIR when winds are blowing within this range.
Next, wind speed was tested. If the wind speed exceeds 5 mph, a second data flag is set to FALSE. A value of 5 mph was used ba sed upon observations of how much wind was required to bend the flame. This value is de pendent on flare tip velocity, but 5 mph was a reasonable average for the test period.

If both the wind direction and wind speed flags are set to FALSE, the data point is flagged as being potentially invalid.
Day by day wind roses are shown in Figure 3.3-7.Performance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 3-28Figure 3.3-7: Day by Day Wind RosesPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-29 

### 3.3.3 PFTIR Aiming Issues Proper aiming of the PFTIR is critical to acqui sition of valid data. Ideally, as discussed above, the PFTIR should be aimed near the cente rline of the flare plume about one to two flame lengths away from the flame tip. At th is distance, it is believed that all thermal destruction reactions have been completed. However, the plume is a moving target. Therefore, in an attempt to maintain the aim of the PFTIR at this optimal sampling point, the instrument must be continually adjusted by th e operator. This task becomes increasingly difficult if the wind is continually shifting a nd it becomes impossible if the wind is blowing the plume directly behind the flare (See Sec tion 3.3.2). Successful aiming is also highly dependent on the skill of the PFTIR operator.

The version of the PFTIR used for the Mara thon test program em ployed two cranks for aiming – one crank was used for tilting the in strument up and down and the other for panning left and right. Continually cranking the inst rument proved quite tiring and several operators were used during the test period.
In order to evaluate aiming accuracy for each te st run, a panel of four individuals reviewed video from the PFTIR aiming camera for each test run. Each panelist scored aiming accuracy for each run on the following scale.
1 – The PFTIR was aimed properl y less than 20% of the time.
2 – The PFTIR was aimed properly between 20% and 50% of the time.
3 – The PFTIR was aimed properly between 50% and 80% of the time.
4 – The PFTIR was aimed properly more than 80% of the time.
The scores from each panelist were averaged for an overall test run score. These scores are presented in Section 5.1 Data Su mmary Tables. In these tables , the test runs are color-coded based on the video score.
It is worth noting that lower video scores corr elate well with the days in which the wind was blowing the plume directly away from the PFTIR.
Another aiming issue examined was the impact of aiming distance from the flame tip. As stated above, the aiming objective was to keep the PFTIR aimed at a point one flame length from the tip of the flame. To test the sensit ivity of this positioning, a test was conducted with the PFTIR initially aimed at the flame tip then moving in steps away from it. This test was conducted on 09/18 from 12:29 to 12:49 during the Condition D test runs. Images from each test taken from the PFTIR aiming camera are show n in Figure 3.3-8 below. The red square is the PFTIR field of view, that is, the spot on the plume being sampled by the PFTIR.Performance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 3-30Figure 3.3-8: Aiming Test: VideoStills from Each Test PointPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-31 The results of this test are shown in the Figur es below. The PFTIR was not able to produce usable data at the flame tip; ther efore, data from this position are not included in the analysis below.
Figures 3.3-9 and 3.3-10 show concentrati on of the plume components at 0.5, 1.0 and 2.0 flame lengths from the flame tip. At two flame lengths, it became difficult for the PFTIR operator to track the plume.



### Aiming Test: Measured Components

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000

0.5 0.5 0.5 0.5 0.5 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 2.0 2.0 2.0 Flame Lengths From Flame TipCO2(ppm-meters)

0 2,000 4,000 6,000 8,000 10,000 12,000 14,000CO and THC (ppm-meters)

CO2
CO
THC



## Figure 3.3-9: Aiming Test: Measured Components

Aiming Test: Measured Components - Zoomed

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000 50,000

0.5 0.5 0.5 0.5 0.5 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 2.0 2.0 2.0 Flame Lengths From Flame TipCO2(ppm-meters)

0 100 200 300 400 500 600 700 800 900 1,000CO and THC (ppm-meters)

CO2
CO
THC



## Figure 3.3-10: Aiming Test: Me asured Components - ZoomedPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-32 The data from the 0.5 flame length test indicate th at absorbance is too st rong at this point and cannot be reliably used to quan tify component concentrations. At this point, the absorption features in the spectra are ve ry non-linear in absorbance. At one flame length, the data becomes less extreme and more useful for analys is. One would expect that, as the PFTIR is moved farther from the flame, the compone nt concentrations would decrease due to increasing dilution of the flare plume. It is interesting to note here that when the PFTIR moved from 1 to 2 flame lengths, con centrations remained roughly the same.

Figure 3.3-10 below shows the CO 2 to CO and CO 2 to THC ratios at each distance.



## Aiming Test: CO 2 

## /CO and CO 2 

## /THC Ratios

0 50 100 150 200 250 300

0.5 0.5 0.5 0.5 0.5 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 2.0 2.0 2.0 Flame Lengths From Flame TipRatio CO2/CO CO2/THC



## Figure 3.3-11: Aiming Test: CO 2 

## /CO and CO 2 

## /THC Ratios

The significance of component ratios is more fully explained in Section 3.3.4.2 below. However, for the purpose of inte rpreting this figure, it is important to understand that ideally, even though the absolute concentrations of each component may vary over a wide range, the ratios should be relatively constant given the sa me flare operating conditions. It can be seen in this figure that the ratios were highly variable. For ex ample, during the one flame length test, the range of the CO 2 /CO ratio varied from about 100:1 to about 250:1. This is a much larger range than expected.
Figure 3.3-11 shows the combustion efficienci es at each distance. Figures 3.3-12 through 3.3-15 show flare operating parame ters during the aiming test.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-33 

## Aiming Test: Combustion Efficiency

94% 95% 96% 97% 98% 99% 100%

0.5 0.5 0.5 0.5 0.5 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 2.0 2.0 2.0 Flame Lengths From Flame TipCombustion Efficiency

CE



## Figure 3.3-12: Aiming Test: Combustion Efficiency



## Aiming Test: Steam Ratios

0.90 1.00 1.10 1.20 1.30 1.40 1.50 1.60

0.5 0.5 0.5 0.5 0.5 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 2.0 2.0 2.0 Flame Lengths From Flame TipRatio

S/VG S/HC



## Figure 3.3-13: Aiming Test: Steam RatiosPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-34 

## Aiming Test: Flow and FGCZ

0 1,000 2,000 3,000 4,000 5,000

0.5 0.5 0.5 0.5 0.5 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 2.0 2.0 2.0 Flame Lengths From Flame Tiplb/hr (flows) Btu/scf (FGCZ)

VG Flow
CZG
HC Flow
N2 Flow



## Figure 3.3-14: Aiming Test: Flow and CZG



## Aiming Test: VG Composition

0 20 40 60 80 100

0.5 0.5 0.5 0.5 0.5 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 2.0 2.0 2.0 Flame Lengths From Flame TipMole Percent (%)

H2
THC
N2



## Figure 3.3-15: Aiming Test: VG CompositionPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-35 

### 3.3.4 Overall Test Variability When assessing overall data uncertainty for this project, it is impor tant to distinguish uncertainty related to precision (repeatabilit y) issues and uncertainty related to bias (“closeness to truth”) issues. This test progr am was designed to generate data to evaluate precision of test results. Due to the nature of this open-path technique, definitive assessments of bias are difficult in the fi eld. The “hot-cell” calibration te sts described in Section 3.3.4.3 below attempt to define and correct some of th e potential biases associated with the PFTIR methodology. However, a definitive assessment of the bias of this technique must be accomplished through a blind validation study. Th is study has not yet been performed for this method.

3.3.4.1 PFTIR Precision Assessment This test program was designed to assess data precision in two ways. First, each test condition was to run in triplicate. An estimat e of precision could then be made by comparing the results from the three runs (run to run vari ation). At least one run for each test condition was to be conducted on a different day (day to day variation) in orde r to take into account longer term variation in meteorological fact ors, flare operation, and PFTIR operation.

During the test program, some additional tests we re added in order to improve data resolution in certain operating areas (e.g. ne ar the flare snuff point). Th ese tests were not conducted in triplicate.

Figure 3.3-16 shows the variability of the data co llected for each run in each test condition. The data are presented as box plots. Each box shows the boundaries of the 25 th and 75 th percentiles and contains, therefor e, 50% of the data for that ru n. The line in the middle of the box indicates the median value of the data. Th e average is shown by a short black line. The “whiskers” at the top and botto m of the box show the range of the data. The data are shown grouped by replicate (rep) for each test condition. Note that flare operating conditions for each replicate are reproduced as closely as possible.Performance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 3-36Condition A19 Condition A11 Condition A8Condition B Condition C Condition DCondition E Condition F Condition GFigure 3.3-16: Run by Run Data Variability Analysis (same scales)Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-37 In addition to the triplicate runs , a longer term measure of test data variab ility was conducted. At least once each day (except for the last day of testing on 09/24/09), a test was conducted at the same set of conditions – Condition B with an SVG of 1.00 4 . This series of test runs is referred to as the Long Term Stability (LTS) test . These data show test method repeatability over a range of meteorological c onditions and other factors. Th e results of the LTS test are discussed in more detail in Section 5.11

Figure 3.3-17 shows a summary of the LTS data as box plots. The blue line connects the average (mean) of each test run.



## Figure 3.3-17: Long Term Stab ility Run by Run Variability

Figure 3.3-18 shows a confidence interval determ ination for the combustion efficiency data from each of the 8 LTS runs. The value for Run 2-8 is shown in red because all of the data points in that run are flagged by the wind speed and direction al gorithm. The data below are shown both with and without this run. Also shown is a determinati on of the upper and lower confidence bounds under three assumptions.

