# Performance Test of Steam-Assisted

and Pressure Assisted Ground Flare Burners with Passive FTIR – Garyville

Final Report

March 21, 2013

Marathon Petroleum Company, LP Garyville Refinery

4663 West Airline Highway
Garyville, LA 70051

Prepared by

Clean Air Engineering, Inc.
Project No: 12082Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 2



# Contents

1.0 Background and Summary

....................................................................................................... 4

2.0 Test Program Overview

.......................................................................................................... 15

2.1 Objectives of Test Program

................................................................................................ 15

2.2 Testing Organiza tion........................................................................................................... 15

2.3 Flare System Components

.................................................................................................. 15

2.3.1 Purpose

........................................................................................................................ 15

2.3.2 Flare Tips (Garyville Refinery)

...................................................................................... 15

2.3.3 Flare Tips (John Zink Test Facility)

............................................................................... 18

2.3.4 Vent Gas and Assist Measurement (John Zink Test Facility)

....................................... 19

2.4 Vent Gas Composition

........................................................................................................ 21

2.5 Test Series Descriptions

..................................................................................................... 22

2.6 PFTIR Testing Description

................................................................................................... 24

2.6.1 PFTIR Locations

............................................................................................................ 24

2.6.2 Video Recordings

......................................................................................................... 25

2.6.3 Preliminary Results and QA/QC

................................................................................... 25

2.6.4 Pilot Test Results

.......................................................................................................... 25

2.6.5 Traverse Results

........................................................................................................... 26

2.7 Measurements Taken During Test Program

...................................................................... 28

2.7.1 Vent Gas Composition

................................................................................................. 28

2.7.2 Net Heating Value of the Combustion Zone (NHVcz)

.................................................. 28

2.7.3 Steam to Vent Gas Ratio (S/VG)

.................................................................................. 29

2.7.4 Exit Velocity

................................................................................................................. 29

3.0 Test Series VS1 and SN1 (SKEC burners)

................................................................................ 30

4.0 Test Series SN2 (Elevated Steam

‐ Assist Flare Tip)

................................................................. 36

5.0 Test Series PA1 and PA2 (LRGO Burners)

............................................................................... 38

6.0 Comparisons to Other Steam

‐ Assisted Flare Tips

.................................................................. 40

7.0 Conclusions

............................................................................................................................ 46 Appendices

............................................................................................................................... ..... 48

A.1 Data Tables

......................................................................................................................... 48

A.2 Process Conditions

............................................................................................................. 51

A.2.1 Test Series SN1

............................................................................................................. 51

A.2.2 Test Series SN2 Nitrogen

............................................................................................. 53

A.2.3 Test Series SN2 Steam

................................................................................................. 55

A.2.4 Test Series VS1

............................................................................................................ 57

A.2.5 Test Series PA1

............................................................................................................ 59

A.2.6 Test Series PA2

............................................................................................................ 61

A.2.7 Test Series LTS

............................................................................................................. 63

A.3 Calculations

........................................................................................................................ 65Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 3

A.3.1 Vent Gas Molecular Weight

........................................................................................ 65

A.3.2 Net Heating Value of Combustion Zone

...................................................................... 65

A.3.3 Steam to Vent Gas Ratio (S/VG)

.................................................................................. 67

A.3.4 Total Hydrocarbons from PFTIR

.................................................................................. 67

A.3.5 Flare Combustion Efficiency

........................................................................................ 67

A.3.6 Tip Velocity

.................................................................................................................. 68

A.3.7 Combustion Efficiency Multiplier

................................................................................ 68

A.4 The PFTIR Test Method ‐ Description, Operation, and Analysis

........................................ 69

A.4.1 Technology Overview

.................................................................................................. 69

A.4.2 PFTIR Calibration Overview

......................................................................................... 70

A.4.3 Siting Configuration

..................................................................................................... 71

A.4.4 Operation

.................................................................................................................... 72

A.4.5 Aiming

.......................................................................................................................... 73

A.4.6 Data Reduction

............................................................................................................ 75

A.4.7 Interferences

............................................................................................................... 79

A.4.8 Data Filtering

............................................................................................................... 79

A.5 PFTIR Theory and Operation

.............................................................................................. 80

A.5.1 PFTIR Analytical Method and Procedure

.................................................................... 80

A.5.2 From Radiance to Transmission Spectra

..................................................................... 81

A.5.3 Determination of Flare Temperature

.......................................................................... 82

A.5.4 From Transmission to Absorption Spectra

.................................................................. 84

A.6 PFTIR QA/QC

...................................................................................................................... 86

A.6.1 Replicates

.................................................................................................................... 86

A.6.2 Simultaneous Runs

...................................................................................................... 87

A.6.3 Traverse Results

.......................................................................................................... 88

A.6.4 Long Term Stability Test

.............................................................................................. 90

A.7 Vent Gas Composition

........................................................................................................... 91

A.8 Personnel Involved with Flare Performance Test

.............................................................. 96

A.9 Minute Data of Runs

.......................................................................................................... 97

A.10 Video Camera Descriptions

.............................................................................................. 98

A.10.1 NEC/Mikron TH5104.................................................................................................. 98

A.10.2 FLIR A320

................................................................................................................... 99

A.10.3 Axis Q1755

............................................................................................................... 100

A.11 Video of Runs

................................................................................................................. 101

A.12 Daily Calibration Data and Spectra

................................................................................. 102

A.13 Background Times and Spectra

....................................................................................... 103

A.14 PFTIR Raw Data and Spectra

.......................................................................................... 104

A.15 Airtech Gas Chromatography Report

............................................................................. 105

A.16 John Zink Test Report

..................................................................................................... 106Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 4



# 1.0 Background and Summary

As required by Paragraph 52 of Marathon Petr oleum Company’s Flar e Consent Decree (No. 2:12-cv-11544-DML-MJH) entered on August 30, 2012, Marathon Petroleum Company (MPC) conducted performance testing on the Garyville gr ound flare burners at the John Zink test facility in Tulsa, Oklahoma from August 3 rd to August 11 th , 2012. This test was the third performance test on refinery flares by MPC, following the test s in Texas City, TX, in 2009 and Detroit, MI, in

2010.

The main objective of the test was to develop an operating envelope for both types of the John Zink burners used on the Garyvill e ground flares. These burners are deployed in multiple stages. The first four stages use the steam assist bu rners (SKEC) and the following stages use the pressure assist burners (LRGO). Each stage is triggered by increasing vent gas flow rate. Therefore, the LRGO burners only operate during high flow venting scenarios. The performance tests were conducted using Passive Fourier Tran sform Infrared (PFTIR) instruments developed by Industrial Monitor and Contro l Corporation (IMACC). The spec ific analytical method used

for these tests is the same method used and validated during testing conducted by the Texas Commission on Environmental Quality (TCEQ) in 2010. This memo summarizes the test results and compares them to results from previous flare tests.

The purpose and major benefit of an assisted flar e is to significantly reduce the amount of smoke (visible emissions) that would otherwise be cr eated by combustion. The burners tested in this program include both steam-assist and pressure-assist . In a typical system, an assist medium such as steam is injected into the flare combustion zone to deliver educted air as well as mixing energy. Pressure assisted flares rely on increased exit velocity of the flar e gas to educt more air into the gas. Over-assist is a generic descrip tion of an undesirable opera ting condition possible in assisted flare systems. For example, in an over-steaming scenario, the amount of steam and

educted air introduced into the combustion reaction zone diminish es, rather than promotes, the efficiency of the combustion process if introduced in large enough quantities relative to the flare gas flow rate.

The operating envelope of a flare is bounded by excess smoke (too little assist) on one side and decreased combustion efficiency resulting in excess emissions of volatile organic compounds (VOCs) (too much assist) on the other. Smoke suppression is easily monitored by visually observing whether smoke is present. However, th e ability to measure or even identify excess emissions caused by over-assisting is a more difficult task. Standard emission estimation techniques have generally assumed a 98% comb ustion efficiency or higher when calculating

VOC emissions from flares re gardless of assist rate.

Regulatory requirements for flares 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 States Environmental Protection Agency (US EPA) from 1983 – 1986. The requirements include maintaining a flare pilot, operating with a minimu m net heating value of 300 BTU/scf in the vent gas, operating at exit velocities of less than 60 ft/s (or up to 400 ft/s depending upon the vent gas net heating value), and operating with a limited amount of visible emissions. However, a flareMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 5

can be operated in compliance with these requirements and still have low combustion efficiency due to over-assisting.

Prior to the recent refinery tests of flare performance, including the US EPA tests in the mid1980s, flare tests were conducted on pilot-scale test flares or on fl ares operating 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 operating condition requires the operator to flare waste gas. Thus, the flare normally operates at high turndown for the majority of the operating year, a condition for which there was little to no available performance data.

In the past, measuring the combustion products from a flare was difficult and dangerous. However, recent technological advances have pro duced remote sensing instruments capable of measuring combustion products such as car bon dioxide, carbon monoxide, and select hydrocarbons without the safety hazards introduced by physically sampling a flare plume. One such instrument is the PFTIR, which characteri zes a plume’s chemical make-up (carbon dioxide, carbon monoxide, and total hydrocarbons) in unit s of concentration × pathlength. Using this technology, the absolute concentrat ion cannot be determined from a flare plume, but the product of concentration × pathlength (e .g., ppmv × meters), can be used in combustion efficiency

calculations. The PFTIR is a re latively new tool and was recently blind-validated against extractive sampling results for flare plume testin g by TCEQ and the University of Texas in 2010. The PFTIR was first used for refinery flare te sting at MPC Texas City in 2009. Several accuracy, precision, and bias checks were performed during th e recent flare tests to better characterize the PFTIR measurement technique.

Because of the practical and logi stical difficulties of conducting a test of a ground flare at an actual refinery, this test program was carried out on a test cell at the John Zink test facility in Tulsa, Oklahoma. Three burners of each type were tested each identical to the burners installed at the Garyville facility.

Figure 1-1: John Zink Test Stand (s howing SKEC burners installed).Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 6

Combustion efficiency was measured under severa l combinations of vent gas composition and flare operating parameters. Each of these combinati ons is referred to as a “test condition” in this report. The following test conditions were used during this project.

Test SN1 SKEC Steam-assist burners. 100% Tulsa natural gas (TNG) Objective: To determine the performance cu rve of the burner at the minimum flow rate.

Test SN2 Large steam-assisted flare tip. 20/80 TNG/propylene Objective: To determine if ni trogen dilution and steam dilution have the same effect on combustion efficiency.

Test VS1 SKEC Steam-assist burners. Velocity Screening Test Variable TNG/nitrogen mix Objective: To identify the minimum NHVcz need ed to maintain a flame over a range of exit

velocities.

Test PA1 LRGO Pressure-assist burn ers. Variable TNG / nitrogen mix. Objective: To determine the minimum NHVcz th at supports good combustion at sonic velocity.

Test PA2 LRGO Pressure-assist burn ers. Variable TNG / nitrogen mix. Objective: To determine the minimum NHVc z that supports good co mbustion at minimum velocity.

The PFTIR performance test conducted on J ohn Zink’s SKEC burners, LRGO burners, and elevated steam flare produced va luable insights into the efficiency performance of ground flare burners under a variety of conditions. Tests we re conducted while flaring gases containing a mixture of Tulsa natural gas (T NG), propylene, and nitrogen. For the results presented below, relationships between combus tion efficiency and other pa rameters were analyzed:

 VG Composition – Composition of the gas be ing sent to the flare tip

 NHVcz – Net heating value of the combustion zone gas (BTU/scf)

 S/VG – Actual steam to vent gas ratio (lb steam/lb vent gas) or (scf steam/scf vent gas)

 Exit Velocity – Velocity of gases exiting the flare tipMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 7

A summary of results from the VS1 and SN1 test s is shown in Figures 1-2 through 1-8 below.

Figure 1-2: NHVcz vs. CE for SN1 & VS1 (SKEC Burners)

Figure 1-3: NHVcz vs. CE for SKEC Burn ers & Other Base Load Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 8

Figure 1-4: S/VG (lb/lb) vs. CE for SN1 & VS1 (SKEC Burners)

Figure 1-5: S/VG (lb/lb) vs. CE for SKEC Burners & Other Base Load Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 9

Figure 1-6: S/VG (scf/scf) vs. CE for SN1 & VS1 (SKEC Burners)

Figure 1-7: S/VG (scf/scf) vs. SKEC Burners & Other Base Load Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 10

Figure 1-8: Tip Velocity vs. Minimum NHVcz (SKEC Burners)

A summary of results from the SN2 test is shown in Figure 1-9 through 1-11 below.

Figure 1-9: NHVcz vs. CE for SN2Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 11

Figure 1-10: S/VG (Mass Basis) vs CE for SN2

Figure 1-11: S/VG (Volume Basis) vs CE for SN2Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 12

Finally, a summary of results from the PA1 and PA2 tests is shown in Figures 1-12 and 1-13

below.

Figure 1-12: NHVcz vs. CE for PA1 & PA2 (LRGO Burners)

Figure 1-13: Tip Velocity vs. NHVcz for LRGO BurnersMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 13

Addition details for each of thes e tests are found in the Results section within the main body of this report.



### Conclusions
The PFTIR test of the SKEC burners, LRGO burners, and elevated steam flare provided data to support the following conclusions.

SKEC Burners

 When TNG is used as fuel, the SKEC burners maintain high combustion efficiency until

NHVcz falls to less than 300 BTU/scf. This is consistent with past PFTIR studies on steam-assisted flare tips.

 The SKEC burners maintain high combustion efficiency at exit velocity limits higher than those established by 40 CFR 60.18 and 63.11. At velocities greater than 60 ft/sec and up to sonic (maximum) velocity, the burne r operates efficiently until the NHVcz falls to a point where the flame is extinguishe d. Therefore, the SKEC burners should be exempt from the velocity limits established in 40 CFR 60.18 and 63.11.

 The S/VG does not appear to be a factor fo r the SKEC tip until th e exit velocity falls below 60 ft/s. Therefore, when operating at ve locities greater than 60 ft/s, an S/VG limit should not apply to the SKEC burners. At velo cities less than 60 ft/s, a S/VG limit of 3 lb/lb or 3 scf/scf could be used by the SKEC burners to assure high combustion efficiency.

 The test data suggests that a Combustion E fficiency Multiplier of 6.37 would be required to maintain 98% combustion efficiency on the North and South Ground Flares. Paragraph

46 of MPC’s flare consent decree states th at as of June 20, 2017, the North and South Ground Flares will be subject to a Combusti on Efficiency Multiplier of 7.1. This appears to be higher than what is required to maintain 98% combustion efficiency.

LRGO Burners

 When TNG is used as fuel, the LRGO burners maintain high combustion efficiency until the NHVcz falls to a point where the flame is extinguished. Under all conditions tested, these burners maintained an average CE equal to or greater than 99%. Under all conditions tested, the flame extinguishes at an NHVcz of approximately 550 BTU/scf. This test program demonstrated that as long as the LRGO burners are lit, they maintain high combustion efficiency. To ensure the LRGO burners are operating at high combustion efficiency, the NHVcz of the LRGO burners should be kept above 550 BTU/scf. This eliminates any need for Combustion Efficiency Multipliers.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 14

 The LRGO burners maintain high combustion e fficiency at exit velocities much higher than those allowed by 40 CFR 60.18 and 63.11. The flares operated efficiently at velocities up to sonic whic h would represent the maxi mum velocity achievable. Therefore, the LRGO burners should be exempt from the velocity limits established in 40

CFR 60.18 and 63.11.

Elevated Steam-Assist Flare

 When steam was used as a diluent, combus tion efficiency dropped off significantly when

NHVcz was reduced below about 300 BTU/scf. This is consistent with past PFTIR studies on large, elevated steam-assisted flare tips. However, when nitrogen was used as a diluent, combustion efficiency did not si gnificantly decline un til NHVcz reached about

200 BTU/scf. The results of this test show a potential difference between the effects of steam dilution and nitrogen dilution on flare combustion efficiency. It should be noted however, that this data conflic ts with other data on nitrog en vs. steam dilution collected in previous tests. More study may be needed to resolve this issue.

Effect of Pilots

 The presence or absence of a pilot does not a ppear to significantly affect the performance of the burners, either positively or negatively.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 15



# 2.0 Test Program Overview

2.1 Objectives of Test Program

The overall objectives of the Garyvi lle test program were as follows:

1. Demonstrate that the John Zink LRGO pre ssure-assisted and SK EC steam-assisted burners can achieve compliance with necessary combustion efficiency requirements at velocities greater than 400 ft/s.

2. Determine the minimum NHVcz that will achieve necessary combustion efficiency requirements on the LRGO pressure-assisted burners.

3. Determine the proper steam-assisted operati ng envelope in terms of NHVcz for the

SKEC steam-assisted burners.



## 2.2 Testing Organization

The test was conducted with the assistance of Cl ean Air Engineering, Industrial Monitoring and Controls Corporation (IMACC), and John Zink.

Clean Air Engineering IMACC John Zink 500 W Wood St. 800 Paloma, Suite 100 11920 East Apache Palatine, IL 60067 Round Rock, TX 78645 Tulsa, OK 74116

Because the test required personnel from John Zi nk’s operations, maintenance, and engineering staff, a cross-functional team was formed be tween IMACC, Clean Air Engineering, John Zink, and MPC in order to staff, m onitor and record test results.



