SRI/USEPA-GHG-QAP-20
September 2003

Environmental Technology
Verification Report

Engineered Concepts, LLC
Quantum Leap Dehydrator

Greenhouse Gas Technology Center
Southern Research Institute

oEPA

Under a Cooperative Agreement With
U.S. Environmental Protection Agency


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EPA REVIEW NOTICE

This report has been peer and administratively reviewed by the U.S. Environmental Protection Agency, and
approved for publication. Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.


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ETV Joint Verification Statement

TECHNOLOGY TYPE:

Emissions Control of Criteria Pollutants, Hazardous
Pollutants, and Greenhouse Gases

APPLICATION:

Natural Gas Dehydration

TECHNOLOGY NAME:

Quantum Leap Dehydrator

COMPANY:

Engineered Concepts, LLC

ADDRESS:

1909 E. 20th St., Farmington, NM 87401

E-MAIL:

gasstripDer@netscape.net

The U.S. Environmental Protection Agency (EPA) has created the Environmental Technology
Verification (ETV) program to facilitate the deployment of innovative or improved environmental
technologies through performance verification and information dissemination. The ETV program goal is
to further environmental protection by accelerating the acceptance and use of improved and cost-effective
technologies. ETV seeks to achieve this by providing high-quality, peer-reviewed performance data to
those involved in the purchase, design, distribution, financing, permitting, and use of environmental
technologies.

ETV works in partnership with recognized standards and testing organizations, stakeholder groups
composed of buyers, vendor organizations, and permitters, and with the full participation of individual
technology developers. The program evaluates technology performance by developing test plans that are
responsive to stakeholders" needs, conducting field or laboratory tests, collecting and analyzing data, and
preparing peer-reviewed reports. All evaluations are conducted in accordance with rigorous quality
assurance protocols. This ensures that the resulting data are of known quality and that the results are
defensible.

Southern Research Institute operates the Greenhouse Gas Technology Center (GHG Center), one of six
ETV Centers, in cooperation with EPA's National Risk Management Research Laboratory. The GHG
Center has recently evaluated the performance of the Quantum Leap Dehydrator (QLD), manufactured by

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Engineered Concepts, LLC, of Farmington, NM. This Verification Statement provides a QLD
verification test summary.

TECHNOLOGY DESCRIPTION

Background

Natural gas often contains excess water vapor at the wellhead which must be removed to avoid pipeline
corrosion and solid hydrate formation. Glycol dehydration is the most widely used natural gas
dehumidification process. Triethylene glycol (TEG) typically absorbs water from natural gas in a
contactor vessel. The TEG absorbs water from the natural gas, but also absorbs methane (CH4), volatile
organic compounds (VOCs), and hazardous air pollutants (HAPs). Gas-assisted or electric pumps
circulate the TEG through a distillation column for regeneration and back to the contactor vessel.
Distillation removes the absorbed water and HAPs from the TEG to the still column vent as vapor.
Conventional dehydrator still columns often emit this vapor directly to the atmosphere. Natural gas
dehydration is the third largest CH4 emission source in the natural gas production industry. Glycol
dehydrators also cause over 80 percent of the industry's annual HAP and VOC emissions.

OLD Technology

Information supplied by Engineered Concepts, LLC provided the basis for this discussion. GHG Center
personnel verified the function and operation of major system components during the test campaign.

The QLD is an integrated system which collects the water and hydrocarbons present in the glycol reboiler
vent stream and separates condensable and non-condensable fluids. The two primary condensable
products are: (1) wastewater, which can be disposed of with treatment and (2) hydrocarbon condensate,
which is a saleable product. The reboiler burner combusts the uncondensable vapors as the system's
primarily fuel. The QLD uses condensation and combustion to reduce both HAP and CH4 emissions.

The QLD uses a series of heat exchangers, condensers, separators, and electric pumps to recover and use
distillation column vapors. First, a liquid removal vacuum separator condenses and collects still column
vent water and HAPs vapors under vacuum. The separator partitions the vapor stream into three
products: (1) wastewater, (2) condensate, and (3) uncondensed hydrocarbon vapors. The separator
discharges the wastewater and condensates into product holding tanks through pneumatically-operated
level controllers. Negative gage pressure, created by glycol flow through an eductor (which provides
additional scrubbing), transfers hydrocarbon vapors to the emissions separator.

The emissions separator further separates liquid products from uncondensable hydrocarbon vapors and
glycol. It transfers liquid products back to the vacuum separator while the reboiler burner combusts the
hydrocarbon vapors. The burner operates continuously and throttles the heat output in response to still
column heat demand. Burner performance is the primary indicator of whether the QLD can combust the
widely varying amounts and quality of fuel gas recovered by the system. The burner system can also
accept makeup natural gas if the still column demands additional heat.

An electric pump circulates approximately four gallons per minute (gpm) of TEG through the natural gas
contactor vessel. A separate pump circulates about 72 gpm within the QLD condensation/separation
system. Electric pumps, in contrast to the widely used gas-assisted pumps, further reduce CH4 emissions
and losses.

Primary QLD air emission sources include: (1) the reboiler burner exhaust, (2) HAPs dissolved in the
recovered wastewater, and (3) pressure-relief vents (PRVs). The QLD fabricator and field installers
certified the equipment as leak-free, so this verification did not quantify fugitive emissions.

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VERIFICATION DESCRIPTION

The GHG Center executed the QLD performance verification test at the Kerr-McGee Gathering Station in
Brighton, CO. The test campaign proceeded under requirements set forth in the Test and Quality
Assurance Plan - Engineered Concepts. LLC Quantum Leap Dehydration (SRI/USEPA-GHG-QAP-20),
June, 2002 (Test Plan). The system was designed to dehydrate approximately 28 million standard cubic
feet per day (mmscfd) of natural gas.

Testing commenced in April 2003, approximately one month after completion of system start-up
activities. Tests consisted of a seven-day operational performance monitoring period followed by one day
of environmental performance testing. The system operated normally during testing, and the GHG Center
evaluated the verification parameters listed below:

Operational Performance

Sales Gas Moisture Content: The field site requires that dry natural gas exiting the QLD process contain
less than seven lb water/mmscf. An inline moisture analyzer continuously monitored and recorded sales
gas moisture readings at one-minute intervals.

Sales Gas Production Rate: The QLD must allow uninterrupted natural gas dehydration and maintain a
continuous natural gas flow. An inline integral orifice meter continuously monitored the natural gas flow
rate. Data were logged in one-minute intervals.

Glycol Circulation Rate: Facilities affected by the 40 CFR Part 63 standard (Subpart HH) regulations
must continuously monitor TEG circulation rates. An ultrasonic meter, installed on the regenerated lean
glycol line, recorded one-minute average circulation rates.

Makeup Natural Gas Flow Rate: A separate meter continuously monitored reboiler burner makeup
natural gas. The one-minute average readings characterized any additional fuel required by the QLD.

Environmental Performance

Reboiler Stack Emission Rates: Emissions tests determined concentration in parts per million volume,
dry (ppmvd) and emission rates in pound per hour (lb/h) for the following air pollutants: nitrogen oxide
(NOx), carbon monoxide (CO), VOCs, HAPs (benzene, toluene, ethylbenzene, xylene, and hexane), and
greenhouse gases (C02 and CH4). Three test runs were conducted, each lasting approximately 90
minutes. All testing conformed to U.S. EPA Title 40 CFR 60 Appendix A Reference Method procedures.

HAP Destruction Efficiency: Dehydration facilities subject to MACT must reduce HAP emissions by 95
percent. The tests verified HAP destruction efficiency as a measure of emissions reduced by the QLD.
HAP destruction efficiency is the HAPs entering the system (absorbed in rich and lean glycol streams)
minus the HAPs emitted from the system (discharged and vented to atmosphere from stack, PRVs, and
wastewater) divided by the HAPs entering the system. HAPs dissolved in the condensate product stream
are not an emission source because the site uses this product as feedstock for other processes. The
regulation defines this as "controlled" or "sequestered" emissions.

Wastewater and Condensate Production Rate: HAP destruction efficiency determination required
volumetric measurement of wastewater and condensate production rates.

Independent GHG Center QA personnel conducted a technical systems audit during testing to ensure that
field activities complied with the Test Plan. The Center's QA Manager implemented a data quality audit

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of at least ten percent of the data to ensure that data reduction and reporting accurately represented actual
results. The field team leader conducted performance evaluation audits to ensure that the measurement
system produced reliable data. In addition to these quality assurance audits, EPA QA personnel
conducted a quality assurance review of the Verification Report and a quality systems audit of the GHG
Center's Quality Management Plan.

PERFORMANCE VERIFICATION

Operational Performance

One-minute readings provided daily average flow rates and moisture content over the seven-day performance
evaluation period. The 75th percentile interval of these readings defined normal operating conditions.

•	The QLD natural gas dehydration process met the test site's 7.00 lb/mmscf moisture content
requirement. Daily average values ranged between 0.89 and 1.28 lb/mmscf.

•	The QLD enabled continuous sales gas flow, with daily average flow rates ranging between 26.8 and
29.3 mmscfd.

•	Daily average glycol circulation rates through the absorption and regeneration process ranged
between 3.00 and 3.77 gpm.

•	The verification test demonstrated that the QLD required little to no makeup natural gas. The normal
range of the makeup natural gas flow rate was 0.00 to 1.76 scfh, which is well below the 166 scfh
design capacity. The volume and fuel quality of the uncondensed hydrocarbon vapors was generally
sufficient to maintain optimum burner control.

Environmental Performance

•	Average NOx concentration for the three test runs was 65.1 ppmvd during normal operations. This
equates to a mass emission rate of 0.0817 lb/h.

•	Emissions of CO and VOCs were low during all three test runs, averaging 0.6 ppmvd (0.0005 lb/h)
and 0.6 ppmvd (0.0003 lb/h), respectively.

•	Stack emissions of all HAP constituents were below the sensitivity of the sampling system. The
detection limit was 0.1 ppmvd, which meets the specifications of the Title 40 CFR 60 Appendix A
reference methods. The hourly average stack HAP emission rate is verified to be less than 0.0016
lb/h.

•	Methane concentrations were not detected during any of the test periods The detection limit was 0.1
ppmvd, which meets the specifications of the Title 40 CFR 60 Appendix A reference methods. C02
concentrations averaged about 9.3 percent of the stack gas volume, equating to a mass emission rate of
111 lb/h.

•	PRVs did not operate at any time during the entire test campaign, nor are releases anticipated during
normal operations. Therefore, no expected emissions were assigned to PRV operation.

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REBOILER STACK EMISSIONS



NOx

CO

voc

ppmvd

lb/h

ppmvd

lb/h

ppmvd

lb/h

Run 1

67.8

0.0873

0.3

0.0003

0.4

0.0002

Run 2

66.0

0.0817

1.0

0.0007

0.8

0.0004

Run 3

61.6

0.0761

0.6

0.0004

0.5

0.0002

Avg.

65.1

0.0817

0.6

0.0005

0.6

0.0003



HAP

CH,

co2

ppmvd

lb/h

ppmvd

lb/h

ppmvd

lb/h

Run 1

<0.6

<0.0016

<0.1

<0.00004

9.5

117

Run 2

<0.6

<0.0016

<0.1

<0.00004

9.2

109

Run 3

<0.6

<0.0015

<0.1

<0.00004

9.1

108

Avg.

<0.6

<0.0016

<0.1

<0.00004

9.3

111

•	HAPs entering the QLD were 9.09 lb/h. Maximum HAPs leaving the system in the reboiler exhaust
and wastewater were 0.0016 and 0.0220 lb/h, respectively. The HAP destruction efficiency is greater
than 99.74 ± 0.01 percent.

•	Wastewater production rate was approximately 0.106 gallons per minute or 6.36 gallons per hour.

•	Saleable condensate product recovery rate was approximately 0.048 gallons per minute or 2.88
gallons per hour.

Signed by: Hugh W. McKinnon, 9-2003

Hugh W. McKinnon, M.D., M.P.H.

Director

National Risk Management Research Laboratory
Office of Research and Development

Signed by: Stephen D. Piccot, 9-2003

Stephen D. Piccot
Director

Greenhouse Gas Technology Center
Southern Research Institute

Notice: GHG Center verifications are based on an evaluation of technology performance under specific,
predetermined criteria and the appropriate quality assurance procedures. The EPA and Southern Research Institute
make no expressed or implied warranties as to the performance of the technology and do not certify that a
technology will always operate at the levels verified. The end user is solely responsible for complying with any and
all applicable Federal, State, and Local requirements. Mention of commercial product names does not imply
endorsement or recommendation.

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SRI/USEPA-GHG-QAP-20
September, 2003



Greenhouse Gas Technology Center

A U.S. EPA Sponsored Environmental Technology Verification ( ElV ) Organization

Environmental Technology Verification Report

Engineered Concepts, LLC
Quantum Leap Dehydrator

Prepared by:

Greenhouse Gas Technology Center
Southern Research Institute
PO Box 13825
Research Triangle Park, NC 27709 USA
Telephone: 919/806-3456

Reviewed by:

Engineered Concepts, LLC [SI
Kerr McGee Gathering, LLC S
Selected Members of GHG Center Stakeholder Panel [SI
U.S. EPA Office of Research and Development QA Team S

\Z\ indicates comments are integrated into Verification Report


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TABLE OF CONTENTS

Page

Appendices 	iii

List of Figures 	iii

List of Tables 	iii

Distribution List	iv

1.0 INTRODUCTION	1-1

1.1.	BACKGROUND	1-1

1.2.	QLD TECHNOLOGY DESCRIPTION	1-2

1.3.	TEST FACILITY DESCRIPTION AND QLD MODIFICATIONS	1-6

1.4.	PERFORMANCE VERIFICATION OVERVIEW	1-10

1.4.1.	Performance Verification Parameters	1-10

1.4.2.	Measurement Approach	1-11

1.4.2.1.	Sales Gas Moisture Content	1-14

1.4.2.2.	Sales Gas Production Rate	1-14

1.4.2.3.	Glycol Circulation Rate	1-14

1.4.2.4.	Makeup Natural Gas Flow Rate	1-15

1.4.2.5.	Reboiler Stack Emission Rates	1-15

1.4.2.6.	HAP Destruction Efficiency	1-16

1.4.2.7.	Additional Supporting Measurement Details	1-16

1.4.2.7.1	Glycol Flow 1-16

1.4.2.7.2	Lean Glycol Sample Condition	1-16

1.4.2.7.3	Lab Analysis	1-17

1.4.2.7.4	Wastewater Discharge Rate	1-17

1.4.2.7.5	HAPs Emitted from Pressure-Relief Vents	1-18

1.4.2.7.6	HAPs Entering in Makeup Natural Gas	1-18

2.0 VERIFICATION RESULTS	2-1

2.1.	OVERVIEW	2-1

2.2.	OPERATIONAL PERFORMANCE	2-2

2.3.	ENVIRONMENTAL PERFORMANCE	2-3

2.3.1.	Reboiler Stack Emissions Performance	2-5

2.3.2.	HAP Destruction Efficiency	2-6

2.3.2.1.	HAP Inputs from Glycol Streams	2-7

2.3.2.2.	HAP Outputs in Reboiler Exhaust Stream	2-9

2.3.2.3.	HAP Outputs in Wastewater Production Stream	2-10

2.3.2.4.	HAP Outputs in Condensate Production Stream	2-12

3.0 DATA QUALITY ASSESSMENT	3-1

3.1.	DATA QUALITY OBJECTIVES	3-1

3.2.	DQO AND DQI RECONCILIATION	3-4

3.2.1.	Sales Gas Flow Rate and Moisture Content	3-7

3.2.2.	Glycol Circulation Rate	3-7

3.2.3.	Makeup Natural Gas Flow Rate	3-8

3.2.4.	Reboiler Stack Emissions	3-9

3.2.4.1.	NO, and TIIC	3-9

3.2.4.2.	CO, CO and ()•	3-9

3.2.4.3.	HAPs	3-9

3.2.4.4.	Moisture Measurement	3-10

3.2.4.5.	Emission Rate Measurement Error	3-10

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3.2.5. HAP Destruction Efficiency	3-10

3.2.5.1. Liquid Analysis Data Quality	3-11

4.0 TECHNICAL AND PERFORMANCE DATA SUPPLIED BY ENGINEERED

CONCEPTS, LLC	4-1

5.0 REFERENCES	5-1

APPENDICES

Page

Appendix A	Rich Glycol Flow Rates	A-l

Appendix B	Emissions Testing QA/QC Results	B-l

Appendix B-l	Summary of Daily Reference Method Calibration Error Determinations	B-2

Appendix B-2	Summary of Reference Method System Bias and Drift Checks	B-3

Appendix B-3	Summary of GC/FID Calibration Results	B-4

Appendix C	Liquid Analysis QA/QC Results	C-l

Appendix C-l	Rich Glycol—Duplicate and Spike Analysis Results	C-2

Appendix C-2	Lean Glycol—Duplicate and Spike Analysis Results	C-3

Appendix C-3	Wastewater—Duplicate and Spike Analysis Results	C-4

Appendix C-4	Condensate—Spike Analysis Results	C-5

Appendix C-5	Rich and Lean Glycol Moisture Content—Duplicate Analysis Results	C-6

Appendix D	Pre-Test Makeup Natural Gas Analysis Data	D-l

Appendix D-l Pre-Test Makeup Natural Gas Analysis	D-2

LIST OF FIGURES

Page

Figure 1-1	Generic Natural Gas Dehydration Process	1-3

Figure 1-2	QLD Natural Gas Dehydration Technology	1-5

Figure 1-3	QLD at Kerr-McGee Gathering Station	1-7

Figure 1-4	QLD Interior	1-8

Figure 1-5	Measurement System Schematic	1-13

Figure 2-1	Operational Parameters Measured During Verification Test Period	2-4

Figure 2-2	Fuel Gas Flow Rates Measured During the Verification Test Period	2-4

LIST OF TABLES

Page

Table 1-1	Test Site Design and Operating Conditions	1-9

Table 1-2	Verification Test Matrix	1-12

Table 1-3	Emissions Testing Methods Summary	1-15

Table 2-1	Pre-Test Operational Data and Establishment of Normal Operating

Conditions	2-2

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Table 2-2	Verification Test Period Operational Data Summary	2-3

Table 2-3	Additional Process Operating Data for Verification Test Periods	2-5

Table 2-4	Reboiler Stack Emissions Summary	2-5

Table 2-5	HAP Destruction Efficiency	2-6

Table 2-6	HAP Inputs From Glycol Streams	2-8

Table 2-7	Reboiler Exhaust Stream HAPs Output	2-10

Table 2-8	Pre-Test Wastewater Discharge Rate Determinations	2-10

Table 2-9	Wastewater Production Rate During Verification Testing	2-11

Table 2-10	HAP Outputs in Wastewater Production Stream	2-12

Table 2-11	Run-Specific Condensate Production Rate	2-13

Table 2-12	HAP Outputs in Condensate Production Stream	2-14

Table 3-1	Verification Parameter Data Quality Objectives	3-1

Table 3-2	Data Quality Indicator Goals and Results	3-2

Table 3-3	Calibration Results and QC Checks	3-5

Table 3-4	Comparison Between Length-of-Stain Moisture Content and

Analyzer Reading	3-7

Table 3-5	Destruction Efficiency Error Determinations	3-12

Table 3-6	Maximum Percent Difference in Duplicate Injection Results	3-12

Table 3-7	Benzene Audit Results	3-13

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LIST OF ABBREVIATIONS AND ACRONYMS

acfh

actual cubic feet per hour

ARL

atmospheric rich/lean method

bcfy

billion cubic feet per year

BTEX

benzene, toluene, ethylbenzene, xylenes

CAR

corrective action report

dscfh

dry standard cubic feet per hour

dscfm

dry standard cubic feet per minute

ECL

Engineered Concepts, LLC

EPA

Environmental Protection Agency

EPA-ORD

Environmental Protection Agency-Office of Research and Development

ETV

Environmental Technology Verification

fps

feet per second

ft

feet (foot)

gal

gallon(s)

gal/in.

gallons per inch

GC

gas chromatograph

GC/FID

gas chromatograph with flame ionization detector

gPm

gallons per minute

GRI

Gas Research Institute (became the Gas Technology Institute)

GTI

Gas Technology Institute

HAP

hazardous air pollutant

hp

horsepower

in.

inches

lb

pound

lb/h

pounds per hour

lb/mmscf

pounds per million cubic feet

LDL

lower detection limit

m

meters

mm

millimeters

MACT

maximum achievable control technology

MDL

method detection limit

mBtu

thousand British thermal units

mBtu/h

thousand British thermal units per hour

ml

milliliter

mg

milligram

mmscfd

million standard cubic feet per day

mmscfh

million standard cubic feet per hour

mscf

thousand standard cubic feet

mscfd

thousand standard cubic feet per day

MW

molecular weight

ng

nanogram

NIST

National Institute of Standards and Technology

ppm

parts per million

pmvd

parts per million by volume, dry

psia

pounds per square inch, absolute

psig

pounds per square inch, gage

PRV

pressure-relief vent (or valve)

QA

quality assurance

QA/QC

quality assurance / quality control

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LIST OF ABBREVIATIONS AND ACRONYMS, CONTINUED

QLD

Quantum Leap Dehydrator

QMP

Quality Management Plan

scfgal

standard cubic feet per gallon

scfh

standard cubic feet per hour

SRI

Southern Research Institute

TEG

triethylene glycol

VOC

volatile organic compound

w.g.

water glass or water head pressure

°F

degrees Fahrenheit

ig

microgram

ig/ml

micrograms per milliliter

il

microliter

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DISTRIBUTION LIST

Engineered Concepts, LLC

Rodney Heath

Kerr-McGee Gathering, LLC

Paul Morehead
Robert Smith

U.S. EPA-Office of Research and Development

David Kirchgessner
Shirley Wasson

Southern Research Institute (GHG Center)

Stephen Piccot
Mark Meech
Robert Richards
Ashley Williamson

Technical Peer Revieweres

Curtis Rueter-Wind River Environmental
James M. Evans, Consultant

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1.0

INTRODUCTION

1.1. BACKGROUND

The U.S. Environmental Protection Agency's Office of Research and Development (EPA-ORD) is
charged with facilitating the deployment of improved and innovative environmental technologies. EPA-
ORD operates the Environmental Technology Verification program (ETV) to achieve this end. ETV's
mission is to further environmental protection by accelerating these technologies acceptance and use.