4 An initial LTS run was conducted on 09/15 using propan e. However, this proved not to be an acceptable condition due to flare smoking and recovery time after the test. This initial test run is not included in any LTS summary data.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-38 

## Figure 3.3-18: Confidence Interval Determination from LTS Data

The data in each row are as follows:

Avg = Average combustion efficiency (CE) SD = Sample standard deviation of the CE RSD = Relative standard devi ation (SD/Avg) of the CE N = Number of data points for each data set % Prob = The chosen probability level to de termine the confidence intervals (99% or 95%) TINV = The coverage factor for the confidence interval calculated from the Student’s t-distribution Factor = The calculated c onfidence limit based on the crit eria above (This is added to and subtracted from the average to arrive at the confidence interval.) LCL = The lower confiden ce limit (Avg – Factor) UCL = The upper confidence limit (Avg + Factor)

Assumption A uses a 99% confidence level. Assumption B uses a 95% confidence level. Assumption C uses a 95% confidence level a nd assumes only three runs are conducted with the data having the same pattern of variation. This assumption is shown since three runs are typical for air emission testing on stacks. Note th at the calculated confidence interval is for the average. Individual runs will have a greater variation.

This analysis shows that the measured co mbustion efficiency under identical process conditions may vary for a flare by about +/- 1.5%.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-39 3.3.4.2 Dilution Assumption Because the flare plume is continually moving dur ing the test, it is impossible to collect all spectra at exactly the same point in the plume. As the gases in the plume move farther from the combustion zone, they are increasingly dilute d by the ambient air. This means that the absolute concentration of the plume component s will vary based solely on where in the plume the PFTIR is aimed and collecting data.

Since the calculation of combustion effi ciency is based on the ratio of CO 2 to total carbon in the plume (i.e. the sum of CO 2 , CO, and THC), it is the ratios of the components that matter rather than their absolute concentration. Ther efore, even though absolute concentrations vary at different measurement points due to dilution, the ratios shou ld be the same since, in theory, all plume components are diluted eq ually at any given sampling point.

The data collected during this test, however, show differing degrees of variation in the CO 2 to CO ratio at different da ta points collected under the same operating conditions. For example, Figure 3.3-19 shows the ratio variability for the LTS test runs.



## Figure 3.3-19: CO 2 

## /CO Ratio Comparison on LTS RunsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-40 

### 3.3.5 PFTIR Calibration

3.3.5.1 Radiance Calibrations Radiance calibrations were conducted at least twice each day with a blackbody IR source located at roughly the same distan ce from the PFTIR as the flare.

0.000 0.001 0.002 0.003 0.004 0.005

500 1000 1500 2000 2500 3000Calibration Factor

Wavenumbers (cm -1 ) Ave Cal
9/15/2009
9/16/2009
09/21/09



## Figure 3.3-20: PFTIR Radiance Calibrations

Calibration factors measured on 09/15, 09/16 and 09/21 and the average calibration factor are shown. The variations between 1500 and 2000 cm -1 are due to the background water. Analysis is not done in that region.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-41 3.3.5.2 Hot Cell Calibration In order to challenge the PFTIR with known concentrations of ga s, hot cell calibrations were performed in laboratory setting after the conclusion of the Texa s City performance test. In this calibration, a known mixture of CO 2 , CO, and methane are metered by mass flow controllers into a heated cell. This cell is placed at the focal point of the collimator used for the radiance and other calibrations and which is located at a distance from the PFTIR. The PFTIR then collects data from the cell and th e data is reduced to produce a concentration result. This result is then compared to the known value of the calibra tion gas concentration. The hot cell calibration was performed at six different concentrations.
From this data, calibration curves were pr oduced as shown in Figures 3.3-21 through 3.3-23 below. The red lines indicate perfect ag reement between the known and measured concentrations and are shown to provide an indication of the magnitude of the correction required for each component.



## Figure 3.3-21: PFTIR Hot Cell Calibration Curve – CO 2Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-42 

## Figure 3.3-22: PFTIR Hot Cell Calibration Curve - CO

Figure 3.3-23: PFTIR Hot Cell Calibration Curve – Methane

These calibration equations were integrated into the analysis software and applied to the PFTIR raw data to produce the final results.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-43 

### 3.3.6 Methane and Heavy Hydrocarbons The choice of which regions of the infrared spectrum to use for analysis of a specific compound depends in large part on the sensitivity of the PFTIR detector for a given region. Methane has spectroscopic features at about 3000 and 1360 wavenumbers that can be used for quantification. Because the Mercury-Cadmiu m-Telluride (MCT) detector used in the PFTIR for this study has low sensitivity in the 3000 wavenumber region, the 1360 wavenumber region was chosen for methane analysis.
The heavier hydrocarbons (C5+) exhibit a large, indistinct feature also at about 3000 wavenumbers. While analysis of the C5+ comp ounds was attempted in this region, the signal to noise ratio was inadequate for reliable qu antification. Unlike methane, however, there are no alternative regions that can be used for C5+ analysis. Therefore, C5+ compounds are not included in the determination of To tal Hydrocarbons in this report.



### 3.3.7 PFTIR Component Errors In the raw data provided by the PFTIR, an error value is provided for each component measured by the PFTIR. This error value is th e residual calculated from fitting the measured spectra to the reference spectra during the Clas sical Least Squares (CLS) portion of the data analysis procedure. These errors show “goodne ss of fit” of the measured spectra to the reference spectra.

These errors are not necessarily an indicator of the accuracy of the reported concentration nor are they an indicator of “maximum possible erro r” for the concentration value and should not be used for that purpose. In fact, these va lues represent the “min imum error” of the concentration measurement. Thes e errors represent the best th at the analysis routine can do in fitting the sample spectra to the reference spectra. The “error” is the residual absorbance left in the quantification regi on and the analyses routine can only remove interference(s) and fit the reference spectra this well. Other sour ces of error can add to the total error of the
measurement.

As noted in the TCEQ Phase 1 report, “It is possi ble, particularly with radiance data that this [residual] error could be very small yet a syst ematic error could still produce a significant effect. This could be the case, for example, if the sky radiance spectrum or the calibration curve used to get plume transmittance from the observed radiance spectrum were incorrect.”Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-44 

### 3.3.8 Lack of Integrated Sampling The carbon dioxide as measured for this study ap peared to have a larg e degree of variability as compared to the other components. This variab ility is believed to be in part a function of the inhomogeneous nature of a the combustion produc ts in the flare plume. Flare flames are well known to produce plumes characterized by a distinctly inhomogene ous distribution of local combustion efficiencies. This inhom ogeneity imposes the requirement of careful combustion efficiency integration over the pl ume both radially and axially to obtain an accurate assessment of emission control performance.

For example, in the US EPA’s 1983-86 inves tigation of the combustion efficiency of industrial flares, the data produced by the extrac tive-sampling protocols demonstrated that to obtain composite combustion efficiency, i.e. a combustion efficiency that accurately represents a flare’s overall emission control pe rformance, requires integration over the flare plume both radially and axially. In order to establish scaling principles in that US EPA investigation, a homologous sequen ce of flare tips (11⁄2”D, 3”D, 6”D, 12”D) was tested that included four 12”D flare tips of which 3 were of commercial design. Further, extractive sampling methods included the development of sp ecial apparatus with a rake appearance that would traverse over the flare plume and produce a composite sample.

When operating flare plumes are tested, the recognition of inhomoge neous distribution of combustion efficiencies is needed to accu rately determine the effective composite combustion efficiency of the plume. It must be noted that the PFTIR used in this study is measuring only one small section of the entire plume cross-section with no integration.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-45 

### 3.4 Conclusions The performance test of the main flare at Ma rathon’s Texas City refinery provided some useful insights to both the operation and performa nce of a petroleum refinery flare, and also of the PFTIR instrument itself.

Overall Observations

 A flare can be operated with greater than 300 BTU/scf vent gas net heating value and with acceptable exit gas velocitie s and still be over-steamed.

 Combustion efficiency becomes erratic and generally begins to decline sharply once the flame transitions from a clean, visible flam e to one that is invisible. However, not all transparent flames have poor combustion efficiency.

 Combustion efficiency declines with in creased steam to hydrocarbon ratios. The same general trends were observed in flare efficiency performance regardless of vent gas composition or turndown factors.

 The PFTIR measures a single point with in the plume and not the composite. Variations in chemical composition within the plume itself may influence results.

 The PFTIR reporting units are in concentra tion x pathlength. This means that the PFTIR cannot be used to determine absolute concentrations or direct emission rates of speciated plume components.

 The PFTIR has not been blind va lidated; therefore, there is no assessment of bias (i.e. closeness to truth) against establ ished extractive sampling techniques.



### 3.5 Recommendations for Further Study Although this test program was robust, several ch allenges were faced during the course of the program. Marathon’s test program was the fi rst opportunity that IMACC used the PFTIR instrument on an operating industrial flare and there were several less ons learned. The areas of improvement identified are as follows:

1. PFTIR site configuration must be well-m apped in accordance with the predominant wind direction observed at the site. Wind directions that cause the flare plume to travel directly away from the PFTIR line of sight must identified prior to testing, and measurements should not be conducted duri ng periods when the wind is from these directions.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 3-46 2. A larger field of view may assist the PFTIRinstrument in measuring a larger plume cross-section and may help alleviate variability due to plume inhomogeneity.

3. Longer run times may also help address th e inhomogeneity issue. Longer run times would allow the PFTIR enough time to navi gate around the plume cross-section and not be influenced by flamelets breaki ng off the flame and passing through the instrument’s field of view. However, it is also possible that longer run times would simply reinforce the existing pattern of va riability. More study is needed on this topic.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-1 

# 4.0 PFTIR TESTING METHOD AND PROCEDURE

4.1 Description and Principles of Passive FTIR The instrument used to determine the gas composition of the flare plume is the Passive Fourier Transform Infrared (PFTIR) analyzer. The PFTIR analysis operates on the principle of spectral analysis of thermal radiation emitted by hot gases. Passive means that no “active” infrared light source is used. Instead, the hot gases of the flare are th e infrared source. The spectrometer is a receiver only. This appro ach is possible because the infrared emission spectra of hot gases has the same patterns or “f ingerprints” as their ab sorption spectra does. Consequently, observing a flare with an infrar ed instrument allows for identification and quantification of species thr ough emission spectroscopy just as with absorption spectroscopy.
For this test program, the PFTIR operation a nd data analysis was overseen by Dr. Robert Spellicy of Industrial Monitor and Control Co rporation (IMACC). Th e instrument and the analytical software were both developed by IMACC.
The PFTIR was positioned north-northeast of the fl are about 180 feet away. Slightly to the east of the flare at approximately the same di stance from the PFTIR, a tent containing the PFTIR calibration equipment was set up. See Section 4.2 for a description of the PFTIR siting and plot plan showing the instrument and flare locations.