## 2.3 Flare System Components

2.3.1 Purpose A flare is one of the most important safety device s in use at a refinery. Its purpose is to safely combust gases generated by emergency or upset c onditions within a process unit. As a result, a flare must function over a large and variable range of operating scenarios. These vary from typical stand-by operation at minimum flow conditi ons to efficiently com busting gases generated from a full power outage or other process safety relief scenario.

Like the Texas City and Detroit flare tests, th e Garyville test addre ssed the normal (i.e., high turndown) operating range. However, the Garyvill e test also included some high flow scenarios. The LRGO burners are only operated during high flow scenarios.

2.3.2 Flare Tips (Garyville Refinery) Garyville constructed two ground flares as part of the Garyville Major Expansion (GME) project in 2008-2009. The ground flares consist of multiple rows of stages, each having multiple burners per row. The first four stages on each ground flare include steam-assist burners, while stages fiveMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 16

and above are pressure-assist burners. The GME North Ground fl are has a total of 10 stages, while the South Ground flare has a total of 8 stag es. Each has an additional maintenance row. The first stage of each flare is always in se rvice. The remaining stages are opened based upon pressure, with advanced programming logic that opens staging valves to successive stages. The steam-assisted burners are SKEC burners, and pressure-assisted burners are LRGO burners. Tables 2.3.2-1 and 2.3.2-2 list design speci fications for the SKEC and LRGO burners.

Figure 2.3.2-1: Left - SKEC Burner. Right - LRGO Burner.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 17



### SKEC Burners

Flare Tip Details

Flare Tip Manufacturer John Zink

Flare Tip Installation Date 2008

‐ 2009

Flare Tip Size 4.64 sq. in. exit area per burner

Flare Tip Model Number SKEC 

### Summary of Flare Design Information

Parameter Value Units

First Stage Design Purge Rate (continuous) per burner 0.833 scfm

Non

‐ First Stage Design Purge Rate (min) per burner 7.9 scfm

Non

‐ First Stage Design Purge Rate (max) per burner 19.26 scfm

Pilot Rate (per pilot) 50 scfh

North Ground Flare Minimum Hydraulic Capacity per burner 4123 lb/hr

North Ground Flare Maximum Hydraulic Capacity per burner 4206 lb/hr

South Ground Flare Minimum Hydraulic Capacity per burner 3475 lb/hr

South Ground Flare Maximum Hydraulic Capacity per burner 3798 lb/hr Table 2.3.2-1: SKEC Burner Specifications



### LRGO Burners

Flare Tip Details

Flare Tip Manufacturer John Zink

Flare Tip Installation Date 2008

‐ 2009

Flare Tip Size 3.11 sq. in. exit area per burner

Flare Tip Model Number LRGO

‐ D 

### Summary of Flare Design Information

Parameter Value Units

Design Purge Rate (min) per burner 7.28 scfm

Design Purge Rate (max) per burner 26.9 scfm

Pilot Rate (per pilot) 50 scfh

North Ground Flare Minimum Hydraulic Capacity per burner 4237 lb/hr

North Ground Flare Maximum Hydraulic Capacity per burner 4280 lb/hr

South Ground Flare Design Hydraulic Capacity per burner 2909 lb/hr

Table 2.3.2-2: LRGO Burner SpecificationsMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 18

2.3.3 Flare Tips (John Zink Test Facility) Because of the practical and logi stical difficulties of conducting a test of a ground flare at an actual refinery, this test program was carried out on a test cell at the John Zink test facility in Tulsa, Oklahoma. Three burners of each type were tested each identical to the burners installed at the Garyville facility.

Figure 1-1: John Zink Test Stand (s howing SKEC burners installed).

The SN2 test series was conducted on an elevated steam-assist flare tip. This is the same flare tip used for the flare study conducte d by TCEQ and the University of Texas. Table 2.3.2-3 lists design specifications for this flare tip.

Figure 2.3.2-2: Elevated Steam-Assist Fl are Tip used for Test Series SN2Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 19



### Elevated Steam-Assist Flare Tip

Flare Tip Details

Flare Tip Manufacturer John Zink

Flare Tip Size 36 sq. in.

Flare Tip Model Number EEF

‐ QSC

‐ 36 

### Summary of Flare Design Information

Parameter Value Units

Pilot Rate (per pilot) 86 scfh

Maximum Hydraulic Capacity (Propylene) 937,000 lb/hr

Table 2.3.2-3: Elevated Steam-A ssist Flare Specifications

2.3.4 Vent Gas and Assist Measurement (John Zink Test Facility) Table 2.3.3-1 lists the equipment used by Airtech Environmental Services to measure the vent gas composition. Table 2.3.3-2 lists the instruments used to monito r and control the vent gas and process conditions during the test campaign.

Equipment Information Manufacturer Model Gas Chromatograph with FID Detector Hewlett Packard 5890 Series II Analytical Column Agilent Technologies HP-Plot/Q Gas Chromatograph with TCD Detector SRI 8610A Analytical Column Suppelco 60/80 Carboxen 1000 Table 2.3.3-1: Gas Chromatography EquipmentMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 20

4” Auto Meter Run (Propylene and Natural Gas)
Instrument Description Instrument
4” Static Pressure Transmitter Rosemount 3051TG 4” Temperature Element Type K Thermocouple 4” Temperature Transmitter Rosemount 3144D 4” Flow Transmitter (Differential Pressure) Rosemount 3051CD 10” Auto Meter Run (Large Natural Gas Flows)
Instrument Description Instrument
10” Static Pressure Transmitter Rosemount 3051CG 10” Temperature Element Type K Thermocouple 10” Temperature Transmitter Rosemount 3144D 10” Flow Transmitter (Differential Pressure) Rosemount 3051CD 1” Portable Meter Run (Small Natural Gas Flows)
Instrument Description Instrument
Multivariable Flow Transmitter Rosemount 3095MA Temperature Element 100 Ohm Pt. RTD 3” Manual Meter Run (Vaporized Nitrogen Flows)
Instrument Description Instrument
Multivariable Flow Transmitter Rosemount 3095MA Temperature Element 100 Ohm Pt. RTD 4” Manual Meter Run (Small Nitrogen Flows)
Instrument Description Instrument
Multivariable Flow Transmitter Rosemount 3095MA Temperature Element 100 Ohm Pt. RTD

Steam Flow
Instrument Description Instrument
Ultrasonic Steam Flow Transmitter GE GS868 Gage Pressure Transmitter Rosemount 3051CG Temperature Element Type K Thermocouple Temperature Transmitter Rosemount 3144PD
Center Steam on 36” QS Steam-Assisted Burner
Instrument Description Instrument Gage Pressure Transmitter Rosemount 3051CG Temperature Element Type K Thermocouple Fuel Manifold (SKEC and LRGO Burners)
Instrument Description Instrument Gage Pressure Transmitter Rosemount 3051CG Temperature Element Type K Thermocouple



### Weather

Instrument Description Instrument Barometric Pressure Sensor R. M. Young 61302L Wind Speed & Direction Instrument R. M. Young 05103 Table 2.3.3-2: John Zink Process Control EquipmentMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 21



## 2.4 Vent Gas Composition

The vent gas composition was determined by both the John Zink flow measurements on the individual gas streams and also by gas chroma tography (GC). Airtech Environmental Services Inc. (Airtech) was contracted to analyze the ve nt gas composition by GC. At the beginning of the test (8/2-8/4, 2012), Airtech found i ssues with the stability of th e GC-TCD analyzer. This issue affected the ability of the GC to accurately measure CO 2 and nitrogen concentrations. Temperature changes within the mobile traile r contributed to the problems. An extra air conditioner was brought into the traile r to stabilize the temperature.

Figure 2.4-1 shows differences between the Airtech GC measurement and the John Zink flow

measurements on each run. Because the Airtec h GC and John Zink flow measurements were very different on 8/3-8/4 and because there were problems with the GC calibration and temperature stability on these days, John Zink flow measurements were used to determine the fuel composition on 8/3-8/4 (SN2 test series). Al so, John Zink flow measurements were used to determine fuel composition for VS1 2 (1) and the long term stability tests as there were no GC samples taken during these runs. The fuel for th e SN1 test series was pure Tulsa Natural Gas (TNG). The fuel composition measurements from the SN1 test were averaged to determine the composition of TNG. This average TNG compositi on was applied to the TNG flow for the runs

where John Zink flow measurements were used instead of the GC measurements. During the early stages of testing, EPA approved the use of the John Zink flow measurements to determine vent gas composition.

Figure 2.4-1: Differences between AirTech and John Zink Vent Gas MeasurementsMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 22



## 2.5 Test Series Descriptions

Each test series is conducted with a different te st gas composition or flow rate. Within each test, the Net Heating Value in the combustion zone (NHV cz) or the Net Heating Value of the vent gas (NHVvg) was varied as specified below. In additi on, with EPA’s approval, the actual test series were slightly modified from the descriptions co ntained in the Consent Decree. These changes are noted in the test series descriptions along with the reasons for the changes.

Test SN1 SKEC Steam-assist burners. 100% TNG Objective: To determine the performance cu rve of the burner at the minimum flow rate. Vent gas flow was set at the lowe st achievable flow rate (~4 f t/sec exit velocity). Steam assist

was varied. The initial test c ondition was set at the minimum st eam rate (cooling steam rate). Subsequent test conditions incr eased the steam rate to achieve successively lower NHVcz values until a combustion efficiency of <93% was m easured or until the flame was extinguished. Combustion efficiency did not drop below 93% until NHVcz was reduced to 100 BTU/scf. . Full

20-minute test runs with replicates were conducted.

Test SN2 Large steam-assisted fl are tip. 20/80 TNG / propylene Objective: To determine if ni trogen dilution and steam dilution have the same effect on combustion efficiency. In the velocity screening tests, both steam and nitrogen are used to maintain a target NHVcz. This test determines whether the assumption that nitrogen and steam have equivalent effect on combustion efficiency is correct. Testing wa s performed on the John Zink steam assisted elevated flare tip used for the TCEQ study re ferenced above. The test was conducted in two phases. First, the NHVcz was lowered by dilution with nitrogen in steps from about 350 Btu/scf to the point at which combusti on efficiency dropped below 93%. In the second phase, the same test conditions were repeated with center steam as the diluent. No upper steam was used. 10-

minute test runs were conducted. There were no replicate runs for this test. A 20/80 TNG/propylene mix was used in this test to be more representative of actua l refinery waste gas.

Test VS1 SKEC Steam-assist burners. Velocity Screening Test Variable TNG/nitrogen Mix Initial Objective: To identify a rough operating cu rve showing the 98% CE as a function of exit velocity and NHVcz

Initial Test Plan: This test will establish a rough operating region to be used for Test VS2. The Test will begin at sonic ve locity, 100% TNG (~900 BTU/scf), and no steam or nitrogen dilution (minimum steam off). NHVcz will be lowered in 100 BTU/scf increments through steam and/or nitrogen dilution until combustion efficiency (CE) drops below 98%. At this point, NHVcz will be held constant while exit velocity decreases in 100 fps increments. This

will continue until CE rises above 98%. At this point, the cycle repeats – holding exit velocity constant and reducing NHVcz until the next “c rossover” point then holding NHVcz constant and decreasing exit velocity. This procedure will be repeated until minimum (baseline) exit velocity is reached. At each point, the NHVcz and exit velocity will be “tuned” to dial in a more precise 98% CE point. The end result will be a series of points defining the 98% CEMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 23

curve as a function of exit velo city and NHVcz. For this rough screening test, runs will be a minimum of 10 minutes in length with no replicates.

Modified Objective: To identify the minimum NHVcz needed to maintain a flame over a range of

exit velocities. Modified Test Plan: The objective of the VS1 tests as describe d in the original test plan was to identify a rough operating curve showing the 98% CE as a function of exit velocity and NHVcz. However, it was evident after the first few test runs that the flame would almost always extinguish before the combustion efficiency drop ped below 98%. At this point, given the test results, it was evident that the original plan was unworkable. A decision was made to change the objective of the VS1 test to identify the minimu m NHVcz necessary to main tain a flame at each exit velocity tested. VS1 repli cates were then performed at the identified minimum NHVcz values. The test began at sonic velocity and 100% Tulsa natural gas (~900 Btu/scf). NHVcz was lowered in 100 Btu/scf increments through stea m and/or nitrogen dilution until the flame was extinguished. This point is then established as the minimum NHVcz needed to maintain a flame at this velocity. The NHVcz was then lowered by 100 Btu/scf for the next test and exit velocity was lowered in 100 fps increments until the flame was extinguished again. This process was

continued to establish the minimum NHVcz needed to maintain a flame over an exit velocity range from sonic down to 4 fps. 10-minute test r uns with selected replic ates were conducted.

Test VS2 SKEC Steam-assist burners. Velocity Screening Test Initial Objective: To establish a robust operating curve showing the 98% CE as a function of exit velocity and NHVcz.

Initial Test Plan: At each of the “crossover” points identified in Test VS1, full 20-minute test runs with replicates will be conducted. At severa l points, curve sensitivity will be determined by sampling at operating conditions slightly above and below the curve. The number of sensitivity points will be determined by how many crossover points are identified. Sensitivity points will be a minimum of 10 minutes with no replicates.

Modified Test Plan: This test series was eliminated becau se the flame was extinguished before CE dropped below 98% during Test VS1. Therefore, it was not possible to establish an operating curve showing 98% CE as a function of exit velocity and NHVcz. To replace VS2, replicate runs were added to the modified Test VS1.

Test PA1 LRGO Pressure-assist burn ers. Variable TNG / nitrogen mix. Objective: To determine the minimum NHVcz th at supports good combustion at sonic velocity.

Initial Test Plan: Operation at maximum (sonic) velocity (~13 pounds pressure) at multiple vent gas NHVcz levels. Initial test was conducted with 100% Tulsa natural gas (~900 Btu/scf). Subsequent test conditions added nitrogen to the fuel to reach successively lower NHVcz values until a combustion efficiency of <93% was reached. In all cases, the flame was extinguished

before the CE level of 93% was reached. Full 20-minute test runs with replicates were

conducted.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 24

Modified Test Plan: The test series was modi fied slightly, although the objective remained the same. The first test point was conducted at an NHVcz of 900 BTU/scf and th e second test point

was conducted at a NHVcz of 600 BTU/scf. At bot h points, the CE was greater than 99%. Because the CE for both points was greater than 99%, it was decided there was no need to test

the LRGO burners at the intermediate NHVcz values of 800 BTU/scf and 700 BTU/scf. The flame was extinguished when the NHVcz reached 550 BTU/scf.

Test PA2 LRGO Pressure-assist burn ers. Variable TNG / nitrogen mix. Objective: To determine the minimum NHVc z that supports good co mbustion at minimum velocity.

Initial Test Plan: Operation at minimum velocity (~4 pounds pressure) at multiple vent gas

NHVcz levels. Initial test was conducted with 100% Tulsa natural gas (~900 Btu/scf). Subsequent test conditions added nitrogen to the fuel to reach successively lower NHVcz values until a combustion efficiency of <93% was reached. In all cases, the flame was extinguished

before the CE level of 93% was reached. Full 20-minute test runs with replicates were

conducted.

Modified Test Plan: The test series was modi fied slightly, although the objective remained the same. The first test point was conducted at an NHVcz of 900 BTU/scf and th e second test point

was conducted at a NHVcz of 600 BTU/scf. At bot h points, the CE was greater than 99%. Because the CE for both points was greater than 99%, it was decided there was no need to test

the LRGO burners at the intermediate NHVcz values of 800 BTU/scf and 700 BTU/scf. The flame was extinguished when the NHVcz reached 550 BTU/scf.



## 2.6 PFTIR Testing Description

The IMACC instrument used to determine gas composition of the flare plume for each test

condition listed in Section 2.5 is the Passive Fourier Transform Infrared (PFTIR) analyzer. PFTIR analysis operates on the principle of spectral analysis of thermal radiation emitted by hot gases. Passive means that no “active” infrared li ght source is used. Instea d, the hot gases of the flare are the infrared source. The spectrometer is a receiver only. This approach is possible because the infrared emission spec tra of hot gases have the same patterns or “fingerprints” as their absorption spectra do. Conse quently, observing a flare with an infrared instrument allows for identification and quantific ation of species through emissi on spectroscopy just as with absorption spectroscopy. A detailed description of the instrument and testing procedures are found in Appendix A.4 and A.5.

2.6.1 PFTIR Locations

Two PFTIR instruments were used for this test program. The locations of the PFTIR instruments were carefully selected with the intent of ensuring a good view of the flare plume regardless of

wind direction.

For the test series on the SKEC and LRGO burner tips, the PFTIR 1 location was inside a trailer northeast of the burner set up. For the SN2 test se ries, the PFTIR 1 location was inside a trailer just northwest of the control r oom. For all test series, the PFTIR 2 location was inside a trailer just south of the control room. Both PFTIRs were operated from the trailers. Both PFTIRsMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 25

collected data during a run for simultaneous readings. However, only some runs had simultaneous readings due to high flow conditions and computer malfunctions.

Figure 2.6.1-1 shows maps of the PFTIR locatio ns in relation to the flares. Appendix A.4.2

contains more detailed information about each PFTIR location.