To realize its mission, ETV independently verifies technology performance and disseminates the results
to a wide variety of public, industry, regulatory, and private stakeholders. Congress funds ETV in
response to the belief that there are many viable environmental technologies that are not being used for
the lack of credible third-party performance data. With performance data developed under ETV,
technology buyers, financiers, and permitters will be better equipped to make informed decisions
regarding environmental technology purchase and use.

EPA's partner organization, Southern Research Institute (SRI) operates the Greenhouse Gas Technology
Center (GHG Center) which is one of six ETV organizations. The GHG Center verifies the performance
of promising greenhouse gas mitigation and monitoring technologies by developing verification
protocols, conducting field tests, collecting and interpreting field and other data, obtaining independent
peer review input, and reporting findings. Externally reviewed "Test and Quality Assurance Plans" (test
plans) and well-established quality assurance (QA) protocols regulate the GHG Center's verification
activities.

Volunteer stakeholder groups guide the GHG Center. These stakeholders advise on specific technologies
most appropriate for testing, help distribute results, and review test plans and "Environmental Technology
Verification Reports" (reports). National and international environmental policy, technology, and
regulatory experts participate in the GHG Center's Executive Stakeholder Group. The group includes
industry trade organizations, environmental technology finance groups, governmental organizations, and
other interested parties. Industry-specific stakeholders also peer-review key GHG Center publications
and guide verification test strategies in those areas related to their expertise.

The GHG Center's Oil and Gas Stakeholder Group has identified a need for independent third-party
methane (CH4) and carbon dioxide (C02) emission reduction technology verification. Natural gas
dehydration is a significant source of these two greenhouse gases and other pollutants. This report
documents the performance of a new dehydration technology that reduces greenhouse gases, hazardous
air pollutant (HAP), and volatile organic compound (VOC) emissions.

Approximately 252,000 natural gas production wells currently operate in the U.S. The natural gas often
contains excess water vapor which can cause corrosion and form solid gas hydrates inside pipelines. The
natural gas production and transportation sectors consequently invest considerable resources to remove
water from natural gas.

Glycol dehydration is the process where dry triethylene glycol (TEG) absorbs water vapor by directly
contacting the sales gas. It is the most widely used natural gas dehumidification process. TEG primarily
absorbs water, but it also absorbs CH4, VOCs, and HAPs from the gas. Dehydrators re-dry the TEG
(usually in at least one reboiler per dehydrator), often emitting both the absorbed water and air pollutants
directly to the atmosphere.

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EPA estimates that the more than 38,000 active glycol dehydrators in the U.S. collectively emit about
18.6 billion cubic feet per year (bcfy) of CH4 [1], Natural gas glycol dehydration is the third largest CH4
emission source within the production sector, creating 17 percent of this sector's total greenhouse gas
emissions [2], Glycol dehydrators are also responsible for 85 and 81 percent of the production sector's
HAP and VOC emissions, respectively [3,4], The EPA promulgated final maximum achievable control
technology (MACT) standards on June 17, 1999, which require that glycol dehydrator owners or
operators reduce HAP emissions by 95 percent [5],

The MACT standard requires affected facilities install control devices to recover or destroy pollutants in
the dehydration vent stream. Engineered Concepts, LLC (ECL), located in Farmington, NM, has
developed a patented gas dehydration technology known as the Quantum Leap Dehydrator (QLD) to meet
this goal. The QLD is an integrated system which collects all the water and hydrocarbons present in the
glycol reboiler vent stream. It condenses and collects most hydrocarbons into a salable product; water is
collected for disposal; and the uncondensed hydrocarbon balance is routed to the reboiler burner for
combustion. The end result of the QLD process is the reduction of both HAP and CH4 emissions.

ECL requested that the GHG Center perform an independent QLD performance verification at a natural
gas gathering station operated by Kerr-McGee Gathering, LLC. This report presents the results obtained
during the recently concluded performance verification test. The Test and Quality Assurance Plan—
Engineered Concepts, LLC Quantum Leap Dehydrator [6] provided the verification test design,
measurement and quality assurance/quality control (QA/QC) procedures. It is available for download
from the GHG Center's web site (www.sri-rtp.com) or the ETV Program web site (www.epa.gov/etv).
ECL, SRI, selected stakeholders, and EPA-ORD have reviewed the test plan and report as evidenced by
the signature pages at the front of both documents. They satisfy the pertinent GHG Center Quality
Management Plan (QMP) requirements.

The following paragraphs describe the QLD technology and the as-built system at the Kerr-McGee site.
The remaining subsections define the verification parameters and briefly describe the test methods used to
quantify these parameters. Section 2.0 presents the verification test results and Section 3.0 assesses data
quality. Circumstances required departures from the Test Plan in some cases and Corrective Action
Reports (CARs) were prepared to describe such modifications. The appropriate sections below discuss
any deviations. Section 4.0 was submitted by ECL and presents additional QLD system information, its
performance at the test site, and other facts the manufacturer deems significant to the reader. The GHG
Center has not independently verified information contained in Section 4.0.

1.2. QLD TECHNOLOGY DESCRIPTION

Comparison between conventional natural gas dehydrators and the QLD is an effective way to understand
the latter's operating principles. Figure 1-1 shows the schematic of a generic dehydrator. The wet natural
gas enters a two-phase separator which divides liquid hydrocarbons from the gas stream. Pipelines route
the liquid products to a condensate storage tank for sale and the wet gas to an absorber. Lean TEG
(which contains little water) directly contacts the wet gas and absorbs the water vapor. Dry natural gas
exits the absorber column as pipeline-quality gas, ready for sale.

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Wet Natural
Gas From -
Compressors

Gas/Liquid

Separator

Lean
„ Glycol



r

Dry
Natural
Gas to
Sales

Liquid
Hydrocarbons
to Tank

Still Vent(H>0,CH4,
C02 HAPs, VOCs)

t

Still
Column

Burner Exhaust (CH^ CO,
C02, HAPs, NOx, VOCs)

Reboiler

14

I

_ Burner Fuel
Natural Gas

Surge Tank

Tnnnrs

Rich
Glycol

J

Rich Glycol/Natural
Gas Mixture

' Regeneration
Process

GasAssjsted

Glycol
Cjrculation
Pump

\

High-Pressure
Natural Gas

Gas

Liquid Products
Rich Glycol
Lean Glycol

Figure 1-1. Generic Natural Gas Dehydration Process

The rich (wet) glycol exiting the absorber contains the constituents which the TEG easily absorbs or
dissolves. These are mainly water, CH4, VOCs, and HAPs. The primary HAPs, as defined in the MACT
regulations [5], include benzene, ethylbenzene, toluene, and xylene (collectively referred to as BTEX)
and n-hexane. These five pollutants are estimated to represent about 99 percent of HAP emissions from
glycol dehydrator vents. A regeneration reboiler removes the absorbed constituents, resulting in a lean
glycol mixture that is suitable for reuse in the absorber.

The regeneration process is the primary emission source. It consists of a glycol circulation pump, a
reboiler still, and a variety of heat exchangers (Figure 1-1). The circulation pump moves the glycol
throughout the system. Conventional dehydrators may employ either of two different types of circulation
pumps: electric-powered and gas-assisted. Gas-assisted pumps are the most common type because many
dehydration facilities are located in remote sites where electricity is not readily available. Gas-assisted
pumps use energy from externally supplied high-pressure natural gas to pressurize the glycol. Since CH4
is the primary constituent in natural gas, CH4 emissions are substantially higher when the glycol/natural
gas mixture passes through the reboiler. Conventional dehydrators may include a reduced-pressure flash
tank (not shown) prior to the reboiler. A flash tank allows dissolved methane to escape and be re-routed
to other processes. This prevents its being emitted from the still column.

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The reboiler strips the absorbed water (and HAPs) out of the glycol and into the still column. The
regenerated lean glycol exits the reboiler and enters a surge tank. The pump then conveys it to a
glycol/gas heat exchanger and back to the absorber. This heat exchanger reduces the lean glycol
temperature prior to the lean glycol entering the absorber tower. This reduces hydrocarbon condensation
within the absorber [7],

The still column vent conveys the stripped water vapor, CH4, HAPs, C02 and VOCs away from the
process. Most conventional dehydrators emit this overhead gas/vapor stream directly to the atmosphere.
The still vent stream contains water vapor (90 percent), trace C02, HAPs, CH4, VOCs, and other
components absorbed from the natural gas.

Two common still vent emission control methods are combustion and condensation. Combustion devices
typically include flares and thermal oxidizers. The Kerr-McGee test site initially controlled still vent
emissions with enclosed flares, but the site was unable to continuously operate them because the vapor
stream's heat content varied widely.

Condensers include water knockout systems and other separation systems that produce condensate
product for sale. These devices vent non-condensable gases to the atmosphere or burn them in a flare,
thermal oxidizers, or the reboiler. An additional emissions control measure used at some sites is to
separate lighter hydrocarbons (such as CH4) from the rich glycol in flash tank separators prior to the still
column.

The QLD also employs both condensation and combustion to control still vent emissions. Its
implementation of controlled condensation and partial vacuum-phase separation produces: 1) a saleable
product, 2) wastewater that does not require significant cleaning, and 3) very little air pollution. The most
significant result is that the reboiler burns uncondensed hydrocarbons, significantly reducing fuel input
requirements and emissions. Figure 1-2 depicts the primary design features. Process modifications to
this system, as compared to the majority of conventional dehydrators, are:

•	Replacement of gas-assisted pump with electric pump (reduces CH4 losses and
emissions);

•	Recovery and use of still vent emissions (eliminates direct release of CH4, HAPs,
and VOCs); and

•	Reboiler burner re-design (reduces natural gas fuel input and emissions).

Major QLD components are:

•	Glycol Circulation Pump An electric pump circulates the glycol through the absorber at about 4
gallons per minute (gpm). This feature is intended to save a significant amount of high-pressure
natural gas over a gas-assisted pump. The Gas Technology Institute (formerly the Gas Research
Institute) estimates that pump gas losses account for as much as three standard cubic feet natural gas
per gallon (scfgal) of glycol circulated. Over 20 thousand standard cubic feet per day (mscfd) natural
gas or $14,600 per year (based on a gas price of $2.00 per mscf) would be saved by switching to an
electric pump at the host site. Note that this analysis is conservative because recent natural gas prices
have risen to $5.45/Mcf and more in some areas. An additional benefit is that CH4 and BTEX,
normally present in increased quantities when a gas-assisted pump is used, will not be vented from
the still column.

•	Effluent Condenser The effluent condenser is a fin-and-tube heat exchanger that reduces the vapor
stream temperature from the still vent to about 120 degrees Fahrenheit (°F) to enable product

1-4


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separation. It uses the rich glycol, circulated from the emissions separator, as the coolant media. The
cooled overhead vapor stream is brought into the liquid removal vacuum separator.

Quantum Leap
Dehydrator
System

absorption/regeneration)

Rich Glycol Circulation (67to72gpm

Hydrocarbon Vapors or Burner Exhaust

Figure 1-2. QLD Natural Gas Dehydration Technology

Liquid Removal Vacuum Separator (vacuum separator) Internal baffles and weirs in this vessel
condense and partition the vapor stream from the still vent into three phases: (1) wastewater, (2)
condensate, and (3) uncondensed hydrocarbon vapors. The condensed hydrocarbons and wastewater
collect in the appropriate chamber and are periodically discharged into storage tanks for sale and
disposal. An eductor system creates a partial vacuum to remove uncondensable hydrocarbons and the
remaining water vapor to the emissions separator.

Glycol Condenser A forced-draft, air-cooled heat exchanger cools the rich glycol exiting the still
column reflux coil and the overhead condenser. Ambient air reduces the glycol temperature to
between 150 and 110 °F. A pipeline conveys condensed liquids, rich glycol, and noncondensable gas
to the emissions separator.

Emissions Separator The emissions separator operates in three phases to separate rich glycol, liquid
hydrocarbons, and gaseous hydrocarbon streams.

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Control valves and piping split the rich glycol exiting the emissions separator. The first stream, about
4 gpm, originates from the bottom of the separator. This is precisely equal to the amount of lean
glycol pumped into the absorber. A 72-gpm pump pressurizes the second rich glycol stream for use
as a working fluid throughout the QLD. The effluent condenser uses about 10 gpm for still vent-
stream cooling. The remainder provides cool glycol to other heat exchangers, compresses the
recovered uncondensed hydrocarbons for use at the burner, and powers the eductor system which, in
turn, creates the required partial vacuum at the vacuum separator.

Separate piping conveys condensed hydrocarbons to the vacuum separator which collects them as
described above. The uncondensed hydrocarbons exit the emissions separator at about 20 pounds per
square inch, gage (psig), and serve as fuel gas for the reboiler burner.

•	Water Exhauster The water exhauster removes any remaining water and condensable hydrocarbons
from the lean glycol. Section 4.0 discusses some of its benefits.

•	Still Column The still column collects the entrained gases, water, and hydrocarbon vapors from the
rich glycol as it flows through the reboiler. The resulting hot lean glycol exits the still column and
reboiler through a glycol/glycol heat exchanger.

•	Reboiler The QLD incorporates a re-designed conventional U-shaped firetube reboiler. The QLD
burner is unlike many commercial burners, in that it contains air injectors which allow effective
combustion with wide ranges in operating pressure and water vapor content. The burner operates
continuously and throttles the heat output in response to reboiler heat demand, in contrast with many
conventional burners which cycle off and on to meet changing demand. The burner can accept up to
30 percent of capacity, or 166 standard cubic feet per hour (scfh) of supplemental natural gas if
needed.

ECL and the test facility installed certain modifications after the initial shakedown period because of site-
specific natural gas conditions. Consequently, the as-tested unit differed from the original design. The
following subsection includes a brief discussion.

Air emission sources include the reboiler burner exhaust, vacuum separator and fuel accumulator vessel
PRVs, HAPs dissolved in the recovered wastewater, and fugitive emissions (which were subsequently
found to be negligible). The QLD uses recovered hydrocarbon vapors as its primary fuel source, so VOC
and HAP emissions may be present in the burner exhaust. There may also be NOx, CO, C02, and
unburned CH4 emissions. The wastewater stream could contain dissolved HAPs which could be emitted
to the atmosphere through evaporation. Wastewater condensation occurs under partial vacuum so there
should be no HAP and CH4 flash-loss emissions.

1.3. TEST FACILITY DESCRIPTION AND QLD MODIFICATIONS

The Kerr-McGee Gathering Facility, located 14 miles northwest of Brighton, CO, processes about 26
million standard cubic feet per day (mmscfd) of natural gas through the QLD. Kerr-McGee installed the
QLD technology after excess moisture content in the still vent caused persistent problems with thermal
oxidizers. Figures 1-3 and 1-4 show the as-built system at the site.

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Effluent

Housing For
Pumps,
Separators, etc.

Reboiler Stack

Reboiler

Figure 1-3. QLD at Kerr-McGee Gathering Station

1-7


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Reboiler

Glycol

Circulation

Pump

Liquid Removal
Vacuum Separator

Wastewater
Discharge Line

Figure 1-4. QLD Interior

ln-ground storage tanks collect and store the wastewater from the QLD and other processes at
atmospheric pressure. Fixed-roof tanks receive the condensate. Contractors periodically transfer the
stored wastewater and condensate into tank trucks for transport and disposal or sale.

Table 1-1 summarizes the test site's key design and operating parameters. These parameters formed the
basis for the test plan's verification strategy.

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Table 1-1. Test Site Design and Operating Conditions

1. Natural gas production rate

26 mmscfd (at 14.7 psia, 60 °F)

2. Sales gas moisture content

< 7 lb water / mmscf natural gas

3. Circulation rates for electric pumps

•	Glycol for absorption and regeneration

•	Glycol for condensation and eductor power

5 gpm, 5-hp motor
72 gpm, 5-hp motor

4. Glycol/Glycol Heat Exchanger

•	Duty

•	Shell operating conditions (lean glycol)

•	Tube operating conditions (rich glycol)

325 mBtu

atmospheric pressure @ 400 °F
30 psig @ 300 °F

5. Reboiler Still

•	Duty

•	Operating Conditions

600 mBtu/h

0 to 2 in. water column (vacuum)

6. Reboiler Burner

•	Total heat input required

•	Fuel gas from the emissions separator

•	Makeup natural gas

•	Stack dimensions

1.2 mmBtu/h

~ 233 to 388 scfh (70 to 80% volume),

specific gravity = -0.75, LHV = -1410 Btu/ft3
- 0 to 166 scfh (0 to 30% volume),

specific gravity = -0.65, LHV = -950 Btu/ft3
10-in. diameter, 20-ft high

7. Glycol Condenser - Glycol/Air Heat Exchanger

•	Duty

•	Rich glycol operating conditions

225 mBtu/h
30 psig@ 150 °F

8. Emissions Separator

•	Dimensions

•	Operating Pressure

30-in. diameter, 6'-6" high
15 psig

9. Vacuum Separator

•	Dimensions

•	Operating Pressure

•	Water discharge rate

•	Condensate discharge rate

20 in. diameter, 5'-6" high
0 to 5 in. w.g. vacuum

Every 1.5-in. change in liquid level - 1.89 gal
Every 1.5-in. change in liquid level - 1.89 gal

10. Effluent Condenser - Vapor/Glycol Heat Exchanger

•	Duty

•	Tube operating conditions (still vapors)

•	Shell operating conditions (rich glycol)

100 mBtu/h

0 to 5 in. w.c. vacuum @ 212 °F
30 psig® 110 °F

Operators discovered that the burner (and reboiler) was not operating at consistent temperature after the
QLD system was installed at the host site. The recovered fuel gas heating value sometimes exceeded that
which could be efficiently burned. The system would upset and remain out of balance for extended
periods because the burner was unable to burn all the gas. Consequently, the recovered fuel gas pressure
would begin to increase such that the eductor was unable to pull an adequate vacuum. The vacuum
separator pressure would rise and break the required -5" water glass (w.g.) partial vacuum. The entire
system operation would destabilize. ECL installed three improvements to prevent this pressure buildup
and to enable proper burner control:

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Pressure-Relief Valve: ECL installed a pressure-relief valve (PRV) in the vacuum separator to
open it to atmosphere when the recovered fuel gas pressure reached 30 psig. The PRV would
close when the recovered fuel gas pressure dropped below 30 psig. This PRV is a safety device.
The system utilizes this feature only during initial system start-up. The vent remains closed
during normal operations.

Fuel Accumulator Vessel: ECL installed a 430-gallon accumulator vessel to dampen the effects
of large swings in fuel gas volumes entering the reboiler burner. The accumulator vessel
increased the fuel gas system's reserve volume during high recovery periods. This allows a
relatively constant volume of fuel gas to be fed to the burner. A pressure-activated valve would
open to atmospheric conditions if the gas pressure in the vessel exceeded 28 psig. This operation
could produce air emissions, but this PRV is also a safety device which would actuate only under
abnormal conditions.

Water-Injection System: ECL installed a compressed air-driven pump to inject a portion of the
vacuum separator's recovered wastewater back into the reboiler. This would increase the reboiler
load when necessary, enabling the burner to demand more fuel. Fuel gas pressure and effluent
condenser temperature control this pump. The effluent condenser temperature is a key control
point because very hot vapors result in inefficient hydrocarbon condensation. The pump operates
when the fuel gas pressure is 20 psig or more and the overhead temperature is 120 °F or less. The
pump automatically shuts down when the fuel pressure falls below 20 psig or the overhead
temperature is greater than 120 °F. ECL specified the water pump with reserve capacity
sufficient to handle all reasonably expected gas compositions at the test facility.

1.4. PERFORMANCE VERIFICATION OVERVIEW

1.4.1. Performance Verification Parameters

The GHG Center developed the QLD verification approach to provide credible performance data of
interest to potential industry users and environmental regulators. Verification parameters consist of:

Operational Performance Parameters:

•	sales gas moisture content and production rate

•	glycol circulation rate

•	makeup natural gas fuel flow rate

Environmental Performance Parameters:

•	reboiler stack emission rates

•	HAP destruction efficiency

The natural gas moisture content leaving the system is the QLD's primary performance indicator. This
stream must not exceed 7 lb water / mmscf (lb/mmscf) gas. Verification tests, therefore, included direct
natural gas moisture content and sales gas production rate measurements.

Process glycol circulation rate is another key QLD performance indicator. Over-circulation requires more
pump energy, more makeup natural gas consumed to operate the reboiler, or more pollutants to be
absorbed and eventually emitted to the atmosphere. Facilities subject to the 40 CFR Part 63 standard [5]

1-10


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(which includes the host site) must monitor glycol circulation rates to minimize such impacts. The GHG
Center used an ultrasonic flow meter to verify lean glycol circulation rates during the verification tests.