In order to collect valid data on flare plume composition, the PFTIR must be aimed at the flare plume approximately one flame length from the flame tip. To accomplish this, an IR camera was mounted on the PFTIR body. The IR image of the flare plume was viewed on a monitor by the PFTIR operator. The aiming of the instrument was accomplished by turning two cranks – one for pan and one for tilt. The most important part of the PFTIR operation was its ability to aim at the proper place within the flare plume. The mechanical crank was problematic during the test as it made track ing the plume during peri ods of wind speed and direction changes very difficult.
Flamelets breaking off the main flame would so metimes cross the instrument’s line of sight, or the instrument would be t oo close to the flame boundary making resulting data suspect. As a result, a complete review of video coll ected during the test wa s conducted and each runPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-2 was given a Video Review score. Items we re identified that will make aiming accuracy better in any future studies conducted with the PF TIR. At the conclusion of the test program, the PFTIR data were analyzed by Dr. Spellicy and the final results provided to Marathon. Details of the data analysis proc edures are found in Appendix A.2. 

### 4.2 PFTIR Siting Configuration Figure 4.2-1 shows the location of the main flare and the PFTIR trailer. Also shown is the location of the two FLIR cameras and one Axis camera located at the project “command center”. A full facility plot plan is shown in Figure 4.2-3 with area below highlighted in red.



## Figure 4.2-1: Location of PFTIR Camera, Flare, and CamerasPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-3 

## Figure 4.2-2: View of Main Flare from PFTIR LocationPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 4-4Figure 4.2-3: Marathon Texas City Plot Plan(Area shown in Figure 4.2-1 shown in red)Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-5 

### 4.3 Background To monitor elevated flares, sta ndard “active” IR spectroscopy could be used. However, it is difficult from a practical standpoint to pass a beam of IR light thr ough an elevated flare plume and then capture the transmitted light. Therefore, for this project, a “passive” approach is used that does not require an independent IR light source. Instead, the IR radiation produced by the hot gases of the flar e plume is used. With this approach, the spectrometer becomes a passive r eceiver of IR radiation. This approach is possible because the IR radiation emitted by hot gas, its “radiance spectrum” has the same patterns or “fingerprints” as its absorption spectrum. Spectroscopic techniques de veloped by Dr. Robert Spellicy, convert this radiance spectrum into an absorption spectrum at which point it can be analyzed with the same techniques used in st andard active IR spectroscopy. This technique is referred to as PFTIR.

However, there is one main difference between these two approaches: the radiance spectrum from a hot gas is proportional to the concentration of the gas (as it is in absorption), but it is also affected by gas temperature. In standard absorption FTIR, the temperature of the gas is known and controlled. With PFTIR measuremen ts on a flare plume, the temperature is unknown. Therefore, when conducting PFTIR meas urements, the temperature of the flare plume must be determined. De tails of how this temperature determination is made are found in Appendix A.2.

Consequently, unlike absorption spectroscopy, the PFTIR signal must be calibrated in absolute units of radiance. Th is requires that the instrument be calibrated utilizing an IR source of known spectral radiance. This calibra tion is accomplished with a commercial black body calibrator. This calibrator produces a known radiance IR distri bution as predicted by the Planck function. Details of this calibration are found in Appendix A.2.

Calibrations were performed each day at the begi nning and end of testing. Calibration results are found in Appendix A.2.



### 4.4 PFTIR Operation
The PFTIR instrument was located north-northeas t of the flare about 180 feet away. It was housed in and operated from a trailer.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-6 

## Figure 4.4-1: PFTIR Trailer

Another view of the PFTIR instrument take n during the TCEQ Pilo t Study is shown in Figure 4.4-2.



## Figure 4.4-2: The PFTIR Instrument Aimin g Camera

Telesco p e S p ectrometer

O p eratin g CrankPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-7 Figure 4.4-3 shows a schematic of the PFTIR set-up.



## Figure 4.4-3: Schematic of PFTIR set-up

Calibration of the equipment was performed tw ice each day. Calibration was completed in the morning prior to commencement of testing and again at the end of the day after testing was completed in order to validate the data coll ected that particular day. Results of these daily calibrations are found in Appendix A.2
The calibration of this equipmen t required three different calib ration sources: a cold source, IR source and a black body source. A more de tailed description of the calibration procedure is found in Appendix A.2. Calibration sources were located under a tent on the ground adjacent to the base of the flare. The locati on was chosen so the distance between the PFTIR and the calibration equipment was approximate ly the same as the ground distance between the PFTIR and the flare.
After calibration was completed, the equipment wa s ready to start testing. A sky background was taken to be used in la ter analysis to subtract b ackground radiance. A new sky background would be taken as sky conditions cha nged during the testing. In PFTIR testing, it is important to adjust collected spectra with repr esentative sky backgrounds.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-8 While the tests were being performed, the team identified several factors that influenced the data collection. The equipment mounting made it difficult to move the instrument. The movement was managed by two manual cranks (pan and tilt), on a commercial azimuthelevation mount. The movements of the mount were not as smooth or sensitive as would be ideal. This made it difficult to follow the plume with the equipment during periods of changing winds. There was also an issue with st ability. The weight of the equipment caused it to bounce around for a few seconds before stabili zing. These have been addressed after the test by re-engineering the azimuth and elev ation mounts and by cont rolling them with a joystick.
During the second day of testing, a failure occu rred that was caused by the PFTIR instrument being pointed at such a severe angle over such long periods of time that the interferometer bearing started to foul. The bearing housing had to be disasse mbled and cleaned. This has also been addressed by modifying the assembly of the FTIR to allow for re-alignment of the FTIR relative to the elevation angl e so this problem should not recur.
Another factor influencing the data was the de termination of the correct location to aim the PFTIR in order to capture the most representative data. For the majority of the test, the team agreed to focus one flame length away from th e tip of the visible flame. Targeting was accomplished by using a thermal IR camera moun ted on the front of the PFTIR. The image from this camera was output to a video monitor in the test trailer. However, occasionally it was very difficult to find a suitable aiming location because the flame or the plume would blend with the sky background or be obscure d by the flare structure depending on the weather conditions.
The wind direction played a major role in the measurements. At certain times, particularly over the last three days of testing, the wind w ould cause the plume to be hidden behind the flare from the viewing angle of the PFTIR. That particular scenario made it virtually impossible to collect a representative sample. Relocating the trailer with its equipment was not an easy option because of location, power and calibration time constraints.
For the most part, testing was performed when the wind direction was at right angles to the field of view of the PFTIR trailer. This aspect angle allowed the PFTIR to measure a representative cross-section of the plume. Ho wever, there were several days in which the wind direction impacted the view-angle and re presentativeness of the plume cross-section was suspect. The constant maneuvering of the in strument to stay targ eted one flare length away from the tip of the visibl e flame was a concern. This may have been resolved for future tests with the joystick contro l of the PFTIR field of view.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-9 

### 4.5 PFTIR Data Reduction Once collected, the raw PFTIR data must be processed to yield the individual flare component concentrations. This data processi ng was performed by Dr. Robert Spellicy from IMACC. Data were compiled at approximately one minute intervals. Each one minute data point consists of approximately 40 individual me asurements averaged into a single spectrum.
As shown in Figure 4.5-1, the total radian ce measured by the PFTIR consists of:

1. The background radiance altered by its tr ansmission through the flare plume and the atmosphere between the plume and the PFTIR instrument.

2. The flare radiance altered by its transmission through the atmosphere between the plume and the PFTIR instrument.

3. The atmospheric radiance of the air be tween the flare plume and the PFTIR instrument.

4. The radiance from the PFTIR instrument itself.



## Figure 4.5-1: Contributions to Total RadiancePerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-10 For this test program, everything except the flare transmission is considered interference. In equation form, the measured plume radiance can be represented by:

N total = N bkg * 

### τ flr

* 

### τ atm + N flr

* 

### τ atm + N atm +N f ) Equation 1

Where:

N total = total radiance (radian ce observed by the PFTIR) N bkg = background sky radiance


### τ flr

= flare transmissivity



### τ atm = atmospheric transmissivity N flr = flare plume radiance N atm = atmospheric radiance N f = radiance of the FTIR instrument itself

In the broadest sense, the data analys is procedure has four major components:

1. Convert the raw interferogram to a single- beam spectrum using a Fourier Transform process,

2. Isolate the flare transmissivity from the other interferences listed above,

3. Convert the isolated flare transmissivity sp ectrum to an absorbance spectrum so it can be further analyzed with sta ndard spectroscopic techniques,

4. Determine the concentrations of individua l components of the flare plume from the absorbance spectrum.
Each of these steps is discussed briefly belo w. A more detailed treatment is found in Appendix A.2.
Step 1 – Convert the raw interf erogram to a radiance spectrum The raw data from the PFTIR are in the form of an interferogram wh ich is radiance as a function of FTIR scan position. The Fourier Transf orm (FT) process converts this data into a radiance spectrum which is radiance as a function of wavelength or, in this case, wavenumber. The result is what is referred to as a “single beam” radiance spectrum. These single beam spectra have been supplied on the da ta hard drives that accompany this report. The FT process is a standard spectroscopic proc edure and is not discus sed in detail in this report.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-11 Step 2 – Isolate the flare transmission spectrum Once the radiance spectrum has been generated, th e flare transmission must be isolated from all the interferants that the PFTIR also “sees”. In order to accomplish this, each term in Equation 1 above must be determin ed. This is done as follows:
Background radiance (N bkg ) – As described in Section 4.1.2, at least once each day, the PFTIR was aimed at an unobstructed part of the sky. Since the background radiance is affected by conditions such as sun position a nd cloud cover, this procedure was repeated whenever a significant change in background was observed.
Flare transmissivity ( 

### τ flr ) – This is the value we are looki ng for and is the result when all competing factors are removed. It actually appears two places: 1) in transmitting the sky background through the flare to the PFTIR and 2) in the radiance term for the flare itself. So the flare transmission must be extracted from the complex mixture of signals received by the PFTIR. This task is accomplished by the IMACC software.
Atmospheric transmissivity ( 