Figure 2.6.1-1: Maps of the PFTIR Location s in Relation to SKEC/LRGO and Elevated Steam-Assist Flare Tips

2.6.2 Video Recordings During the test program, video cameras recorded flare activity from both PFTIR locations. At each location, one stationary visible light camera and one stationary infrared light camera were recording the flare tip. Additionally, one in frared camera was mounted on each PFTIR and recorded the aiming position of each PFTIR. The t ypes of cameras used during the test program are listed in Appendix A.10

.

2.6.3 Preliminary Results and QA/QC On-site preliminary combustion efficiency resu lts were computed. On-site replicate and run length decisions were made with the preliminary combustion efficiency results. By design, these preliminary results did not take into acc ount the sky backgrounds, compound lists, and interferents that are incorporat ed after the test program is co mplete (see Appendix A.4.9). Thus, the final combustion efficiency results may change from field measurements.

To ensure useable combustion efficiency result s from the PFTIR, serveral QA/QC tests were performed during the test program. These tests in cluded simultaneous measurements, a pilot test series, and multiple traverses. Appendix A.6 contains data from these QA/QC tests.

2.6.4 Pilot Test Results In order to determine whether or not the pi lot had any measureable effect on combustion efficiency, combustion efficiency was measured on the SKEC burners with NHVcz set at 400 BTU/scf and exit velocity set at 20 ft/s. Data wa s collected first with th e pilot lit, and second with the pilot off. Figure 2.6.4-1 shows the results of the pilot test. From this test, it is clear that the pilot does not play a signifi cant role in maintaining good combustion efficiency on the SKECMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 26

burners. The average combustion efficiency with the pilot lit was 98.1%. The average combustion efficiency with the pilot off was 98.6%.

Figure 2.6.4-1: Pilot Test Results

2.6.5 Traverse Results The optimum aiming point for the PFTIR is typica lly about one flame length from the flame tip. This insures that all combustion is complete prior to measurement. Optimal aiming position is monitored by observing the intensity of the CO 2 and CO lines in the single beam spectrum and the effects on the resulting absorbance spectrum. This is done to avoid detector saturation.

When the flare is obviously lit but the PFTIR reports a combustion efficiency of 0%, this indicates improper aiming of the PFTIR. A combus tion efficiency measurement of 0% when the

flare is lit indicates that the PFTIR is unable to measure CO 2

.

In order to determine how sensitive aiming posit ion is with respect to determination of combustion efficiency, a traverse along the plum e path was conducted. During this traverse, the PFTIR was gradually moved farther from the fl ame tip while measuring combustion efficiency under constant conditions. Figure 2.6.5-1 shows th e result of the VS1 traverse. Both PFTIRs participated in the VS1 traverse. The VS1 traver se conditions were the same conditions used in the VS1 6 test runs. Figure 2.6.5-2 shows examples of PFTIR aiming positions.

The traverse shows that as l ong as the PFTIR is aimed between the flame tip and one flame length from the flame tip, the PFTIR combustion efficiency measurements will be relatively consistent. However, if the PFTIR aiming position is farther than one flame length away from the flame tip, the signal to noise ratio may dr op to a point where the PFTIR cannot effectively measure combustion efficiency.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 27

Figure 2.6.5-1: VS1 Traverse Results

Figure 2.6.5-2: Example Aiming PointsMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 28



## 2.7 Measurements Taken During Test Program

The PFTIR performance test conducted on J ohn Zink’s SKEC burners, LRGO burners, and elevated steam flare produced va luable insights into the efficiency performance of ground flare burners under a variety of conditions. Tests we re conducted while flaring gases containing a mixture of Tulsa natural gas (T NG), propylene, and nitrogen. For the results presented below, relationships between combus tion efficiency and other pa rameters were analyzed:

 VG Composition – Composition of the gas be ing sent to the flare tip

 NHVcz – Net heating value of the combustion zone gas (BTU/scf)

 S/VG – Actual steam to vent gas ratio (lb steam/lb vent gas) or (scf steam/scf vent gas)

 Exit Velocity – Velocity of gases exiting the flare tip

These parameters were selected because they can potentially be us ed during normal flare operation to maintain high combustion efficiency . Paragraph 53 of MPC’s Flare Consent Decree required that these measurements were made during the test program. Analysis of the combustion efficiency results from the PFTIR duri ng this test established a relationship between combustion efficiency and these parameters. De scriptions of the calculations for these parameters are contained in Appendix A.3.

2.7.1 Vent Gas Composition Vent gas composition is measured so that NHVcz can be determined. Vent gas composition

cannot be used alone in a flare control scheme because it does not take into account any assist media that is added downstream of the measurement point.

Section 2.4 explains how VG co mposition was measured. Secti on 2.5 describes the vent gas compositions for each test series.

2.7.2 Net Heating Value of the Combustion Zone (NHVcz) NHVcz may be used as a control parameter for flare operation. The relationship between NHVcz and combustion efficiency has a wider scope and ta kes into account more process variables than a steam-based parameter. For example, inerts in the vent gas are taken into account for the NHVcz calculation so the relationship to combustion efficiency remains valid when inerts are variable in the vent gas. NHVcz requires the flare operator to measure vent gas composition. Using a GC, vent gas composition may only be m easured in 10+ minute increments due to the lengthy analytical cycle.

NHVcz, which includes total assist media to the fl are tip, is a calculated term representing the net heating value of all components in the combusti on zone. The combustion zone is directly above the flare tip and is the poin t at which all materials combine for combustion. The NHVcz is

therefore the resultant heat content from the mixtur e of the vent gas from the flare header and the

total assist media.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 29

2.7.3 Steam to Vent Gas Ratio (S/VG) S/VG can be used to supplement a flare contro l scheme but cannot be used alone since it does

not take into account the effects of inerts in the vent gas. Es tablishing a relationship between S/VG and combustion efficiency enables flare oper ators to better program steam control logic to improve combustion efficiency.

2.7.4 Exit Velocity Exit velocity can impact flare performance by contributing to flame instability. For some burners, a relationship between vent gas compos ition (NHVcz, LFLcz), assist media (S/VG), exit velocity, and combustion efficiency may be established to minimize flame instability.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 30



# 3.0 Test Series VS1 and SN1 (SKEC burners)

The fuel gas for both test series was TNG. The VS1 test began at sonic velocity and a NHVcz of 900 BTU/scf. Tip velocity and NHVcz were adjusted incrementally to determine an acceptable operating envelope for the SKEC burners. NHVcz was controlled with both steam and nitrogen injection. For the VS1 test series, CE remained relatively constant at a high level until the flare

went out. The SN1 tests were c onducted at a tip velocity of 4 fps. NHVcz was lowered from 300

BTU/scf to 50 BTU/scf in 50 BTU/scf increments using steam injection. For the SN1 test series, the flare did not extinguish and combustion effi ciency showed significant decline around NHVcz

levels of 300 BTU/scf and S/VG levels of 3 lb/lb or 3 scf/scf. This is consistent with past PFTIR studies on steam-assisted flare tips.

Figure 3.0-1 shows the relationship between NHV cz and CE. Figure 3.0-2 shows the relationship

between NHVcz and CE for the SKEC burners with past base load test series. Figure 3.0-3 shows the relationship between S/VG (mass basi s) and CE. Figure 3.0-4 shows the relationship between S/VG (mass basis) and CE for the SKEC bur ners with past base load test series. Figure 3.0-5 shows the relationship between S/VG (vol ume basis) and CE. Figure 3.0-6 shows the relationship between S/VG (volume ba sis) and CE for the SKEC burners with past base load test series. Figure 3.0-7 shows the minimum NHVcz require d to maintain a flame over a range of exit

velocities. These values are co mpared to the EPA velocity limits from 40 CFR 60.18 and 63.11.

The test results show that the SKEC burners are capable of maintaining very high combustion efficiency at velocities exceeding th e limits established by 40 CFR 60.18 and 63.11.

Paragraph 53d of the MPC Flare Consent Decree requires MPC to propose Combustion Efficiency Multipliers for calculating the NHV cz-limit for the North and South Ground Flares. Using daily vent gas composition data for bot h the North and South Ground flares from 3/7/2012 – 3/17/2013, an average net heating value of th e vent gas at its lower flammability limit (NHV vglfl ) was determined. NHV vg-lfl can be used to determine a ppropriate Combustion Efficiency Multipliers for the North and South Ground Flares . Table 3.0-1 contains average vent gas concentrations and other calculated parameters for both the North and South Ground Flares. In the future, the South Ground Flare vent gas com position will resemble the North Ground Flare vent gas composition. Therefore, the North a nd South Ground Flares should use the same Combustion Efficiency Multiplier. The test da ta suggests that a Combustion Efficiency Multiplier of 6.37 would be required to maintain 98% combustion efficiency on the North and South Ground Flares. Paragraph 46 of MPC’s flare consent decree states that as of June 20, 2017, the North and South Ground Flares will be s ubject to a Combustion Efficiency Multiplier of 7.1. This appears to be higher than what is required to maintain 98% combustion efficiency.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 31

Figure 3.0-1: NHVcz vs. CE for SN1 & VS1 (SKEC Burners)

Figure 3.0-2: NHVcz vs. CE for SKEC Bu rners & Other Base Load Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 32

Figure 3.0-3: S/VG (lb/lb) vs. CE for SN1 & VS1 (SKEC Burners)

Figure 3.0-4: S/VG (lb/lb) vs. CE for SKEC Burners & Other Base Load Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 33

Figure 3.0-5: S/VG (scf/scf) vs. CE for SN1 & VS1 (SKEC Burners)

Figure 3.0-6: S/VG (scf/scf) vs. SKEC Bu rners & Other Base Load Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 34

Figure 3.0-7: Tip Velocity vs. Minimum NHVcz for SKEC BurnersMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 35

Compound South Ground

Flare North Ground

Flare

Oxygen (mol %) 0.02 0.10

Carbon Monoxide (mol %) 0.00 0.02
Nitrogen (mol %) 1.99 6.53

Carbon Dioxide (mol %) 0.06 0.86
Hydrogen (mol %) 86.43 16.78

Methane (mol %) 7.00 62.47
Acetylene (mol %) 0.00 0.00
Ethylene (mol %) 0.10 0.29

Ethane (mol %) 2.02 5.24
Propylene (mol %) 0.13 0.30

Propane (mol %) 1.09 3.02

Iso

‐ butane (mol %) 0.23 0.69

N

‐ butane (mol %) 0.19 0.78

1

‐ butene (mol %) 0.02 0.10

Trans

‐ butene (mol %) 0.00 0.04

Cis

‐ butene (mol %) 0.00 0.03

1,3

‐ butadiene (mol %) 0.00 0.00

Pentane + (mol %) 0.09 2.71

Other Parameters

Vent Gas Volume % 99.38 99.96

NHVvg (BTU/scf) 1,208.66 1,081.47

LFLvg (volume %) 0.0404 0.0435

NHV vg

‐ lfl (BTU/scf) 48.83 47.08
Proposed NHV

cz

‐ limit (BTU/scf) 300 300
Appropriate Combustion Efficiency Multiplier 6.14 6.37 Table 3.0-1: Average VG Compositions, Ca lculated Parameters, and Appropriate Combustion Efficiency Multipliers fo r the North and South Ground FlaresMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 36



# 4.0 Test Series SN2 (Elevated Steam

‐ Assist Flare Tip)

The purpose of the SN2 test series was to comp are the effects of nitrogen dilution vs. steam dilution on flare performance. The SN2 test was conducted on the elevated steam-assisted flare used for the TCEQ tests. Two test series were co nducted. One test series used nitrogen to adjust

NHVcz and one test series used center steam to ad just NHVcz. For both test series, the fuel was an 80% propylene/20% TNG mixture.

Each test series began with NHVcz set to 350 BTU/scf. The NHVcz was lowered to 150 BTU/scf in 50 BTU/scf increments using either st eam or nitrogen for dilution. The results of the two tests show that nitrogen dilution and steamdilution may have a different effect on flare combustion efficiency. When steam was used as the diluent, combustion efficiency began to

decline at an NHVcz of 300 BTU/scf. This is co nsistent with past PFTIR studies of steamassisted flare tips. However, when nitrogen was used as the diluent, combustion efficiency did not show significant decline unt il an NHVcz of 200 BTU/scf. Note that these results conflict with other steam vs. nitrogen dilution tests conducted on ea rlier PFTIR test programs.

Figure 4.0-1 shows the relationship between NHV cz and CE. Figure 4.0-2 shows the relationship

between S/VG and CE for the SN2 Steam test se ries on a mass basis. Figure 4.0-3 shows the relationship between S/VG and CE for the SN 2 steam test series on a volume basis.

Figure 4.0-1: NHVcz vs. CE for SN2Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 37

Figure 4.0-2: S/VG (Mass Basis) vs. CE for SN2 Steam

Figure 4.0-3: S/VG (Volume Basis) vs. CE for SN2 SteamMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 38



# 5.0 Test Series PA1 and PA2 (LRGO Burners)

Two different tests were conducted on the LRGO pressure-assisted burners: PA1 and PA2. The fuel gas for the both test series was TNG. Nitr ogen was used to adjust NHVcz. The PA1 test was conducted at sonic velocity and the PA2 test wa s conducted at minimum velocity. For both test series, CE remained relatively constant at a very high level until the flare went out around 550

BTU/scf.

Figure 5.0-1 shows the relationship between NHV cz and CE. Finally, Figure 5.0-2 shows the

results from the LRGO PA1 and PA2 tests in co mparison to the EPA velocity limits from 40

CFR 60.18 and 63.11. The test results show that the LRGO burners are capable of maintaining very high combustion efficiency at velocities exceeding the li mits established by 40 CFR 60.18

and 63.11.

Figure 5.0-1: NHVcz vs. CE for PA1 and PA2 (LRGO Burners)Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 39

Figure 5.0-2: Tip Velocity vs. NHVcz for LRGO BurnersMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 40



# 6.0 Comparisons to Other Steam

‐ Assisted Flare Tips

Figures 6.0-1, 6.0-4, and 6.0-7 show the results of the Garyville steam-assisted tests with the results of previous PFTIR tests of steam-assisted flares from Texas City, Detroit, Flint Hills Resources (FHR), and TCEQ. Figures 6.0-2, 6.0- 5, and 6.0-8 show only the results of the

Marathon steam-assisted test se ries. Figures 6.0-3, 6.0-6, and 6.0-9 show only the results of the

SKEC burner tests with base load tests from Texas City, Detroit, and FHR. The results from the

SN2 test series correlate well to the results from the tests of other large, steam-assisted flares. This is expected since this test was conducted on an elevated flare tip -- the same tip that was used for the TCEQ steam test se ries. The SN2 results match the results of the propylene tests conducted by TCEQ. However, at Texas City and Detroit, combustion effi ciency appeared to drop off at higher NHVcz levels. This trend was not observed during the SN2 tests. The VS1 test runs were conducted with high NHVcz values, so a significant drop in combustion efficiency was not observed during the VS1 test series. Combustion efficiency on the SKEC burners appeared to remain high until NHVcz dropped be low 300 BTU/scf or until S/VG was increased to approximately 3 lb/lb or 3 scf/scf. This was consistent with past PFTIR studies, most specifically with test series at base load conditions. However, the test results for the SN1 test series differ from the elevated tip results in that they show that the SKEC tip tends to be more

efficient at lower NHVcz values. In one case, the measured com bustion efficiency was greater

than 97% at an NHVcz value as low as 150 BTU/ scf. The improved performance at very low NHVcz levels may be a result of non-mixing steam.

At the low flow and low NHVcz conditions during the SN1 test, the combustion zone was very small and compact and located below the steam in jection point in the plume. This may account for the higher than expected combustion effi ciency measured under these conditions. Under these extremely low flow rates, non-mixing st eam is present. This non-mixing steam plays no role in the combustion zone, resulting in the higher than expected results.

It should be noted that the flames tested on a ll of the elevated tips at high turndown can be classified as a “buoyant” flame. Flames generated on the ground flar e burners are, in general, at much higher exit velocities and can be classified as a “jetting” flame. The one exception is the SN1 test series where the burners were operating at extremely low flow rates not indicative of normal operation (i.e. ~ 4 ft/sec). With this flow ra te, the flame could be cl assified as “buoyant”.

It is expected from the available literature that jetting flames have different performance characteristics than buoyant flames. Jetting flames tend to inspirate more air as a consequence of their higher exit velocity and thus tend to achieve higher combustion efficiency at lower NHVcz

values.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 41

Figure 6.0-1: NHVcz vs. CE for all MPC, FH R, and TCEQ Steam-Assisted Test Series

Figure 6.0-2: NHVcz vs. CE for all MPC Steam-Assisted Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 42

Figure 6.0-3: NHVcz vs. CE for SKEC Bu rners & Other Base Load Test Series

Figure 6.0-4: S/VG (lb/lb) vs. CE for all MPC, FHR, & TCEQ Steam-Assisted Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 43

Figure 6.0-5: S/VG (lb/lb) vs. CE for all MPC Steam-Assisted Test Series

Figure 6.0-6: S/VG (lb/lb) vs. CE for SKEC Burners & Other Base Load Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 44

Figure 6.0-7: S/VG (scf/scf) vs. CE for all MP C, FHR, & TCEQ Steam-Assisted Test Series

Figure 6.0-8: S/VG (scf/scf) vs. CE fo r all MPC Steam-Assisted Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 45

Figure 6.0-9: S/VG (scf/scf) vs. SKEC Bu rners & Other Base Load Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 46



# 7.0 Conclusions

The PFTIR test of the SKEC burners, LRGO burners, and elevated steam flare provided data to support the following conclusions.