The GHG Center also monitored the makeup natural gas flow rate fed to the reboiler. Makeup-gas data is
useful information to technology users for estimation of possible QLD fuel savings.

Operational performance monitoring occurred after the completion of QLD start-up and shakedown and
ECL subsequently announced the system to be functioning normally. These steps ensured the collection
of representative data. The GHG Center monitored all operational parameters as one-minute averages for
seven days. Section 2.2 reports the daily and overall production averages found during the monitoring
period.

Environmental performance parameters quantified the reboiler exhaust stack criteria pollutant,
greenhouse gases, and HAPs emission rates. Three 90-minute (nominal) emissions test runs verified all
environmental parameters over a one-day test period while the system was operating at "normal
conditions". The seven days of operational data prior to testing formed the basis for establishing normal
operating conditions. The test plan specified the normal operating range as the rates represented by 75
percent of the individual one-minute operational data entries.

The GHG Center also verified HAP destruction efficiency to determine the QLD's ability to recover or
destroy HAPs taken up from the sales gas by the glycol.

1.4.2. Measurement Approach

Table 1-2 summarizes the text matrix. It identifies the required measurements and type of data collected.
Figure 1-5 illustrates the measurement system and provides numbered locations for each measurement.
The following subsection provides a measurement strategy overview for each verification parameter. The
test plan provides detailed background discussions and procedures.

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Table 1-2. Verification Test Matrix

Verification
Parameter

Location

Descriptionb

Units

Method/
Instrument

Sampling Intervals3

Sales Gas
Moisture

1

Sales gas moisture
content

lb H20 /
mmscf gas

Electrolytic moisture
transmitter

1-min averages, reported as
daily averages and run
averages

Content and
Production Rate

Sales gas flow rate

mmscfd

Integral orifice meter

1-min averages, reported as
daily averages and run
averages

Glycol

Circulation Rate

2

Lean glycol flow
rate

gpm

Ultrasonic flow meter

1-min averages, reported as
daily averages and run
averages

Makeup Natural



Makeup natural
gas flow rate

scfh

Turbine flow meter

1-min averages reported as
daily averages and run
averages

Gas Fuel Flow
Rate

7

BTEX

concentration in
makeup natural gas

ppm

Sample collection by GHG
Center, analysis by
independent laboratory

3 gas samples collected per
test run (if preliminary
samples indicate BTEX >
10,000 ppm)

Reboiler Stack
Emission Rates

4

C02, NOx, CO,
CH4, THC, and
HAP concentration
& emission rates

ppm and
lb/h

Varies, see Table 1-3

three test runs (90 minutes
each), reported as average for
each test run





Lean glycol flow
rate

gpm

Turbine flow meter

1-min averages, reported as
average for each test run



2

HAP concentration
in lean glycol

ig/mL

Sample collection by GHG
Center, analysis by
independent laboratory

4 liquid samples per test run,
reported as average for each
test run



3

Rich glycol flow
rate

gpm

Lean glycol flow rate
corrected for water and
hydrocarbon content

1-min averages, reported as
average for each test run



HAP concentration
in rich glycol

ig/mL

Sample collection by GHG
Center, analysis by
independent laboratory

4 liquid samples per test run,
reported as average for each
test run

HAP Destruction
Efficiency

5

Wastewater flow
rate

gpm

Prior to testing, determine
discharge rate per "dump"
and per inch of sight glass
level change. Record times
and number of each
discharge dump occurring
during test run

Each time discharge dump
occurs





HAP concentration
in wastewater

ig/mL

Sample collection by GHG
Center, analysis by
independent laboratory

4 liquid samples per test run,
reported as average for each
run



6C

Condensate flow
rate

gpm

Record condensate sight
glass height before and
after each dump. Use
wastewater discharge rate
in gal/in. to calculate
condensate discharge rate
in gal/dump

Each time discharge occurs





HAP concentration
in condensate
product stream

ig/mL

Sample collection by GHG
Center, analysis by
independent laboratory

4 liquid samples per test run,
reported as average for each
run

(continued)

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Table 1-2. Verification Test Matrix (Concluded)

Verification
Parameter

Location

Descriptionb

Units

Method/
Instrument

Sampling Intervals3

HAP Destruction
Efficiency

8

Vacuum separator
vent gas flow rate

scfin

Assigned as 0 because vent was capped throughout testing

HAP concentration
in vacuum
separator vent gas

ig/mL

9

Accumulator
vessel vent gas
flow rate

scfin

Dry gas meter, slack tube
manometer, and
thermocouple meter

Assigned as 0 because dry
gas volume counter did not
change throughout testing

HAP concentration
in accumulator
vent gas

ig/mL

Sample collection by GHG
Center, analysis by
independent laboratory

a For destruction efficiency, a test run corresponds to the 90-minute stack rim.
b HAPs are the sum of BTEX and n-Hexane.

c HAPs dissolved in the condensate product are reported for information purposes. They are not used to determine HAP
destruction efficiency. See section 1.4.2.6

I	y Filter	,JMaterJxhauster^	1	)i I

i		 J . 	 . «*£_X X I

¦5— S	1	Glvcol/Glvcol Heat	•

Rich Glycol Circulation (for
condensation/separation)

Lean Glycol

Hydrocarbon Vapors or Burner Exhaust

Glvcol/Glvcol Heat

Equalizing Line J

System Boundary

Figure 1-5. Measurement System Schematic

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1.4.2.1.

Sales Gas Moisture Content

The host site continuously monitors sales gas moisture as a part of normal operations (Location 1, Figure
1-5). The GHG Center used the one-minute average moisture data to measure the QLD's operational
performance. Test personnel obtained the data files from the host site's central computer.

The host site had replaced the MEECO moisture sensor (as described in the test plan) with a new
Panametrics brand sensor. The Panametrics meter provided the same performance: moisture
measurement range of 0 to 20 lb/mmscf, lower detection limit (LDL) of 0.2 lbs/mmscf, and a rated
accuracy of ± 5 percent of reading. Panametrics calibrated the meter with National Institute of Standards
and Technology (NIST) - traceable instruments prior to installation.

1.4.2.2.	Sales Gas Production Rate

The host site uses an Emerson MVS205 Multi-Variable Sensor orifice meter to document sales gas
production. The GHG Center used the meter's one-minute average sales gas production data to measure
the QLD's operational performance. Test personnel obtained the data files from the host site's central
computer.

The sales gas meter contains a 4.00-inch orifice plate and is temperature and pressure compensated to 60
°F, 14.7 psia (gas industry standard conditions). Its operating range is 0 to 2 mmscfh with a rated
accuracy of ± 1 percent of reading. Site personnel calibrated the flow meter with NIST-traceable
reference standards prior to testing.

1.4.2.3.	Glycol Circulation Rate

The GHG Center initially planned to use the site's Halliburton MC-II EXP turbine meter to measure
glycol circulation rate (Location 2, Figure 1-5). However, a performance comparison with the GHG
Center's ultrasonic meter (Controlotron 1010EP1) revealed a large discrepancy (greater than two percent
allowed in the Test Plan). The site investigated potential turbine meter problems while the GHG Center
and ECL evaluated the glycol pump's theoretical capacity. The consensus was that the ultrasonic meter
reported flow rates that were within the expected range for this pump. Consequently, the GHG Center
used ultrasonic meter for the verification test. Section 3.0 and associated Corrective Action Reports
(CARs) document these findings.

The ultrasonic meter is a digitally integrated flow-metering system that consists of a portable computer
and ultrasonic fluid flow transmitters. The meter determines fluid velocity by measuring ultrasonic pulse
transit times between the transducers. A precision-mounting jig secures the transducers to the pipe at a
known distance apart. The operator enters the fluid composition (100 percent TEG for this test), pipe
diameter, material, wall thickness, and expected sonic velocity into the meter's computer. The flow meter
determines the sonic velocity based on the known distance between the transducers under zero-flow
conditions with the pipe full of fluid. It multiplies the fluid velocity by the internal area of the pipe, and
reports one-minute average volumetric flow rate during operation.

The flow meter's overall rated accuracy is ± 1.0 percent of reading and can be used on pipe sizes ranging
from 0.25 to 360 inches in diameter with fluid flow rates ranging from zero to 60 feet per second (fps).

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1.4.2.4.

Makeup Natural Gas Flow Rate

The QLD reboiler burner can accept up to 166 scfh makeup natural gas as supplemental fuel. A
Halliburton MC-II EXP turbine meter installed on the one-inch (inside diameter) gas line upstream of the
reboiler (Location 7, Figure 1-5) measured makeup gas flow. The site's central computer collects the
one-minute average data and test personnel obtained the data files from the host site.

The Halliburton flow analyzer is a turbine meter and integral signal display and transmitter with a linear
flow range sufficient to measure gas flows should the reboiler operate on makeup gas only (0 to 600
scfh). The manufacturer used a piston-type volume prover to calibrate the meter. It is temperature and
pressure compensated, and provided mass flow output accurate to ± 1.0 percent at standard conditions.

1.4.2.5. Reboiler Stack Emission Rates

Cubix Corporation, an independent stack testing contractor located in Austin, TX, performed reboiler
stack emissions testing to determine concentrations and emission rates for the following air pollutants:
CO, THCs, GHGs (C02, NOx, and CH4), BTEX, and total HAPs (BTEX plus n-hexane). Cubix
conducted three 90-minute (nominal duration) test runs for each parameter while the system was
operating at normal conditions.

All the test procedures are well-documented Title 40 CFR 60 Appendix A reference methods. Table 1-3
summarizes reference methods performed for emissions testing supporting this verification. The test plan
provides a detailed discussion of the test methods and QA/QC requirements.

Emission rates reported in Section 2.0 are in terms of parts per million by volume dry (ppmvd). These
values, correlated with the stack volumetric flow rates in dry standard cubic feet per minute (dscfm), yield
pound per hour (lb/h) emission rates for NOx, CO, CH4, VOC, hexane, BTEX, and HAPs. VOC
emissions are the sum of all organic compounds minus methane and ethane emissions according to
Colorado Department of Public Health and Environment regulations. HAP emissions at this facility are
the sum of hexane and BTEX emissions.

Table 1-3. Emissions Testing Methods Summary

Measurement
Variable

U.S. EPA
Reference
Method

Analyzer Type

Instrument Range

NOx

7E

TEI Model 42C (chemiluminescence)

0 to 100 ppm

CO

10

TEI Model 48C (NDIR)

0 to 100 ppm

THC

25A

JUM Model VE-7 (FID)

0 to 100 ppm

o2

3A

CAI Model 200 (Paramagnetic)

0 to 25%

o
o

3A

CAI Model 200 (NDIR)

0 to 20%

ch4

18

Hewlett Packard 5890a (GC/FID)

0 to 100 ppm

BTEX3, n-Hexane

18

Hewlett Packard 5890a (GC/FID)

0 to 100 ppm

Exhaust gas
volumetric flow rate

1A and 2C
(modified)

Differential Pressure

9,000 to 11,000 scfh

Moisture

4

Gravimetric

Oto 100%

a Includes separate benzene, toluene, ethylbenzene, and xylene quantification

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1.4.2.6.

HAP Destruction Efficiency

Section 2.6 of the Test Plan discusses HAP destruction efficiency, the required measurements, and the
calculations in detail. Destruction efficiency is the net HAPs entering the system boundary (from the
glycol) minus that leaving the system from emissions sources divided by the net HAPs entering the
system. Testers determined the HAPs inputs via the Atmospheric Rich/Lean Method for Determining
Glycol Dehydrator Emissions (ARL) [8],

HAP emission sources at this site are: fugitive leaks, the reboiler burner exhaust stack, wastewater, and
PRVs. The GHG Center determined that fugitive leaks are negligible because the fabricator certified the
system to be leak-tight. This certification was documented, signed, and provided to the GHG Center.
The burner stack may emit unburned HAPs to the atmosphere and HAPs dissolved in the wastewater can
be released during disposal.

HAPs dissolved in the condensate stream are deemed to be "controlled" or "sequestered" and not
considered an emission. This is consistent with 40 CFR Part 63 and is documented in the Test Plan.

1.4.2.7. Additional Supporting Measurement Details

The following sections discuss verification test events and conditions beyond those presented in the test
plan.

1.4.2.7.1	Glycol Flow

Direct flow measurement of the rich glycol stream is difficult due to the presence of multi-pollutant,
multi-phase (liquid, vapor) products. Therefore, the natural gas industry, EPA, and the Gas Technology
Institute (GTI) normally assign the process circulation rate (measured on the lean glycol stream) as the
rich glycol flow rate.

This causes a negative bias (approximately 4 percent during this verification) in the reported rich glycol
flow rate because of the rich glycol's higher water and hydrocarbon content. This bias is minimized by
modifying the ARL method by correcting the lean glycol flow rate to yield the true rich glycol flow rate.
The procedure required rich and lean glycol analyses for density, water content, and total hydrocarbon
content. Analysts then applied these data to produce the correction. Appendix A describes the approach.

1.4.2.7.2	Lean Glycol Sample Condition

The lean glycol temperature was about 210 °F. The sample tubing passed through an ice water bath
during sampling. This allowed the samples to cool before entering the sample vials. The rich glycol
samples did not require cooling because the rich glycol temperature was close to the absorber temperature
(approximately 90 to 100 °F). The rich glycol samples were extremely foamy. The foam developed as
dissolved gas escaped when the glycol was exposed to atmospheric conditions during sampling. This is
equivalent to sampling a conventional glycol dehydrator with no flash tank. The ARL method warns that
volatile components in the glycol can be unavoidably lost during sampling under these conditions. Such
losses would result in understatement of glycol hydrocarbon concentrations. Section 2.3.2 provides
further discussion of this phenomena and its possible effects on the verification results.

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1.4.2.7.3 Lab Analysis

Enthalpy Analytical of Durham, NC, analyzed the glycol samples for HAPs and moisture via gas
chromatography/flame ionization detector (GC/FID) and Karl Fischer titration, respectively. The
laboratory used a Hewlett-Packard 5890 Series II GC (with FID) and a hydrogen carrier gas. The
capillary columns were Restek 20 meter (m) x 0.18 millimeter (mm) Rtx-1. The method detection limit
(MDL) was as low as 6.0 micrograms per milliliter (i g/ml) depending on the required dilutions.

1.4.2.7.4 Wastewater Discharge Rate

The GHG Center quantified the volume of nine wastewater discharges before the verification by
capturing each discharge in a tared bucket, noting the bucket's full weight, and measuring the
temperature. Center personnel also logged the changes in liquid level by reading an engineer's scale
attached to the liquid sight glass on the vacuum separator. The water weight divided by the density at the
recorded temperature yields the gallons per dump for each discharge. The sight glass level change
divided by the gallons per dump yields gallons per inch of movement on the sight glass. Section 2.0
presents the results as 3.057 gal/dump or 1.283 gallons per inch (gal/in.) with a maximum variation of 1.2
percent.

GHG Center personnel logged the time of each wastewater dump during all test runs during the
verification. The measured discharge rate (3.057 gal/dump) divided by the elapsed time between two
successive discharges yielded the wastewater flow rate (gpm). For example, discharge number 323
occurred at 14:03 and discharge number 324 occurred at 14:31 (28 minutes later). The first test run
started at 14:03, so, during the first minute, the system produced 3.057/28 or 0.109 gpm.

The field team leader collected wastewater samples from the petcocks located on the vacuum separator
vessel instead of from the discharge traps described in the Test Plan (Location 5, Figure 1-5). His
observation during an initial site visit was that the vacuum separator vessel had separate tapped and
plugged ports available for liquid (wastewater and hydrocarbon) sampling. Discharge trap installation
would have required extensive pipeline modifications. The GHG Center consequently determined that
installation of petcocks directly into the separator vessel was the best sampling method. An April 4, 2003
CAR documented this determination.

The field team leader opened the vacuum separator manual vent valve to break the vacuum during each
sampling event. This allowed the samples to be collected. The open valve caused a momentary process
upset and the QLD system began to pressurize. The vacuum separator pressure quickly re-stabilized to
desired negative gage pressure after closing the sample valve.

These upsets also caused perturbations in stack gas emission concentration. Test personnel observed this
problem during the verification test runs. The GHG Center determined that the perturbations would not
significantly affect the overall verification results because stack gas concentrations quickly returned to
normal when the valve was closed. Also, installing the discharge traps at that point would have
introduced significant delays into the test campaign. The stack test verification results therefore do not
include the time periods corresponding to the liquid sampling disturbances. Section 3.0 describes the
technique the GHG Center analysts used to identify these invalid time periods.

The laboratory analyzed the wastewater samples by the purge-and-trap method. All dilutions were six-
fold, or one milliliter (ml) of sample plus 5 ml of MeOH solvent. The analyst used a Restek 60 m x 0.32
mm Rtx-1 capillary column. Other equipment and procedures were as described above for the glycol
sample analysis.

1-17


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The laboratory employed the same analysis procedures described earlier for the glycol samples except
that all dilutions were 1001 to 1, or 10 microliters (il) of sample added to 10 ml solvent.

1.4.2.7.5	HAPs Emitted from Pressure-Relief Vents

The automatic PRVs at the accumulator vessel and the vacuum separator were potential intermittent (non-
continuous) emission points. The PRV would open to atmosphere if the accumulator vessel gas pressure
exceeded 28 psig. The vacuum separator PRV opens and emits gases to atmosphere only when gas
pressures in the QLD system reach a level high enough to upset the overall system function. GHG Center
personnel observed that this happened only during initial system start-up and shake-down activities. The
vent remains closed during all normal operations once the pressure stabilizes.

The GHG Center developed measurement techniques for quantifying HAP emissions from both sources
(Locations 8 and 9, Figure 1-5). ECL had stabilized the system such that high-pressure conditions no
longer occurred during normal operations. Neither of the PRVs opened during the verification test. The
GHG Center verified that the resulting HAP emission rate was zero lb/h. Internal CARs contain complete
documentation on the PRVs.

1.4.2.7.6	HAPs Entering in Makeup Natural Gas

The GHG Center determined BTEX in the makeup natural gas to assess the possible effects on the total
HAP inputs to the system boundary. Additional samples would be collected during verification testing if
preliminary testing indicated BTEX levels in the natural gas were greater than 10,000 ppm.

The field team leader collected three makeup natural gas samples prior to the verification tests. Appendix
D presents the results and they indicate that BTEX entering the system from the makeup gas is negligible.
Additional sampling during the verification test runs was not required.

1.4.2.7.7	Miscellaneous Considerations

HAP destruction efficiency does not require the condensate product HAP mass flow rate. It is, however,
useful data with which to complete an entire QLD system mass balance. The condensate production rate
may also be useful to readers interested understanding the recovery potential of the saleable product. This
report, therefore, presents condensate production rate (gpm) and HAPs (lb/h) within the condensate
stream. The flow rate determination requires the gallons per inch approach described above for the
wastewater flow rate determination.

Observation of condensate sight-glass level changes by field personnel quantified the condensate
production rate. The GHG Center did not directly quantify the discharges because of its hazardous
properties, especially when handled in open containers. The vacuum separator vessel collects both the
wastewater and condensate, separated by a weir and bulkhead system. The cylindrical vessel's diameter
is constant throughout. This means that a one-inch level change in both sections of the vessel correspond
to the same liquid volume. A one-inch level change in the condensate product's sight glass corresponds
to the same volume as measured by a one-inch level change in the wastewater sight glass, or 1.283 gal/in.
as described above.

1-18


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2.0

VERIFICATION RESULTS

2.1. OVERVIEW

Installation and start-up activities for the QLD system occurred in Winter of 2002. ECL then installed the
fuel accumulator vessel, the water injection pump, and the vacuum separator and fuel accumulator PRVs
in response to the conditions described in Section 1.2. ECL pronounced the system to be functioning
properly in late March 2003. The GHG Center initiated verification testing in April 2003.

GHG Center personnel did not perform leak tests (soap screening) because the system fabricator
performed industry-standard system pressure tests during and after final assembly. The fabricator
performed air- and hydrostatic-pressure tests. Air testing consisted of using 125 psig compressed air to
pressurize the pipe spools or assemblies. Operators then applied soap solution or submerged the
assembly in water, noted any bubbling, and performed repairs as needed. Hydrostatic testing consisted of
having operators fill the vessel or assembly with water and then pressurize it, watching for any leakage.
The fabricator's certification listed no significant leaks. Physical wear, settlement, and vibration likely
did not cause new leaks by the time the verification tests occurred because this was new equipment used
in a new application. Although ECL performed repairs and modifications after the site installed the QLD,
they also performed the appropriate leak checks prior to restarting the unit. The GHG Center, therefore,
assigned the fugitive leak rate as negligible.

Operational performance testing occurred between April 23 and 29, 2003. The GHG Center acquired
seven days of continuous sales gas moisture, sales gas flow, make-up gas flow, and glycol circulation rate
data during this period. The QLD consistently met or exceeded specifications as summarized below:

•	The moisture content of dry natural gas was well below the 7.00 lb/mmscf limit required by
the operator throughout the entire monitoring period. Actual daily average values ranged
between 0.89 and 1.28 lb/mmscf.

•	The QLD enabled continuous operation of the sales gas stream, with daily average flow rates
ranging between 26.8 and 29.3 mmscfd.

•	The QLD system burned all uncondensable hydrocarbon vapors without venting them to the
atmosphere. The system accomplished this with little or no makeup natural gas. Makeup
natural gas flow rate was between 0.00 and 1.76 scfh, well below the 166 scfh initially
expected.

