HRVOC Monitoring Requirements

1. HRVOC Monitoring Requirements • Cooling Towers • Must measure flow and continuous concentration in all cooling tower return streams • Must file QA/QC plan with state for approval • Approval - how long will it take? How consistent will reviews be? • Will delay implementation of projects • El Paso stripper, sparger or gas transfer membranes will be required, not a lot of experience with this in our plants • El Paso stripper and operating conditions, equations defined in Appendix P • Total strippable VOC measurement opens doors to other techniques • Methane/ethane exclusion • Minimum detection limits of no more than 10 ppbw in water • Review math in Appendix P, assumes total transfer to gas phase of VOCs • Henry’s Law evaluation not required • Cycle time for analysis • Shorter if using total hydrocarbons or some other aggregate property analyzer • If using speciation anyway the ability to get measurement done in 15 minutes is easier. • Calibration • Local calibration direct into analyzer • Periodic testing of water/hydrocarbon mix Texas City ISA Section Meeting

2. Monitoring Cooling Towers and Flares • Flares • Concentration and flow measurement required in header after last knockout, BTU measurement also required • Design and operating conditions for some flares will make this a very unique situation • Monitoring requirements list Performance Specification 9 (PS 9), a GC method for the calibration requirements • Too specific, should be able to use other analysis methods such as FTIR, mass spectrometers, and calorimeters • PS 9 performance requirements are too stringent, e.g., 120 deg. C sample lines and oven • Different test methods for organics and inorganics • Why not use a calibration gas method like we do with other analyzers rather than rely on lab tests? • Since we have to do compounds necessary for HRVOCs and BTU how far out do we analyze? Texas City ISA Section Meeting