SKEC Burners

 When TNG is used as fuel, the SKEC burners maintain high combustion efficiency until

NHVcz falls to less than 300 BTU/scf. This is consistent with past PFTIR studies on steam-assisted flare tips.

 The SKEC burners maintain high combustion efficiency at exit velocity limits higher than those established by 40 CFR 60.18 and 63.11. At velocities greater than 60 ft/sec and up to sonic (maximum) velocity, the burne r operates efficiently until the NHVcz falls to a point where the flame is extinguishe d. Therefore, the SKEC burners should be exempt from the velocity limits established in 40 CFR 60.18 and 63.11.

 The S/VG does not appear to be a factor fo r the SKEC tip until th e exit velocity falls below 60 ft/s. Therefore, when operating at ve locities greater than 60 ft/s, an S/VG limit should not apply to the SKEC burners. At velo cities less than 60 ft/s, a S/VG limit of 3 lb/lb or 3 scf/scf could be used by the SKEC burners to assure high combustion efficiency.

 The test data suggests that a Combustion E fficiency Multiplier of 6.37 would be required to maintain 98% combustion efficiency on the North and South Ground Flares. Paragraph

46 of MPC’s flare consent decree states th at as of June 20, 2017, the North and South Ground Flares will be subject to a Combusti on Efficiency Multiplier of 7.1. This appears to be higher than what is required to maintain 98% combustion efficiency.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 47

LRGO Burners

 When TNG is used as fuel, the LRGO burners maintain high combustion efficiency until the NHVcz falls to a point where the flame is extinguished. Under all conditions tested, these burners maintained an average CE equal to or greater than 99%. Under all conditions tested, the flame extinguishes at an NHVcz of approximately 550 BTU/scf. The results of this test program demonstrat e that as long as th e LRGO burners are lit, they maintain high combustion efficiency. To ensure the LRGO burners are operating at high combustion efficiency, the NHVcz of th e LRGO burners should be kept above 550 BTU/scf. This eliminates any need for Combustion Efficiency Multipliers.

 The LRGO burners maintain high combustion e fficiency at exit velocities much higher than those allowed by 40 CFR 60.18 and 63.11. The flares operated efficiently at velocities up to sonic whic h would represent the maximum velocity achievable. Therefore, the LRGO burners should be exempt from the velocity limits established in 40

CFR 60.18 and 63.11.

Elevated Steam-Assist Flare

 When steam was used as a diluent, combusti on efficiency dropped o ff significantly when

NHVcz was reduced below about 300 BTU/scf. This is consistent with past PFTIR studies on large, elevated steam-assisted flare tips. However, when nitrogen was used as a diluent, combustion efficiency did not si gnificantly decline un til NHVcz reached about

200 BTU/scf. The results of this test show a potential difference between the effects of steam dilution and nitrogen dilution on flare combustion efficiency. It should be noted however, that this data conflic ts with other data on nitrog en vs. steam dilution collected in previous tests.

Effect of Pilots

 The presence or absence of a pilot does not a ppear to significantly affect the performance of the burners, either positively or negatively.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 48



# Appendices

A.1 Data Tables

Due to the large quantity of data collected for th is project, three levels of data reduction are provided. Sections 3-6 are the most concise summary providing run averages for a few key parameters at each test condition. Appendix A.2 pr ovides more details on the individual test series, show a large number of test paramete rs, and provide wind information. Appendices A.11 through A.16 contain raw run data collected dur ing the test program and any additional calibration or support data.

Data Summary Tables The following data table includes summary data for each run. Column headings for this table are

described below:

Condition: The designation for each test condition described in Section 2.5.

Run: The run number indicating the test and replicate. For exampl e, Run 3 (2) indicates Test 3, Replicate 2. A test is a given NHV cz and exit velocity set points.

Run ID: The unique identifier assigned to each test run Flare Tip: The specific flare tip te sted during a test run.

Start Time: The date and time each run began.

End Time: The date and time each run ended.

Std Flare Gas Flow: The average vent gas flow in standard cubic feet per hour.

Flare Gas Flow: The average vent gas flow in pounds per hour. Flare Tip Velocity: The average velocity that the vent gas is exiting the tip in feet per second.

Flare Gas NHV: The average net heating value of the ve nt gas in BTU per standard cubic foot.

Steam Flow: The average steam flow to the flare tip in pounds per hour. This is the sum of the center steam flow (constant at 250 lb/hr) and ring steam flow.

Instrument: The instrument(s) used to measure the fuel composition. Nitrogen: The average mole percent nitrogen in the vent gas.

THC: The average mole percent of tota l hydrocarbons in the vent gas. MWvg: The average molecular weight of the vent gas in pounds per pound-mole.

Wind Direction: The average wind direction during the run in degrees. Wind Speed: The average wind speed during the run in miles per hour.

S/VG: The average steam to vent gas ratio during the run.

NHVcz: The average combustion zone gas net heati ng value in BTU per st andard cubic foot. CE (weighted): The average weighted combustion efficiency for the run.Table A.1-1: Data Summary for All SKEC Test RunsCondition Run RunID Flare StartTime Endtime StdFlareGasFlow FlareGasFlow FlareTipVelocity FlareGasNHV SteamFlow Instrument Nitrogen THC MWvg WindDirection WindSpeed S/VG(calc) NHVcz CE(weighted)‐‐ ‐‐ ‐‐Tip‐‐ ‐‐scf/hr lb/hr ft/s BTU/scf lb/hr‐‐mol% mol% lb/lbmol °(N=0,E=90) mph (lb/lb) BTU/scf %SN1 1(1) 32 SKEC 8/7/201215:41:15 8/7/201216:19:00 1,361 60 3.91 909 130 GC 2.0 100.2 17.0 206 5.0 2.17 299 97.7SN1 1(2) 49 SKEC 8/9/20129:54:20 8/9/201210:16:00 1,359 61 3.90 917 129 GC 1.5 98.5 17.3 294 7.7 2.12 302 98.5SN1 1(3) 59 SKEC 8/9/201217:31:20 8/9/201217:55:00 1,379 61 3.96 905 121 GC 2.4 99.2 17.1 226 10.2 1.97 315 97.1SN1 2(1) 33 SKEC 8/7/201216:45:40 8/7/201217:11:00 1,373 61 3.95 905 183 GC 1.9 99.0 17.2 69 4.7 2.99 235 97.8SN1 2(2) 50 SKEC 8/9/201210:25:01 8/9/201210:45:00 1,359 61 3.91 916 166 GC 1.5 97.7 17.2 286 8.5 2.74 254 97.4SN1 2(3) 60 SKEC 8/10/20129:14:45 8/10/20129:37:00 1,376 61 3.95 920 172 GC 1.4 98.4 17.2 119 7.0 2.81 250 96.2SN1 3(1) 39 SKEC 8/8/20129:26:45 8/8/201210:03:00 1,343 61 3.86 911 233 GC 1.5 98.3 17.5 280 5.3 3.82 193 94.5SN1 3(2) 51 SKEC 8/9/201210:55:30 8/9/201211:16:00 1,358 61 3.90 916 238 GC 1.5 97.7 17.2 278 7.0 3.93 193 94.3SN1 3(3) 61 SKEC 8/10/20129:47:30 8/10/201210:09:00 1,365 61 3.92 920 236 GC 1.3 96.9 17.2 213 7.2 3.88 196 93.5SN1 4(1) 40 SKEC 8/8/201210:19:00 8/8/201210:43:00 1,348 61 3.87 917 328 GC 1.4 97.2 17.3 302 6.0 5.42 148 97.4SN1 4(2) 52 SKEC 8/9/201211:37:30 8/9/201211:58:00 1,359 60 3.90 910 331 GC 1.3 97.0 17.1 158 9.6 5.49 147 96.0SN1 4(3) 62 SKEC 8/10/201210:23:45 8/10/201210:45:00 1,364 60 3.92 928 324 GC 1.3 100.6 17.1 161 8.1 5.36 153 92.9SN1 5(1) 41 SKEC 8/8/201211:09:30 8/8/201211:33:00 1,355 60 3.89 909 533 GC 1.0 96.1 17.1 282 5.4 8.87 97 81.3SN1 5(2) 53 SKEC 8/9/201212:10:30 8/9/201212:32:00 1,358 60 3.90 909 518 GC 1.4 96.0 17.1 127 10.8 8.58 99 94.0SN1 5(3) 63 SKEC 8/10/201210:53:01 8/10/201211:15:00 1,366 60 3.92 913 519 GC 1.1 99.5 17.0 138 8.1 8.60 100 88.5SN1 6(1) 42 SKEC 8/8/201211:49:50 8/8/201212:13:00 1,315 60 3.78 892 1149 GC 3.8 91.8 17.5 290 6.0 19.22 45 87.4SN1 6(2) 54 SKEC 8/9/201212:43:15 8/9/201213:04:00 1,340 60 3.85 898 1018 GC 2.8 95.8 17.2 187 10.8 17.01 52 87.7SN1 6(3) 64 SKEC 8/10/201211:22:50 8/10/201211:44:00 1,356 60 3.90 911 1115 GC 1.2 100.7 17.0 194 9.9 18.59 49 89.8VS1 1(1) 19 SKEC 8/6/201213:47:50 8/6/201214:04:00 392,925 17,656 1129.09 902 192 GC 2.7 96.3 17.3 53 6.8 0.01 892 99.7VS1 2(1) 20 SKEC 8/6/201214:18:01 8/6/201214:28:00 362,252 17,010 1040.95 835 1201 FlowMeters 10.0 89.4 18.1 99 5.2 0.07 779 100.0VS1 2(2) 47 SKEC 8/8/201216:32:01 8/8/201216:45:00 381,306 18,364 1095.71 788 257 GC 13.9 82.9 18.6 234 6.2 0.01 777 99.9VS1 2(3) 55 SKEC 8/9/201214:55:45 8/9/201215:09:00 358,285 16,968 1029.55 820 257 GC 11.9 87.3 18.3 83 10.3 0.02 808 99.8VS1 3(1) 21 SKEC 8/6/201216:05:01 8/6/201216:17:00 243,725 11,871 700.36 774 1474 GC 16.8 83.3 18.8 148 5.9 0.12 685 99.8VS1 4(1) 22 SKEC 8/6/201216:59:40 8/6/201217:11:00 241,229 12,228 693.19 701 306 GC 24.6 76.1 19.5 240 3.7 0.03 682 99.8VS1 4(2) 46 SKEC 8/8/201215:56:01 8/8/201216:09:00 241,212 12,345 693.14 707 260 GC 22.7 74.3 19.7 278 10.4 0.02 691 99.1VS1 4(3) 56 SKEC 8/9/201215:21:30 8/9/201215:33:00 244,023 12,380 701.22 720 256 GC 21.5 75.5 19.6 216 8.8 0.02 704 99.8VS1 5(1) 23 SKEC 8/6/201217:43:30 8/6/201217:55:00 275,875 14,076 792.74 691 299 GC 25.8 74.0 19.7 93 5.2 0.02 675 99.8VS1 6(1) 25 SKEC 8/7/201210:56:30 8/7/201211:10:00 102,104 5,452 293.40 646 263 GC 32.4 71.1 20.6 183 4.9 0.05 613 99.5VS1 6(2) 45 SKEC 8/8/201215:16:01 8/8/201215:28:00 102,714 5,502 295.16 619 257 GC 32.2 65.6 20.7 256 8.3 0.05 587 99.7VS1 6(3) 57 SKEC 8/9/201215:52:30 8/9/201216:04:00 103,920 5,448 298.62 650 259 GC 27.9 65.3 20.2 192 10.1 0.05 617 99.9VS1 7(1) 29 SKEC 8/7/201212:45:45 8/7/201212:57:00 34,825 1,930 100.07 563 256 GC 40.0 61.4 21.4 185 2.9 0.13 487 98.5VS1 7(2) 44 SKEC 8/8/201214:45:01 8/8/201214:57:00 34,155 1,904 98.15 580 256 GC 37.9 60.5 21.5 286 8.9 0.13 499 99.0VS1 7(3) 58 SKEC 8/9/201216:36:01 8/9/201216:48:00 35,784 1,916 102.83 613 255 GC 32.8 63.9 20.6 181 9.1 0.13 532 99.4VS1 9a(1) 31 SKEC 8/7/201214:34:01 8/7/201214:47:00 21,078 1,180 60.57 537 253 GC 42.2 58.0 21.6 108 4.8 0.21 428 97.1VS1 Traverse1,PFTIR1 26.1 SKEC 8/7/201211:20:40 8/7/201211:24:00 102,848 5,584 295.54 612 263 GC 35.7 66.4 20.9 208 6.6 0.05 580 99.7VS1 Traverse2,PFTIR1 27.1 SKEC 8/7/201211:24:40 8/7/201211:29:00 102,356 5,571 294.13 604 260 GC 36.4 65.5 21.0 215 6.3 0.05 572 99.1VS1 Traverse3,PFTIR1 28.1 SKEC 8/7/201211:32:40 8/7/201211:36:00 99,132 5,409 284.86 595 264 GC 37.0 64.7 21.0 141 5.1 0.05 563‐‐VS1 Traverse1,PFTIR2 26.2 SKEC 8/7/201211:20:40 8/7/201211:24:00 102,848 5,584 295.54 612 263 GC 35.7 66.4 20.9 208 6.6 0.05 580 99.6VS1 Traverse2,PFTIR2 27.2 SKEC 8/7/201211:24:40 8/7/201211:29:00 102,356 5,571 294.13 604 260 GC 36.4 65.5 21.0 215 6.3 0.05 572 99.8VS1 Traverse3,PFTIR2 28.2 SKEC 8/7/201211:32:40 8/7/201211:36:00 99,132 5,409 284.86 595 264 GC 37.0 64.7 21.0 141 5.1 0.05 563 99.7PilotTest On(2) 17 SKEC 8/6/201210:44:20 8/6/201210:51:00 6,882 307 19.77 912 442 GC 1.7 97.6 17.2 112 6.2 1.44 384 98.1PilotTest Off(1) 18 SKEC 8/6/201210:59:10 8/6/201211:06:00 7,595 339 21.83 912 437 GC 1.7 97.6 17.2 99 6.5 1.29 409 98.6Weather CalculationsTestConditions ProcessData VGCompositionDataMarathonPetroleum‐GaryvilleGroundFlareBurnerTestReportPage50Table A.1-2: Data Summary for All LRGO Test RunsTable A.1-3: Data Summary for All SN2 Test RunsCondition Run RunID Flare StartTime Endtime StdFlareGasFlow FlareGasFlow FlareTipVelocity FlareGasNHV SteamFlow Instrument Nitrogen THC MWvg WindDirection WindSpeed S/VG(calc) NHVcz CE(weighted)‐‐ ‐‐ ‐‐Tip‐‐ ‐‐scf/hr lb/hr ft/s BTU/scf lb/hr‐‐mol% mol% lb/lbmol °(N=0,E=90) mph (lb/lb) BTU/scf %PA1 1(1) 68 LRGO 8/10/201216:30:30 8/10/201216:52:00 321,086 14,192 1376.57 909 0 GC 1.6 97.8 17.0 115 8.9‐‐909 98.7PA1 1(2) 74 LRGO 8/11/201210:28:30 8/11/201210:50:00 314,583 14,040 1348.69 911 0 GC 1.2 98.3 17.2 146 7.9‐‐911 100.0PA1 1(3) 75 LRGO 8/11/201210:55:40 8/11/201211:17:00 317,181 14,075 1359.83 910 0 GC 1.3 98.4 17.1 148 6.5‐‐910 100.0PA1 4(1) 69 LRGO 8/10/201217:11:15 8/10/201217:33:00 275,855 14,960 1182.66 587 0 GC 36.8 63.7 20.9 164 10.0‐‐587 98.5PA1 4(3) 73 LRGO 8/11/201210:01:01 8/11/201210:22:00 293,124 15,868 1256.69 597 0 GC 36.3 65.4 20.9 128 8.8‐‐597 99.8PA1 4(4) 76 LRGO 8/11/201211:25:30 8/11/201211:42:00 290,601 15,876 1245.88 581 0 GC 37.8 63.3 21.1 129 4.6‐‐581 100.0PA2 1(1) 65 LRGO 8/10/201214:29:45 8/10/201214:51:00 181,306 8,026 777.30 910 0 GC 1.6 98.8 17.1 197 13.1‐‐910 98.9PA2 1(2) 66 LRGO 8/10/201215:08:01 8/10/201215:29:00 181,094 8,036 776.40 911 0 GC 1.6 97.1 17.1 148 12.6‐‐911 98.8PA2 1(3) 67 LRGO 8/10/201215:39:30 8/10/201216:00:00 181,265 8,035 777.13 908 0 GC 1.6 97.0 17.1 143 11.0‐‐908 100.0PA2 4(1) 71 LRGO 8/11/20129:12:50 8/11/20129:34:00 164,334 8,786 704.54 610 0 GC 33.8 66.1 20.6 104 6.7‐‐610 99.8PA2 4(2) 77 LRGO 8/11/201212:53:20 8/11/201213:16:00 161,703 8,848 693.26 578 0 GC 39.1 64.5 21.1 152 5.4‐‐578 99.4PA2 4(3) 78 LRGO 8/11/201213:23:40 8/11/201213:45:00 163,071 8,937 699.13 577 0 GC 39.3 64.6 21.1 151 6.0‐‐577 99.3LTS 1 6 LRGO 8/3/201220:24:15 8/3/201220:40:00 91,509 4,080 3530.89 912 0 FlowMeters 1.7 97.6 17.2 174 10.7‐‐912 99.9LTS 3 24 LRGO 8/6/201218:31:33 8/6/201218:43:00 91,832 4,095 3543.37 912 0 FlowMeters 1.7 97.6 17.2 62 5.7‐‐912 100.0LTS 4 38 LRGO 8/7/201217:57:20 8/7/201218:15:00 91,222 4,067 3519.81 912 0 FlowMeters 1.7 97.6 17.2 68 7.9‐‐911 100.0LTS 6 70 LRGO 8/10/201218:03:20 8/10/201218:15:00 92,239 4,113 3559.07 912 0 FlowMeters 1.7 97.6 17.2 197 7.8‐‐912 99.6LTS 7 79 LRGO 8/11/201214:11:10 8/11/201214:23:00 90,257 4,024 3482.59 912 0 FlowMeters 1.7 97.6 17.2 190 4.6‐‐912 99.4TestConditions ProcessData VGCompositionData Weather CalculationsCondition Run RunID Flare StartTime Endtime StdFlareGasFlow FlareGasFlow FlareTipVelocity FlareGasNHV SteamFlow Instrument Nitrogen THC MWvg WindDirection WindSpeed S/VG(calc) NHVcz CE(weighted)‐‐ ‐‐ ‐‐Tip‐‐ ‐‐scf/hr lb/hr ft/s BTU/scf lb/hr‐‐mol% mol% lb/lbmol °(N=0,E=90) mph (lb/lb) BTU/scf %SN2Nitrogen 1 7 TCEQ 8/4/20129:56:15 8/4/201210:08:00 84,999 6,541 3.34 346 0 FlowMeters 81.8 18.1 29.7 202 15.0‐‐346 99.0SN2Nitrogen 2 8 TCEQ 8/4/201210:13:40 8/4/201210:25:00 85,427 6,528 3.36 301 0 FlowMeters 84.2 15.8 29.5 190 13.8‐‐301 99.1SN2Nitrogen 3 9 TCEQ 8/4/201210:33:20 8/4/201210:45:00 85,737 6,498 3.37 251 0 FlowMeters 86.9 13.1 29.2 188 13.0‐‐251 98.8SN2Nitrogen 4 10 TCEQ 8/4/201210:51:01 8/4/201211:03:00 85,424 6,418 3.36 198 0 FlowMeters 89.6 10.4 29.0 194 12.0‐‐198 97.1SN2Nitrogen 5 11 TCEQ 8/4/201211:12:01 8/4/201211:23:00 85,725 6,389 3.37 149 0 FlowMeters 92.2 7.8 28.7 206 13.4‐‐149 87.2SN2Steam 1(2) 2 TCEQ 8/3/201217:15:55 8/3/201217:28:00 13,362 1,286 3.35 1902 3363 FlowMeters 0.3 99.5 37.1 143 11.6 2.62 298 98.7SN2Steam 2(1) 3 TCEQ 8/3/201217:53:55 8/3/201218:05:00 15,756 1,514 3.38 1899 3284 FlowMeters 0.3 99.5 37.0 153 10.4 2.17 348 98.9SN2Steam 3(1) 4 TCEQ 8/3/201218:21:40 8/3/201218:33:00 11,452 1,104 3.29 1905 3383 FlowMeters 0.3 99.5 37.2 146 9.6 3.07 260 96.3SN2Steam 4(2) 12 TCEQ 8/4/201211:48:01 8/4/201212:04:00 6,717 644 3.35 1895 3670 FlowMeters 0.3 99.5 37.0 190 12.7 5.70 149 67.8SN2Steam 4(3) 14 TCEQ 8/4/201212:38:50 8/4/201212:50:00 6,698 644 3.32 1902 3635 FlowMeters 0.3 99.5 37.1 215 8.5 5.64 151 71.4SN2Steam 5(1) 13 TCEQ 8/4/201212:17:20 8/4/201212:29:00 8,889 856 3.39 1903 3612 FlowMeters 0.3 99.5 37.1 210 9.7 4.22 196 82.2TestConditions ProcessData VGCompositionData Weather CalculationsMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 51