•	The daily average glycol circulation rate varied between 3.00 and 3.77 gpm.

Environmental performance testing occurred on April 30, 2003, after completion of operational tests on
the previous day. The GHG Center representatives met with the ECL and Kerr-McGee representatives
prior to emissions testing to verify that the seven-day operational test period had yielded results typical of
normal plant operations. Each of the three test runs acquired between 70 to 85 minutes of stack emissions
data, summarized as follows:

•	Overall average emission rates for NOx, CO, and VOC from the reboiler stack were 0.0817,
0.0005, and 0.0003 lb/h, respectively.

•	HAP concentrations in the reboiler stack were non-detectable. Maximum HAPs leaving the
system in the reboiler exhaust and wastewater were 0.0016 and 0.0220 lb/h, respectively.

2-1


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•	PRVs did not operate at any time during the entire test campaign, nor are releases anticipated
during normal operations. Therefore, no expected emissions were assigned to PRV operation.

•	HAP destruction efficiency was greater than 99.74 ± 0.01 percent.

•	Average wastewater and condensate production rates were 6.36 and 2.88 gph, respectively.

The following subsections present the verification test data for each parameter.

2.2. OPERATIONAL PERFORMANCE

Table 2-1 summarizes daily performance data for the four primary operational performance parameters.
The results are representative of 85 to 100 percent of one-minute data recorded in a 24-hour period except
for the first test day (April 23). The table shows that the values for all key operational parameters are
relatively consistent from day-to-day. This supports the conclusion that the QLD operations are stable.

Table 2-1. Pre-Test Operational Data and Establishment of Normal Operating Conditions"

Date

Hours

Of
Valid
Data

Sales Gas
Moisture Content'

Sales Gas
Flow Rate'

Makeup Natural Gas
Flow Rate'

Glycol
Circulation Rate

(lb H20/mmscf)

(mmscfd)

(scfh)

(gpm)

Range

Average

Range

Average

Range

Average

Range

Average

4/23/03

15.05

0.80

to

1.69

1.02

28.67

to

31.39

29.31

0.11

to

345.98

16.32

1.55

to

6.04

3.63

4/24/03

24.00

0.79

to

1.03

0.89

26.18

to

32.02

28.63

0.00

to

220.19

1.22

1.47

to

4.00

3.30

4/25/03

20.73

0.91

to

1.44

1.12

26.09

to

29.96

28.38

0.00

to

190.44

0.63

0.00c

to

4.71

3.00

4/26/03

24.00

0.73

to

1.99

1.28

26.13

to

29.97

28.15

0.00

to

317.04

1.68

0.64

to

5.34

3.21

4/27/03

23.95

0.95

to

1.69

1.27

25.69

to

28.83

26.88

0.00

to

3.92

0.83

1.79

to

4.23

3.67

4/28/03

24.00

0.85

to

1.76

1.24

23.13

to

29.96

26.81

0.00

to

706.33

5.41

1.68

to

4.61

3.68

4/29/03

24.00

0.89

to

1.64

1.18

25.20

to

29.96

27.38

0.00

to

3.61

0.83

1.87

to

4.43

3.77

Overall Average



1.14



27.9



3.85



3.47

Normal Operating
Conditions1

0.89

to

1.50



26.54

to

29.26



0.00

to

1.76



3.14

to

3.93



s Normal operating condition is defined as the range represented by 75 percent of individual one-minute measurement values
b Source-Kerr-McGeeoperations.

c The flow meter reported zero during certain times on this date because of aeration in the pipeline.

When the onerator added makeut) TEG to the svstem. The aeration ceased and the flowmeter resumed normal onerations.

The overall daily average sales gas moisture content was 1.14 lb/mmscf. The highest level recorded was
1.99 lb/mmscf which is well below the site's 7.00 lb/mmscf requirement. The normal operating range for
this parameter (based on 75 percent of the one-minute data) is from 0.89 to 1.50 lb/mmscf.

The sales gas flow rate varied little throughout the test period. The overall average daily production rate
was 27.9 mmscfd. The normal range for this parameter is from 26.5 to 29.3 mmscfd.

The glycol recirculation rate, measured on the lean side, averaged about 3.47 gpm. The circulation rate
remained between 3 and 4 gpm during the majority of the monitoring period. Rates higher than 5 gpm
were recorded for one hour on April 23 and about two minutes on April 26. The elevated rates are not
typical, since they occurred for an extremely short period of time. The normal operating range for the
glycol recirculation rate is between 3.14 and 3.93 gpm.

ECL expected the reboiler to consume up to 166 scfh of makeup natural gas (about 30 percent of burner
capacity) in the initial design phase. Recovered hydrocarbon vapors would supply the remaining fuel

2-2


-------
requirement. Table 2-1 shows that the reboiler burner actually consumed significantly less makeup gas.
This amounts to a significant fuel savings for the site operator and demonstrates complete use of waste
gas that would normally be vented. The overall average makeup natural gas flow rate was 3.85 scfh.
However, the normal operating range was well below this average (0.00 to 1.76 scfh). The data show
some higher intermittent gas flow rates, but these generally lasted for less than 15 minutes in a 24-hour
period. The verification data demonstrated that the QLD system is capable of recovering and using high-
Btu, wet hydrocarbon vapors as a primary process fuel.

2.3. ENVIRONMENTAL PERFORMANCE

Environmental performance verification tests took place on April 30, 2003. The Test Plan required three
90-minute test runs to verify reboiler stack emissions performance and HAPs destruction efficiency. The
GHG Center, however, deemed some data as invalid because wastewater and condensate sampling events
disrupted the QLD process. Valid data varied between 70 and 85 minutes per test run. Section 3.0
discusses the invalidated data.

Table 2-2 shows test run times and duration. The table also summarizes average sales gas moisture
content, average sales gas flow rate, average makeup natural gas flow rate, and the average glycol
circulation rate. Figures 2-1 and 2-2 are operational data time series plots which correspond to the test
runs. The data demonstrate that verification tests occurred while the system was operating at normal
conditions. The average values observed during each test run are representative of the normal operating
range established in the pre-test evaluation (see Table 2-1).



Table 2-2

. Verification Test Period Operational Data Summary





Run Times

Run
Duration3

Average Sales
Gas Moisture
Content

Average Sales
Gas Flow Rate

Average
Makeup
Natural Gas
Flow Rate

Average Lean
Glycol Flow
Rate



Start

Stop

(mins)

(lb H20/mmsct)

(mmscfd)

(scfh)

(gpm)

Run 1

14:30

16:23

85

1.25

28.49

0.48

3.77

Run 2

17:01

18:30

70

1.36

28.45

0.84

3.60

Run 3

18:57

20:27

72

1.16

28.53

2.77

3.89





Overall Average

1.25

28.49

1.37

3.75

3 Excludes times corresponding to invalid data

2-3


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1.6

31

|—Moisture Content	Gas Flow Rate |

Figure 2-1. Operational Parameters Measured During Verification Test Period

0 			*			 24

rCMP)^lfl(DSCOO)OrCN(Otlfl(DSCOO)OrCM(0^lfl(DKCOO)OrCN|P)^lfl
c>itq^tq^tqcoiOrcoiOrcoiorcoqn^qn^qc>iM;qfOiOrniOr
cocoQrooidddT-T-T-CNifNifNicococo^^ihuriihfflfflffiNNNcococoaiaiaid

Time (Hrs)

Time (Hrs)



7

Run 1
^	~

Figure 2-2. Fuel Gas Flow Rates Measured During the Verification Test Period

2-4


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GHG Center personnel also monitored several key process variables although they were not required in
the Test Plan. They were: absorber operating temperature and pressure, still column vapor exit
temperature, and emissions separator operating temperature. They were measured and reported to
provide the capability of comparing this system to other systems. Test personnel logged these data from
instruments permanently installed at the site. Table 2-3 summarizes the data.

Table 2-3. Additional Process Operating Data for Verification Test Periods

Verification
Test Run No.

Absorber

Still Column Vapor
Exit Temperature

Emissions Separator
Temperature

Temperature

Pressure

(°F)

(psig)

(°F)

(°F)

Run 1

98- 130a

1010

106 - 129

114.95 - 115.71

Run 2

102 - 105

1010

94 - 120

111.37 - 114.58

Run 3

90-94

1010

110 - 128

103.94 - 106.90

3 This 130°F reading is suspect. It occurred only once, and all other readings were 105°F or less.

The following subsections present reboiler stack emissions and HAP destruction efficiency results.

2.3.1. Reboiler Stack Emissions Performance

All test runs conformed to the applicable reference method procedures (see Table 1-3). The reference
method results are in terms of parts per million by volume, dry (ppmvd), corrected for moisture content.
C02 emissions are in volume percent. These values, correlated with stack gas flow rates, yield lb/h
emission rates as follows:

where:

Q *MIV * C „

E		pi	Eqn. 1

385.15 * 106

Eib/h	=	emission rate (lb/h)

Qstd	=	stack gas volumetric flow rate (dscfh)

MW	=	pollutant molecular weight, pounds per pound mole (lb/lbmol)

Cpoii	=	pollutant concentration (ppmvd)

385.15	=	standard cubic feet per pound mole (scf/lb.mol)

-v6

10	= parts per million

All pollutant and gas emissions were relatively consistent between the three test runs. Table 2-4
summarizes the run average NOx, CO, VOC, CH4, C02 and HAP concentrations, emission rates and the
overall average emissions from the reboiler stack.

Table 2^4. Reboiler Stack Emissions Summary

Verf.
Test
Run

No.

Exhaust

o2

Stack
Gas
V elocity

Stack
Flow
Rate

NOx
Emissions

CO
Emissions

VOC Emissions

ch4

Emissions

co2

Emissions

Total HAP
Emissions

%

ft/sec

dscfh

ppmvd

lb/h

ppmvd

lb/h

ppmvd

lb/h

ppmvd

lb/h

%

lb/h

ppmvd

lb/h

Run 1

6.4

23.64

10,793

67.8

0.0873

0.3

0.0003

0.4

0.0002

<0.1

< 0.00004

9.5

117

<0.6

<0.0016

Run 2

6.7

23.72

10,369

66.0

0.0817

1.0

0.0007

0.8

0.0004

<0.1

< 0.00004

9.2

108

<0.6

<0.0016

Run 3

6.8

24.27

10,359

61.6

0.0761

0.6

0.0004

0.5

0.0002

<0.1

< 0.00004

9.1

107

<0.6

<0.0015



Avg. | 6.6| 23.87| 10,507| 65.l| 0.0817| 0.6| 0.0005| 0.6| 0.0003| < 0.l| <0.00004| 9.3| lll| <0.6 | < 0.0016

2-5


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Average N0X emissions were 65.1 ppmvd and 0.0817 lb/h. Emissions of CO and VOCs were very low
during all three test runs, averaging 0.6 ppmvd (0.0005 lb/h) and 0.6 ppmvd (0.0003 lb/h), respectively.

A continuously extracted stack gas sample, periodically injected into a gas chromatograph, provided the
material for organic (CH4, HAPs) concentration determinations. Test personnel performed six injections,
each about 15 minutes apart, during each test run. The analyst determined that each HAP constituent was
consistently below the instrument's detection limit (< 0.1 ppmvd). This equates to an average hourly
emission rate of < 0.0016 lb/h which is well below the site's permit requirement. All methane results
were also below the GC/FID's detection limit (< 0.1 ppmvd).

C02 concentrations averaged 9.3 percent, corresponding to an average 111 lb/h emission rate.

Test personnel conducted all sampling system QA/QC checks in accordance with test plan specifications.
These included analyzer linearity tests, sampling system bias and drift checks, interference tests, and use
of audit gases. Section 3 discusses the QA/QC check results.

2.3.2. HAP Destruction Efficiency

Table 2-5 summarizes HAP destruction efficiency for each test run and the overall average. Note that the
test plan specified that ARL glycol sample analyses data correlated with the glycol flow rate form the
basis for the quantity of HAPs entering the system. This means that an average of 9.09 lb/h net HAPs
entering the system with less than 0.0236 lb/h leaving it results in a destruction efficiency exceeding
99.74 ± 0.01 percent. Section 3.2.5 discusses the accuracy derivation for this determination.

Table 2-5. HAP Destruction El

flciency

Verification Test
Run No.

HAPrich

HAPiean

net HAPjn

HAPwastewater

I l \Ps|ack

11 \ I\ ented

HAPemitted

HAP DE

lb/h

lb/h

lb/h

lb/h

lb/h

lb/h

lb/h

%

Run 1

9.83

0.33

9.50

0.0209

<0.0016

0.00

0.0226

99.76

Run 2

8.37

0.37

8.00

0.0220

<0.0016

0.00

0.0236

99.70

Run 3

10.19

0.40

9.79

0.0232

<0.0015

0.00

0.0245

99.75



Average

9.46

0.37

9.09

0.0220

0.0016

0.00

0.0236

99.74

90% Confidence Interval

1.62

0.06

1.62

0.0020

0.00015



0.002

0.01

The overall HAP average mass rate in the condensate product stream was 16.41 lb/h. This means that net
HAPs entering the system (as determined by the ARL method) were consistently less than the summed
HAPs in the two effluent (stack gas and wastewater) and one product (condensate) streams. The glycol
streams failed to account for approximately 7.34 lb/h of the total mass exiting the system.

The GHG Center targeted the rich glycol samples as the primary location where HAP mass loss could
have occurred after ruling out potential flow measurement problems or bias. The field team leader
withdrew rich glycol at absorber pressure (1010 psig) into a sampling vial at atmospheric pressure during
each sampling event. The rich glycol foamed instantly as it entered the vial. The foam was not allowed
to overflow the vial, it was capped immediately, and stored on ice according to the ARL procedure. The
reader should note that these procedures directly correspond to the ARL sampling instructions for glycol
dehydrators without flash tank gas separators. The method's Figure A-l [9] specifies, in the absence of a
flash tank, a sampling location between the charcoal filter and the reboiler. Section A.4.4 indicates that
rich glycol from that sampling location "generally sprays from the sample line as a foamy aerosol" which
is consistent with the field conditions.

2-6


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Test personnel did, however, deviate from the ARL method in one respect. As documented in a GHG
Center corrective action report (CAR), field personnel did not employ an iced cooling coil for the rich
glycol samples because the rich glycol was at absorber temperature, or about 90 to 100 °F throughout the
test runs. Section A.4.2 of the ARL method requires that the sample pass through an iced cooling coil,
but "cooling the glycol sample is not necessary if the temperature of the glycol is less than 70 °F" [9], It
is possible that this temperature discrepancy may have negatively biased the rich glycol HAPs
concentrations. The HAPs may have volatilized and escaped while the foamy glycol filled the sampling
vials. The GHG Center cannot conclusively state whether this was the primary cause. GRI studies have
found that the ARL method does negatively bias VOC, but not necessarily BTEX results [8,10],

This possible negative bias could cause a negative effect on the reported HAPs destruction efficiency.
Table 2-5 shows that the destruction efficiency, based on average HAP inputs of 9.46 lb/h (as quantified
by the ARL method) is 99.74 percent. If the HAP inputs are assumed to be at least equal to the sum of
the wastewater, stack gas, and condensate HAPs (average 16.41 lb/h), the resulting destruction efficiency
is 99.86 percent. The GHG Center therefore concludes that the QLD emits very little HAPs and that
overall destruction efficiency is 99.74 percent (or more) in either scenario.

2.3.2.1. HAP Inputs from Glycol Streams

Table 2-6 summarizes the average glycol flow rates for the three test runs as measured with the ultrasonic
flow meter. The lean glycol flow rates were between 3.77 and 3.92 gpm. The corrected rich glycol flow
rates were between 3.77 and 4.05 gpm. The added water content and hydrocarbons increased rich glycol
flow rate by about 4 percent.

2-7


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Table 2-6. HAP Inputs From Glycol Streams

Run 1

Concentration, CLean (Ig/mL)

V Lean

HAPlean



Lean 1

Sample 1

Sample 2

Sample 2a

Sample 3

Average

Ig/mL

lb/gal

gpm

lb/h

n-Hexane

6.00

ND

6.00

ND

6.00

ND

6.00

ND

6.00

0.0000501

3.769

0.01

Benzene

69.4



54.0



68.2



59.1



62.66

0.0005229

3.769

0.12

Toluene

89.6



66.5



87.6



69.4



78.26

0.0006531

3.769

0.15

Ethylbenzene

6.00

ND

6.00

ND

6.00

ND

6.00

ND

6.00

0.0000501

3.769

0.01

p-Xylene

16.6



15.6



14.8



19.9



16.73

0.0001396

3.769

0.03

o-Xylene

6.00

ND

6.00

ND

6.00

ND

6.00

ND

6.00

0.0000501

3.769

0.01

Total HAP

193.58



154.14



188.63



166.28



175.66

0.0014659

3.769

0.33



Concentration, Crm, (Ig/mL)

VRjch

HAPRich

Difference
net HAPin

Rich 1

Sample 1

Sample 2

Sample 2a

Sample 3

Average

Ig/mL

lb/gal

gpm

lb/h

lb/h

n-Hexane

140.13



107.27



144.50



137.00



132.22

0.0011034

3.916

0.26

0.25

Benzene

1660.5



1424.8



1704.8



1394.5



1546.13

0.0129031

3.916

3.03

2.91

Toluene

2744.7



2393.9



2843.6



2293.2



2568.85

0.0214381

3.916

5.04

4.89

Ethylbenzene

58.98



51.47



62.31



48.01



55.19

0.0004606

3.916

0.11

0.10

p-Xylene

614.6



545.7



647.7



511.2



579.80

0.0048386

3.916

1.14

1.11

o-Xylene

137.67



120.91



144.49



113.18



129.06

0.0010771

3.916

0.25

0.24

Total HAP

5356.52



4644.02



5547.40



4497.10



5011.26

0.0418210

3.916

9.83

9.50

Run 2

Concentration, CLean (Ig/mL)

V Lean

HAPlean



Lean 2

Sample 1

Sample 2

Sample 2a

Sample 3

Average

Ig/mL

lb/gal

gpm

lb/h

n-Hexane

6.00

ND

6.00

ND

6.00

ND

6.00

ND

6.00

0.0000501

3.604

0.01

Benzene

82.5



74.4



68.6



75.5



75.25

0.0006280

3.604

0.14

T oluene

102.5



94.5



86.6



92.8



94.11

0.0007853

3.604

0.17

Ethylbenzene

6.00

ND

6.00

ND

6.00

ND

6.00

ND

6.00

0.0000501

3.604

0.01

p-Xylene

20.6



16.1



24.8



14.3



18.96

0.0001582

3.604

0.03

o-Xylene

6.00

ND

6.00

ND

6.00

ND

6.00

ND

6.00

0.0000501

3.604

0.01

Total HAP

223.66



202.98



197.99



200.64



206.32

0.0017218

3.604

0.37



Concentration, Crm, (Ig/mL)

VRjch

HAPRich

Difference
net HAPin

Rich 2

Sample 1

Sample 2

Sample 2a

Sample 3

Average

Ig/mL

lb/gal

gpm

lb/h

lb/h

n-Hexane

135.27



122.23



119.66



134.68



127.96

0.0010679

3.772

0.24

0.23

Benzene

1476.1



1461.7



1332.5



1467.7



1434.50

0.0119715

3.772

2.71

2.57

Toluene

2197.3



2355.2



2133.1



2275.6



2240.32

0.0186964

3.772

4.23

4.06

Ethylbenzene

44.96



47.96



42.70



43.75



44.84

0.0003742

3.772

0.08

0.07

p-Xylene

474.4



508.0



458.7



470.2



477.84

0.0039878

3.772

0.90

0.87

o-Xylene

106.65



112.41



100.60



103.05



105.68

0.0008819

3.772

0.20

0.19

Total HAP

4434.72



4607.53



4187.29



4495.03



4431.14

0.0369797

3.772

8.37

8.00

Run 3

Concentration, CLean (Ig/mL)

V Lean

HAPlean



Lean 3

Sample 1

Sample 2

Sample 2a

Sample 3

Average

ig/ml

lb/gal

gpm

lb/h

n-Hexane

6.00

ND

6.00

ND

6.00

ND

6.00

ND

6.00

0.0000501

3.887

0.01

Benzene

74.3



74.3



71.6



86.0



76.57

0.0006390

3.887

0.15

Toluene

91.1



88.7



86.5



105.6



92.98

0.0007760

3.887

0.18

Ethylbenzene

6.00

ND

6.00

ND

6.00

ND

6.00

ND

6.00

0.0000501

3.887

0.01

p-Xylene

17.1



21.6



16.5



18.4



18.41

0.0001536

3.887

0.04

o-Xylene

6.00

ND

6.00

ND

6.00

ND

6.00

ND

6.00

0.0000501

3.887

0.01

Total HAP

200.51



202.67



192.57



228.09



205.96

0.0017188

3.887

0.40

(continued)

2-8


-------
Table 2-6. HAP Inputs From Glycol Streams (concluded)

Rich 3

Concentration. Cnm dsi/ml,)

VRjch

HAPRich

Difference
net HAPin

Sample 1

Sample 2

Sample 2a

Sample 3

Average

Ig/mL

lb/gal

gpm

lb/h

lb/h

n-Hexane

144.62



128.69



144.76



135.22



138.32

0.0011544

4.047

0.28

0.27

Benzene

1652.1



1566.6



1576.0



1592.6



1596.84

0.0133263

4.047

3.24

3.09

Toluene

2609.8



2517.0



2529.8



2665.7



2580.59

0.0215361

4.047

5.23

5.05

Ethylbenzene

50.25



51.93



51.89



53.51



51.90

0.0004331

4.047

0.11

0.09

p-Xylene

524.0



542.0



544.3



550.5



540.19

0.0045081

4.047

1.09

1.06

o-Xylene

115.01



121.90



121.59



120.08



119.64

0.0009985

4.047

0.24

0.23

Total HAP

5095.74



4928.21



4968.39



5117.57



5027.48

0.0419563

4.047

10.19

9.79



Overall Avg

Sample 1

Sample 2

Sample 2a

Sample 3

Average

Avg.
Flow
Rate

Avg.
Mass
Rate

Difference
net HAPin

ig/mL

ig/mL

ig/mL

ig/mL

ig/mL

lb/gal

gpm

lb/h

lb/h

Lean - Total
HAP

205.92



186.60



193.06



198.33



195.98

0.0016355

3.753

0.37



Rich - Total
HAP

4962.33



4726.59



4901.03



4703.23



4823.29

0.0402523

3.912

9.46

9.09

ND Non-detect or analytical result below the minimum detection limit (MDL)
Viean Lean glycol flow rate, gpm
Vrich Rich glycol flow rate, gpm

Table 2-6 also summarizes the GC/FID results. The table shows that four lean and four rich samples were
collected during each test run. The field team leader collected samples 2 and 2a sequentially and all other
samples were collected about 20 minutes apart.