### τ atm ) – This value is determined by aiming the PFTIR at at an IR source and taking the ratio of the value obtai ned (minus the atmospheric radiance) to a “synthetic background” spectrum. This s ynthetic background (referred to as I 0 ) represents the shape of the radiance spectrum that would be generated by the PFTIR in the absence of all gases. For this project the IR source was a SiC source operated at a temperature of 1250 K. This is a standard source used in most active FTIR system s. This source has sufficient signal throughout the infrared to allow for a transmission spectrum to be determined over the range of wavenumbers needed.
Flare plume radiance (N flr ) – Plume radiance is (1 – plume transmission) times the Planck function (evaluated at the temp erature of the plume). The radiance is what is measured by the PFTIR but it is mixed in with other signals an d so must be corrected with respect to this interference.
Atmospheric radiance (N atm ) – This value is determined by aiming the PFTIR at very cold source in the calibration telescope located at the same distance from the PFTIR as the flare. Any radiance observed will then be due to the intervening atmosphere plus any radiance from the PFTIR instrument itself. This measured value is referred to as M n . For this project, the cold source was an aluminum bar immersed in liquid nitrogen.
PFTIR radiance (N f ) – PFTIR radiance is the emissions of the instrument itself. It is measured together with atmospheri c radiance and is part of the M n measurement. Once these values are known, they are app lied to the total radiance spectrum by IMACC proprietary software to isol ate the flare transmission spectrum. For a more detailed description of this pr ocess, see Appendix A.2.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-12 Step 3 – Convert the transmission spectrum to an absorption spectrum Once the flare transmission spectrum has been isolated, it must be converted to an absorbance spectrum so that standard spectro scopic techniques can be used for further analysis. Transmission and absorbance are related by the Beer-Lambert law through the following equation.

( ) c l plume 

# e ν 

# τ −Κ ∗ ∗


## = Equation 2
Essentially, absorbance is the ne gative log of transmission, thus:
Absorbance( ν ) = (0.434)K( ν ) * c * l Equation 3
See Appendix A.2 for further detail. This conve rsion is a standard spectroscopic procedure.
Step 4 – Determine the concentrations of individual components in the flare plume Once the absorbance spectrum has been generate d, there are several analytical techniques that may be used to estimate individual co mponent concentrations. For this project, a modified Classical Least Squares (CLS) analys is was used. IMACC proprietary software was used for this step of the data analysis . The modifications to standard CLS include algorithms for linearizing the absorbance for each analyte with concentration, corrections for spectral baseline shifts, corrections for any sp ectral line shifts obser ved, and algorithms for dynamic reference spectra selection based upon observed concentrations of each compound.
The CLS technique compares measured spectra to combinations reference spectra of known concentration and interfering compounds and ma tches the absorbance of the data and the references to determine gas concentration. This process is performed for all components present to account for all sp ectral features present.
After fitting, CLS also determines the difference or residual between the measured and scaled references. The fitting process minimizes the resi duals in each analysis region. The software used for this project uses dyna mic reference selection to sele ct reference spectra based upon measured gas concentrations. In most cases, th is means different reference spectra will be chosen for each analyte in the measured spectru m. This process will be repeated up to four times to optimize all spectra compared to the measured data.
A flow chart of the PFTIR data analys is process is shown in Figure 4.5-2.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-13 

## Figure 4.5-2: PFTIR Data Analysis ProgressionPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 4-14 

### 4.6 Q-Branch Subtraction If an absorption feature becomes too strong, it wi ll saturate (become totally absorbing) and it is not useful for spectroscopic analysis. During this test program, some of the CO 2 data points at long wavelength exhibited this problem. Rather than discard the spectra as invalid, the analytical process was refined to addre ss this issue, avoiding the spectral regions considered to be invalid. This refinement, referred to here as Q-Branch Subtraction, is described in Appendix A.2.
For some data points, a region of the IR spect rum, called the “Q-Branch”, was opaque in the IR (saturated the detector) and was, therefor e, not linear in concentration. The refined analyses routine does not cont ain the Q branch or any regi ons for other compounds, which are opaque or otherwise too heavily interfered with by other compounds. This is part of the quality assurance one does af ter collecting FTIR data.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-1 

# 5.0 DATA TABLES
Due to the large quantity of data collected fo r this project, three levels of summary are provided. Section 5.1 is the most concise su mmary providing run averages for a few key parameters at each test condition. Section 5.2 pr ovides more detail on the individual test conditions, shows a larger number of paramete rs and also provides information on wind effects.



### 5.1 Data Summary Tables Tables 5.1-1 through 5.1-10 below present summary data for each test condition. Column headings for these tables are described below:

Condition : This is the designation for each te st condition described in Section 2.4. New Run : This is the revised run number indicati ng the test and replic ate. For example, Run 3-2 indicates Test 3, Replicate 2. A test is a given S/VG ratio. PFTIR Start Date/Time : The date and time each run began. PFTIR Stop Date/Time : The date and time each run ended. Min : The number of minutes for each run S/VG : Steam to Vent Gas ratio (lb/lb) S/HC : Steam to Hydrocarbon ratio (lb/lb) S/S521 : Ratio of actual steam to API 521 recommended steam CZG : Heat content of vent gas in the combustion zone (BTU/scf) Smoke : Smoke rating given to the test accordi ng to the scale provided in Table 3.2-1 CO2p : CO 2 as measured by the PFTIR (ppm-meters) CO2m Low : The low range of CO 2 emissions from the flare as predicted by mass balance. See Section 3.2.3 for further details. CO2m High : The high range of CO 2 emissions from the flare as predicted by mass balance. See Section 3.2.3 for further details. CE : Combustion Efficiency as calculated with PFTIR data Video Score : A score from a video review panel indicating the degree to which the PFTIR was aimed properly during each run. See Section 4.3.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-2 Note that individual runs are color-coded corresponding to the video review score. Runs scoring between 1.0 and 1.9 (correct aiming <20 %) are shaded blue. Runs scoring between 2.0 and 2.9 (correct aiming between 20% and 50%) are shown with blue text.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-3 

## Table 5.1-1: Condition A19 Test Result Summary

Table 5.1-2: Condition A11 Test Result Summary

Table 5.1-3: Condition A8 Test Result SummaryPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-4 

## Table 5.1-4: Condition B Test Result Summary

Table 5.1-5: Condition C Test Result Summary

Table 5.1-6: Condition D Test Result SummaryPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-5 

## Table 5.1-7: Condition E Test Result Summary

Table 5.1-8: Condition F Test Result Summary

Table 5.1-9: Condition G Test Result Summary

Table 5.1-10: LTS Test Result SummaryPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-6 

### 5.2 Test Condition A19 The purpose of the Condition A tests is to simula te plant normal base load -- this is the typical flow condition for the flare and represen ts day-to-day operati on. Actual testing for this condition was conducted at three vent ga s mass flow rates: 1,900 lb/hr, 1,100 lb/hr, and 800 lb/hr. This section addresses testing conducted at 1,900 lb/hr. This condition (along with Condition A11) represents typica l historic vent gas flow rates.



### 5.2.1 Process Conditions The values of several key flare operating para meters are shown in Figures 5.2-1 and 5.2-2 below.



## Figure 5.2-1: Condition A19 Flow and CZG Heat Content

Figure 5.2-2: Condition A19 Vent Gas CompositionPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-7 

### 5.2.2 Steam Ratios The Steam to Vent Gas (S/VG) and Steam to Hydrocarbon (S/HC) ra tios corresponding to each test condition are shown in Table 5.2-1. Values are rounded to the nearest 0.5.



## Table 5.2-1: Condition A19 Steam Ratios

Test S/VG S/HC

1 1.00 1.80 2 1.25 2.05 3 1.50 2.25 4 2.00 3.00 5 2.50 3.20 6 2.70 3.60 7 3.00 4.50



### 5.2.3 Wind Conditions The direction and speed of the wind can have a significant impact on the quality of data collected by the PFTIR. See S ection 3.3.2 for a further discussi on of wind effects. Figure 5.2-3 shows wind direction and speed during this Test Condition. The area within the blue 60 deg angle triggers the wind flagging algorithm as described in Section 3.3.2.



## Figure 5.2-3: Condition A19. Wind Speed and Direction during TestPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 5-85.2.4 ResultsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-9 

### 5.3 Test Condition A11 The purpose of the Condition A tests is to simulate plant normal base load -- this is the typical flow condition for the flare and represents day-to -day operation. Actual testing for this condition was conducted at three vent gas mass flow rate s: 1,900 lb/hr, 1,100 lb/hr and 800 lb/hr. This section addresses testing conducted at 1,100 lb/hr. This condition (along with Condition A19) represents typical historic vent gas flow rates.



### 5.3.1 Process Conditions The values of several key flare operating para meters are shown in Figures 5.3-1 and 5.3-2 below. The data presented are the run averages.



## Figure 5.3-1: Condition A11 Flow and CZG Heat Content

Figure 5.3-2: Condition A11 Vent Gas CompositionPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-10 

### 5.3.2 Steam Ratios The Steam to Vent Gas (S/VG) and Steam to Hydrocarbon (S/HC) ratios corresponding to each test condition are shown in Table 5.3- 1. Values are rounded to the nearest 0.5.



## Table 5.3-1: Condition A11 Steam Ratios

Test S/VG S/HC

1 1.35 2.00 2 1.80 3.35 3 2.00 3.95 4 2.50 4.55 5 3.00 5.65 6 3.50 5.80 7 4.00 7.70 8 4.50 8.45 9 5.00 9.50 10 5.25 10.05 11 5.40 10.55 12 5.75 10.80 13 6.00 11.85 14 6.95 13.50



### 5.3.3 Wind Conditions The direction and speed of the wind can have a significant impact on the quality of data collected by the PFTIR. See Section 3.3.2 for a further discussion of wind effects. Figure 5.3-3 shows wind direction and speed dur ing this Test Condition. The area within the blue 60 deg angle triggers the wind fla gging algorithm as described in Section 3.3.2.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-11 

## Figure 5.3-3: Condition A11. Wind Speed and Direction during TestPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 5-125.3.4 ResultsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-13 

### 5.4 Test Condition A8 A8 was achieved by minimizing normal refinery fuel gas sweep flow for the sole purpose of achieving low heating value conditions suitable for Test G. Analysis of this region is not representative of normal operating conditions of the Texas City main flare. Data are presented here for informational purposes only. In addi tion, the test data fo r this condition were compromised by adverse wind conditions. Therefor e, data from this test condition is not considered valid and reliable conclusions rega rding combustion efficiency cannot be made.