## A.2 Process Conditions

A.2.1 Test Series SN1 The purpose of test series SN1 is to determine th e performance curve of the SKEC burners at the

minimum flow rate.

Process Conditions Figures A.2.1-1 shows vent gas composition, pr ocess conditions, wind speed, and wind direction

for test series SN1.

Figure A.2.1-1: Vent gas composition, vent gas flow, exit velocity, NHVcz, S/VG, wind speed, and wind direction for SN1Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 52

Run Table

Table A.2.1-1 details which PFTIR was used for each run, the run leng th, and any important

notes.

Run PFTIR Used Run Length Notes 1 (1) Both 37 minutes 1 (2) PFTIR 2 21 minutes 1 (3) PFTIR 2 23 minutes 2 (1) Both 25 minutes 2 (2) PFTIR 2 20 minutes 2 (3) Both 22 minutes 3 (1) PFTIR 2 36 minutes 3 (2) PFTIR 2 20 minutes 3 (3) Both 21 minutes 4 (1) PFTIR 2 23 minutes 4 (2) PFTIR 2 21 minutes 4 (3) Both 21 minutes 5 (1) PFTIR 2 23 minutes 5 (2) PFTIR 2 21 minutes 5 (3) Both 22 minutes 6 (1) PFTIR 2 23 minutes 6 (2) PFTIR 2 21 minutes 6 (3) Both 21 minutes

Table A.2.1-1: Run Details for SN1Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 53

A.2.2 Test Series SN2 Nitrogen The purpose of test series SN2 Nitrogen is to determine if nitrogen dilution and steam dilution have the same effect on combustion efficiency.

Process Conditions Figures A.2.2-1 shows vent gas composition, pr ocess conditions, wind speed, and wind direction for test series SN2 Nitrogen.

Figure A.2.2-1: Vent gas composition, vent ga s flow, exit velocity, NHVcz, wind speed, and wind direction for SN2 NitrogenMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 54

Run Table

Table A.2.2-1 details which PFTIR was used for each run, the run leng th, and any important

notes.

Run PFTIR Used Run Length Notes 1 (1) Both 11 Minutes 2 (1) Both 11 Minutes 3 (1) Both 11 Minutes 4 (1) Both 11 Minutes 5 (1) Both 11 Minutes Table A.2.2-1: Run Details for SN2 NitrogenMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 55

A.2.3 Test Series SN2 Steam The purpose of test series SN2 Steam is to dete rmine if nitrogen dilution and steam dilution have the same effect on combustion efficiency.

Process Conditions Figures A.2.3-1 shows vent gas composition, pr ocess conditions, wind speed, and wind direction

for test series SN2 Steam.

Figure A.2.3-1: Vent gas composition, vent gas flow, exit velocity, NHVcz, S/VG, wind speed, and wind direction for SN2 SteamMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 56

Run Table

Table A.2.3-1 details which PFTIR was used for each run, the run leng th, and any important

notes.

Run PFTIR Used Run Length Notes 1 (1) N/A 3 Minutes Aborted because of issues with boiler consistency 1 (2) Both 11 Minutes 2 (1) Both 11 Minutes 3 (1) Both 11 Minutes 4 (1) N/A 6 Minutes Aborted because of issues with boiler consistency 4 (2) Both 16 Minutes 4 (3) Both 11 Minutes 5 (1) Both 11 Minutes

Table A.2.3-1: Run Details for SN2 SteamMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 57

A.2.4 Test Series VS1 The purpose of test series VS1 is to identify the minimum NHVcz needed to maintain a flame over a range of exit veloci ties on the SKEC burners.

Process Conditions Figures A.2.4-1 shows vent gas composition, pr ocess conditions, wind speed, and wind direction

for test series VS1.

Figure A.2.4-1: Vent gas composition, vent gas flow, exit velocity, NHVcz, S/VG, wind speed, and wind direction for VS1Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 58

Run Table

Table A.2.4-1 details which PFTIR was used for each run, the run leng th, and any important

notes.

Run PFTIR Used Run Length Notes 1 (1) Both 15 Minutes 2 (1) PFTIR 1 12 Minutes 2 (2) PFTIR 2 13 Minutes 2 (3) PFTIR 2 13 Minutes 3 (1) Both 12 Minutes Flare went out by itself after data collection stopped. 4 (1) Both 11 Minutes 4 (2) PFTIR 2 12 Minutes 4 (3) PFTIR 2 11 Minutes 5 (1) Both 11 Minutes 6 (1) Both 13 Minutes 6 (2) PFTIR 2 12 Minutes 6 (3) PFTIR 2 11 Minutes 7 (1) Both 11 Minutes 7 (2) PFTIR 2 12 Minutes 7 (3) PFTIR 2 12 Minutes 8 (1) N/A 3 Minutes Aborted because two burners went out. 9a (1) Both 12 Minutes 9a (2) PFTIR 2 15 Minutes Stack behind flare plume. No useable data.

Table A.2.4-1: Run Details for VS1Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 59

A.2.5 Test Series PA1 The purpose of test series PA1 is to dete rmine the minimum NHVcz that supports good combustion at sonic velocity on the LRGO burners.

Process Conditions Figures A.2.5-1 shows vent gas composition, pr ocess conditions, wind speed, and wind direction

for test series PA1.

Figure A.2.5-1: Vent gas composition, vent ga s flow, exit velocity, NHVcz, wind speed, and

wind direction for PA1Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 60

Run Table

Table A.2.5-1 details which PFTIR was used for each run, the run leng th, and any important

notes.

Run PFTIR Used Run Length Notes 1 (1) Both 21 Minutes 1 (2) Both 21 Minutes 1 (3) Both 21 Minutes 4 (1) Both 21 Minutes 4 (2) N/A 2 Minutes Run abor ted after burner went out. 4 (3) Both 21 Minutes 4 (4) Both 17 Minutes Run stopped after burner went out.

Table A.2.5-1: Run Details for PA1Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 61

A.2.6 Test Series PA2 The purpose of test series PA2 is to dete rmine the minimum NHVcz that supports good combustion at minimum velocity on the LRGO burners.

Process Conditions Figures A.2.6-1 shows vent gas composition, pr ocess conditions, wind speed, and wind direction

for test series PA2.

Figure A.2.6-1: Vent gas composition, vent ga s flow, exit velocity, NHVcz, wind speed, and

wind direction for PA2Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 62

Run Table

Table A.2.6-1 details which PFTIR was used for each run, the run leng th, and any important

notes.

Run PFTIR Used Run Length Notes 1 (1) Both 21 Minutes 1 (2) Both 21 Minutes 1 (3) Both 21 Minutes 4 (1) Both 21 Minutes 4 (2) Both 22 Minutes 4 (3) Both 21 Minutes

Table A.2.6-1: Run Details for PA2Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 63

A.2.7 Test Series LTS The purpose of test series LTS is to demonstrate the repeatability of PFTIR measurements over an extended period. This test may also provi de information on the effects of uncontrolled

variables such as wind on the overall test result. The LTS test series was conducted on the LRGO burners. Every effort was made to ensure the c ontrollable variables were held as constant as possible from run to run.

Process Conditions Figures A.2.7-1 shows vent gas composition, pr ocess conditions, wind speed, and wind direction

for test series LTS.

Figure A.2.7-1: Vent gas composition, vent ga s flow, exit velocity, NHVcz, wind speed, and

wind direction for LTSMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 64

Run Table

Table A.2.7-1 details which PFTIR was used for each run, the run leng th, and any important

notes.

Run PFTIR Used Run Length Run Notes

1 PFTIR 2 15 Minutes

2 PFTIR 2 13 Minutes Process data l ogger turned off. Run Discarded.

3 Both 11 Minutes

4 PFTIR 2 17 Minutes

5 PFTIR 2 11 Minutes Run consider ed an outlier. Run Discarded.

6 Both 12 Minutes

7 Both 12 Minutes

Table A.2.7-1: Run Details for LTSMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 65



## A.3 Calculations

The following calculations are used this report. In addition to the calculations listed below, many of the calculations used in reducing the PFTIR data are provided in Appendix A.5.

The Gas Chromatograph (GC) meas ured the following hydrocarbons.

i Measured Component MW (lb/lb-mol) NHV (BTU/scf) LFL (Vol. %) Range GC

Units 1 Nitrogen 28.02 0 ∞ 0 - 100 Mole %

2 Carbon Dioxide 44.01 0 ∞ 0 - 100 Mole %

3 Methane 16.04 896.2 5.0 0 - 100 Mole %

4 Ethane 30.07 1595.3 3.0 0 - 100 Mole % 5 Propane 44.1 2281.4 2.1 0 - 100 Mole % 6 Propylene 42.08 2150.6 2.4 0 - 100 Mole %

7 Normal Butane 58.12 2967.5 1.8 0 - 100 Mole % Table A.3-1. List of hydrocarbons measured by Gas Chromatograph

A.3.1 Vent Gas Molecular Weight The hydrocarbon molecular weight is calculated as:

ܹܯ ௚ ௩ ݈݋݉ ෍ ൌ

௜ ܹܯ ∗ ௜ ଻

௜ୀଵ Equation A.3-1

Where:

MW vg = molecular weight of the vent gas (lb/lb-mol)

MW i = molecular weight of each compound i from Table A.3-1 (lb/lb-mol)

mol i = mole percent of each compound i from Table A.3-1 (%)

A.3.2 Net Heating Value of Combustion Zone The Net Heating Value of the Vent Gas (NHVvg) is calculated and reported from the GC at the conclusion of each analytical cycle. The Net H eating Value is the Lower Heating Value or LHV

defined as:

“Lower Heating Value” or “LHV” shall mean the theoretical total 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 the produced water is vaporized and all combustion products re main at, or are returned to, 25° Centigrade; however, the standard for dete rmining the volume corresponding to one mole is 20° Centigrade.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 66

The Combustion Zone Gas Net Heating Value is the flow-weighted average NHV of all combustion zone components. The contribution of pilot gas to the NHVcz is not considered significant.

ܰܪܸ
௖௭ ൌ ൫ܳ
௩௚ ∙ ܰܪܸ ௩௚ ൯ ൫ܳ
௩௚ ൯ ൅ ሺ ܳ
௦ ሻ Equation A.3-2

Where:

NHV
cz = combustion zone gas net heating value " ("BTU" ⁄ scf) Q vg = volumetric vent gas flow rate (scf/hr)

NHV vg = net heating value of vent gas (Btu/scf) Q

s = volumetric steam flow rate (scf/hr)

The calculation of each component is shown below.

Volumetric flow rates Gas and steam flow data was provided in units of mass flow (lb/hr). This was converted to volumetric flow (scf/hr) by the following equation.

ܳൌ݉ ሶ

∙ 385.5

ܯܹ Equation A.3-3

Where:

Q = volumetric flow rate for steam or vent gas (scf/hr)

m ሶ = mass flow rate for st eam or vent gas (lb/hr) MW = molecular weight of steam or vent gas (lb/lb-mol) 385.5 = molar volume of an ideal gas at 68 °F and 1 atm (scf/lb-mol)

Net heating value of the vent gas

ܸܪܰ ௚ ௩ ݔ෍ൌ

௜ ܸܪܰ ∗ ௜ ଻

௜ୀଵ Equation A.3-4

Where:

NHV vg = net heating value of vent gas (BTU/scf)

i = individual pure component in vent gas

x i = concentration of individual pure co mponent in vent gas (volume fraction)

NHV i = net heating value of pure individual component i (Btu/scf)Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 67

A.3.3 Steam to Vent Gas Ratio (S/VG)

The Steam to Vent Gas Ratio is calcula ted (as the name implies) as follows:

S/VG ൌ ݉ ሶ ௦௧௘௔௠

݉

ሶ ௩௚ Equation A.3-5

Where:

S/VG = steam to vent gas ratio (lb/lb)

݉

ሶ ௦௧௘௔௠ = steam mass flow rate (lb/hr)

݉

ሶ ௩௚ = vent gas mass flow rate (lb/hr)

Note: S/VG may also be calculated on a volumetri c basis using steam and vent gas volumetric

flow rates.