The lean glycol HAPs mass rate is smaller than the rich stream. This demonstrates that the QLD glycol
regeneration process is indeed removing a significant mass of HAPs through condensation and
combustion. The overall average HAP concentration in rich and lean glycol streams was 4823.29 ig/mL
and 195.98 ig/mL, respectively. The primary HAP species present in both streams are benzene and
toluene, followed by p-xylene.

Net HAPs entering the QLD system boundary ranged between 8.00 and 9.79 lb/h at a minimum and the
overall average is 9.09 ± 1.09 lb/h with a 90 percent confidence interval.

2.3.2.2. HAP Outputs in Reboiler Exhaust Stream

Section 2.3.1 shows that HAP concentrations in the reboiler exhaust stream were below the instrument's
detection limit. Table 2-7 summarizes the mass emission rate results. Note that the lb/h detection limits
vary because the volumetric flow rate varied from run to run.

2-9


-------
Table 2-7. Reboiler Exhaust Stream HAPs Outputs

Verification
Run No.



Concentration, CS|ad;

H^Psiadt

ppm

lb/h

Run 1

n-Hexane

<0.1

<0.000241

Benzene

<0.1

<0.000218

Toluene

<0.1

<0.000258

Ethylbenzene

<0.1

<0.000297

p-Xylene

<0.1

<0.000297

o-Xylene

<0.1

<0.000297

Total HAP

<0.00161

Run 2

n-Hexane

<0.1

<0.000232

Benzene

<0.1

<0.000210

Toluene

<0.1

<0.000247

Ethylbenzene

<0.1

<0.000286

p-Xylene

<0.1

<0.000286

o-Xylene

<0.1

<0.000286

Total HAP

<0.00155

Run 3

n-Hexane

<0.1

<0.000232

Benzene

<0.1

<0.000210

Toluene

<0.1

<0.000247

Ethylbenzene

<0.1

<0.000285

p-Xylene

<0.1

<0.000285

o-Xylene

<0.1

<0.000285

Total HAP

<0.00154

Overall Avg.

0.00157

2.3.2.3. HAP Outputs in Wastewater Production Stream

Table 2-8 shows the wastewater discharge amounts per dump based on nine dump cycles. Five dumps
occurred during Run 1 and 2, and three dumps occurred during Run 3 of the verification test. The field
team leader collected these data prior to the test campaign. The data show that the discharge rate was
repeatable: 3.057 ± 0.019 gal/dump or 1.283 ± 0.007 gal/in. Test planners expected this consistency
because the repeatability of the pneumatically operated controllers were 1/1000 of an inch. The test plan
anticipated that, for the size and configuration of the vacuum separator, the discharge repeatability would
be better than ±2.0 percent. The actual repeatability was about ±0.6 percent.

Table 2-8. Pre-Test Wastewater Discharge Rate Determinations

Date

Time

Time
Diff

Dump

Tare

Full

Gain

Temp

Density

Discharge Rate

Sight Glass Readings

Dis-
charge
Rate

Start

End

Diff

min

ID

lb

lb

lb

degF

lb/gal

gal/dump

gpm

in

in

in

gal/in.

4/7/03

12:42



1

2.31

27.93

25.62

91

8.301810

3.0861











13:33

51

2

2.31

27.93

25.62

91

8.301810

3.0861

0.0605

3.4063

1.0000

2.4063

1.2825

14:24

51

3

2.33

27.72

25.39

92

8.300227

3.0590

0.0600

3.3750

1.0000

2.3750

1.2880

15:24

60

4

2.32

27.81

25.49

93

8.298644

3.0716

0.0512

3.3750

1.0000

2.3750

1.2933

16:23

59

5

2.30

27.81

25.51

91

8.301810

3.0728

0.0521

3.4063

1.0000

2.4063

1.2770

4/8/03

10:12



23

2.30

27.32

25.02

101

8.285780

3.0196



3.0000

0.6250

2.3750

1.2714

12:07

115

25

2.29

27.62

25.33

101

8.285780

3.0570



3.0156

0.6250

2.3906

1.2788

12:56

49

26

2.30

27.50

25.20

103

8.282211

3.0427

0.0621

3.0000

0.6406

2.3594

1.2896

15:10

134

29

2.30

27.27

24.97

111

8.267735

3.0202













Average:

3.0572



Average:

1.2829

2-10


-------
Table 2-9 shows the elapsed times between dump cycles for each test run.

Table 2-9. Wastewater Production Rate During Verification Testing





Time

Elaps.

Dump

Discharge
Rate

Waste-
water
Produc-
tion Rate
Per Dump



Elapsed
Time
Since
Dump

Fraction of

Time
Relative to

Run
Durationb

Weighted
Wastewater
Production
Rate0

Run-

Specific
Average
Wastewater
Production
Rate,

Wastewater

Date

Time

Diff

Min

ID

gal/dumpa

gpm



Min



gpm

gpm

4/30/03

14:03





323

3.0572















14:31

0:28

28

324

3.0572

0.1092

Run 1 Start:
14:30

1

0.008850

0.0010





15:00

0:29

29

325

3.0572

0.1054



29

0.256637

0.0271





15:39

0:39

39

326

3.0572

0.0784



39

0.345133

0.0271





16:06

0:27

27

327

3.0572

0.1132



27

0.238938

0.0271





16:31

0:25

25

328

3.0572

0.1223

Run 1 Stop:
16:23

17

0.150442

0.0184

0.101



17:09

0:38

38

329

3.0572

0.0805

Run 2 Start:
17:01

8

0.089888

0.0072





17:27

0:18

18

330

3.0572

0.1698



18

0.202247

0.0344





17:52

0:25

25

331

3.0572

0.1223



25

0.280899

0.0344





18:23

0:31

31

332

3.0572

0.0986



31

0.348315

0.0344





18:50

0:27

27

333

3.0572

0.1132

Run 2 Stop:
18:30

7

0.078652

0.0089

0.119



19:28

0:38

38

334

3.0572

0.0805

Run 3 Start:
18:57

31

0.344444

0.0277





19:57

0:29

29

335

3.0572

0.1054



29

0.322222

0.0340





20:25

0:28

28

336

3.0572

0.1092

Run 3 Stop:
20:27

30

0.333333

0.0364

0.098

Overall Average

0.106

a Based on the average discharge rate determined during pre-test evaluation (Table 2-8)
b Duration for Run 1 = 113 mins, Rim 2 = 89 mins, and Run 3 = 90 mins
c Wastewater production rate multiplied by fraction of time between dumps

Wastewater total volume for Runs 1, 2, and 3 was 11.36, 10.61, and 8.83 gallons, respectively. Based on
the elapsed times for each test run, the wastewater production rate varied between 0.101 and 0.119 gpm.
The overall average production rate was 0.106 gpm.

Table 2-10 summarizes the laboratory analysis results for four wastewater samples collected during each
test run. Benzene and toluene were the primary HAP constituents. Average concentrations ranged
between 368 and 472 ig/mL. Multiplication of these concentrations by the production rates shown in
Table 2-9 yields the run-specific mass emission rates. The HAP emission rate for all three test runs was
0.0220 Ml

2-11


-------
Table 2-10. HAPs Outputs in Wastewater Stream

Run 1

Concentration, CWastev

rater Og/mL)

Wastewater
Production
Rate,

^^Wastewater

HAINvatei

Sample ID

Sample ID

Sample ID

Sample ID

Average

1

2

2a

3

ig/mL

lb/gal

gpm

lb/h

n-Hexane

0.801

ND

1.001

ND

1.001

ND

1.001

ND

0.951

0.000008

0.101

0.00005

Benzene

200.489



227.145



313.737



289.688



257.764

0.002151

0.101

0.01298

Toluene

104.976



113.377



175.446



157.164



137.741

0.001150

0.101

0.00693

Ethylbenzene

0.971

J

1.279

J

1.918

J

1.642

J

1.453

0.000012

0.101

0.00007

m- and p-Xylene

8.352



9.058



16.928



15.516



12.463

0.000104

0.101

0.00063

o-Xylene

2.829

J

3.434

J

5.570



5.212



4.261

0.000036

0.101

0.00021

Total HAP

318.417



355.294



514.600



470.223



414.634

0.003460

0.101

0.0209

Run 2

n-Hexane

0.400

ND

1.001

ND

1.464

J

1.001

ND

0.967

0.000008

0.119

0.00006

Benzene

186.603



271.942



146.598



284.810



222.488

0.001857

0.119

0.01328

Toluene

96.426



165.647



78.479



168.820



127.343

0.001063

0.119

0.00760

Ethylbenzene

0.855

J

1.635

J

1.001

ND

1.803

J

1.324

0.000011

0.119

0.00008

m- and p-Xylene

8.629



15.951



7.379



16.304



12.066

0.000101

0.119

0.00072

o-Xylene

2.671



5.173



2.485

J

5.408



3.934

0.000033

0.119

0.00023

Total HAP

295.584



461.350



237.407



478.147



368.122

0.003072

0.119

0.0220

Run 3

n-Hexane

1.001

ND

1.001

ND

1.001

ND

1.001

ND

1.001

0.000008

0.098

0.00005

Benzene

275.285



272.485



291.060



307.250



286.520

0.002391

0.098

0.01407

Toluene

156.729



157.039



165.044



168.717



161.882

0.001351

0.098

0.00795

Ethylbenzene

1.609

J

1.555

J

1.706

J

1.677

J

1.637

0.000014

0.098

0.00008

m- and p-Xylene

15.815



15.510



16.673



16.276



16.068

0.000134

0.098

0.00079

o-Xylene

5.391



5.090



5.367



5.323



5.293

0.000044

0.098

0.00026

Total HAP

455.829



452.680



480.850



500.245



472.401

0.003942

0.098

0.0232

Overall Avg.

Total HAP

356.610 423.108



410.952



482.871



418.386 0.003

0.106 0.0220

ND Non-detect or analytical result below the minimum detection limit (MDL)
J Analytical result between the MDL and the limit of quantification (LOQ)

2.3.2.4. HAP Outputs in Condensate Production Stream

The run-specific condensate production rate determination first requires an estimate of the condensate
discharge rate (gal/dump). The gal/in. discharge rate would be identical for both product streams because
the liquids collect in a common vessel and the condensate pneumatic level controller is identical to the
wastewater level controller. GHG Center personnel recorded the initial and final condensate sight-glass
levels before and after each dump cycle. The sight-glass level change (in.) multiplied by the wastewater
discharge rate reported in Section 2.3.2.3 (1.283 gal/in.) yielded condensate discharge rate (gal/dump).
Table 2-11 summarizes the results for each test run.

2-12


-------
Table 2-11. Run-Specific Condensate Production Rate

Date

Time

Time
Ref

Elaps
Ref

Dump
Ref

Condensate Sight-Glass
Reading

Waste
water
Discharge
Rate3

Condensate
Discharge
Rateb

Condensate
Production Rate

Elapsed
Time
Since
Dump

Fraction
of Time
Relative
to Run
Duration0

Weighted
Condensate
Production
Rated

Run-Specific

Average
Condensate
Production
Rate,
v

Start

End

Diff

Diff

Min

ID

in.

in.

in.

gal/in.

gal/dump

gpm



Min



gpm

gpm

4/30/03

13:50





200

2.6250

0.3438

2.2813

1.2829

2.9267













14:45

0:55

55

201

2.5625

0.2500

2.3125

1.2829

2.9668

0.0539

Run 1

Start:

14:30

15

0.1327

0.0072



15:46

1:01

61

202

2.5938

0.1875

2.4063

1.2829

3.0871

0.0506



61

0.5398

0.0273



16:44

0:58

58

203

2.5938

0.3438

2.2500

1.2829

2.8866

0.0498

Run 1

Stop:

16:23

37

0.3274

0.0163

0.051

17:25

0:41

41

204

2.5938

0.1875

2.4063

1.2829

3.0871

0.0753

Run 2

Start:

17:01

24

0.2697

0.0203



18:41

1:16

76

205

2.5938

1.1875

1.4063

1.2829

1.8041

0.0237

Run 2

Stop:

18:30

65

0.7303

0.0173

0.038

19:19

0:38

38

206

2.5938

0.3438

2.2500

1.2829

2.8866

0.0760

Run 3

Start:

18:57

22

0.2444

0.0186



20:17

0:58

58

207

2.5938

0.3125

2.2813

1.2829

2.9267

0.0505

Run 3

Stop:

20:27

68

0.7556

0.0381

0.057

Overall Average

0.048

a Based on the average discharge rate determined during pre-test evaluation (Table 2-9).
b Estimated by multiplying wastewater discharge rate by level change in sight glass reading.
c Duration for Run 1 = 113 minutes, Run 2 = 89 minutes, and Run 3 = 90 minutes.
d Wastewater production rate multiplied by fraction of time between dumps.

2-13


-------
Two to three complete condensate dumps occurred during each test run. The overall average condensate
production rate was 0.048 gpm. The condensate recovery rate was about half as much as the wastewater
production rate.

Table 2-12 summarizes the laboratory analysis results for four condensate samples collected during each
test run. Similar to the wastewater stream, benzene, toluene, and p-xylene were the primary HAP
constituents in each condensate sample. Average HAP concentrations ranged between 637,339 and
714,412 ig/ml. Multiplication of these concentrations by the production rates shown in Table 2-11
resulted in run-specific mass emission rates. The overall average HAP production rate from the
condensate product stream was 16.41 lb/h.

Table 2-12. HAP Outputs in Condensate Production Stream

Run 1

Concentration, CWater (ig/mL)

Condensate
Production
Rate,

Condensate

HAP

Condensate

Sample ID

Sample ID

Sample ID

Sample ID

Average

1

2

2a

3

ig/mL

lb/gal

gpm

lb/h

n-Hexane

10,107



8,776



10,370



9,589



9711

0.08

0.051

0.25

Benzene

212,553



176,446



222,001



208,710



204928

1.71

0.051

5.21

Toluene

383,335



315,392



407,011



381,067



371701

3.10

0.051

9.45

Ethylbenzene

8,033



6,589



8,663



8,129



7854

0.07

0.051

0.20

m- and p-

Xylene

84,897



69,741



90,867



85,705



82803

0.69

0.051

2.11

o-Xylene

18,307



15,027



19,666



18,573



17893

0.15

0.051

0.45

Total HAP

717,233



591,971



758,578



711,773



694,889

5.80

0.051

17.67

Run 2

n-Hexane

9,790



10,707



9,514



9,259



9817

0.08

0.038

0.19

Benzene

206,344



225,489



200,974



197,164



207493

1.73

0.038

3.91

Toluene

379,359



415,395



370,220



363,980



382238

3.19

0.038

7.20

Ethylbenzene

8,192



9,157



8,315



8,191



8464

0.07

0.038

0.16

m- and p-

Xylene

86,724



95,446



83,958



82,771



87225

0.73

0.038

1.64

o-Xylene

18,847



20,866



18,683



18,302



19175

0.16

0.038

0.36

Total HAP

709,256



777,061



691,665



679,667



714,412

5.96

0.038

13.47

Run 3

n-Hexane

9,170



9,052



9,336



7,536



8773

0.07

0.057

0.25

Benzene

191,505



190,064



196,546



162,279



185098

1.54

0.057

5.25

Toluene

351,340



350,878



361,019



298,660



340474

2.84

0.057

9.67

Ethylbenzene

7,987



7,976



8,272



6,700



7734

0.06

0.057

0.22

m- and p-

Xylene

80,639



80,386



82,471



68,505



78000

0.65

0.057

2.21

o-Xylene

17,838



17,814



18,260



15,124



17259

0.14

0.057

0.49

Total HAP

658,479



656,169



675,904



558,803



637,339

5.32

0.057

18.09

Overall Avg.

Total HAP I 694,9891 I 675,0671 I 708,7161 I 650,0811 I 682,2131 5.69| 0.0481 16.41

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3.0

DATA QUALITY ASSESSMENT

3.1. DATA QUALITY OBJECTIVES

The test plan specified methodologies, instruments, and QA/QC requirements which would ensure that
the final results have known data quality. The test plan's stipulations lead to specific data quality
objectives (DQOs) for each verification parameter. Each measurement that contributes to a verification
parameter determination has stated data quality indicators (DQIs) which, if met, ensure achievement of
the applicable DQO.

The establishment of DQOs begins with the determination of each verification parameter's desired
confidence level. Test planners then identify the expected values of all contributing measurements and
determine the tolerable error level. Table 3-1 summarizes the test plan's specified DQOs for each
verification parameter. The table also shows those achieved during the test campaign.

Table 3-1. Verification Parameter Data Quality Objectives

Verification Parameter

Allowable Measurement Error a

Achieved

Sales Gas

Flow Rate
Moisture Content

± 1%

± 2 °C dewpoint

±0.13%
± 1 °C dewpoint

Glycol Circulation Rate

± 1%

± 0.4%

Makeup Natural Gas





Makeup Natural Gas Flow Rate

± 1%

±0.8%

BTEX Content

±5%

n/ac

Reboiler Exhaust Stack Emissions

Concentration (ppm or%)





NOx

± 2% of FS or 2 ppm

2.0 ppm

CO

± 2% of FS or 2 ppm

1.2 ppm

o2

± 2% of FS or 0.5%

0.2%

co2

± 2% of FS or 0.5%

0.4%

THC

± 5%o of FS or 5 ppm

2.0 ppm

CH4

± 5%o of FS or 5 ppm

0.1 ppm

HAPs

± 5%o of FS or 5 ppm

0.6 ppm

Emission Rate (lb/h)b





NOx

± 0.0088 lb/h

0.0048 lb/h

CO

± 0.0053 lb/h

0.0009 lb/h

co2

± 16.2 lb/h

7.5 lb/h

THC

±0.0031 lb/h

0.0009 lb/h

CH4

±0.00019 lb/h

0.000003 lb/h

HAPs

±0.018 lb/h

0.0001 lb/h

HAP Destruction Efficiency

± 0.5%

±0.01%

a Full scale (FS) during testing was 0 -100 ppm. for NOx, CO, THC, CH4, and FlAPs

Full scale during testing was 0 - 25% for 02 and C02
b Stated as 7% of the emission rate when the concentration is at 100% of analyzer span and stack flow is 10,507 dscfh.
c Not available. Please refer to Section 3.2.3.

Analysts most often state the DQIs in terms of measurement accuracy, precision, and completeness.
Table 3-2 specifies each DQI goal and those achieved during testing.

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Table 3-2. Data Quality Indicator Goals and Results

Measurement Variable

Instrument Type /
Manufacturer

Instrument
Range (FS)a

Accuracy

Completeness

Goal"

Actual0

How Verified /
Determined

Goal

Actual

Sales Gas

Flow Rate

Emerson Model
MVS205 Orifice
Meter

0 to 2 mmscfh

± 1% reading

±0.13% reading

Field calibration with NIST-
traceable reference
standards

90% of 1-min

average

readings

Opr. Testing: 93%
Env. Testing: 84%

Moisture
Content

MEECO (test plan)

Panametrics

(installed)

0 to 20 lb/mmscf

± 2 °C Dewpoint

± 1 °C Dewpoint

Calibration with NIST-
traceable reference standard

Opr. Testing: 93%
Env. Testing: 84%

Glycol

Circulation

Rate

Flow Rate

Controlotron
Ultrasonic Flow
Meter

Pipe diameter: 0.25
to 360 inch
Flow velocity: 0 to
60 fps

± 1% reading

± 0.4% reading

Calibration with NIST-
traceable reference standard

Opr. Testing: 85%
Env. Testing: 84%

Makeup
Natural Gas

Fuel Flow
Rate

Flaliburton MC-II
EXP turbine meter

0 to 1,500 scfh

± 1% reading

± 0.8% reading

Calibration with NIST-
traceable reference standard

Opr. Testing: 93%
Env. Testing: 84%

BTEX Content

GC/FID HP Model
5890 or Equivalent

0 to 10,000 ppm

% Diff. in 3 Pt.
Calibration < 5%

n/ad

Calibration with certified
standards

Pre-test: 2
samples

2 samples

Exhaust

Stack

Emissions

NOx Concen.