### 5.4.1 Process Conditions The values of several key flare operating para meters are shown in Figures 5.4-1 and 5.4-2 below.



## Figure 5.4-1: Condition A8 Flow and CZG Heat Content

Figure 5.4-2: Condition A8 Vent Gas CompositionPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-14 

### 5.4.2 Steam Ratios The Steam to Vent Gas (S/VG) and Steam to Hydrocarbon (S/HC) ratios corresponding to each test condition are shown in Table 5.4- 1. Values are rounded to the nearest 0.5.



## Table 5.4-1: Condition A8 Steam Ratios

Test S/VG S/HC

1 1.85 3.55 2 2.20 4.65 3 3.00 6.30 4 3.55 7.00 5 4.00 8.10 6 4.50 8.60 7 4.90 9.80 8 5.05 9.90 9 5.45 11.65 10 5.70 12.15


### 5.4.3 Wind Conditions The direction and speed of the wind can have a significant impact on the quality of data collected by the PFTIR. See Section 3.3.2 for a further discussion of wind effects. Figure 5.4-3 shows wind direction and speed duri ng this Test Condition. The area within the blue 60 deg angle triggers the wind fla gging algorithm as described in Section 3.3.2.



## Figure 5.4-3: Condition A8. Wind Sp eed and Direction During TestPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 5-155.4.4 ResultsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-16 

### 5.5 Test Condition B To demonstrate flare performance with a hi gher flow rate of hydrocarbons by adding gas (refinery fuel gas) that has a lo w S/VG ratio for smokeless operation.



### 5.5.1 Process Conditions The values of several key flare operating para meters are shown in Figures 5.5-1 and 5.5-2 below.



## Figure 5.5-1: Condition B Flow and CZG Heat Content

Figure 5.5-2: Condition B Vent Gas CompositionPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-17 

### 5.5.2 Steam Ratios The Steam to Vent Gas (S/VG) and Steam to Hydrocarbon (S/HC) ratios corresponding to each test condition are shown in Table 5.5- 1. Values are rounded to the nearest 0.5.



## Table 5.5-1: Condition B Steam Ratios

Test S/VG S/HC

1 0.40 0.55 2 0.50 0.65 3 0.75 1.00 4 1.00 1.30 5 1.25 1.65 6 1.50 2.00 7 1.60 2.10 8 1.70 2.25 9 1.80 2.40 10 1.90 2.50


### 5.5.3 Wind Conditions The direction and speed of the wind can have a significant impact on the quality of data collected by the PFTIR. See Section 3.3.2 for a further discussion of wind effects. Figure 5.5-3 shows wind direction and speed dur ing this Test Condition. The area within the blue 60 deg angle triggers the wind fla gging algorithm as described in Section 3.3.2.



## Figure 5.5-3: Condition B. Wind Sp eed and Direction During TestPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 5-185.5.4 ResultsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-19 

### 5.6 Test Condition C The purpose of the Condition C tests is to demonstr ate flare performance at flow rates similar to Test B, with addition of a saturated gas (propa ne) that would require a higher S/VG ratio for smokeless operation than the gas added in Condition B. Propane is also one of the materials most frequently used in indepe ndent-pilot scale test studies.



### 5.6.1 Process Conditions The values of several key flare operating para meters are shown in Figures 5.6-1 and 5.6-2 below.



## Figure 5.6-1: Condition C Flow and CGZ Heat Content

Figure 5.6-2: Condition C Vent Gas CompositionPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-20 

### 5.6.2 Steam Ratios The Steam to Vent Gas (S/VG) and Steam to Hydrocarbon (S/HC) ratios corresponding to each test condition are shown in Table 5.6- 1. Values are rounded to the nearest 0.5.



## Table 5.6-1: Condition C Steam Ratios

Test S/VG S/HC

1 0.30 0.40 2 0.50 0.60 3 0.95 1.30 4 1.20 1.35 5 1.30 1.45


### 5.6.3 Wind Conditions The direction and speed of the wind can have a significant impact on the quality of data collected by the PFTIR. See Section 3.3.2 for a further discussion of wind effects. Figure 5.6-3 shows wind direction and speed duri ng this Test Condition. The area within the blue 60 deg angle triggers the wind fla gging algorithm as described in Section 3.3.2.



## Figure 5.6-3: Condition C. Wind Speed and Direction during TestPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 5-215.6.4 ResultsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-22 

### 5.7 Test Condition D The purpose of the Condition D test is similar to Condition C but adds un saturates (olefins) to demonstrate performance at an even highe r S/VG ratio needed for smokeless operation.



### 5.7.1 Process Conditions The values of several key flare operating para meters are shown in Figures 5.7-1 and 5.7-2 below.



## Figure 5.7-1: Condition D Flow and CZG Heat Content

Figure 5.7-2: Condition D Vent Gas CompositionPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-23 

### 5.7.2 Steam Ratios The Steam to Vent Gas (S/VG) and Steam to Hydrocarbon (S/HC) ratios corresponding to each test condition are shown in Table 5.7- 1. Values are rounded to the nearest 0.5.



## Table 5.7-1: Condition D Steam Ratios

Test S/VG S/HC

1 0.40 0.45 2 0.55 0.60 3 0.75 0.85 4 1.00 1.15 5 1.10 1.25 6 1.20 1.40 7 1.30 1.55 8 1.60 1.80 9 1.80 2.00 10 2.00 2.30


### 5.7.3 Wind Conditions The direction and speed of the wind can have a significant impact on the quality of data collected by the PFTIR. See Section 3.3.2 for a further discussion of wind effects. Figure 5.7-3 shows wind direction and speed duri ng this Test Condition. The area within the blue 60 deg angle triggers the wind fla gging algorithm as described in Section 3.3.2.



## Figure 5.7-3: Condition D. Wind Speed and Direction during TestPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 5-245.7.4 ResultsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-25 

### 5.8 Test Condition E The purpose of the Condition E test is the same as Test D, but with a higher flow rate (and thus higher unsaturate mass flow) to see flare perf ormance at higher flows for the unsaturate condition



### 5.8.1 Process Conditions The values of several key flare operating para meters are shown in Figures 5.8-1 and 5.8-2 below.



## Figure 5.8-1: Condition E Flow and CZG Heat Content

Figure 5.8-2: Condition E Vent Gas CompositionPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-26 

### 5.8.2 Steam Ratios The Steam to Vent Gas (S/VG) and Steam to Hydrocarbon (S/HC) ratios corresponding to each test condition are shown in Table 5.8- 1. Values are rounded to the nearest 0.5.



## Table 5.8-1: Condition E Steam Ratios

Test S/VG S/HC

1 0.20 0.20 2 0.55 0.60 3 1.00 1.00 4 1.10 1.10 5 1.20 1.20 6 1.30 1.30


### 5.8.3 Wind Conditions The direction and speed of the wind can have a significant impact on the quality of data collected by the PFTIR. See Section 3.3.2 for a further discussion of wind effects. Figure 5.8-3 shows wind direction and speed duri ng this Test Condition. The area within the blue 60 deg angle triggers the wind fla gging algorithm as described in Section 3.3.2.



## Figure 5.8-3: Condition E. Wind Speed and Direction during TestPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 5-275.8.4 ResultsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-28 

### 5.9 Test Condition F The purpose of the Condition F test is to dem onstrate performance when operating at higher levels of hydrogen than typically fo und in the base load. Hydrogen (H 2 ) has been shown to have exceptional combustion characteristic s, but it has a low volumetric heat content (275 BTU/scf). Note that the base load may contain nominal amounts of hydrogen from 10 to 30%. mole weight.
Note that this test condition differs from others because the objective was not to determine how S/VG affects combustion efficiency, but rather how H 2 affects flare performance. Therefore, during the first part of this test series, H 2 levels were increased while holding S/VG constant. In the latter part of the test, a higher S/VG was used. Also note that virtually all of the data from this test conditi on are compromised due to adverse wind conditions on the day of testing. See Figure 5.9-3 below for a wind rose showing wind speed and direction on this day. Due to these adve rse conditions, this data is considered invalid and is not used to draw conclusions regardi ng flare performance under the tested conditions.



### 5.9.1 Process Conditions The values of several key flare operating para meters are shown in Figures 5.9-1 and 5.9-2 below.



## Figure 5.9-1: Condition F Fl ow and CZG Heat ContentPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-29 

## Figure 5.9-2: Condition F Vent Gas Composition

5.9.2 Steam Ratios The Steam to Vent Gas (S/VG) and Steam to Hydrocarbon (S/HC) ratios corresponding to each test condition are shown in Table 5.9- 1. Values are rounded to the nearest 0.5.



## Table 5.9-1: Condition F Steam Ratios

Test S/VG S/HC

1 0.45 2.20 2 0.45 1.65 3 0.45 1.30 4 4.00 8.35 5 1.00 2.00 6 0.45 0.85Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-30 

### 5.9.3 Wind Conditions The direction and speed of the wind can have a significant impact on the quality of data collected by the PFTIR. See Section 3.3.2 for a further discussion of wind effects. Figure 5.9-3 shows wind direction and speed duri ng this Test Condition. The area within the blue 60 deg angle triggers the wind fla gging algorithm as described in Section 3.3.2.