A.3.4 Total Hydrocarbons from PFTIR The total hydrocarbon values reported by the PFTIR measurements are adjusted by carbon weighting as follows:

ܶܥܪ
௪ ൌ ܥ ஼ு ర ൅2∙ܥ ஼ మ ு ర ൅3∙ܥ ஼ య ு ల ൅ 4 ∙ ൫ܥ
஻௨௧ ൅ ܥ ଵ,ଷ஻௨௧ ൯

ܥ∙5൅ ஼ு Equation A.3-6

Where:

THC

w = weighted total hydrocarbons from PFTIR (ppm•m)

C CH4 = methane from PFTIR (ppm•m)

C C2H4 = ethylene from PFTIR (ppm•m)

C C3H6 = propylene from PFTIR (ppm•m)

C But = butane from PFTIR (ppm•m)

C 1,3But = 1,3 butadiene from PFTIR (ppm•m)

C HC = pentane and larger hydrocarbons from PFTIR (ppm•m) 2,3,4,5 = number of carbon atoms in each molecule"

A.3.5 Flare Combustion Efficiency Combustion Efficiency means the efficiency of converting organic compounds to carbon dioxide as measured in the flare plume. Flare com bustion efficiency is calculated as follows:

ൌ ܧܥ ܱܥ ଶ
ܱܥ ଶ ܥܪܶ ൅ ܱܥ ൅
௪ Equation A.3-7

Where:

CE = flare combustion efficiency (%)

CO 2 = carbon dioxide from PFTIR (ppm•m) CO = carbon monoxide from PFTIR (ppm•m)

THC

w = weighted total hydrocarbons from PFTIR (ppm•m)Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 68

A.3.6 Tip Velocity

The velocity of the combustion zone gas ( v czg ) also referred to as “tip velocity” is calculated as

follows.

ݒ ௖௭௚ ൌ ܳ ௩௚ ൅ ܳ ௖ି௦௧௘௔௠
ܣ ௣௜௧ Equation A.3-8

Where

v czg = velocity of the combustion zone gas Q vg = volumetric flow rate of the vent gas Q c-steam = volumetric flow rate of the vent gas

A tip = open area of the flare tip

A.3.7 Combustion Efficiency Multiplier

The Combustion Efficiency Multiplier is calculated as follows

ܣ ൌ ܸܪܰ
௭௖ ∗

ܸܪܰ ௚௩ ܮܨܮ ∗ ௚௩ Equation A.3-9

Where

A = combustion efficiency multiplier

NHV vg = net heating value of the vent gas

LFL vg = lower flammability limit of the vent gas

NHV
cz * = target net heating valu e of the combustion zoneMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 69



## A.4 The PFTIR Test Method ‐ Description, Operation, and Analysis

A.4.1 Technology Overview The instrument used to measure the gas compos ition of the flare plume is the Passive Fourier Transform Infrared (PFTIR) analyzer. To m onitor elevated flares, standard “active” IR spectroscopy could be used. However, it is difficu lt from a practical standpoint to pass a beam of IR light through an elevated flare plume and then capture the transmitted light. A flare plume is constantly moving and would require that the IR light beam constantly move to remain inside the flare plume. Therefore, for this project, a “pa ssive” approach is used that does not require an independent IR light source. PFTIR analysis ope rates 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 sp ectrometer is a receiver only.

Most stack test and fence-line measurement tech nologies either physically extract a sample of gas from a stack into a sample cell or “shoot” a reference beam across the stack or along the fence-line. These technologies measure how much of a reference IR beam is absorbed by the gas at various wavelengths. This process generates an “absorption spectrum”. Since these techniques are a mature technology, many references and soft ware tools available for analyzing absorption

spectra.

The PFTIR approach is possible because hot gases emit radiation at the same frequencies as they

absorb. The result is referred to as a “radiance spectrum.” Since the infrared radiance spectra of hot gases have the same patterns or “fingerprint s” as the absorption spectra, it is possible to convert radiance spectra to absorp tion spectra and then to use the many available analytical tools to determine gas concentrations. Figure A.4.3-1 shows a schematic of a PFTIR measuring a flare plume.

For this test program, Dr. Robert Spellicy of Industrial Monitor and Control Corporation (IMACC) oversaw the PFTIR operation and data analysis. Dr. Spellicy and IMACC developed both the PFTIR instrument and the analytical software.

Figure A.4.1-1: Schematic of PFTIR Measuring a Flare PlumeMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 70

There is one main difference between the two ap proaches: the radiance spectrum from hot gases is proportional to the con centration of the gas (as it is absorp tion), but it also affected by gas temperature. In standard absorption FTIR, the te mperature of the gas is known and controlled. With PFTIR measurements on a flare plume, the temperature is unknown. Therefore, when conducting PFTIR measurements, the temperature of the flare plume must be determined. Details of how this temperature determinatio n is made are found in Appendix A.5.3.

Consequently, unlike absorption sp ectroscopy, the PFTIR signal must be calibrated in absolute units of radiance. This requires that the instrume nt be calibrated utilizing an IR source of known spectral radiance. This calibration is accomplishe d with a commercial black body calibrator. This calibrator produces a know n IR distribution as predicted by th e Planck function. Details of the calibration are found in Appendix A.4.2.

Calibrations were performed each day at the begi nning and end of testing. Calibration results are found in Appendix A.12.

A more detailed treatment of PFTIR theory is found in Appendix A.5.

A.4.2 PFTIR Calibration Overview In order to perform calibrations on the PFTIR, a calibration cart is used. See Figure A.2-1. This cart consists of a telescope, identical to the te lescope on the PFTIR. At the focal point of the telescope is a mount where various calibration materials are placed as described below. The telescope acts as a collimator providing a collimat ed beam with the same diameter as the PFTIR telescope. When the collimator and the PFTIR ar e aligned, the calibration source fills the PFTIR field of view. To perform the calibrations, the cali bration cart was placed next to the base of the

flare and aimed toward the PFTIR. The two were then aligned and each calibration source, in turn, was placed in the collimator. The PFTIR then collected data from each source. This data is then used in the analytical software to calibra te the raw signal and to correct for interferences.

Figure A.4.2-1: The Calibration CartMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 71

Several calibrations were perfor med throughout the test program to account for the effects of sky background and atmospheric radiance and transm ittance. Three radiant sources with various characteristics were placed at the focal point of the collimator at roughly the same distance from the PFTIR as the flare. Precise alignment of th e PFTIR with the collimat or was critical during these calibrations. The sky bac kground calibrations were perfor med as needed during testing.

Calibration files are f ound in Appendix A.12.

Black Body Calibration To calibrate the PFTIR signal in absolute units of radiance, a black body with an IR source of known spectral radiance was used. A commercia l black body calibrator was placed in the collimator at the base of the flare, which produced a known IR spectrum as predicted by the Planck function. The calibration of this black body standard is traceable to the National Institute for Standards and Technology (NIST). This calibration was done at least once each day.

IR Source Calibration To determine the atmospheric transmission lo ss between the flare plume and the PFTIR, an infrared (IR) source was placed in the collimator at the base of the flare. It created a strong IR signal that the PFTIR could dete ct to determine atmospheric transmission. This calibration was done at the beginning and end of each day.

Cold Source Calibration

Since the air and PFTIR are not at absolute zero, they radiate also. This radiation will be detected by the PFTIR. To determine the atmospheric radiance generated by the air between the flare plume and the PFTIR and from the PFTIR instrument itself, a cold source of liquid nitrogen in a windowed cup was placed in the col limator at the base of the flar e. It zeroed any radiance except for that created by the atmosphere and the PFTIR . This calibration was done at the beginning and end of each day.

Sky Background Calibration Background radiance calibrations were conducted as needed duri ng the test program. When the background changed behind the flare plume, such as when clouds were passing, backgrounds

were taken more often. It was not uncommon to take a background every 10 minutes during a run. During the background calibration, the PFTIR w ould swing off the flare plume and collect a reading for approximately one minute, then sw ing back to the flare plume and continue collecting data. Background times are included in the PFTIR raw data in Appendix A.13.

A.4.3 Siting Configuration Figure A.4.3-1 shows the locations of the SKEC /LRGO burners and the elevated steam-assist flare tip, as well as each PFTIR. For testing conducted on the SKEC and LRGO burner tips, the

PFTIR 1 location was inside a tr ailer northeast of the burner set up. For the SN2 test series, the PFTIR 1 location was inside a trailer just northwest of the control room. Fo r all test series, the PFTIR 2 location was inside a trailer just south of the control room. Both PFTIRs were operated

from the trailers.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 72

Whenever possible data was collected by both PFTIRs during a run for simultaneous readings. However, only some runs had simultaneous readi ngs due to high flow conditions and equipment

malfunctions.

The main control room for the flare test was located at the flare pad just west of the SKEC/LRGO burner manifold. Two computer displa ys showed process data from the plant and

video camera feeds from each PFTIR location. All camera recording was stopped and started

from the control room. Radios were used to co mmunicate between the flare test control room and

the PFTIR locations.

Figure A.4.3-1: Maps of the PFTIR Location s in Relation to SKEC/LRGO and Elevated Steam-Assist Flare Tips

A.4.4 Operation

Each PFTIR was housed in a trailer. These trailers were positioned to obtain the best view of the flare plumes regardless of wind conditions. Calibr ations for each PFTIR were performed at the beginning and end of each day. Results of thes e daily calibrations are found in Appendix A.12. After calibration was completed, the equipment was ready to begin testing. Before each test run, a sky background was obtained. Additional sky ba ckgrounds were taken approximately every 10 minutes or as sky conditions changed during testing.

Both PFTIRs collected data during a run for simu ltaneous readings. However, for some runs only one PFTIR was operational due to high flow c onditions and equipment malfunctions. When both PFTIRs were collecting spectra, the results were averaged to determine combustion efficiency.

Wind speed changed the profile of the flare plum e. When the wind speed was relatively low, the flare plume was more upright and compact. When the wind speed was relatively high, the flare plume was more horizontal and elongated. Aimi ng was adjusted for wind speed to capture a representative section of the flare plume that was not too close to the flare flame and not too cold

for the PFTIR to be effective.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 73

A.4.5 Aiming Proper aiming of the PFTIR is critical to acquisi tion of consistent, reli able data. Ideally, the

PFTIR should be aimed near the centerline of th e flare plume about one flame length away from the flame tip. At this distance, all thermal destruction reactions have reached completion. However, the plume is a moving target. Therefore, in an attempt to maintain an optimal view, the PFTIR operator must continually adjust the ai ming position of the PFTIR. This task becomes increasingly difficult when the wind is shiftin g, causing the plume to move in different directions. Aiming is poor and re adings are invalid when the fl are plume is blowing directly away from the PFTIR.

Because two PFTIRs were used at separate locations for the tests, at least one PFTIR always had a good view of the flare plume. Aiming videos were monitored during the test program to ensure that acceptable aiming was maintained. The best opportunity for the PFTIR to obtain a representative sample of the flare plume is when:

1. The flame is buoyant and plume is risi ng directly 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. Figure A.4.5-1 shows a perpendicular view from a PFTIR location.

Figure A.4.5-1: 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. Figure A.4.5-2 shows an ex ample of poor PFTIR alignment. When this occurs, the flare structure, tip, and flame block the view of the plume fr om the PFTIR, making it difficult to obtain a representative sample of the plume.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 74

Figure A.4.5-2: Example of Poor Plume Alignment with PFTIR

This effect can be seen visually on the PFT IR aiming camera. Figure A.4.6-3 shows example images of good plume alignment and poor plume alignment, respectively. The crosshair on the images shows the PFTIR field aiming point. Data collected from a poorly aligned plume may

result in invalid data.

Figure A.4.6-3: Left – Aiming Camera with Good Plume Alignment. Right – Aiming Camera with Poor Plume AlignmentMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 75

To avoid the problem of poor plume alignment, tw o PFTIRs were placed at separate locations so at least one PFTIR had good plume alignment rega rdless of wind direction. However, because many of the test runs featured high exit velocities, wind speed and direction had little impact on the ability of the PFTIRs to get a good reading.

A.4.6 Data Reduction Once collected, the raw PFTIR data must be pro cessed to yield the indi vidual flare component concentrations. This data processing was perfor med by Dr. Robert Spellicy from IMACC. Data were compiled at approximately one minute inte rvals. Each one minute point consists of approximately 40 individual measuremen ts averaged into a single spectrum.

The data analysis 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 spec trum to an absorbance spectrum so it can be further analyzed with standa rd 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 below. A more detailed treatment is found in Appendix

A.5.

Step 1 – Convert the raw interf erogram to a radiance spectrum

The raw data from the PFTIR are in the form of an interferogram, which is radiance as a function of FTIR scan position. The Fourier Transform (F T) process converts this data into a radiance spectrum, which is radiance as a function of wave length or, in this case, wavenumber. The result is what is referred to as a “single beam” radian ce spectrum. These single beam spectra have been supplied on the data hard drives that accompany this report. The FT process is a standard spectroscopic procedure and is not disc ussed in detail in this report.

Step 2 – Isolate the flare transmission spectrum Once the radiance spectrum has been generated, the flare transmission must be isolated from all

the interferants that the PFTIR also “sees”. In order to accomplish this, each term in Equation

A.4-1 above must be determined. This is done as follows:Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 76

Background radiance (N bkg ) – As described in Appendix A.4.5, 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 and 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 a ppears two places: 1) in transmitting the sky background through the flare to the PFTIR and 2) in the radiance term for the flare itself. 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 an IR source and taking the ratio of the value obtained (minus the atmos pheric radiance) to a “synthetic background” spectrum. This syntheti c 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 systems. Th is source has sufficien t 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 plume radiance is the desired measurement for flare testing. However, as disc ussed elsewhere, the plume radiance signal is mixed with other signals and so must be co rrected with respect to this interference.

Atmospheric radiance (N atm ) – This value is determined by aimi ng 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 atmosphe re plus any radiance from the

PFTIR instrument itself. This meas ured value is referred to as M

n . For this project, the cold source was a windowed cup filled with liquid nitr ogen where the level of the liquid nitrogen was just below the collimator inlet.

PFTIR radiance (N f ) – PFTIR radiance is the emissions of th e instrument itself. It is measured together with atmospheric ra diance 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 isolate the flare transmi ssion spectrum. For a more detailed description of this process, see Appendix A.5.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 77

Step 3 – Convert the transmission spectrum to an absorption spectrum Once the flare transmission spectrum has been isol ated, it must be converted to an absorbance spectrum so that standard spectroscopic tec hniques can be used for further analysis. Transmission and absorbance are related by th e Beer-Lambert law through the following equation.



## ߬ ௣௟௨௠௘ 

## ൌ ݁ ି௄ ሺ జ ሻ ∗௖∗௟ Equation A.4-2

Essentially, absorbance is the ne gative log of transmission, thus:

Absorbance ሺ ߭ ሻ ൌ ሺ 0.434 ሻ ܭሺ߭ሻ ∗ ܿ ∗ ݈ Equation A.4-3

See Appendix A.5 for further detail. This convers ion is a standard spec troscopic procedure.

Step 4 – Determine the concentrations of individual components in the flare plume Once the absorbance spectrum has been generated, th ere are several analytical techniques that may be used to estimate individual component concentrations. For this project, a modified Classical Least Squares (CLS) analysis 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 concentrat ion, corrections for spectral baseline shifts, corrections for any spectral lin e shifts observed, a nd 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 spectr al 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, this means different reference spectra will be chosen for each analyte in the measured spectrum. 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 A.4-10.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 78

Figure A.4.8-1: PFTIR Data Analysis Progression 

## PFTIR Data Analysis Progression

Interferogram

(volts vs cm retardation)

Radiance Spectrum (Single Beam)

(volts vs wavenumber) Radiant Energy From

Flare PlumeFourierTransform

Mn Corrected Radiance Spectrum (Single Beam)

(volts vs wavenumber)SubtractMn

Converted Radiance Spectrum (Single Beam)

(Radiance Units)Apply BBCalibration Bkgnd Corrected Radiance Spectrum (Single Beam)

(Radiance Units)Sky BackgroundCorrection Flare Plume

Transmittance Spectrum

(Radiance Units)IMACCSoftware

Flare Plume

Absorbance

Spectrum

(Radiance Units)NegativeLog

Individual Component

Concentration

(ppm-meters)CLSAnalysis Note: Data indicated in grey boxes are provided as raw

data fi les.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 79

A.4.7 Interferences For final analysis of the PFTIR spectra, a list of possible interferences is included with the

method and raw PFTIR data files. These include components that are likely to appear in the spectra but have no impact on the combustion e fficiency calculation. The major interferent is typically water, but other compounds like oz one and nitrogen oxides are also included.

A.4.8 Data Filtering The raw FTIR data (one minute averages) are repo rted from the analytical software with a 2- sigma (2 σ ) error calculated from the fit of the re ference spectra to th e sample spectra. Any individual component measurement that wa s less than 2 times this error (i.e., 4 σ ) was not used in calculating combustion efficiency.

This filtering eliminates non-detectable indivi dual components from the combustion efficiency calculation. For very poor combustion efficiencies, the CO 2 region of the spectra is very weak and might not pass through the detecti on filter described above. Without a CO 2 reading, the combustion efficiency drops to zero. However, this does not mean that combustion is not occurring. It just means that the signal for CO 2 is too weak to detect. Evidence of combustion still appears with the detection of CO, a product of ineffi cient combustion, but this cannot be

used to calculate combustion efficienc y. Therefore, runs that do not have CO 2 readings but do have CO readings are marked as below the detection limit for CO 2 . No combustion efficiency is listed for these runs, even t hough the flare is not snuffed.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 80



## A.5 PFTIR Theory and Operation

A.5.1 PFTIR Analytical Method and Procedure Gases have highly variable absorption with wave length. It is this vari ation that produces the absorption patterns that allow for their identificati on in the infrared. If th e transmission of a gas is given by ߬ ሺ ߥ, ܶ ሻ then ሾ 1െ߬ ሺ ߥ, ܶ ሻሿ is the amount of absorption. Th e radiation the gas emits at

temperature T is then given by:

ܰ ሺ ߥ, ܶ ሻ ൌ ሾ 1െ߬ ሺ ߥ, ܶ ሻሿ ∙ ܰ ௕௕ ሺ ߥ, ܶ ሻ Equation A.5-1

For flare measurements, it is this signal that is being detected from the hot gases above the

combustion zone.