Chemiluminescent/
TEI Model 42C

0 to 100 ppmv

± 2% FS or
± 2 ppmv

< 2.0% FS or
± 2.0 ppmv c

Calculated following EPA
reference method
calibrations (Before and
after each test run)

three valid 90
minute runs
(90- percent
completeness)

Run 1: 85 mins
Run 2: 70 mins
Run 3: 72 mins

CO Concen.

NDIR / TEI Model
48C

0 to 100 ppmv

± 2% FS or
± 2 ppmv

< 1.2% FS or
± 1.2 ppmv c

THC Concen.

FID / JUM Model
VE-7

0 to 100 ppmv

± 5% FS or
± 5 ppmv

< 2.0% FS or
± 2.0 ppmv c

CO2 Concen.

NDIR / CAI Model
200

0 to 25%

± 2% FS or
±0.5%

< 1.7% FS or
± 0.4% c

O2 Concen.

NDIR / CAI Model
200

0 to 25%

± 2% FS or
±0.5%

< 0.9% FS or
± 0.2% c

CFLt Concen.

GC/dual FID, HP
Model 5890a

0 to 100 ppmv

± 5% FS or
± 5 ppmv

±0.1 ppmvf

HAP Concen.

±0.6 ppmv1'8

FhO Content

NA

0 to 100%

± 5% reading

± 5% reading

NIST-traceable equipment
calibrations (pitot,
thermocouple, gas meter,
and balance)

Stack Gas
Flow Rate

Pitot and
thermocouple

NA

± 5% reading

± 5% reading

(continued)

3-2


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Table 3-2. Data Quality Indicator Goals and Results (concluded)

Measurement
Variable

Instrument Type /
Manufacturer

Instrument
Range (FS)a

Accuracy

Completeness

Goal"

Actual0

How Verified /
Determined

Goal

Actual

HAPs in

Liquid

Streams

Wastewater
Discharge Rate

NA

NA

Repeatability of ±
1% between dump
cycles

±0.6%

Manual collection and
weighing of wastewater
produced during a
discharge dump

Minimum of 3
dump captures
in pre-weighed
container

9 dump cycles
captured

HAPs in rich
glycol, lean
glycol,
wastewater,
and condensate

GC/FID

0 to 1000 ppm,
nominal

< 5% diff. in 3 pt.
calibration

< 5% diff in cal. error

Minimum of 3 pt.
calibration with certified
standard.

3 samples per
test run

4 samples per test
run

< 5%

Maximum diff in

duplicate

injections

rich glycol: 2.9%c
lean glycol: 4.5%)c
wastewater: 9.8%o c'e

Duplicate sampling and
analysis on at least one
rich, lean, and
wastewater sample.

s FS: full scale

b In the Test Plan, FS for NOx, CO, and THC was 0-100 ppm, and 0-50 ppm for CH4 and HAPs. For 02 and C02, FS was 0 - 25%.

During the test, FS for all compounds except CH4 and HAPs was same as those defined in the Test Plan. For CH4 and HAPs, FS was changed to 0 -100 ppm.

The accuracy goals listed here represent the FS of instruments used during testing.
c Actual values shown represent the maximum system error observed throughout the test periods.

See the discussion in Section 3.2.3

e The laboratory prepared and injected one duplicate sample aliquot, unlike the duplicate injections for the GC/FID analyses. Goal for this duplicate analysis was ± 10%.
f Cubix calibrated the GC/FID at low, medium, and high levels. Since stack gas concentrations were non-detectable, error at the low level calibration is the assigned error. See Appendix B-3.
8 Represents compounded average error for all HAPs at low reference concentration.

3-3


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3.2. DQO AND DQI RECONCILIATION

Data completeness goals are summarized in Table 3-2. "Completeness" is defined as the number or
percent of valid determinations actually made relative to those specified in the Test Plan.

The goal for operational parameters was at least 90 percent valid data during each 24-hour segment of the
7-day monitoring period or during each test run. Nearly all one-minute data collected during 5 of the 7
days were valid. The remaining two days included 15.05 hours and 20.73 hours of one-minute data
(Table 2-1). On average, 93 percent of the one-minute measurements data were valid and the GHG
Center used those data to report operational performance results.

The field team leader discovered during the first environmental performance test run that sampling events
at the vacuum separator caused process upsets. The reboiler stack CO (and other gas) concentrations
would rise or drop abruptly when the manual vent valve was opened to break the vessel's vacuum. The
GHG Center invalidated data where CO concentration was greater than 90 percent of the average initial
value for two consecutive data points and until the concentration reached 90 percent of a stable final value
following the event.

Test personnel observed that the primary upset indicators were CO concentration step changes. The step
changes were clear and well-defined during all but one sampling event. Other stack gas concentrations
changed unpredictably during sampling events with known CO step changes. It was impossible to tell
during the one sampling event with no CO step change whether other gas concentration changes were due
to the sampling event or normal variability. Exclusive use of the CO step changes as a criterion may have
left invalid data in the set. The GHG Center therefore invalidated the data collected during this sampling
event. Cubix performed no gas chromatograph injections during this period.

The actual run durations were 85, 70, and 72 minutes for runs 1, 2, and 3, respectively, after analysts
removed invalid data. The tests, therefore, did not meet completeness goals for Runs 2 and 3. The GHG
Center believes that this does not affect the overall verification results because:

•	Environmental performance results were extremely consistent from run to run, and

•	Most regulatory instrumental analyzer test runs must acquire, at most, 60 minutes of
valid data. This means that the test data are adequate for regulatory purposes.

It should also be noted that the test plan specified 90-minute test runs to accommodate the time required
for the sampling events.

The Test Plan specified three liquid samples to be collected from each liquid stream per run. Table 3-2
shows that the field team leader collected four valid samples. This met the completeness goals.

Table 3-3 shows the planned and achieved accuracy goals. Instrument calibrations (by the manufacturer
or performed in the field) or reasonableness checks form the basis for the achieved accuracies. Table 3-3
identifies the QA/QC checks performed during the tests and how these results contribute to DQI
reconciliation. The following subsection discusses each instrument's accuracy results and the effect on
the corresponding DQO.

3-4


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Version 1.2-August 13, 2003	DRAFT

Do not cite, quote, use, or distribute without written permission from GHG Center

Table 3-3. Calibration Results and QC Checks

Parameter

QA/QC Check

When
Performed/
Frequency

Expected or Allowable Result

Maximum Results Measured3

Sales Gas

Flow Rate

Field calibration by
manufacturer

Beginning of
test

Differential pressure: 6 point cal.
Static pressure: 4 point cal.
Temperature: 1 point cal.

Results should be less than 1% of
NIST traceable reference values

Diff. pressure (10 pt. cal): ± 0.12%
Static pressure (4 pt. cal): ± 0.12%
Temperature (1 pt. cal): ± 0.01%

Avg. flow rate error: +0.13%g



Factory calibration
by manufacturer

Most recently

available

records

± 2 °C dewpoint of NIST-
traceable calibration standard

± 1 °C dewpoint

Moisture
Content

Field check - adjust
sampling rate into
moisture meter

Beginning of
test

Moisture reading at 50% and
200% of normal sampling rate
should be 0.5 and 2 times the
reading at normal rate

Not performed; documented in CAR



Reasonableness
check - compare
with manually
collected gas sample

2 samples per
day of testing

±21% of lab results

400% or 2.21 lb/mmscf

Glycol Circulation Rate

Lean Glycol
Flow Rate

Reasonableness
check - compare
with ultrasonic meter

Beginning of
test

± 2% of NIST-traceable ultrasonic
meter reading

For Run 1, avg. rate for site meter
= 5.14 gpm, and avg. rate for
ultrasonic meter =3.82 gpm. Avg.
percent difference = 34.6%. GHG
Center used ultrasonic meter
during testing.

Factory calibration
by manufacturer
(Controlotron)

Beginning of
test

± 1% of NIST-traceable calibration
standard

± 0.4%

Makeup Natural Gas

Flow Rate

Factory calibration
by manufacturer

Beginning of
test

± 1% of NIST-traceable calibration
standard

± 0.8%

BTEX
Content

Calibration of
GC/FID with gas
standards

Prior to
analysis

± 5% of reference value

n/a. See discussion in Section
3.2.3

Duplicate analysis

Each sample

± 5% difference

Not Performed

Reboiler Stack Emissions

NOx

N02 converter
efficiency

Once before
testing begins

98% efficiency or greater

99.2%

NOx, CO,
co2, o2

Analyzer calibration
error test

Daily before
testing

± 2% of analyzer span or less

NOx: 0.9% of span or 0.9 ppmvd
CO: 1.9% of span or 1.9 ppmvd
CO,: 0.96% of span or 0.24%
02: 1.12% of span or 0.28%

System bias tests

Before and after
each test run

± 5% of analyzer span or less

NOx: 2.0% of span or 2.0 ppmvd
CO: 1.2% of span or 1.2 ppmvd
C02: 1.7% of span or 0.4%
02: 0.9% of span or 0.2%

Calibration drift test

After each test

± 3% of analyzer span or less

NOx: 0.5% of span or 0.5 ppmvd
CO: 1.5% of span or 1.5 ppmvd
C02: 0.6% of span or 0.2%
02: 0.9% of span or 0.2%

THC

System bias tests

Before and after
each test run

± 5% of analyzer span or less

2.0% of span or 2.0 ppmvd

System calibration
drift test

After each test

± 3% of analyzer span or less

0.7% of span or 0.7 ppmvd

(continued)

3-5


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Table 3-3. Calibrations and QC Checks (concluded)

Parameter

QA/QC Check

When
Performed/
Frequency

Expected or Allowable Result

Maximum Results Measured3



Duplicate analysis

Each sample

± 5% difference

NA°

ch4

GC/FID calibration

Prior to
analysis of 6
samples per
run

± 5 ppm or less

0.1 ppmvc



Duplicate analysis

Each sample

± 5% difference

NA°

HAP
Content

GC/FID calibration

Prior to
analysis of 6
samples per
run

± 5 ppm or less

0.6 ppmvc,d

Stack Gas
Flow Rate

Thermocouple
calibration

Once after
testing

± 1.5% of average stack temp,
recorded during final test run

0.22%

Liquid Measurements

Wastewater

Discharge

Rate

Determine

wastewater discharge
rate for 3 dumps (i.e.,
collect liquid in tared
container and
monitor sight glass
level change per
dump cycle).

Beginning of
test

± 2% difference in discharge rate
(gal/dump and gal/in.)

For 9 dump cycles, 95%
confidence interval was ± 0.6% of
mean discharge rate



Calibration of
GC/FID with gas
standards by certified
laboratory

Prior to
analysis

± 5% of reference value

Pre- and post-test calibration error
< 5% of reference value



Duplicate injection

Each sample

± 5% difference

Rich glycol: 2.9%e
Lean glycol: 4.5%e
Condensate: 2.0%e

HAP
Content

Duplicate analysis

One sample

± 5% difference

Rich glycol: 2.3% e
Lean glycol: 45.1% e'f
Wastewater: 9.8%) e,f
Condensate: not performedf



3 benzene audit
samples

Prior to
analysis

± 5% of certified concentration

For audit concen. in range of:
Rich glycol Results: -10.1 %of
Lean glycol and wastewater
results: -6.5%of
Condensate results: 4.2%)



Comparison with
internal standard

3 liquid
samples

± 5% of spike levels

Rich glycol: 8.0%o e,t
Lean glycol: 7.4%o e'f
Wastewater: 22%o e'f
Condensate: 9%o e,f

a See Appendix B and C for individual test run results.

b Not Applicable. Cubix performed on-line sampling for CH4, BTEX, and n-hexane. This eliminated the need for duplicate grab

(bag) samples. Instead, Cubix conducted six individual sample injections during each test run.
c Cubix calibrated the GC/FID at low, medium, and high levels. Since the measured stack gas concentration was non detectable,

error at the low level is the assigned error. See Appendix B for results for each compound.
d Represents compounded average error for all HAP species at low reference concentration.
e Represents maximum value observed for a HAP compound. See Appendix C for results for each compound.
f See Section 3.2.5.1 for discussion.

g The host facility (not the manufacturer) performed the most recent calibration with NIST-traceable instruments. Total flow rate
error is quoted from the calibration certificate.

3-6


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3.2.1. Sales Gas Flow Rate and Moisture Content

The DQO and DQI goal for sales gas flow rate was + 1 percent. The DQI for sales gas moisture was ±2
°C dewpoint.

Kerr McGee calibrated sales gas flow meter with NIST-traceable analyzers on March 12, 2003. Analysts
employed ten differential-pressure, four static-pressure, and a single-point temperature standard. Table 3-
3 shows that the calibration checks were below the target levels. The calibration certificate states that
overall flow meter error was ±0.13 percent.

The moisture analyzer manufacturer subjected the instrument to a 14-point NIST-traceable calibration on
December 14, 2001. The Test Plan Table 3-2 specifies this instrument must be accurate to "± 5 percent of
reading". The manufacturer states this specification is incorrect. The instrument specification should be
"± 2 °C dewpoint". All calibration results were less than ± 1 °C dewpoint.

The Test Plan specified a reasonableness check to be performed on the moisture analyzer. The field team
leader collected two sales gas samples and determined the moisture content length-of-stain ("Draeger"
brand) tubes. The results were as follows:

Table 3-4. Comparison Between Length-of-Stain Moisture Content and Analvzer Reading



Draeger Tube Result

Analyzer Reading

Difference

Time

mg/mL

lb/mmscf

lb/mmscf

%

lb/mmscf

15:32

0.05

3.12

1.26

248

1.86

19:58

0.10

6.24

1.13

552

2.56

Average

0.08

4.68

1.20

400

2.21

It is evident that this reasonableness check is not a valid cross-check of the instrument's performance.
This is understandable because Draeger specifies that the method standard deviation for mid-range
readings (i.e., 0.5 mg/L) is ± 15 to 20 percent of reading. The method detection limit is 0.05 mg/L and, at
small concentrations, the percentage errors can become very large.

3.2.2. Glycol Circulation Rate

The test plan specified a maximum glycol circulation rate error of 1.0 percent. A reasonableness check
indicated that the site's flow meter output did not agree with the ultrasonic flow meter within the 2
percent specified in the Test Plan. The site average lean glycol flow rate for a one-hour comparison test
was 5.14 gpm while the GHG Center's flow meter reported 3.83 gpm (a difference of 34.6 percent). The
GHG Center calculated the pump's theoretical flow capacity at 4.13 gpm based on the manufacturer's
specifications and assuming a 95 percent efficiency. This agrees very closely with the actual
instantaneous ultrasonic flow meter measurements taken during steady-state operations. The ultrasonic
flow meter is therefore the source of the reported glycol circulation rates.

The manufacturer calibrated the GHG Center's ultrasonic flow meter on October 11, 2002. Lab
personnel subjected the instrument to a four-point NIST-traceable calibration using 1.9-inch carbon steel
pipe. The calibration range varied between 10.3 and 50.6 gpm. The error at 10.3 gpm, which is closest to
the flow rates observed during testing, was 0.4 percent of reading. This value is assigned as the error
achieved, which satisfies the 1 percent goal.

3-7


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3.2.3. Makeup Natural Gas Flow Rate

The Test Plan specified a 5-point calibration of the makeup natural gas meter to be within ± 1 percent.
The manufacturer's calibration certificate dated February 7, 2002, shows that-at from 20 to 100 percent
of the meter's design capacity of 1500 actual cubic feet per hour (acfh)-maximum error was ±0.8
percent.

The field team leader collected three makeup natural gas samples to determine if significant BTEX was
entering the system through that gas stream. This could bias the HAP destruction efficiency results.
Empact Analytical Systems, Inc. (Empact), performed the extended natural gas analysis.

The Test Plan specified that the lab would calibrate the GC/FID prior to each sample analysis, perform
duplicate injections, and analyze each sample "in duplicates to determine total measurement error"
(Section 3.4). Empact personnel have stated that the analysts did not perform these steps as described.
This lab employed the ASTM D6730 method for detailed hydrocarbon analysis. The method requires
two GC machines: (1) the primary for major gas constituents (including non-hydrocarbons) and (2) the
secondary for the selected HAPs.

Analysts checked the primary GC with a certified standard daily. The high heating value response must
be within 1.0 percent of the standard. They then compared the two systems' response to the pentane in
the samples. Identical response implies that the two systems were responding similarly. Analysts then
entered the method's published reference factors for the selected HAP components to the secondary
machine. The secondary GC was not directly challenged with certified standards.

The laboratory's procedure did not conform to the Test Plan, so the GHG Center is unable to determine if
the laboratory met the + 5.0 accuracy goal. This accuracy was to have been shown by duplicate injections
of a certified standard, which the laboratory did not perform. In addition, the laboratory records for the
primary GC's certified standard challenge, the pentane cross-responses, and how they relate to overall
accuracy are not available. These omissions, however, have minimal effect on the HAPs destruction
efficiency because of the low makeup natural gas flow rates observed during the test runs.

The Test Plan specified that makeup natural gas BTEX could significantly impact HAPs destruction
efficiently only if concentrations exceeded 10,000 ppm. The laboratory results in Appendix D show that
makeup gas BTEX as 310 ppm or less for all three samples. Even if BTEX had equaled 10,000 ppm,
total BTEX entering the burner would have been very low as shown by the following calculations:

•	BTEX mass per volume per ppm (assuming equal proportions of all constituents) = 3.90
mg/m3 per ppm [11], or 2.435 x 10-7 lb/ft3 per ppm;

•	Total BTEX at 10,000 ppm = 2.44 x 10-3 lb/ft3;

•	BTEX inputs to the burner, at 1.37 scfh (the average makeup natural gas flow rate) = 3.34
x 10"3 lb/h.

It is highly unlikely that this 3.34 x 10"3 lb/h of BTEX would have been unaffected as it passed through
the combustion zone. The non-detectable BTEX concentrations in the stack support this conclusion. If
all the BTEX had passed through and up the stack intact, the total HAPs escaping from the system would
have been (Table 2-5):

•	0.02 lb/h from the wastewater,

•	0.0013 lb/h in the stack gas, and

•	0.0034 lb/h in the makeup natural gas passed through the combustion zone to the stack.

3-8


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In this case, destruction efficiency would have been 0.0247/9.09, or 99.73 percent, as compared to the
99.74 percent reported in Section 2.3.2. This analysis, then, indicates that the QA/QC discrepancies
described here do not significantly affect the test results.

3.2.4. Reboiler Stack Emissions

EPA reference method requirements form the basis for the DQOs specified in the test plan. Each method
specifies sampling and calibration procedures and data quality checks. This ensures collection of run-
specific instrument and sampling system drift and accuracy data throughout the emissions tests. The
data quality indicator goals required to meet the DQOs consisted of an assessment of sampling system
error (bias) and drift for NOx and THC, bias and drift for CO, C02, and 02, and GC/FID calibration for
HAPs. The following subsections discuss the achieved goals as presented in Tables 3-2 and 3-3.
Appendix B summarizes all calibration, linearity, bias, and drift results.

3.2.4.1.	NOx and THC

Test personnel performed NOx and THC sampling system calibration error tests prior to each test run.
All calibrations employed EPA Protocol No. 1 calibration gases. The four NOx and THC calibration
gases were zero, 25, 45, and 85 to 90 percent of span.

Table 3-2 shows that the system calibration error goal for NOx was ± 2.0 ppm. The maximum actual
measured error was precisely this value. The maximum system error was ±2.0 ppm for THC which is
less than the ± 5.0 ppm goal.

Test operators established the NOx analyzer's linearity at the beginning of the test day. Its span was 0 to
100 ppm. The results shown in Appendix B indicate excellent instrument linearity with calibration errors
of 0.94 percent of span or less.

System response to the zero and mid-level calibration gases provided a measure of drift and bias at the
end of each test run. The maximum sampling system drift was 0.51 ppm for NOx and 0.67 ppm for THC,
which were both below the method's maximum allowable drift. Testers also performed a NOx converter
efficiency test as described in Section 3.5 of the test plan. The converter efficiency was 99.2 percent,
which exceeds the 98-percent goal specified in Table 3-3.

3.2.4.2.	CO, C02 and 02

CO, C02, and 02 drift and bias checks were similar to those described for NOx and THC. Maximum drift
was 1.5 percent of span for CO, 0.6 percent of span for C02, and 0.9 percent of span and 02. All test
runs, therefore, met the drift and bias goals.

3.2.4.3.	HAPs

The test plan specified EPA Method 18 for determining stack gas organic concentrations. Test operators
injected calibration gas standards into the GC to establish a concentration standard curve prior to sample
analysis. The operator repeated the injections until the average of all desired compounds from three
separate injections agreed to within 5.0 percent of the certified value. Appendix B summarizes the
results. The acceptance criterion was met for all compounds.

3-9


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The analysts injected the mid-range standard to quantify instrument drift at the completion of each test.
The analyst would repeat the calibration process used for the average of the two calibration curves to
determine concentrations if he observed a variance larger than 5.0 percent. Appendix B shows that no
variance was more than 5.0 percent.

Method 18 also specifies a recovery study. The analyst checked the entire sampling system with a mid-
level calibration gas. Repeated injections were analyzed until the area counts of the desired compounds
from three separate injections agreed to within 5 percent of their average. The difference between the
average response from the gas injected through the probe and injected directly must be less than 10
percent. All recoveries conformed to this specification (Appendix B).

3.2.4.4.	Moisture Measurement

Cubix calibrated the dry gas meter used for moisture testing prior to field use in accordance with EPA
methodology. Testers also conducted a post-test calibration check with a primary standard bell prover.
The pre- and post-test calibrations differed by less than 5.0 percent as required by the reference method.