## Figure 5.9-3: Condition F. Wind Speed and Direction during TestPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 5-315.9.4 ResultsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-32 

### 5.10 Test Condition G The purpose of the Condition G test is to demonstrate performance with additional inert material (i.e. nitrogen) combined with hydrogen in the ba se load. The objective was to seek an overall vent gas heat content of less than 300 BTU/sc f or less than 200 BTU/scf in flare combustion zone. In addition to the inert testing, this test provides data point demonstrating the effect of hydrogen on a low BTU gas. Note that virtually all of the data from this test condition are compromi sed due to adverse wind conditions on the day of testing. See section 5.10-3 below for a wind rose showing wind speed and direction on this day. Due to these adverse conditions, this data is considered invalid and is not used to draw conclusions regarding flare performance under the tested conditions.



### 5.10.1 Process Conditions The values of several key flare operating pa rameters are shown in Figures 5.10-1 and 5.10-2 below.



## Figure 5.10-1: Condition G Flow and CZG Heat ContentPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-33 

## Figure 5.10-2: Condition G Vent Gas Composition

5.10.2 Steam Ratios The Steam to Vent Gas (S/VG) and Steam to Hydrocarbon (S/HC) ratios corresponding to each test condition are shown in Table 5.10- 1. Values are rounded to the nearest 0.5.



## Table 5.10-1: Condition G Steam Ratios

Test S/VG S/HC

1 0.55 1.50 2 0.55 1.60 3 0.55 2.90 4 0.50 2.90 5 0.60 3.45 6 0.70 4.10Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-34 

### 5.10.3 Wind Conditions The direction and speed of the wind can have a significant impact on the quality of data collected by the PFTIR. See Section 3.3.2 for a further discussion of wind effects. Figure 5.10-3 shows wind direction and speed during this Test Condition. The area within the blue 60 deg angle triggers the wi nd flagging algorithm as described in Section 3.3.2.



## Figure 5.10-3: Condition G. Wind Speed and Direction during TestPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 5-355.10.4 ResultsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-36 

### 5.11 Long Term Stability Test The purpose of the Long Term Stability (LTS) test is to obtain an indication of the repeatability of the PFTIR measurement system. This test differs from the other tests conduc ted under this project in that the objective of the LTS was to reproduce process conditions as accurately as possible for each test run. Therefore, the run-to-r un variation in test resu lts is an indication of the instrument repeatability.
The initial test condition chos en for the LTS runs was Condition C at an SV/G of 1.00. However, after one test run, it wa s decided that this c ondition was not suitable for the LTS series because 1) the flare was smoking at this conditio n, and 2) the flare recovery time was very long (1 to 2 hours) before another test condition coul d be run. Data from this first LTS run are included in the Appendix but is not included in the data analysis in this Section. The LTS test conditions were changed to Conditi on B at an S/VG of 1.00. This condition proved satisfactory, especially since Condition B provided the most stable flare operation of any test condition.



### 5.11.1 Process Conditions The values of several key flare operating pa rameters are shown in Figures 5.11-1 and 5.11-2 below.



## Figure 5.11-1: Long Term Stabil ity Flow and CZG Heat ContentPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-37 

## Figure 5.11-2: Long Term Stab ility Vent Gas Composition

5.11.2 Steam Ratios The Steam to Vent Gas (S/VG) and Steam to Hydrocarbon (S/HC) ratios corresponding to each test condition are shown in Table 5.11- 1. Values are rounded to the nearest 0.5.



## Table 5.11-1: Long Term Stability Steam Ratios

Test S/VG S/HC

1 1.00 1.30 2 1.00 1.35 3 1.00 1.35 4 1.00 2.00 5 1.00 1.30 6 1.00 1.35 7 1.00 1.25 8 1.00 1.30Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 5-38 

### 5.11.3 Wind Conditions The direction and speed of the wind can have a significant impact on the quality of data collected by the PFTIR. See Section 3.3.2 for a further discussion of wind effects. Figure 5.11-3 shows wind direction and speed during this Test Condition. The area within the blue 60 deg angle triggers the wi nd flagging algorithm as described in Section 3.3.2.



## Figure 5.11-3: Long Term Stabilit y. Wind Speed and Direction during TestPerformance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 5-395.11.4 ResultsPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-1 

# 6.0 APPENDIX

A.1 Calculations
A.2 PFTIR Calibration and Operation

A.3 VOC Emission Calculations

A.4 Personnel Involved with Flare Performance TestPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-3 

## Appendix A.1 Calculations

The following calculations ar e used this report.
1. Mass Flow - Hydrocarbons The flare vent gas GC measures the fo llowing hydrocarbons on a 10-minute cycle.

i Measured Component MW Range GC Units

1 Methane 16.04 0 - 100 Mole %

2 Ethane 30.07 0 - 100 Mole % 3 Ethylene 28.06 0 - 100 Mole % 4 Acetylene 26.04 0 - 100 Mole %
5 Propane 44.10 0 - 100 Mole % 6 Propylene 42.08 0 - 100 Mole %

7 Iso-Butane 58.12 0 - 100 Mole %

8 Normal Butane 58.12 0 - 100 Mole %
9 i-Butene, Butene-1 56.11 0 - 100 Mole %

10 Trans-Butene-2 56.11 0 - 100 Mole %

11 Cis-Butene-2 56.11 0 - 100 Mole %
12 1,3 Butadiene 54.09 0 - 100 Mole %
13 Pentane-Plus (C5+) 72.15 0 - 100 Mole %

Table A.1-1. List of hydrocarbons meas ured by Gas Chromatograph The hydrocarbon mass flow rate is determined as follows:

Q HC = MW i × HCmol i

386     



i = 1 13 

##  × Q FM Eq. A.1-1Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-4 Where: Q HC = Total hydrocarbon flow (lb/hr)

MW i = Molecular weight of each com pound (i) from Table A.1-1 above Q FM = Vent gas flow from ultrasonic monitor (scf/hr)

HC mol i = lb-mole of each compound (i) as a percenta ge of total mole% of vent gas from GC 386 = Molar volume of an ideal gas at 68 °F and 1 atm (scf/lb-mole)

2. Hydrocarbon Molecular Weight



### MW hc 

### = MW i 

### ×

i = 1 13 

#  HCmol i 

### HCmol total 

###     

 Eq. A.1-2

Where:

MW hc = Molecular weight of the hydrocarbon fraction of the vent gas (lb/lb-mole)

MW i = Molecular weight of each com pound (i) from Table A.1-1above

HCmol i = lb-mole of each compound (i) as a percen tage of total mole% of vent gas from GC

HCmol total =lb-mole of total hydrocarbon fraction of the vent gas

3. Net Heating Value The Net Heating Value of the Vent Gas is calculat ed from the GC data at the conclusion of each analytical cycle (~10 minutes). The Net Heating Value is the Lower Heating Value or LHV defined as:

“Lower Heating Value” or “LHV” shall mean the theoretical tota l quantity of heat liberated by the complete combustion of a unit volume or weight of a fuel initially at 25° Centigrade and 760 mmHg, assuming that th e produced water is vaporized and all combustion products remain at, or are re turned to, 25° Centigrade; however, the standard for determining the volume corresponding to one mole is 20° Centigrade.

The Net Heating Value of the Flare Combustion Zone Gas is determined as follows:Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-5 

### NHV FCZG 

### = ( VG )( NHV VG 

### )(386 / MW VG 

### ) 

## [ ] + ( PG )( NHV PG 

### )(386 / MW PG 

### ) 

## [ ] ( VG )(386 / MW VG 

### ) + ( PG )(386 / MW PG 

### ) + ( S )(386 /18) 

## [ ] Eq. A.1-3

Where:

Parameter Description (Unit) Source

NHV FCZG = Flare Combustion Zone Gas net heating value (BTU/scf) Result

VG = Vent Gas mass flow rate (lb/hr) From ultrasonic flare gas flow monitor

NHV VG = Vent Gas Net Heating Value (BTU/scf) From GC

MW VG = Vent Gas molecular weight (lb/lb-mole) From ultrasonic flow monitor
PG = Pilot Gas mass flow rate (lb/hr) Constant = 6

NHV PG = Pilot Gas net heating value (BTU/scf) Constant = 898

MW PG = Pilot Gas molecular weight (lb/lb-mole) Constant = 18.5
S = Actual total steam mass flow rate (lb/hr) From ultrasonic steam flow monitor
386 = Constant (scf/lb-mole @ 68 °F and 1 atm) Ideal Gas LawPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-6 4. Steam Ratios Five steam ratios are included in this report. They are calculated as described below.

a) Actual Total Steam to API 521 Total Steam Ratio (S/S 521 ) The Actual Total Steam to API 521 Total Steam Ratio is calculated as follows:

S S 521 Eq. A.1-4

Where: S = Actual Total Steam Mass Rate (lb/hr)

S 521 = API 521 Total Steam Mass Rate (lb/hr)

The Actual Total Steam Mass Rate is calculated as:

S = FR ATS × (18 / 386)

Where: S = Actual Total Steam Mass Rate (lb/hr)

FR ATS = Steam Volumetric Flow Rate (scf/hr) from the ultrasonic flow monitor 18 = MW of water (lb/lb-mole) 386 = Constant (scf/lb-mole @ 68 °F and 1 atm)

The API 521 Total Steam Mass Rate is calculated as:

S 521 = 0.0067 × MW VG + 0.275 

## [ ] × VG Eq. A.1-5

Where:

S 521 = API 521 Total Steam Mass Rate (lb/hr)

MW VG = Vent Gas molecular weight (lb/lb -mole) from ultrasonic flow monitor VG = Vent Gas mass flow rate (lb/ hr) from ultrasoni c flow monitorPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-7 Note: The equation is derived from a regr ession on the compound-specific steam-to-gasratios (pounds of steam to pounds of gas) set forth in Table 11 of the American Petroleum Institute’s Recommended Practice 521 (Fifth Edition, May 2007)

b) Actual Total Steam to Vent Gas Ratio (S/VG) The Actual Total Steam to Vent Ga s Ratio is calculated as follows:

S VG Eq. A.1-6

Where:

S = Actual Total Steam Mass Ra te (lb/hr) calculated above VG = Vent Gas Mass Rate (lb/hr) as meas ured by the ultrasonic flow monitor. Direct measurement - no external calculation required.

c) Actual Total Steam to Hydrocarbon Ratio (S/HC) The Actual Total Steam to Vent Ga s Ratio is calculated as follows:

S HC Eq. A.1-7

Where:

S = Actual Total Steam Mass Ra te (lb/hr) calculated above HC = Hydrocarbon Mass Flow Rate (lb/hr) as calculated above.

d) API 521 Total Steam to Vent Gas Ratio (S521/VG) The API 521 Total Steam to Vent Gas Ratio is calculated as follows:

S 521 VG Eq. A.1-8

Where:

S 521 = API 521 Total Steam Mass Rate (lb/hr) as calculated above VG = Vent Gas Mass Rate (lb/hr) as meas ured by the ultrasonic flow monitor. Direct measurement - no external calculation required.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-8 e) API 521 Total Steam to Hydrocarbon Ratio (S521/HC) The API 521 Total Steam to Hydrocarbon Ratio is calculated as follows:

S 521 HC Eq. A.1-9

Where:

S 521 = API 521 Total Steam Mass Rate (lb/hr) as calculated above HC = Hydrocarbon Mass Flow Rate (lb/hr) as calculated above.