As shown in Figure A.5.1-1, the total radi ance measured by the PFTIR consists of:

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

2. The flare radiance altered by its transmission through the a tmosphere between the plume

and the PFTIR instrument.

3. The atmospheric radiance of th e air between the flare plum e and the PFTIR instrument.

4. The radiance from the PFTIR instrument itself.

Figure A.5.1-1: Contributions to the measured flare radiance.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 81

The total radiant signal r eceived then consists of:

ܰ

௧௢௧௔௟ ൌ ܰ ௕௞௚ ∙ ߬ ௙௟௥ ∙ ߬ ௔௧௠ ൅ ܰ ௙௟௥ ∙ ߬ ௔௧௠ ൅ܰ ௔௧௠ ൅ ܰ ௙ Equation A.5-2

In Equation A.5-2, the arguments ሺ ߥ, ܶ ሻ have been dropped for clar ity and the individual terms

are:

ܰ ௧௢௧௔௟ ൌ total radiance

ܰ

௕௞௚ ൌ background sky radiance



### ߬ ݂݈ݎ ൌ flare transmissivity



### ߬ ௔௧௠ ൌ atmospheric transmissivity

ܰ

௔௧௠ ൌ atmospheric	radiance

ܰ

௙ ൌ radiance	of	the	FTIR	instrument	itself

The actual measurements performed by the PFTIR consist of the following:

ܯ

௥௟௙ ൌ the measured plume radiance

ܯ ௕ ൌ the measured background radiance taken by moving the PFTIR off the flare to monitor the sky b ackground. This is given by:

ܯ ௕ ൌ ܰ ௕௞௚ ∙ ߬ ௔௧௠ ൅ ܰ ௔௧௠ ൅ ܰ ௙ ܯ

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

ܯ ௕௕ ൌ a measurement made looking at the calibration source with a commercial black body emitter in the source

߬ ௔௧௠ ൌ measured atmospheric path transmission

A.5.2 From Radiance to Transmission Spectra Based on these measurements Equation A.5-2 can be rearranged to give the plume transmission

as:

߬ ௙௟௥ ൌ ܥ ∙ ൫ܯ ௥௟௙ െ ܯ
௡ ൯െܰ

஻஻ ௙௟௥ ∙ ߬ ௔௧௠ ܯሺ ∙ ܥ ௕ ܯ െ
௡ ܰሻെ ஻஻ ௙௟௥ ∙ ߬ ௔௧௠ Equation A.5-3

In this equation, the superscript 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. This is the in itial derivation that ha s had some proprietary modifications to improve stability and performance.

Atmospheric transmission ߬ ௔௧௠ is also measured using the ca libration 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.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 82

Atmospheric transmission is then given by:

߬ ௔௧௠ ൌ ܯ ூோ െ ܯ
௡ ܫ ଴ Equation A.5-4

M IR is the measured signal from the ca libration source using the IR source and M

n is the

measured cold source as defined ear lier. The only term not defined is I 0 . This is the so-called synthetic background. It is frequently used in open-path FTIR measur ements to convert a measured spectrum to transmission. It represents the shape of the spectrum that the PFTIR would measure if no gases were present. It can be synthesized from the ሺ ܯ ூோ െ ܯ
௡ ሻ measurement by doing a mathematical fit to points in the spectrum known to be fr ee 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 laboratory), 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 0 spectrum.

Figure A.5.2-1: Development of synthetic spectrum

A.5.3 Determination of Flare Temperature With Equations A.5-3 and A.5-4, Equation A.5-2 then contains only measured or computed
terms. However, to compute the Planck function at the temperature of the flare, ܰ ஻஻ ௙௟௥ , the flare gas temperature must be known. Fortunately, this can be measured using features in the PFTIR

data itself. One convenient feat ure is the CO band near 2150 cm -1 . Figure A.2-3 shows this band at two different temperatur es. The upper plot is at ambien t temperature (300 K) and the bottom plot is at 550 K. The effect of increasi ng temperature is to ex pand the band shifting the peak position away from band center while increa sing the strength of the weaker lines fartherMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 83

from band center. This is a sensi tive function of temperature, so the shape of the band essentially

measures temperature.

Figure A.5.3-1: Structure of the Fundamental CO Band 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 dict ated 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 transiti on. This “population” of the initial states is dictated by the Boltzmann di stribution which is given by:

ܰ

௃" ൌ ܰ ଴ ∙ 1 ൅ "ܬ ∙ 2

ܳ ∙ ݁ ିா"

௞∙் Equation A.5-5

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 available, E” the energy of the initial

state, k Boltzmann’s constant, T the absolute temperature, and Q a “partition sum.” The partition sum is just the sum of the exponential term ove r all possible energy levels. If the log of the measured intensity of the CO lines is plotted agai nst the initial st ate energy, the plot is linear and its slope is proportional to

݄ܿ

݇ܶ Equation A.5-6

Where h is Planck’s constant and c the speed of light.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 84

Temperature can therefore be determined by measur ing the slope of the plot. An example of this process is shown in Figure A.5.3-2. In this ca se the temperature was 225°C and the group of lines to the left in Figure A.5.3- 2 was used. These are defined as the R-branch lines of the CO

band.

Figure A.5.3-2 Plot of the log of the measured intensity of the CO lines vs. initial state

energy

Given temperature, all terms in Equation A.5-3 can be determined. Equation A.5-3 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.5.4 From Transmission to Absorption Spectra As in normal absorption spectrosc opy, the transmission is exponentia l in gas concentration. That is transmission is given by:

߬ ௣௟௨௠௘ ൌ ݁ ି௄ ሺ ఔ ሻ ∙௖∙௟ Equation A.5-7Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 85

Where ܭ ሺ ߥ ሻ is the absorption coefficient for the spectral line, c the gas concentration, and l the path length in the gas. Effectively ܭ ሺ ߥ ሻ is the reference standard in the FTIR for the gas being monitored. Taking the negative l og of this equation gives what is called Absorbance. For historical reasons, log base 10 is used and thus gives:

ܣ ܾݎ݋ݏܾܽ݊ܿ݁ ሺ ߥ ሻ ൌ ሺ 0.434 ሻ ∙ ܭ ሺ ߥ ሻ ∙ܿ∙݈ Equation A.5-8

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 analyzed using standard Classical Least Squares (CLS) procedures to get the indivi dual gas concentrations in the spectrum.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 86



## A.6 PFTIR QA/QC

A.6.1 Replicates Replicate runs were performed for many of th e test conditions. Table A.6.1-1 below shows the largest absolute variation in combustion efficiency between all test replicates.

1 st Replicate 2 nd Replicate 3 rd Replicate 4 th Replicate

Condition CE (%) CE (%) CE (%) CE (%) Largest Δ CE (%)

SN1 1 97.7 98.5 97.1 1.4

SN1 2 97.6 97.4 96.2 1.6

SN1 3 94.5 94.3 93.5 1.0

SN1 4 97.4 96.0 92.9 4.5

SN1 5 81.3 94.0 88.5 12.7

SN1 6 87.4 87.7 89.8 2.4 SN2 Nitrogen 1 99.0 N/A SN2 Nitrogen 2 99.1 N/A SN2 Nitrogen 3 98.8 N/A SN2 Nitrogen 4 97.1 N/A SN2 Nitrogen 5 87.2 N/A

SN2 Steam 1 98.7 N/A

SN2 Steam 2 98.9 N/A

SN2 Steam 3 96.3 N/A

SN2 Steam 4 67.8 71.4 3.6

SN2 Steam 5 82.2 N/A

VS1 1 99.7 N/A

VS1 2 100.0 99.9 99.8 0.2

VS1 3 99.8 N/A

VS1 4 99.8 99.1 99.8 0.7

VS1 5 99.8 N/A

VS1 6 99.5 99.7 99.9 0.4

VS1 7 98.5 99.0 99.4 0.9

VS1 9a 97.1 N/A

PA1 1 98.7 100.0 100.0 1.3

PA1 4 98.5 99.8 100.0 1.5

PA2 1 98.9 98.8 100.0 1.2

PA2 4 99.8 99.4 99.3 0.5

Table A.6.1-1: Combustion Effi ciencies of Replicate RunsMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 87

A.6.2 Simultaneous Runs Several runs during the test campaign were pe rformed with both PFTIRs collecting data. The Table A.6.2-1 below lists the average combustion efficiencies for each run from both PFTIRs.

Run PFTIR 1 CE (%) PFTIR 2 CE (%) CE Difference (%) SN1 1 (1) 97.7 93.1 4.6 SN1 2 (1) 97.6 97.2 0.4 SN1 2 (3) 96.2 93.8 2.4 SN1 3 (3) 93.5 94.1 0.6 SN1 4 (3) 92.9 93.2 0.3 SN1 5 (3) 88.5 91.8 3.3 SN1 6 (3) 88.4 89.8 1.4 VS1 1 (1) 99.7 99.8 0.1 VS1 3 (1) 99.8 99.7 0.1 VS1 4 (1) 99.8 99.9 0.1 VS1 5 (1) 99.8 99.6 0.2 VS1 6 (1) 99.5 99.8 0.3 VS1 7 (1) 98.5 99.5 1.0 VS1 9a (1) 97.1 99.1 2.0 SN2 Nitrogen 1 99.0 98.9 0.1 SN2 Nitrogen 2 99.1 98.7 0.4 SN2 Nitrogen 3 98.8 97.7 1.1 SN2 Nitrogen 4 97.1 96.4 0.7 SN2 Nitrogen 5 87.2 80.2 7.0 SN2 Steam 1 (2) 98.7 98.0 0.7 SN2 Steam 2 (1) 98.9 98.9 0.0 SN2 Steam 3 (1) 96.3 96.5 0.2 SN2 Steam 5 (1) 82.2 88.3 6.1 PA1 1 (1) 98.7 96.3 2.4 PA1 1 (2) 100.0 99.7 0.3 PA1 1 (3) 100.0 99.7 0.3 PA1 4 (1) 98.5 99.9 1.4 PA1 4 (3) 99.8 99.9 0.1 PA1 4 (4) 100.0 99.8 0.2 PA2 1 (1) 98.9 99.9 1.0 PA2 1 (2) 98.8 100.0 1.2 PA2 1 (3) 99.9 100.0 0.1 PA2 4 (1) 99.8 99.9 0.1 PA2 4 (2) 99.4 99.4 0.0 PA2 4 (3) 99.3 99.9 0.6

Table A.6.2-1: Simultaneous RunsMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 88

A.6.3 Traverse Results The optimum aiming point for the PFTIR is typica lly about one flame length from the flame tip. This insures that all combustion is complete prior to measurement. Optimal aiming position is monitored by observing the intensity of the CO 2 and CO lines in the single beam spectrum and the effects on the resulting absorbance spectrum. This is done to avoid detector saturation.

When the flare is obviously lit but the PFTIR reports a combustion efficiency of 0%, this indicates improper aiming of the PFTIR. A combus tion efficiency measurement of 0% when the

flare is lit indicates that the PFTIR is unable to measure CO 2

.

In order to determine how sensitive aiming posit ion is with respect to determination of combustion efficiency, a traverse along the plum e path was conducted. During this traverse, the PFTIR was gradually moved farther from the fl ame tip while measuring combustion efficiency under constant conditions. Figure 2.6.5-1 shows th e result of the VS1 traverse. Both PFTIRs participated in the VS1 traverse. The VS1 traver se conditions were the same conditions used in the VS1 6 test runs. Figure 2.6.5-2 shows example PFTIR aiming positions.

The traverse shows that as l ong as the PFTIR is aimed between the flame tip and one flame length from the flame tip, the PFTIR combustion efficiency measurements will be relatively consistent. However, if the PFTIR aiming position is farther than one flame length away from the flame tip, the signal to noise ratio may dr op to a point where the PFTIR cannot effectively measure combustion efficiency.

Figure A.6.3-1: VS1 Traverse ResultsMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 89

Figure A.6.3-2: Example Aiming PointsMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 90

A.6.4 Long Term Stability Test The purpose of test series LTS is to demonstrate the repeatability of PFTIR measurements over an extended period. This test may also provi de information on the effects of uncontrolled

variables such as wind on the overall test result. The LTS test series was conducted on the LRGO burners. Every effort was made to ensure the c ontrollable variables were held as constant as possible from run to run. Figure A.6.4-1 shows the results of the long term stability test.

Figure A.6.4-1: NHVcz vs CE for Lo ng Term Stability Test SeriesMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 91



# A.7 Vent Gas Composition

Figure A.7-1 shows the vent gas component distri bution for each run. Figure A.7-2 shows the net heating value contributions of each vent gas com ponent for each run. Tables A.7-1 to A.7-3 list the vent gas component distribution for each run. Ta bles A.7-4 to A.7-6 list the net heating value contributions of each vent gas component for each run.

Figure A.7-1: Vent Gas Component Distribution for Each Run

Figure A.7-2: Vent Gas Net Heating Value Contributions for Each RunMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 92

Table A.7-1: Vent Gas Component Di stribution for all SKEC Test Runs Condition Run Nitrogen Carbon Dioxide Methane Ethane Propane Propylene Normal Butane Total Molar Weight

‐‐ ‐‐ (mol %) (mol %) (mol %) (mol %) (mol %) (mol %) (mol %) (mol %) (lb/lb

‐ mol)

SN1 1 (1) 2.0 0.2 95.8 4.1 0.3 0.0 0.0 102.4 17.0

SN1 1 (2) 1.5 0.8 93.1 4.7 0.6 0.0 0.1 100.8 17.3

SN1 1 (3) 2.4 0.4 94.7 4.1 0.4 0.0 0.1 102.1 17.1

SN1 2 (1) 1.9 0.9 94.5 4.2 0.3 0.0 0.0 101.9 17.2

SN1 2 (2) 1.5 0.6 92.7 4.4 0.5 0.0 0.1 99.8 17.2

SN1 2 (3) 1.4 0.5 93.3 4.6 0.5 0.0 0.1 100.3 17.2

SN1 3 (1) 1.5 1.6 92.9 4.7 0.6 0.0 0.1 101.4 17.5

SN1 3 (2) 1.5 0.6 92.7 4.4 0.5 0.0 0.1 99.8 17.2

SN1 3 (3) 1.3 0.6 91.9 4.3 0.6 0.0 0.1 98.8 17.2

SN1 4 (1) 1.4 1.0 92.0 4.5 0.6 0.0 0.1 99.6 17.3

SN1 4 (2) 1.3 0.8 92.8 3.7 0.4 0.0 0.1 99.1 17.1

SN1 4 (3) 1.3 0.0 95.0 4.9 0.6 0.0 0.1 101.9 17.1

SN1 5 (1) 1.0 1.0 92.0 3.7 0.3 0.0 0.1 98.1 17.1

SN1 5 (2) 1.4 1.0 91.9 3.7 0.4 0.0 0.1 98.4 17.1

SN1 5 (3) 1.1 0.7 95.2 3.8 0.4 0.0 0.1 101.3 17.0

SN1 6 (1) 3.8 0.8 87.1 4.2 0.5 0.0 0.1 96.4 17.5

SN1 6 (2) 2.8 0.7 91.6 3.7 0.4 0.0 0.1 99.2 17.2

SN1 6 (3) 1.2 0.8 96.5 3.7 0.4 0.0 0.1 102.7 17.0

VS1 1 (1) 2.7 0.8 91.5 4.2 0.4 0.0 0.1 99.7 17.3

VS1 2 (1) 10.0 0.7 85.1 3.8 0.4 0.0 0.1 100.0 18.1

VS1 2 (2) 13.9 0.9 79.3 3.2 0.3 0.0 0.0 97.6 18.6

VS1 2 (3) 11.9 0.4 82.9 3.9 0.4 0.0 0.1 99.5 18.3

VS1 3 (1) 16.8 0.4 79.3 3.6 0.4 0.0 0.0 100.5 18.8

VS1 4 (1) 24.6 0.3 72.8 3.1 0.3 0.0 0.0 101.0 19.5

VS1 4 (2) 22.7 1.2 70.6 3.3 0.3 0.0 0.0 98.1 19.7

VS1 4 (3) 21.5 1.0 71.8 3.3 0.4 0.0 0.1 98.1 19.6

VS1 5 (1) 25.8 0.0 70.5 3.1 0.3 0.0 0.0 99.8 19.7

VS1 6 (1) 32.4 0.5 66.7 3.9 0.4 0.0 0.1 104.0 20.6

VS1 6 (2) 32.2 0.8 62.6 2.7 0.2 0.0 0.0 98.6 20.7

VS1 6 (3) 27.9 0.3 62.4 2.6 0.2 0.0 0.0 93.6 20.2

VS1 7 (1) 40.0 0.5 58.2 2.9 0.2 0.0 0.0 101.9 21.4

VS1 7 (2) 37.9 0.7 57.0 2.4 1.1 0.0 0.0 99.2 21.5

VS1 7 (3) 32.8 0.3 61.0 2.6 0.2 0.0 0.0 97.0 20.6

VS1 9a (1) 42.2 0.3 55.3 2.5 0.2 0.0 0.0 100.6 21.6

VS1 Traverse 1, PFTIR 1 35.7 0.3 62.4 3.5 0.4 0.0 0.1 102.4 20.9

VS1 Traverse 2, PFTIR 1 36.4 0.3 61.7 3.4 0.4 0.0 0.1 102.3 21.0

VS1 Traverse 3, PFTIR 1 37.0 0.3 61.1 3.3 0.3 0.0 0.0 102.1 21.0

VS1 Traverse 1, PFTIR 2 35.7 0.3 62.4 3.5 0.4 0.0 0.1 102.4 20.9

VS1 Traverse 2, PFTIR 2 36.4 0.3 61.7 3.4 0.4 0.0 0.1 102.3 21.0

VS1 Traverse 3, PFTIR 2 37.0 0.3 61.1 3.3 0.3 0.0 0.0 102.1 21.0

Pilot Test On (2) 1.7 0.7 92.9 4.2 0.5 0.0 0.1 100.0 17.2

Pilot Test Off (1) 1.7 0.7 92.9 4.2 0.5 0.0 0.1 100.0 17.2Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 93