3.2.4.5.	Emission Rate Measurement Error

The test plan's DQO for mass emission rate was ± 7.0 percent for all pollutants. The basis for this is the
allowable concentration measurement errors compounded with the ± 5.0 percent stack flow rate error.
The test plan based each pollutant's concentration error on that analyzer's full-scale reading. The test
plan also describes how each analyzer error contributes to the overall emission rate error.

An example follows: Assume the stack flow rate is 10,507 dry standard cubic feet per hour (dscfh) and
the NOx concentration is equal to the analyzer's 100 ppm span. Pollutant mass flow rate is the
concentration multiplied by the exhaust stack flow rate (Eqn. 1, Section 2.3.1). The corresponding NOx
emission rate is 0.125 lb/h. Seven percent of this is 0.0088 lb/h, so the NOx lb/h determination must be
accurate to ± 0.0088 lb/h to meet this DQO. Table 3.1 summarizes the planned and achieved emission
rate DQOs for all the pollutants.

The stack flow measurement methods specify pre- and post-test thermocouple calibrations at the average
stack gas temperature, as referenced to a NIST-traceable thermometer. The thermocouple and reference
thermometer readings must be within 1.5 percent of each other to be acceptable. This temperature
measurement error, combined with the Type-S pitot calibration, stack gas moisture measurement, and
composition uncertainties yield an overall ±5.0 percent (of reading) volumetric flow rate measurement
error [12],

The highest NOx, CO, THC, and HAP measurement errors were 2.0 ppm, 1.2 ppm, 2.0 ppm, and 0.6
ppm, respectively. Propagation of these errors with the 5.0 percent stack flow rate error results in an
emission rate error to be 0.0048 lb/h or less in all cases. Table 3-1 shows that the tests met DQOs for all
criteria and hazardous pollutants.

3.2.5. HAP Destruction Efficiency

The test plan specified that HAP destruction efficiency measurement error must be less than 0.5 percent.
The plan also describes how actual error achieved requires propagation of multiplicative and additive
concentration and flow rate measurement errors.

3-10


-------
The achieved error for each measurement (summarized in Table 3-5) yields an overall destruction
efficiency error of 0.01 percent absolute percentage units. The absolute error is relatively small because
the total error for HAPemitted and HAPm are very small, or ± 0.173 ± 0.0003 lb/h, respectively. These tests,
therefore, met the DQO for HAP destruction efficiency.

3.2.5.1. Liquid Analysis Data Quality

The laboratory developed pre- and post-test calibration curves for each HAP constituent using a minimum
of three calibration standards. The lab analyzed all calibration levels in duplicate with required agreement
within 5.0 percent of the mean of the two injections. Calibration levels bracketed the concentrations of
the lean glycol, rich glycol, wastewater, and condensate samples.

Lab personnel performed duplicate sample injections. The concentration report is the average of the two
injections. Table 3-6 summarizes the highest percent difference observed for lean glycol, rich glycol, and
condensate samples. The percent difference for all samples was less than 5 percent, which met the
specified goal.

3-11


-------
Table 3-5. Destruction Efficiency Error Determination



Measurement

Avg.
Result

Measurement Error

Source / Comment

Relative
(%)

Absolute"

HAPsin
Lean Glycol
Stream

Flow Rate

Mean

gpm

3.753

±0.4

±0.015

Accuracy of ultrasonic flow meter

Concentration

Cllean

lb/gal

0.002

±25.25

± 0.0004

Weighted average lean glycol
concentration error for all HAP
constituents

Mass Emission
Rate

HAPiem

lb/h

0.368

±25.25

±0.093

Error propagation for multiplication
function

HAPsin
Rich Glycol
Stream

Flow Rate

Vrich

gpm

3.912

±0.9

±0.035

Error for lean glycol flow rate plus 0.5%
error assigned to other measurements
(e.g., water content, density)

Concentration

C||L||

lb/gal

0.040

± 1.25

±0.001

Weighted average rich glycol
concentration error for all HAP
constituents

Mass Emission
Rate

HAPrich

lb/h

9.462

± 1.54

±0.145

Error propagation for multiplication
function





HAPta

lb/h

9.094

± 1.90%

±0.173

Error propagation for subtraction
function

HAPsin
Wastewater

Flow Rate

^Wastewater

gpm

0.106

±0.6

±0.0006

Assigned as the 95%-confidence
interval of wastewater discharge rate

Concentration

p

^Wastewater

lb/gal

0.003

±0.99

±0.0000

Weighted average concentration error
for all HAP constituents in wastewater

Mass Emission
Rate

HAPwastew

ater

lb/h

0.022

± 1.16

±0.0003

Error propagation for multiplication
function

HAPsin
Condensate3

Flow Rate

^Condensate

gpm

0.048

±0.6

±0.0003

Assigned as the 95%-confidence
interval of wastewater discharge rate

Concentration

^Condensate

lb/gal

5.693

± 10.00

±0.569

Weighted average concentration error
for all HAP constituents in condensate

Mass Emission
Rate

I IA I\; , 11 ] d:J 1 ]

sate

lb/h

16.409

± 10.02

± 1.643

Error propagation for multiplication
function

HAPsin
Stack

Flow Rate

Vstack

dscfh

10,507

±5.0

±525

Assigned as specified in reference
method

Concentration

C stack

ppm
tMW

57.469

± 1.07

±0.613

Weighted average GC calibration error
for all HAP constituents in condensate

Mass Rate

HAP Stack

lb/h

0.002

±5.11

±0.0001

Error propagation for multiplication
function



HAP,.,.,

lb/h

0.023

± 1.15

±0.0003

Error propagation for addition function

Intermediate Calculation: HAPemitted/HAPin



0.00256

+ 2.21

0.0000566

Error propagation for division function

HAP Destruction Efficiency | DE

%

99.74

± 0.00567c

0.0000566

Error propagation for subtraction function

a Not used to compute destruction efficiency because HAPs contained in the condensate products is assigned to be controlled.
b See right-most "Measurement" column for units.
c Rounds to + 0.01%.

Table 3-6. Maximum Percent Difference in Duplicate Injection Results



n-Hexane

Benzene

Toluene

Ethylbenzene

m- and p- Xylene

o-Xylene

Lean Glycol

0.2%

4.5%

4.2%

NA

3.6%

NA

Rich Glycol

2.9%

1.5%

1.4%

1.7%

1.4%

1.3%

Condensate

2.0%

1.3%

1.1%

1.1%

1.3%

1.1%

3-12


-------
The laboratory did not perform duplicate injections of the wastewater samples. The analyst prepared and
analyzed a duplicate aliquot for the first sample from each test run with required agreement within 10.0
percent for each analyte. The detailed lab report shows that all wastewater purge-and-trap analyses met
this criterion.

The laboratory also selected one sample from each batch of lean glycol, rich glycol, and wastewater
samples for duplicate preparation and analysis. Appendix C presents the results. The percent difference
between the rich glycol initial and duplicate preparation concentrations ranged between 1.5 and 2.3 for
the six HAP constituents analyzed. The percent difference was much greater (16.6 to 45.1 percent) for
the lean glycol sample. The reason for the high error is unclear, but because the lean glycol concentration
levels were very small, they do not contribute significantly to the overall lean HAP mass flow rate error.
The duplicate analysis results for the wastewater sample were similar to rich glycol sample.

The benzene, toluene, and m, p-Xylene results presented in Appendix C-2 show large discrepancies
between the duplicate lean glycol sample preparations. The analytical laboratory (Enthalpy Analytical,
Durham, NC) attributes this to inhomogeneity in the liquids. Benzene and other HAPs do not necessarily
mix uniformly in TEG and the mixtures can stratify easily. The laboratory had observed similar
differences for samples taken before the test campaign. These differences also appeared in the rich glycol
and wastewater duplicate preparations and analyses in the pretest samples. The matrix spike and recovery
results imply that the laboratory properly executed the sample dilutions and other procedures.

Analysts spiked a 3.75-ml aliquot of a lean glycol sample and 3.5-ml aliquots of a rich glycol and a
condensate sample with known amounts of the target analytes. They then analyzed the spiked samples.
Appendix C summarizes the spike amounts and the resulting recovery efficiencies. All spike recovery
efficiencies were between 88.1 and 109 percent.

The lab prepared a stock solution containing 80 ig/mL of all six wastewater analytes. The analyst added
25 uL of this prepared solution to 2.5 mL of a 1001-fold dilution of sample 1 (Run 1). Appendix C
summarizes the results. The recovery efficiencies ranged from 104 to 122 percent.

The GHG Center submitted three "blind" audit samples for analysis. Each contained benzene
concentrations similar to those expected in the glycol and condensate samples. Table 3-7 summarizes the
percent difference between the reported and certified concentrations. The results suggest that the
laboratory under-reported benzene in the rich and lean glycol and over-reported it in the condensate. This
could have affected the mass balance discussed in Section 2.3.2.

Table 3-7. Benzene Audit Results

Blind
Sample ID

Certified
Concentration

As-Analyzed
Concentration

Percent
Difference

ig/mL

ig/mL

B1090309

200

187

-6.5

B3010280

2,000

1,799

-10.1

B3010279

20,000

20,833

4.2

3-13


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3-14


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4.0 TECHNICAL AND PERFORMANCE DATA SUPPLIED
BY ENGINEERED CONCEPTS, LLC

Note: This section provides an opportunity for Engineered Concepts, LLC to provide additional
comments concerning the OLD and its features not addressed elsewhere in this report. The GHG Center
has not independently verified the statements made in this section.

The QLD process can be incorporated by retrofitting dehydrators presently installed in the field or by
integrating the process into the design of new dehydrators. Either package will produce a hydrocarbons
emissions control system eliminating the need for auxiliary equipment such as an effluent condenser, flare
stack, or thermal oxidizer.

The QLD process covered by this report utilizes a condensing water exhauster to super-dry the process
glycol. This allows high dew point depressions and efficient sales gas dehydration. The condensing
water exhauster technology replaced the gas stripping employed for this purpose in the previous reboiler
used at this site. Elimination of the gas stripping reduced gas consumption by more than 27 mscfd. Total
still column vent emissions from the previous reboiler, including all of the gas used for gas stripping,
were collected and routed to a thermal oxidizer.

For the QLD process to operate properly, the burner system must be able to throttle over the entire firing
range. The QLD system uses specially designed throttling burners first introduced by Olman Heath
Company. For new dehydrators incorporating the QLD system, throttling burners will be supplied with
the package. On retrofit dehydrators the existing burners may need to be replaced with throttling burners.

Because the QLD process collects and compresses the hydrocarbons, these vapors are fed directly into the
standard reboiler fuel train with only minor modifications. Alternately, the vapors can also be routed
through a low pressure fuel line to other equipment at the site. This is a significant improvement over
systems that collect the vapors at or near atmospheric pressure.

The host site had electricity available. Where electricity is not available (such as at remote wellhead
locations) the QLD system incorporates an electric engine/generator set capable of producing 5 kW of
240/480 VAC power. The engine/generator set is rated for 40,000 hours of continuous service and uses
natural gas for fuel.

The condensing water exhauster and side stream glycol cooling are able to save approximately $12,500
natural gas annually (based on $2.00 per mscf). This analysis assumes:

•	TEG concentration of 99.8 percent using Nb=l for a "Stahl" Stripping Column,

•	3 scf stripping gas per gallon of TEG circulated (Gas Processors Suppliers
Association, Eleventh Edition, 1998, Figure 20-65)

The following table illustrates a full analysis of the typical utility consumption and QLD emissions as
compared to a conventional dehydration system.

4-1


-------


Conventional Dehydrator

QLD

Lean TEG circulation rate, gpm (1)

4

4

Reboiler fuel required, Btu per day (1)

(11.8 mm)

(13.4 mm)

Pump used

Kimray

electric

Electric

Make-up fuel consumed, Btu per day NHV (1) (2)

0

(6.5 mm)

negligible (3)

Gas required to power Kimray pump, scfd (4)

32,256

0

0

Excess flash gas NHV, Btu per day (5)

(40.1 mm)

0

0

Gas stripping required, scfd (6)

17,280

17,280

0

Gas stripping NHV, Btu per day

(19.3 mm)

(19.3 mm)

0

Power required for pump, hp

0

3.8

3.8

Power required for circ pump, hp

0

0

6.3

Power required for fan cooler, hp

0

0

10

Total power consumed by motors, hp

0

3.8

20.1

Total energy consumed by motors, Btu / day (7)

0

(0.8 mm)

(4.1 mm)

Condensate recovered, BPD

negligible (8)

negligible (8)

2.3

Condensate recovered, Btu per day

negligible

negligible

11.4 mm

Net energy consumed by process, Btu per day (9)

(71.2 mm)

(31.9 mm)

(6.1 mm)

Hydrocarbon emissions, lbs per day (10)

3437

1715

negligible (11)

(1)	Based on assumed reboiler firing efficiency of 50 percent and for design basis of 25 mmscfd at
1000 psig, 120 °F inlet gas temperature and 99.8 percent TEG by weight. Figures are based on
BRE Prosim modeling program results.

(2)	Assumes that gas from flash separator is routed to reboiler burner. Flash gas would include gas
used to power Kimray pump (if applicable).

(3)	QLD required essentially zero makeup fuel from the plant system.

(4)	Kimray power gas is 5.6 scf per gallon at 1000 psig.

(5)	Flash gas in excess of that required to fire the reboiler.

(6)	Stripping gas rate is 3 scf per gallon based on using packed gas stripping column and 99.8 percent
wt TEG.

(7)	For QLD, assume 20.1 total horsepower, 24-hour operation, 2545 Btu per horsepower, and 30
percent efficiency. Total energy usage is:

4.1 mmBtu per day = 20.1 * 24 * 2545

0.3 * 1000000

(8)	For modeling purposes only it was assumed that a condenser was installed on still column effluent
outlet and a condenser temperature of 120 °F.

(9)	Summed heat values: Condensate minus the sum of excess flash gas, stripping gas, reboiler fuel,
and pump power consumption

(10)	Still column emissions after condenser plus excess gas from flash separator. Includes all
hydrocarbon emissions (BTEX, VOCs, HAPs, methane etc).

(11)	Miniscule quantities of hydrocarbons were dissolved in the condensed water phase.

It is apparent that QLD outperforms a conventional dehydrator based on energy consumption and

emissions.

The QLD system designers estimated that a conventional dehydrator at this site would require a Kimray

PV -type gas-assisted glycol pump. The Kimray Oil and Gas Equipment Controls Catalog, Section G,

4-2


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Page 8, states that this pump would use 5.6 scf of gas per gallon of glycol circulated at 1000 psig. At four
gallons per minute, total daily usage would be:

32256 scfd = 5.6 * 4 * 60 * 24

Annual gas savings, based on $2.00 per mscf, would be:

$23546 = (32256/1000) * 2.00 * 365.

This contrasts with the $14,600.00 estimated in Section 1.2. The reader should note that this analysis is
conservative because natural gas prices have recently risen to above $5.00/mscf in some areas.

4-3


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4-4


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5.0

REFERENCES

[1]	Methane Emissions from the Natural Gas Industry: Volume 2, Technical Report; EPA-6.00/R-96-
080b, U.S. Environmental Protection Agency, National Risk Management Research Laboratory:
Research Triangle Park, NC, Jun. 1996.

[2]	Methane Emissions from the Natural Gas Industry: Volume 1, Executive Summary, EPA-6.00/R-96-
080a, U.S. Environmental Protection Agency, National Risk Management Research Laboratory:
Research Triangle Park, NC, Jun. 1996.

[3]	National Emissions Standards for Hazardous Air Pollutants for Source Categories: Oil and Natural
Gas Production and Natural Gas Transmission and Storage—Background Information for Proposed
Standards', EPA-453/R-94-079a, U.S. Environmental Protection Agency: Office of Air Quality Planning
and Standards, Research Triangle Park, NC, Apr. 1997.

[4]	Preliminary Assessment of Air Toxic Emissions in the Natural Gas Industry, Phase I, Topical Report,
GRI-94/0268, Gas Research Institute: Chicago, IL, 1994.

[5]	National Emission Standards for Hazardous Air Pollutants for Source Categories, Subpart HH—
National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production
Facilities', 40 CFR 63, U.S. Environmental Protection Agency: Washington, DC, Jun. 17 1999.

[6]	Test and Quality Assurance Plan—Engineered Concepts, LLC Quantum Leap Dehydrator, Southern
Research Institute GHG Gas Technology Center: Research Triangle Park, NC, Jun. 2002.

[7]	GRI's Environmental Program in Glycol Dehydration of Natural Gas;
www.gastechnologv.org/pub/oldcontent/tech/ets/glydehy/glytop.htm. Gas Technology Institute: Chicago,
IL, Mar. 2002.

[8]	Atmospheric Rich/Lean (ARL) Method for Determining Glycol Dehydrator Emissions; Gas Research
Institute: Chicago, IL, Mar. 1995.

[9]	GRI Topical Report-Glycol Dehydrator Emissions: Sampling and Analytical Methods and Estimation
Techniques, Volume 1, Appendix A: Atmospheric Rich/Lean Glycol Method Standard Procedure; Gas
Research Institute: Chicago, IL, 1995.

[10]	Glycol Dehydrator Emissions: Sampling and Analytical Methods and Estimation Techniques; Gas
Research Institute: Chicago, IL, 1995.

[11]	Pocket guide to Chemical Hazards; U.S. Department of Health and Human Services: Washington,
DC, 1990.

[12]	Shigehara, R.T., Todd, W.F., and W.S. Smith. Significance of Errors in Stack Sampling
Measurements; presented at the annual meeting of the Air Pollution Control Association: St. Louis, MO,
1970.

[13]	Skoog, Douglas A., and Donald M. West. Fundamentals of Analytical Chemistry, 4th Edition; CBS
College Publishing: Philadelphia, PA, 1982.

5-1


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5-2


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APPENDIX A

Appendix A-1. Rich Glycol Flow Rates	

A-l


-------
Appendix A-l

Rich Glycol Flow Rates

The ARL method involves:

•	Measurement of chemical concentrations in the lean glycol (lb/gal)

•	Measurement of chemical concentrations in the rich glycol (lb/gal)

•	Measurement of the lean glycol volumetric flow rate (gpm)

•	Calculating the chemical concentration differences (lb/gal)

•	Multiplying the concentration difference by the lean glycol flow rate to yield the
chemical's mass flow rate (lb/min)

The calculated mass flow rate for each compound is assigned to be the same in both streams (rich and
lean). This approach assumes that mass contribution from water present in the rich glycol is negligible in
the overall mass balance. The rich glycol volumetric flow will always be slightly greater than the lean
glycol flow because of added water, BTEX, and other hydrocarbons absorbed from the natural gas stream.

The reboiler and still column in the QLD system remove the diluents (thereby producing the lean glycol)
upstream of the flow measurement device. The ARL method, therefore, slightly under-reports actual
mass flow for the chemicals of interest because it assumes that the lean and rich glycol flows are
identical.

A more accurate approach is to estimate the rich glycol flow rate by correcting for the chemical species
present in the rich stream. In fact, the GRI-GLY Calc dehydrator emissions modeling program includes
such a correction. The key to implementing this approach is that while the water, BTEX, and
hydrocarbon concentrations are different between the rich and lean glycol flows, the stream's TEG mass
content does not change (except under process upset conditions). The following glycol stream properties
were obtained to quantify the rich glycol flow rate:

•	Rich and lean glycol density (g/ml)

•	Rich and lean glycol water content (weight percent)

•	Rich and lean glycol total hydrocarbons content (ig/ml)

This flow rate is used in Equation 3 to more accurately report HAPs entering the QLD system boundary.
The following paragraphs discuss the analysis, provide an example, and present the test results.

The first step quantified the TEG mass flow rate throughout the system. The lean glycol mass flow rate
was:

m, =V, p,	Eqn. A-l

lean lean ~ lean	i

where:

mlean = lean glycol mass flow rate (ig/min)

Vkan = lean glycol volumetric flow rate (measured by the Ultrasonic meter),

gpm x 3785.41 = (ml/min)
plean = lean glycol density (i g/ml)

The lean glycol mass flow rate represented the sum of the water, hydrocarbons, and TEG mass flows.
The TEG mass flow rate was therefore:

A-2


-------
m teg— ™ lean (™H20Jean + ™mCJean )

Eqn. A-2

where:

mTEG =	TEG mass flow rate (ig/min)

™ mo jean	= water mass flow rate in the lean glycol (i g/min)

Mwcjean	= lolal hydrocarbon mass flow rate in the lean glycol (ig/min)

The laboratory reported weight percent water and total hydrocarbon mass per unit volume. These data,
combined with the measured lean glycol volumetric flow rate, yield the water and total hydrocarbon mass
flow rates as follows:

H2O Jean

(H 0	^

n 2 "wt%Jean

ioo u

V,

lean

Eqn. A-3

= {mclean)vle,

Eqn. A-4

where:

h7o>

2^wt%,lean

= lean glycol water content (weight percent)

mc,

= concentration of hydrocarbons in lean glycol (i g/ml)

BTEX and hexanes constitute the majority of these hydrocarbons. All test runs showed that their area in
the lean glycol sample chromatograms averaged from 58.3 to 72.1 percent of all hydrocarbon peaks
recorded. The laboratory did not speciate other hydrocarbons, but they state that the FID response to
these hydrocarbons will be linear. Therefore, 176 ig/ml of BTEX and hexanes with an area percent of
62.2 yields total hydrocarbons of 1/0.622 x 176, or 282 ig/ml. Analysts computed the average area
percent of the BTEX and hexanes for each test run and applied the concept according to the following
equations

=

ZHAPle,

Area %,

Eqn. A-5

where:

IHAPlean = summation of BTEX and hexanes for each sample, average value

for all samples in each run (ig/ml)

Area%iean = average BTEX and hexanes area percent for all samples in each

TEG mass flow rate is:

™TEG — lean

(	H (1	^

11 2^wt%Jean	YJJCJ

f^lean	100	^^lean	lean

Eqn. A-6

Rich glycol volumetric flow rate was derived from the following equations:

^ TEG,rich rich TEG,rich

Vrichpri,

Eqn. A-7

A-3


-------
m.