5. Total Hydrocarbons Two hydrocarbon calculations are us ed in this report – weighted and unweighted. Each is shown below.

a) Total Hydrocarbons (unweighted)



### THC = C CH 4 

### + C C

2 H 4 

### + C C 3 H 6 

### + C But 

### + C 13 But 

### + C HC Eq. A.1-10

Where: THC = Total Hydrocarbon conc entration (ppm-meters)

C CH4 = Concentration of methane (ppm-meters)

C C2H4 = Concentration of ethylene (ppm-meters)

C C3H6 = Concentration of propylene (ppm-meters)

C But = Concentration of butane (ppm-meters)

C 13But Concentration of 1,3 Butadiene (ppm-meters)

C HC = Concentration of all C5+ hydrocarbons (ppm-meters)

b) Total Hydrocarbons (weighted)



### THC
w 

### = C CH 4 

### + ( C C

2 H 4 

### × 2) + ( C C 3 H 6 

### × 3) + ( C But 

### × 4) + ( C 13 But 

### × 4) + ( C HC 

### × 5) Eq. A.1-11Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-9 Where:

THC w = Total Hydrocarbon weighted concentration (ppm-meters)

C xxx = Concentration of individual hydrocarbons as in above equation
2, 3, ...= Number of carbon atoms in each molecule

6. Flare Combustion Efficiency “Flare Combustion Efficiency” means the actual measured efficiency of converting organic carbon compounds to carbon dioxide as de termined by the following equation:

CE = CO 2 CO 2 + CO + OC Eq. A.1-12

Where: CE = Combustion Efficiency

CO 2 = Carbon Dioxide (vol. %) measured by the PFTIR immediately above the Flare Combustion Zone CO = Carbon Monoxide (vol. %) measured by the PFTIR immediately above the Flare Combustion Zone OC = Organic Carbon (vol. %) measured by the PFTIR immediately above the Flare Combustion Zone, counting each carbon molecule separately where the concentration of each individual compound is multiplied by the number of carbon atoms it contains before summing (e.g. 0. 1 volume percent ethane shall count as 0.2 volume percent OC because ethane has two carbon atoms).

7. Flare Destruction Efficiency “Flare Destruction Efficiency” means the actual measured efficiency of converting organic carbon compounds to carbon dioxide and carbon monoxide as determined by the following equation:

DE = CO 2 + CO CO 2 + CO + OC Eq. A.1-13Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-10 Where: DE = Destruction Efficiency

CO 2 = Carbon Dioxide (vol. %) measured by the PFTIR immediately above the Flare Combustion Zone CO = Carbon Monoxide (vol. %) measured by the PFTIR immediately above the Flare Combustion Zone OC = Organic Carbon (vol. %) measured by the PFTIR immediately above the Flare Combustion Zone, counting each carbon molecule separately where the concentration of each individual compound is multiplied by the number of carbon atoms it contains before summing (e.g. 0. 1 volume percent ethane shall count as 0.2 volume percent OC because ethane has two carbon atoms).Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-11 

## Appendix A.2 PFTIR Calibration and Operation

A.2-1 PFTIR Analytical Method and Procedure Gases have highly variable absorption with wavelengt h. It is this variat ion that produces the absorption patterns that allow for their identification in the infrared. If the transmission of a gas is given by τ ( ν ,T) then [1 - τ ( ν ,T)] is the amount of absorption. The radiation the gas emits at temperature T is then given by:

N

( ν, Τ ) = [1 - τ (ν ,T)] * N bb ( ν ,T) (1)
For flare measurements, it is this signal that is being detected from the hot gases above the combustion zone.
However, there are also other contributions to th e signal an analyzer “sees.” As shown in Figure A.2-1, the background (typically th e sky) has some emission, also defined by equation (2) that when transmitted through the plume and the interven ing atmosphere is seen by the analyzer. The plume emissions transmitted through this same atmos pheric path provides the signal of interest. The intervening atmosphere itself has some emis sion as does the FTIR instrument itself. These are also seen by the analyzer.

Figure A.2-1: Contributions to the measured flare radiance that must be accounted for.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-12 The total radiant signal r eceived then consists of: N total = N bkg * 

### τ flr

* 

### τ atm + N flr

* 

### τ atm + N atm +N f (2 )
In Equation (3), the arguments ν ,T have been dropped for clarity and the individual terms are:

N total = total radiance N bkg = background sky radiance


### τ flr

= flare transmissivity



### τ atm = atmospheric transmissivity N flr = flare radiance N atm = atmospheric radiance N f = radiance of the FTIR instrument itself
The actual measurements performed by the PFTIR consist of the following:

M flr = The measured plume radiance given by equation (2) M b = The measured background radian ce taken by moving the PFTIR off the flare to monitor the sky background. This is given by

M b = N bkg * 

### τ atm + N atm +N f

M n = A measurement made looking at the calibration source (see below) with a cold (liquid nitrogen ) emitter in place of the normal (black body)

M bb = A measurement made looking at the calibration source with a commercial black body emitter in the source


### τ atm = Measured atmospheric path transmission

A.2-2 From Radiance to Transmission Spectra Based on these measurements Equation (3) can be rearranged to give the plume transmission as:



### ( ) ( ) flr flr n BB atm flr flr b n BB atm 

### C
C 

# N M M N M M τ τ τ ∗ − −∗

= ∗ − −∗ (3)

In this equation, the superscrip t on the Planck f unction radiance (N BB ) denotes that this is the Planck function computed at the temperature of the flare. C is a calibration measurement made with a black body calibration source.
Atmospheric transmission 

### τ atm is also measured using the calib ration source. In this case the black body is replaced by a standard infrared source and the measurement is made at a path length roughly equal to that of the slant-path from the PFTIR to the flare.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-13 Atmospheric transmission is then given by:

0 IR n
atm 

# M M I τ −
= (4)

M IR is the measured signal from the calib ration source using the IR source and M n is the measured cold source as defined earli er. The only term not defined is I 0 . This is the so-called synthetic background. It is frequently used in open-path FTIR meas urements to convert a measured spectrum to transmission. It repres ents the shape of the spectrum that the PFTIR would measure if no gases were present. It can be synthesized from the (M IR – M n ) measurement by doing a mathematical fit to poin ts in the spectrum known to be free of molecular absorptions. An example is given in Figure A.2-2. In this Figure, the bottom plot is the measured spectrum (here a relatively clean spectrum done in the labo ratory), the middle plot the points chosen for fitting, and the top plot the mathematical fit to the chosen points. The top plot is the I o spectrum.

Figure A.2-2 Development of Synthetic Spectrum

A.2-3 Determination of Flare Temperature With Equations (4) and (5), Equation (3) then co ntains only measured or computed terms. However, to compute the Planck func tion at the temperature of the flare

f lr
BB 

# N (5)Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-14 the flare gas temperature must be known. Fortunately, this can be measured using features in the PFTIR data itself. One convenient feature is the CO band near 2150 cm -1 . Figure A.2-3 shows this band at two different temper atures. The upper plot is at am bient temperature (300 K) and the bottom plot is at 550 K. The effect of incr easing temperature is to expand the band shifting the peak position away from band center while increas ing the strength of the weaker lines farther from band center. This is a sensitive function of temperatur e, so the shape of the band essentially measures temperature.

Figure A.2-3. Structure of the Fundamental CO Ba nd at 300K (top) and 550K (bottom) Showing Alteration of Band Shape with Temperature
The CO lines arise (in emission) from a transition of the molecule from a higher vibration/rotation state to a lo wer one. The transitions are dictated by quantum mechanics. However, the intensities of the individual li nes are strongly influe nced by the number of molecules in the initial state available to make the transition. This “population” of the initial states is dictated by the Boltzmann di stribution which is given by:

" 0 2"1 " exp J J E Q kT 

## N N + −  

=     (6)

Here N j” is the number of molecules in the initia l rotational state defi ned by the rotational quantum number J”. N 0 is the total number of molecules av ailable, E” the energy of the initial state, k Boltzmann’s constant, T the absolute temp erature, and Q a “partition sum.” The partition sum is just the sum of the exponential term over all possible energy levels. If the log of thePerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-15 measured intensity of the CO lines is plotted agai nst the initial state energy, the plot is linear and its slope is proportional to

hc kT (7)

Where h is Planck’s constant and c the speed of light.
Temperature can therefore be determined by measuri ng the slope of the plot. An example of this process is shown in Figure B-5. In this case the temperature was 225 ° C and the group of lines to the left in Figure B-4 was used. These are defined as the R-branch lines of the CO band.

Figure A.2-4 Plot of the log of the measured intensity of the CO lines vs. initial state energy
Given temperature, all terms in Equation 3 ca n be determined. Equa tion 3 represents the transmission spectrum, just as would be observed if an active FTIR were used and an IR beam propagated through the plume. As a result, the same algorithms used in normal spectroscopy can be used to analyze this transmission spectrum.