Table A.7-2: Vent Gas Component Di stribution for all LRGO Test Runs

Table A.7-3: Vent Gas Component Di stribution for all SN2 Test Runs Condition Run Nitrogen Carbon Dioxide Methane Ethane Propane Propylene Normal Butane Total Molar Weight

‐‐ ‐‐ (mol %) (mol %) (mol %) (mol %) (mol %) (mol %) (mol %) (mol %) (lb/lb

‐ mol)

PA1 1 (1) 1.6 0.6 93.6 3.8 0.3 0.0 0.0 100.0 17.0

PA1 1 (2) 1.2 1.1 93.6 4.2 0.4 0.0 0.0 100.6 17.2

PA1 1 (3) 1.3 0.8 94.1 3.9 0.4 0.0 0.1 100.6 17.1

PA1 4 (1) 36.8 0.3 61.0 2.5 0.2 0.0 0.0 100.8 20.9

PA1 4 (3) 36.3 0.4 62.4 2.7 0.2 0.0 0.0 102.1 20.9

PA1 4 (4) 37.8 0.4 60.4 2.7 0.2 0.0 0.0 101.5 21.1

PA2 1 (1) 1.6 0.6 94.4 3.9 0.4 0.0 0.1 101.0 17.1

PA2 1 (2) 1.6 0.6 92.7 4.0 0.4 0.0 0.1 99.4 17.1

PA2 1 (3) 1.6 0.7 92.9 3.7 0.4 0.0 0.1 99.3 17.1

PA2 4 (1) 33.8 0.5 63.5 2.2 0.3 0.0 0.0 100.3 20.6

PA2 4 (2) 39.1 0.4 61.6 2.7 0.2 0.0 0.0 104.0 21.1

PA2 4 (3) 39.3 0.5 61.6 2.7 0.2 0.0 0.0 104.4 21.1

LTS 1 1.7 0.7 92.9 4.2 0.5 0.0 0.1 100.0 17.2

LTS 3 1.7 0.7 92.9 4.2 0.5 0.0 0.1 100.0 17.2

LTS 4 1.7 0.7 92.9 4.2 0.5 0.0 0.1 100.0 17.2

LTS 6 1.7 0.7 92.9 4.2 0.5 0.0 0.1 100.0 17.2

LTS 7 1.7 0.7 92.9 4.2 0.5 0.0 0.1 100.0 17.2

Condition Run Nitrogen Carbon Dioxide Methane Ethane Propane Propylene Normal Butane Total Molar Weight

‐‐ ‐‐ (mol %) (mol %) (mol %) (mol %) (mol %) (mol %) (mol %) (mol %) (lb/lb

‐ mol)

SN2 Nitrogen 1 81.8 0.0 3.4 0.2 0.0 14.6 0.0 100.0 29.7

SN2 Nitrogen 2 84.2 0.0 2.9 0.1 0.0 12.7 0.0 100.0 29.5

SN2 Nitrogen 3 86.9 0.0 2.4 0.1 0.0 10.5 0.0 100.0 29.2

SN2 Nitrogen 4 89.6 0.0 1.9 0.1 0.0 8.3 0.0 100.0 29.0

SN2 Nitrogen 5 92.2 0.0 1.5 0.1 0.0 6.3 0.0 100.0 28.7

SN2 Steam 1 (2) 0.3 0.1 18.6 0.8 0.1 80.0 0.0 100.0 37.1

SN2 Steam 2 (1) 0.3 0.1 18.8 0.8 0.1 79.8 0.0 100.0 37.0

SN2 Steam 3 (1) 0.3 0.1 18.4 0.8 0.1 80.2 0.0 100.0 37.2

SN2 Steam 4 (2) 0.3 0.1 19.1 0.9 0.1 79.4 0.0 100.0 37.0

SN2 Steam 4 (3) 0.3 0.1 18.6 0.8 0.1 80.0 0.0 100.0 37.1

SN2 Steam 5 (1) 0.3 0.1 18.5 0.8 0.1 80.1 0.0 100.0 37.1Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 94

Table A.7-4: Vent Gas Net Heating Valu e Contribution for all SKEC Test Runs Condition Run Nitrogen NHV Carbon Dioxide NHV Methane NHV Ethane NHV Propane NHV Propylene NHV Normal Butane NHV Total NHVvg

‐‐ ‐‐ BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf

SN1 1 (1) 0.0 0.0 838.5 64.1 6.0 0.0 0.7 909.4

SN1 1 (2) 0.0 0.0 827.9 74.7 12.5 0.0 2.3 917.3

SN1 1 (3) 0.0 0.0 831.6 63.6 8.3 0.0 1.9 905.3

SN1 2 (1) 0.0 0.0 831.2 65.7 7.1 0.0 1.1 905.1

SN1 2 (2) 0.0 0.0 832.0 69.7 12.0 0.0 2.7 916.4

SN1 2 (3) 0.0 0.0 832.9 73.0 11.8 0.0 2.3 920.0

SN1 3 (1) 0.0 0.0 821.2 73.6 13.2 0.0 2.7 910.8

SN1 3 (2) 0.0 0.0 832.0 69.7 12.0 0.0 2.7 916.4

SN1 3 (3) 0.0 0.0 832.9 70.2 13.6 0.0 3.0 919.6

SN1 4 (1) 0.0 0.0 827.6 72.6 13.3 0.0 3.1 916.5

SN1 4 (2) 0.0 0.0 839.0 60.0 9.4 0.0 2.0 910.5

SN1 4 (3) 0.0 0.0 835.6 76.0 13.7 0.0 3.0 928.3

SN1 5 (1) 0.0 0.0 840.3 60.3 6.1 0.0 2.3 909.0

SN1 5 (2) 0.0 0.0 837.0 59.9 9.6 0.0 2.1 908.5

SN1 5 (3) 0.0 0.0 842.0 59.4 9.7 0.0 2.0 913.1

SN1 6 (1) 0.0 0.0 809.1 69.2 11.7 0.0 2.5 892.5

SN1 6 (2) 0.0 0.0 827.4 59.4 9.5 0.0 2.0 898.4

SN1 6 (3) 0.0 0.0 841.9 57.7 9.4 0.0 2.0 911.0

VS1 1 (1) 0.0 0.0 822.3 67.5 9.9 0.0 1.9 901.7

VS1 2 (1) 0.0 0.0 762.1 61.0 9.6 0.0 2.0 834.7

VS1 2 (2) 0.0 0.0 727.8 53.1 6.2 0.0 1.2 788.2

VS1 2 (3) 0.0 0.0 746.6 62.9 9.1 0.0 1.7 820.2

VS1 3 (1) 0.0 0.0 706.7 57.2 8.2 0.0 1.4 773.6

VS1 4 (1) 0.0 0.0 645.7 48.3 6.0 0.0 0.9 700.9

VS1 4 (2) 0.0 0.0 644.8 53.1 7.9 0.0 1.5 707.2

VS1 4 (3) 0.0 0.0 656.3 53.3 8.6 0.0 1.8 719.9

VS1 5 (1) 0.0 0.0 633.5 50.3 6.4 0.0 0.9 691.1

VS1 6 (1) 0.0 0.0 574.7 59.5 9.9 0.0 2.4 646.4

VS1 6 (2) 0.0 0.0 569.0 43.7 5.3 0.0 1.0 618.9

VS1 6 (3) 0.0 0.0 597.1 45.0 5.9 0.0 1.5 649.6

VS1 7 (1) 0.0 0.0 511.8 45.4 5.4 0.0 0.7 563.3

VS1 7 (2) 0.0 0.0 514.6 39.0 25.1 0.0 0.8 579.5

VS1 7 (3) 0.0 0.0 563.6 42.7 5.7 0.0 1.3 613.3

VS1 9a (1) 0.0 0.0 492.2 40.4 4.3 0.0 0.6 537.4

VS1 Traverse 1, PFTIR 1 0.0 0.0 545.9 54.6 9.3 0.0 2.1 611.9

VS1 Traverse 2, PFTIR 1 0.0 0.0 541.0 52.9 8.2 0.0 1.6 603.6

VS1 Traverse 3, PFTIR 1 0.0 0.0 536.0 51.2 7.1 0.0 1.0 595.3

VS1 Traverse 1, PFTIR 2 0.0 0.0 545.9 54.6 9.3 0.0 2.1 611.9

VS1 Traverse 2, PFTIR 2 0.0 0.0 541.0 52.9 8.2 0.0 1.6 603.6

VS1 Traverse 3, PFTIR 2 0.0 0.0 536.0 51.2 7.1 0.0 1.0 595.3

Pilot Test On (2) 0.0 0.0 832.2 66.6 10.5 0.0 2.2 911.6

Pilot Test Off (1) 0.0 0.0 832.2 66.6 10.5 0.0 2.2 911.6Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 95

Table A.7-5: Vent Gas Net Heating Valu e Contribution for all LRGO Test Runs

Table A.7-6: Vent Gas Net Heating Valu e Contribution for all SN2 Test Runs Condition Run Nitrogen NHV Carbon Dioxide NHV Methane NHV Ethane NHV Propane NHV Propylene NHV Normal Butane NHV Total NHVvg

‐‐ ‐‐ BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf

PA1 1 (1) 0.0 0.0 839.0 60.5 7.5 0.0 1.5 908.6

PA1 1 (2) 0.0 0.0 834.0 66.9 8.7 0.0 1.4 911.0

PA1 1 (3) 0.0 0.0 837.9 62.1 8.6 0.0 1.6 910.2

PA1 4 (1) 0.0 0.0 542.0 39.7 4.5 0.0 0.8 587.0

PA1 4 (3) 0.0 0.0 547.6 42.4 5.6 0.0 1.0 596.6

PA1 4 (4) 0.0 0.0 532.9 41.7 5.4 0.0 0.9 580.9

PA2 1 (1) 0.0 0.0 838.1 61.4 8.6 0.0 1.7 909.7

PA2 1 (2) 0.0 0.0 836.0 64.1 8.8 0.0 1.8 910.7

PA2 1 (3) 0.0 0.0 837.6 60.2 8.7 0.0 1.8 908.3

PA2 4 (1) 0.0 0.0 567.4 35.7 5.7 0.0 1.1 609.9

PA2 4 (2) 0.0 0.0 530.3 41.2 5.5 0.0 0.9 577.8

PA2 4 (3) 0.0 0.0 528.7 41.8 5.4 0.0 0.9 576.9

LTS 1 0.0 0.0 832.2 66.6 10.5 0.0 2.2 911.6

LTS 3 0.0 0.0 832.2 66.6 10.5 0.0 2.2 911.6

LTS 4 0.0 0.0 832.2 66.6 10.5 0.0 2.2 911.6

LTS 6 0.0 0.0 832.2 66.6 10.5 0.0 2.2 911.6

LTS 7 0.0 0.0 832.2 66.6 10.5 0.0 2.2 911.6

Condition Run Nitrogen NHV Carbon Dioxide NHV Methane NHV Ethane NHV Propane NHV Propylene NHV Normal Butane NHV Total NHVvg

‐‐ ‐‐ BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf BTU/scf

SN2 Nitrogen 1 0.0 0.0 30.7 2.5 0.4 312.9 0.1 346.5

SN2 Nitrogen 2 0.0 0.0 26.3 2.1 0.3 272.3 0.1 301.2

SN2 Nitrogen 3 0.0 0.0 21.9 1.8 0.3 226.6 0.1 250.6

SN2 Nitrogen 4 0.0 0.0 17.5 1.4 0.2 178.8 0.0 197.9

SN2 Nitrogen 5 0.0 0.0 13.1 1.0 0.2 134.9 0.0 149.3

SN2 Steam 1 (2) 0.0 0.0 166.8 13.3 2.1 1,719.0 0.4 1,901.7

SN2 Steam 2 (1) 0.0 0.0 168.4 13.5 2.1 1,715.0 0.5 1,899.4

SN2 Steam 3 (1) 0.0 0.0 164.8 13.2 2.1 1,724.2 0.4 1,904.7

SN2 Steam 4 (2) 0.0 0.0 171.3 13.7 2.2 1,707.5 0.5 1,895.1

SN2 Steam 4 (3) 0.0 0.0 166.8 13.3 2.1 1,719.0 0.4 1,901.7

SN2 Steam 5 (1) 0.0 0.0 165.8 13.3 2.1 1,721.7 0.4 1,903.3

## A.8 Personnel Involved with Flare Performance Test

Marathon Petroleum Company, LP Jim Manning

Brandon Monistere

Jim Wilkins

Ruth Cade



### Clean Air Engineering, Inc.

Scott Evans

Dan Pearson

Tim Rodak Jim Wright

Volker Schmid Junior Lopez



### Industrial Monitor and Control Corporation (IMACC) Dr. Robert Spellicy

Mark Sloss



### John Zink Company, LLC

Zach Kodesh

Scott Fox Cliff Pugh

Richard Lawhead Craig Skaggs

Charlie Crown

Marvin ThomasMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 97



## A.9 Minute Data of Runs

Minute data spreadsheets and charts are located on the digital media provided with this report.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 98



## A.10 Video Camera Descriptions

During the test program, a total of six video cameras recorded flare activity from the lot and road locations (see Appendix A.4.2 for location informa tion). Four infrared ca meras and two visible light cameras were used. This appendix de scribes the video cameras used. Appendix A.11

contains the video ta ken by these cameras.

A.10.1 NEC/Mikron TH5104 This infrared camera was used as an aiming camera for PFTIR 1. It was mounted on the PFTIR telescope. The PFTIR operator used the image fr om this camera to aim the instrument. An examination of this video stream gives an in dication of PFTIR aiming accuracy. Figure A.6-1 shows an example image from this camera. The crosshair (added for this report) shows the area analyzed by PFTIR 1 (see Appendix A.4.2 for location descriptions).

Figure A.10.1-1: Image fr om NEC/Mikron TH5104Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 99

A.10.2 FLIR A320 This infrared camera was used as a stationary thermal camera at both PFTIR locations. It captured a general thermal view of the flare durin g the test program. It has a broad spectral range from 7.5 to 13 microns (1333 to 769 wavenumb ers). The temperature scale on the camera was not calibrated for transparent gases, so any temperatures shown were considered relative indicators only. Figures A.10.2-1 and A.10.2- 2 show example images from the FLIR A320

cameras. The FLIR A320 camera was mounted on PFTIR 2. The PFTIR ope rator used the image from this camera to aim the instrument. Figure A.6-4 shows an example image of the FLIR A320 camera being used as the aiming camera for PFTIR 2.

Figure A.10.2-1: Image from FLIR A320 – Stationary

Figure A.10.2-1: Image from FLIR A320 – PFTIR 2 AimingMarathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 100

A.10.3 Axis Q1755 This visible light camera was used as a stationa ry visual camera at both PFTIR locations. The HD cameras provided a detailed visible light im age of the flare operation. The purpose of the Axis Q1755 cameras was to provide a visual im age corresponding to the PFTIR locations during testing. Figure A.6-5 shows example images from the Axis Q1755 camera.

Figure A.10.3-1: Images from Axis Q1755Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 101



## A.11 Video of Runs

Videos of runs are located on the digital media provided with this report.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 102



## A.12 Daily Calibration Data and Spectra

Daily Calibration Data and Spectra are located on the digital media provided with this report.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 103



## A.13 Background Times and Spectra

Background Times and Spectra are located on the digital media provided with this report.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 104



## A.14 PFTIR Raw Data and Spectra

PFTIR raw data and spect ra are located on the digital media provided with this report.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 105



## A.15 Airtech Gas Chromatography Report

The Airtech Gas Chromatogra phy Report is located on the digital media provided with this report.Marathon Petroleum ‐ Garyville Ground Flare Burner Test Report Page 106



## A.16 John Zink Test Report

The John Zink Test Report is located on the digital media provided with this report.