A.2-4 From Transmission to Absorption Spectra As in normal absorption spectroscop y, the transmission is exponential in gas concentration. That is transmission is given by:Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-16 ( ) c l plume 

# e ν 

# τ −Κ ∗ ∗


## = (8)

Where K( ν ) is the absorption coefficient for the spectra l line, c the gas concentration, and l the path length in the gas. Effectively K( ν ) is the reference standard in the FTIR for the gas being monitored. Taking the negative log of this equation gives what is called Absorbance. For historical reasons, log base 10 is used and thus gives:
Absorbance( ν ) = (0.434)K( ν ) * c * l (9)

where the constant 0.434 is the log base 10 of e . Absorbance is linear in concentration times path length and the absorbance spectrum is anal yzed using standard Classical Least Squares (CLS) procedures to get th e individual gas concentrations in the spectrum.

A.2-5 Determination of Component Concentrations with Classical Least Squares Analysis In most real measurement scenarios, there are se veral gases present. The job of Classical least squares is to analyze a measured spectrum and de termine the concentration of all gases that have features in the spectrum. To make the job as ea sy as possible, the full spectrum is divided into analysis regions. These regions are chosen to have strong features of the gases of interest and to have as few as possible other gas features present. Because of the complexity of infrared spectra, it is not possible to find regi ons with only one compound presen t. There are always other compounds absorbing in the same region and these become interferrants in the analysis. CLS then tries to match the measured spectrum usi ng a combination of reference spectra each of which is scaled in concentration to make the ma tch as good as possible. In mathematical form this is:
(10)

The i in this equation is the da ta point number which simply counts all the data points (or wavenumber points) in the analys is region. The j sums over all the compounds present in the region. Because there will be hundreds of points (i) in any analysis region and only a small number of compounds (j) the best way to make the right side of this equation match the left side is to perform a least squares fitting. This is th e same process that is don e in fitting a curve to data points in a plot. The least squares pro cess essentially makes the difference given by
(11)
as small as possible. In reality, this is done by minimizing the sum of the square differences or
(12)
To minimize equation (12) its deri vative is taken and this derivativ e is set to zero (the condition for a minimum). In the process of doing this , two new sums appear. These are defined as:Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-17 (13)

and
(14)

In terms of these two sums the minimizing of equation (12) come s down to solving the equation:
(15)
This can be put in matrix form as:
(16)
The formal solution to this is to multip ly both sides by the inverse matrix of giving the gas concentration matrix as:
(17)
If this is put back in the form of sums it is:
(18)
The determination of gas concentrations therefor e reduces to forming the sums in equations 13 and 14, generating the inverse of the X matrix and substituting in equation 18 to compute the concentrations.
One bonus in solving by least squares is that the errors associated with the fitting can be determined. These are essentially the differenc es of equation 11. However, generally one reports the standard deviation or RM S difference. This is defined by:

(19)

Here N is the total number of data points in the region and NJ the number of concentrations being solved for. By substituting in the definition of Δ and rearranging terms, it can be shown that this can be expressed as:

(20)

All terms in this equation are as defined previously and Z jj is the j,j diagonal element of the Z matrix which is the inverse of the X matrix. What is normally reported in CLS routines is 2* σ or the 95% confidence interval.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-18 To compute combustion efficiency , the concentrations of CO, CO 2 , and total hydrocarbon (THC) are used to compute:

[soot] [THC] [CO] [CO2] [CO2] Eff + + + = (21)
The remaining term, [soot], is the concentration of any soot present. If it is present at any significant concentration, it will be seen in the IR spectra as an attenua tion of the signal with characteristic spectral shapes driven by particle size distribution. It is not believed that soot will be a significant issue in most well run flares but if it is present procedur es can be developed to treat it.

A.2-6 Additional Detail on Determinat ion of Flare Plume Temperature As stated above, transmission is given by:

(22) Absorbance is defined as the log of transmittance. For historical reasons, this is log base 10 so absorbance is:

(23)

κ ( ν ) is the absorption coefficient. It consists of the line strength and a “form factor” that is dependent on the broadening mechanism for the c onditions of the measurement. At pressures near atmospheric, the broadening is pressure broadening so the lin e shape is given by the Lorentz function. This makes equal to:

(24)

The peak of the absorption coefficient is then given by ν = :

(25)

But the line strength is given by:

(26)

The first exponential term is the Boltzman dist ribution. The second te rm is the spontaneous emission term and the final expression the qua ntum mechanical transition moment for thePerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-19 transition. Because the variation in the transition moment across the band is small, the important term is the Boltzman distribution. The Boltzman di stribution says that the line strength will vary as the initial state energy E” ratioed to Q. Wh ere Q is the sum of all the possible energy levels (E”) for the molecule. Because S will vary as:

(27)

so will For molecules like CO the initi al state energy E” is given by:

(28)

Where B v is the rotational constant for vibrationa l state v and J is the quantum number for rotational state J. Given these definitions:

(29)

Where h is Planck’s constant and c is the speed of light. Therefore the absorbance which is the log of this gives:

-log[ = (30)

This means that a plot of the peak absorbance of the lines times their half width against B v J(J+1) will be linear and the slope will be:

hc kT (31)

This is, therefore, a measur ement of the temperature.

A.2-7 Additional Detail on Q-Branch Subtraction If an absorption becomes too strong, it will satu rate (become totally absorbing), and it is not useful for spectroscopic analysis. Duri ng this test program, some of the CO 2 data points at long wavelength exhibited this problem. Rather than discard the spectra as invalid, an alternative analysis was applied, avoiding th e spectral regions considered to be invalid. This alternative analysis, referred to here as Q- branch Subtraction, is described below. All minute-by-minute CO 2 data points have the Q-branch subtracted.

In the case of CO 2 , the analytical region used is from 725 cm -1 to 765 cm -1 .This band has P, Q and R branches structures as shown in Figure A.2- 5. The Q-branch, as is typical, is narrow andPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-20 very intense compared to the P and R branches. This is because the Q-br anch consists of many overlapped lines each adding to the absorption intensity.

Figure A.2-5: CO 2 Band at 725 to 765 cm -1 Showing P, Q, and R, Branches
If absorption features are not too strong (absorba nce < 1.0 absorbance units-AU) they tend to be linear in absorbance. As they get stronger, the center of the lines become opaque (absorbance > 1.0 AU) and become very non linear. The only gr owth possible for an op aque line is in the wings which will grow more as the square root of concentration (i.e. the line just gets broader in total absorption). An example of this is shown in Figures A.2-6 and A.2-7. Figure A.2-6 shows the transmission of a very strong CO 2 band with the Q-branch becoming totally absorbing (opaque). In absorbance units the same spect rum appears as in Figure A.2-7. The opaque Qbranch has absorbance ~2.0 AU.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-21 Figure A.2-6: CO 2 Band at 725 cm -1 to 765 cm -1 Showing Q-branch Totally Absorbing near 741 cm -1

Figure A.2-7: CO 2 Band of Figure A.2-6 Converted to Absorbance (The Q-branch has absorbance ~ 2.0)

When absorbance gets too strong, the analysis will be compromised because of the slow variation of absorbance with c oncentration. To optimize the analysis method, opaque regions must be avoided. For the CO 2 band above, this means eliminating the Q-branch from the analysis when it gets too strong. An example of this is shown in Figure A.2-8. Here, the band is divided into two windows (as s hown in white) excluding the Q-br anch from analysis, shown in grey. This division of analysis windows allo ws the reliable quantif ication of much higher concentrations of CO 2 than would be otherwise possible.Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-22 Figure A.2-8: Analysis Region for CO2 Showing S ub-windows (in white) eliminating the Q-branch from the AnalysisPerformance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-23 

## Appendix A.3 VOC Emission Calculations

The CAA 114 request received by Marathon Petroleum Company required that the emissions from flares be estimated as a result of this perf ormance test. The emissions rate and destruction removal efficiency of non-methane, non-ethane or ganics are required to be submitted, along with speciated compounds in terms of ppmvd, pounds pe r hour (lb/hr) and tons per year (ton/yr).

The Passive FTIR cannot be used to determine abso lute concentrations in the flare plume. The resulting output is in terms of concentrati on x pathlength, and the pathlength remains an unknown. In fact, due to wind speed, direction, and other external fact ors, the pathlength was constantly in motion, likely changing from run av erage to run average for any given test series. Therefore, the PFTIR data cannot be used to de termine the absolute concentration or emissions rate of speciated compounds.
Marathon has prepared the following estimates of non-methane, non-ethane total VOCs in the using the following estimating technique.

) ( Nitrogen Hydrogen Methane Ethane VOC x x x x VG VG Q + + +

− =
Where,
Q voc = Flow Rate of VOC compounds (lb/hr)
VG = Total vent gas flow (lb/hr)

x i = mass fraction of component as measured by the gas chromatograph present on flare header.



### ) 1 ( DRE Q E VOC

VOC 

### − × =
Where,

E voc = Emissions rate of VOC compounds (lb/hr)

DRE = Destruction Removal Efficien cy calculated using PFTIR data.Performance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 6-24Performance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 6-25Performance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 6-26Performance Test of a Steam-Assisted Elevated FlareMarathon Petroleum Company, Texas City Main FlarePage 6-27Performance Test of a Stea m-Assisted Elevated Flare Marathon Petroleum Company, Texas City Main Flare

Page 6-28 

## Appendix A.4 Personnel Involved with Flare Performance Test

Alison Moscarillo, Marathon Ruth Cade, Marathon Brian Wilt, Marathon Elizabeth Brackin, Marathon John Bigham, Marathon J.P. Mahan, Marathon Lloyd Criss, Marathon Richard Gardin, Marathon Adolfo Yanez Jr., Marathon Eric Campbell, Clean Air Engineering Scott Evans, Clean Air Engineering Jodi Kizzee, Marathon Harold Scott, Marathon Alejandro Acuña, Marathon Katie Rickle, Marathon Todd Palmer, Marathon Melissa Seedorf, Marathon Curtis Laush, IMACC Melissa Walker, Marathon Jim Franklin, John Zink Gary Pope, John Zink Robert Spellicy, IMACC Tom Kindervater, Marathon Scott Fox, John Zink Lucy Thurston, Marathon Raul Vela, Marathon Keegan Mukabana, Marathon Peter Kaufmann, Clean Air Engineering Walter Lizard, Marathon Bill O’Donnell, Marathon Karen Utley, Marathon Jerry Isam, Marathon