Vrich = —1222		Eqn. A-8

^ TEG,rich Prich

where:

cteg, rich = TEG concentration in the rich glycol (proportion)

= rich glycol mass flow rate (ig/min)

Vrlch = rich glycol volumetric flow rate, ml/min -7- 3785.41 = (gpm)
prich = rich glycol density (ig/ml)

Rich glycol TEG concentration was:

^	H2^wt%,rich ^	\- t

Prich	inn Prich	rich

cteg,rich =	Eqn. A-9

Prich

where:

H20wP/orich = rich glycol water content (weight percent)
mcnch = summation of all rich glycol hydrocarbons (i g/ml)
rich = rich glycol density (ig/ml)

The HHC rich value in equation A-4 was the average of the summed BTEX and hexanes corrected to the
area percent hydrocarbons.

Substituting Equation A-9 into Equation A-8 yields a rich glycol volumetric flow rate of:

Vnch =	Hn mTE°		Eqn. A-10

^	ii 2^wt%,rich ^	^r7/_,

Prich	|qq Prich ~ rich

A-4


-------
The following table provides a sample calculation for Run 1, taken from the field data.

Table A-l. Rich Glyco

Volumetric Flow Rate Calculation for Run 1

Parameter

Units

Value

^lean

gpm

3.7688

^'lean

ml/min

14266.4

Plean

ig/ml

1.125 x 106

H20wt%,lean

wt%

0.552

UUP,

lean

ig/ml

176

Area%iean

area%

62.2

mc,

lean

ig/ml

282

rh

TEG

ig/min

1.596x 1010

Prich

ig/ml

1.119xl06

H20 Mit%rich

wt%

3.25

UUP

rich

ig/ml

5011

Area%nch

area%

80.1

mc

rich

ig/ml

6256

^'rich

gpm

3.916

This example shows that the additional mass of water and hydrocarbons results in the rich glycol flow
rate to be about 4 percent higher than the lean glycol flow rate. Table A-2 presents the results for each
test run.

A-5


-------
Version 1.2-August 13, 2003	DRAFT

Do not cite, quote, use, or distribute without written permission from GHG Center

Table A-2. Determination of Rich Glycol Flow Rates

Runl

VLean

VLean



RllOLean RllOLean



H2C>Lean

HAPLean

HAP

HC

niTEG



RllORich RllORich



H2C>Rjch

HAPRich

HAP

HC

VRich

















Area%Lean

T OtalLean













Area"...,.,-.

T otalRich



Sample#

gpm

ml/min

SamplelD

g/ml ig/ml

Sample

wt%

ig/ml

AreaPct

ig/ml

ig/min

Sample

g/ml ig/ml

Sample

wt%

ig/ml

AreaPct

ig/ml

gpm











ID











ID



ID











la









2001

0.486

194

70.0









1001

3.35

5357

80.0





2





4002

1.125

2002

0.512

154

58.3





3002

1.119

1002

3.31

4644

79.9





2a









2003

0.539

189

58.4









1003

3.05

5547

80.4





3









2021

0.672

166











1021

3.27

4497







Averages

3.7688

14266.4



1.125 1.1250



0.552

176

62.2

282

1.596



1.119 1.1190



3.25

5011

80.1

6256

3.9161









x 10 6











x 10 10



x 10 6













Run 2

VLean

VLean



RhOLean RhOLean



H2C>Lean

HAPLean

HAP

HC

niTEG



RllORich RllORich



H2C>Rjch

HAPRich

HAP

HC

VRich

















Area%Lean

T OtalLean













Area"...,.,-.

T otalRich



Sample#

gpm

ml/min

SamplelD

g/ml ig/ml

Sample

wt%

ig/ml

AreaPct

ig/ml

ig/min

Sample

g/ml ig/ml

Sample

wt%

ig/ml

AreaPct

ig/ml

gpm











ID











ID



ID











la









2005

0.601

224

61.8









1005

3.38

4435

78.3





2





4006

1.136

2006

0.625

203

57.7





3006

1.12

1006

3.2

4608

79.7





2a









2007

0.626

198

60.7









1007

3.13

4187

81.1





3









2008

0.564

201

62.5









1008

3.12

4495

79.2





Averages

3.6035

13640.8



1.136 1.1360



0.604

206

60.7

340

1.540



1.120 1.1200



3.21

4431

79.6

5569

3.7716









x 10 6











xlO10



x 10 6













Run3

VLean

VLean



RllOLean RhOLean



H2C>Lean

HAPLean

HAP

HC

niTEG



RllORich RllORich



H2C>Rjch

HAPRich

HAP

HC

VRich

















Area%Lean TOtalLean













Area"..,,..

TotalRich



Sample#

gpm

ml/min

SamplelD

g/ml ig/ml

Sample

wt%

ig/ml

AreaPct

ig/ml

ig/min

Sample

g/ml ig/ml

Sample

wt%

ig/ml

AreaPct

ig/ml

gpm











ID











ID



ID











la









2009

0.575

201

61.8









1009

3.11

5096

79.1





2





4010

1.132

2010

0.684

203

58.8





3010

1.122

1010

3.08

4928

78.6





2a









2011

0.564

193

72.1









1011

3.24

4968

79.1





3









2012

0.583

228

59.9









1012

3.11

5118

81.3





Averages

3.8871

14714.1



1.132 1.1320



0.602

206

63.2

326

1.655



1.122 1.1220



3.14

5027

79.5

6322

4.0466









x 10 6











x 10 10



x 10 6













6


-------
APPENDIX B

Emissions Testing QA/QC Results

Appendix B-l. Summary of Reference Method Calibration Error Determinations	B-2

Appendix B-2. Summary of Reference Method System Bias and Drift Checks	B-3

Appendix B-3. Summary of GC/FID Calibration Results	B-4

B-l


-------
Appendix B-l. Summary of Daily Reference Method Calibration Error Determination





Range

Value

Response

Difference

Calibration

Date

Gas

(ppm for NOx, CO, and THC; % for O2 and CO2)

Error (% of Span)*

4/30/03

NOx

100

0.0

0.09

0.09

0.09

(Runs 1 - 3)





25.1

25.19

0.09

0.09







44.6

44.67

0.07

0.07







84.5

85.44

0.94

0.94



CO

100

0.0

0.00

0.00

0.00







24.9

23.27

1.63

1.63







45.3

43.87

1.43

1.43







90.8

88.86

1.94

1.94



co2

25

0.0

0.03

0.03

0.12







11.96

11.72

0.24

0.96







4.00

3.81

0.19

0.76







20.0

19.83

0.17

0.68



o2

25

0.0

0.02

0.02

0.08







11.97

12.12

0.15

0.60







4.00

4.10

0.10

0.40







21.0

21.28

0.28

1.12

Error (% of cal qas)*



THC

100

0.0

0.47

0.47









25.5

25.17

0.33

1.29







45.7

44.63

1.07

2.34







89.0

90.3

1.30

1.46

* Allowable calibration error is 2% of span.

B-2


-------
Appendix B-2. Summary of Reference Method System Bias and Drift Checks

Analyzer Spans: NOx = CO = THC = 100 ppm, C02 = 02 = 25%



Initial



Run Number



Cal

1

2

3

NOxZero System Response (ppm)

0.08

0.59

0.89

0.38

0.09 System Bias (% span)

-0.01

0.50

0.80

0.29

Drift (% span)

na

0.51

0.30

0.51

NOx Mid (Hi) System Response (ppm)

84.01

83.51

83.44

83.84

85.44 System Bias (% span)

-1.43

-1.93

-2.00

-1.60

Drift (% span)

na

0.50

0.07

0.40

CO Zero System Response (ppm)

0.00

0.10

0.10

0.00

0.00 System Bias (% span)

0.00

0.10

0.10

0.00

Drift (% span)

na

0.10

0.00

0.10

CO Mid System Response (ppm)

43.40

44.90

45.10

45.10

43.87 System Bias (% span)

-0.47

1.03

1.23

1.23

Drift (% span)

na

1.50

0.20

0.00

C02 Zero System Response (ppm)

0.30

0.20

0.10

0.10

0.03 System Bias (% span)

1.08

0.68

0.28

0.28

Drift (% span)

na

0.40

0.40

0.00

C02 Mid System Response (ppm)

11.30

11.45

11.30

11.42

11.72 System Bias (% span)

-1.68

-1.08

-1.68

-1.20

Drift (% span)

na

0.60

0.60

0.48

02 Zero System Response (ppm)

0.13

0.20

0.25

0.06

0.02 System Bias (% span)

0.44

0.72

0.92

0.16

Drift (% span)

na

0.28

0.20

0.76

02 Mid System Response (ppm)

12.22

12.22

12.13

12.04

12.12 System Bias (% span)

0.40

0.40

0.04

-0.32

Drift (% span)

na

0.00

0.36

0.36

THC Zero System Response (ppm)

0.00

0.03

0.00

0.00

0.47 System Bias (% span)

-0.47

-0.44

-0.47

-0.47

Drift (% span)

na

0.03

0.03

0.00

THC Mid System Response (ppm)

46.57

46.60

46.00

45.33

44.63 System Bias (% span)

1.94

1.97

1.37

0.70

Drift (% span)

na

0.03

0.60

0.67

Allowable system bias is 5% span, allowable drift is 3% span.

B-3


-------


Appendix B-3.

Summary of GC/FID Calibration Results





pre test low gas

















max dif-

relative

absolute



ref value

inj 1

inj 2

inj 3

avg

diff 1

diff 2

diff 3

ference

error%

error ppm



ppm



















Methane

5.02

549

526

542

539.00

10.00

13.00

3.00

13.00

2.41

0.12

n-Hexane

5.03

3826

3826

4068

3906.67

80.67

80.67

161.33

161.33

4.13

0.21

Benzene

4.9

3984

3984

3736

3901.33

82.67

82.67

165.33

165.33

4.24

0.21

Toluene

4.8

4014

4014

4011

4013.00

1.00

1.00

2.00

2.00

0.05

0.00

Ethylbenzene

4.5

3748

3748

3879

3791.67

43.67

43.67

87.33

87.33

2.30

0.10

o-Xylene

4.8

3558

3558

3507

3541.00

17.00

17.00

34.00

34.00

0.96

0.05

m-Xylene

4.2

3049

3049

3164

3087.33

38.33

38.33

76.67

76.67

2.48

0.10

pre test mid gas

ref value

inj 1

inj 2

inj 3

avg

diff 1

diff 2

diff 3

max dif-

repeatability absolute
% error ppm



ppm







ference





Methane

50.2

5701

5402

5750

5617.67

83.33

215.67

132.33

215.67

3.84

1.93

n-Hexane

50.4

37102

35023

34126

35417.00

1685.00

394.00

1291.00

1685.00

4.76

2.40

Benzene

50.6

35873

37287

36962

36707.33

834.33

579.67

254.67

834.33

2.27

1.15

Toluene

48.7

39496

43519

41503

41506.00

2010.00

2013.00

3.00

2013.00

4.85

2.36

Ethylbenzene

48.7

41149

43781

41972

42300.67

1151.67

1480.33

328.67

1480.33

3.50

1.70

o-Xylene

42.7

37977

41546

39962

39828.33

1851.33

1717.67

133.67

1851.33

4.65

1.98

m-Xylene

45.3

36631

39616

37117

37788.00

1157.00

1828.00

671.00

1828.00

4.84

2.19

pre test hi gas

















max dif-

repeatability

absolute



ref value

inj 1

inj 2

inj 3

avg

diff 1

diff 2

diff 3

%

error ppm



ppm







ference



Methane

100

11384

10821

11900

11368.33

15.67

547.33

531.67

547.33

4.81

4.81

n-Hexane

101

67628

70172

73001

70267.00

2639.00

95.00

2734.00

2734.00

3.89

3.93

Benzene

99.1

71325

74034

72208

72522.33

1197.33

1511.67

314.33

1511.67

2.08

2.07

Toluene

99.2

77633

78861

77587

78027.00

394.00

834.00

440.00

834.00

1.07

1.06

Ethylbenzene

99.2

73475

72497

76150

74040.67

565.67

1543.67

2109.33

2109.33

2.85

2.83

o-Xylene

99.2

73166

71481

74490

73045.67

120.33

1564.67

1444.33

1564.67

2.14

2.12

m-Xylene

99.2

71269

68884

71848

70667.00

602.00

1783.00

1181.00

1783.00

2.52

2.50

post test mid gas

















max dif-

repeatability absolute



ref value

inj 1

inj 2

inj 3

avg

diff 1

diff 2

diff 3

%

error ppm



ppm















ference





Methane

50.2

5975

5789

5764

5842.67

357.33

171.33

146.33

357.33

6.12

3.07

N-Hexane

50.4

36136

37704

36739

36859.67

719.00

2287.00

1322.00

2287.00

6.20

3.13

Benzene

50.6

38482

38248

38099

38276.33

1774.67

1540.67

1391.67

1774.67

4.64

2.35

Toluene

48.7

42821

43477

42730

43009.33

1315.00

1971.00

1224.00

1971.00

4.58

2.23

Ethylbenzene

48.7

44238

44035

43208

43827.00

1937.33

1734.33

907.33

1937.33

4.42

2.15

o-Xylene

42.7

40512

42657

41642

41603.67

683.67

2828.67

1813.67

2828.67

6.80

2.90

m-Xylene

45.3

39301

39630

38877

39269.33

1513.00

1842.00

1089.00

1842.00

4.69

2.12

Overall stack gas HAPs concentration error is an additive function of the individual HAPs concentration
errors. Such errors compound as the square root of the summed individual absolute errors, squared [13],
The following table shows the error propagation for stack gas HAPs. Each individual concentration was
taken as 0.1 ppm because this was the method's lower detection limit. The relative errors, upon which the
absolute errors are based, are taken from the "pre-test low gas" calibrations summarized above.



Stack Gas HAPs Error Propagation





Chemical

Molecular Weight,

PPM

Mass,

Relative Error,

Absolute



lb/lb.mol



ig/m3

Percent

Error, ig/m3

Hexane

86.18

0.1

8.618

4.13

0.3559

Benzene

78.00

0.1

7.800

4.24

0.3307

Toluene

92.00

0.1

9.200

0.05

0.0046

Ethylbenzene

106.17

0.1

10.617

2.30

0.2442

p-Xylene

106.17

0.1

10.617

2.48

0.2633

o-Xylene

106.17

0.1

10.617

0.96

0.1019



Compounded Absolute Error =

square soot (sum [individual error]2)



0.6127

B-4


-------
APPENDIX C

Liquid Analysis QA/QC Results

Appendix C-l. Rich Glycol—Duplicate Sample Preparation and Spike Analysis Results	C-2

Appendix C-2. Lean Glycol—Duplicate Sample Preparation and Spike Analysis Results	C-3

Appendix C-3. Wastewater—Duplicate Sample Preparation and Spike Analysis Results	C-4

Appendix C-4. Condensate—Spike Analysis Results	C-5

Appendix C-5. Rich and Lean Glycol Moisture Content—Duplicate Analysis Results	C-6

C-l


-------
Appendix C-l. Rich Glycol-Duplicate Sample Preparation and Spike Analysis Results



Duplicate Analysis

Spike Analysis

Sami

)le ID

Concentration (na/mL)



Sam

ale ID

Spike
Amount

Catch
Weight -
Native
Amount

Catch
Weight -
Spiked
Sample

0/

/o

Recoverv

Run No.

Sample
No.

Initial

Duplicate

% Dif-
ference

Run No.

Sample
No.

iq

iq

iq

n-Hexane

Run 1

2

107 ND

106 ND

1.5

Run 2

1

35.9

78.9

114

98.1

Benzene

Run 1

'2

1,425

1,454

2.1

Run 2

1

437

861

1334

108.0

Toluene

Run 1

2

2,394

2,443

2

Run 2

1

734

1282

2022

101.0

Ethyl-benz

sne Run 1

2

51.5

52.7

2.3

Run 2

1

19.0

26.2

45.1

99.3

m- and
p-Xylene

Run 1

2

546

558

2.2

Run 2

1

182

277

457

99.1

o-Xylene

Run 1

2

121

124

2.3

Run 2

1

38.4

62.2

100

98.5

ND Non-detect or analytical result below the minimum detection limit (MDL)
J Analytical result between the MDL and the limit of quantification (LOQ)

MDL = 1.00 ug/mL
LOQ = 2.00 ug/mL

C-2


-------
Appendix C-2. Lean Glycol-Duplicate Sample Preparation and Spike Analysis Results



Duplicate Analysis

Spike Analvsis

Sam

Die ID

Concentration (ng/mL)



Sam

ale ID

Spike
Amount

uatcn
Weight -
Native
Amount

uatcn
Weight -
Spiked
Sample

0/

/o

Recoverv

Run No.

Sample
No.

Initial

Duplicate

% Difl

Run No.

Sample
No.

ia

ia

ia

n-Hexane

kun 2

'2

8.00 ND

8.00 ND

0.0

Kun '6

3

2GA

0.0

¦it.t

mu

Benzene

kun 2

2

54.0

8b.4

4t).1

Kun 3

3

DZ4



iuy.u

aa. (

Toluene

kun 2

2

bb.D

W2

4 2.3

Kun 6

6

bl.8

bb.U

11ZU

88.1

Ethyl benzene

kun '2

2

b.O J

8.0

0.0

Kun '6

'6

i>8.0

0.0

24.1

Q1Q

m- and p-

kun 2

2

ID.b

lb.4

Ib.b

Kun 3



2B.U

11.&

3&.b

bZb

o-Xylene

kun 2

2

b.U J

b.U

U.U

Kun 6

6

I'd. b

U.U

24.2

94./

ND Non-detect or analytical result below the minimum detection limit (MDL)
J Analytical result between the MDL and the limit of quantification (LOQ)

MDL = 1.00 ug/mL
LOQ = 2.00 ug/mL

C-3


-------
Appendix C-3. Wastewater-Duplicate Sample Preparation and Spike Analysis Results





Duplicate Analysis

Spike Analysis

Sam

Die ID

Concentrat

ion (na/mlJ



Spike
Amount

Catch
Weight -
Native
Amount

Catch
Weight -
Spiked
SamDle

0/

/o

Recovery

Run No.

Sample No.

Initial

Duplicate

% Dif-
ference

ia

ia

ig

n-Hexane

Run 1

1

801 ND

803 ND

0

200

0

210

105

Benzene

Run 1

1

200,489

198,778

0.9

200

501

745

122

Toluene

Run 1

1

104,976

102,520

2.4

200

262

478

108

Ethyl-benzem

Run 1

1

971 J

880 ND

9.8

200

2.43

211

104

m- and p-Xyk

rie Run 1

1

8,352

8,176

2.1

200

20.9

232

105

o-Xylene

Run 1

1

2,829 J

2,679

5.4

200

7.07

215

104

ND Non-detect or analytical result below the minimum detection limit (MDL)
J Analytical result between the MDL and the limit of quantification (LOQ)

MDL = 2.00 ng
LOQ = 8.00 ng

C-4


-------
Appendix C-4. Condensate Product-Spike Analysis Results



Spike Analysis

Sarrmle ID

Spike
Amount

Catch
Weight-
Native
Amount

Catch
Weight -
Spiked
Sample

%

Recovery

Run No.

Sample
No.

¦g

¦g

¦g

n-Hexane

Run 2

1

35.9

34.2

69.5

98.4

Benzene

Run 2

1

437

721

1195

109.0

Toluene

Run 2

1

734

1326

2071

102.0

Ethyl-bei

izefaen 2

1

19.0

28.6

48.8

106.0

m-and p-

XyfciDft 2

1

182

303

487

101.0

o-Xylene

Run 2

1

38.4

65.9

105

102.0

MDL = 1.00ug/mL
LOQ = 2.0GLig/mL

C-5


-------
Appendix C-5. Rich and Lean Glycol Moisture Content-Duplicate Analysis Results



RICH GLYCOL

% Dif-
ference

LEAN GLYCOL

% Dif-
ference

Sample ID

Moisture Content

Moisture Content

Run No.

Sample No.

Initial

Duplicate

Initial

Duplicate

Run 1

1

3.380

3.310

-1.05

0.487

0.485

-0.21



2

3.100

3.050

-0.81

0.508

0.516

0.78



2a

3.050

3.050

0.00

0.550

0.531

-1.76



3

3.300

3.250

-0.76

0.681

0.664

-1.26

Run 2

1

3.350

3.400

0.74

0.608

0.595

-1.08



2

3.180

3.220

0.63

0.616

0.634

1.44



2a

3.120

3.140

0.32

0.634

0.619

-1.20



3

3.120

3.120

0.00

0.558

0.570

1.06

Run 3

1

3.100

3.130

0.48

0.566

0.584

1.57



2

3.100

3.060

-0.65

0.692

0.676

-1.17



2a

3.240

3.230

-0.15

0.561

0.567

0.53



3

3.080

3.140

0.96

0.589

0.578

-0.94









-0.02





-0.19

NOTE: % Difference = 	—	xlOO -100

^ Average (Initial, Duplicate) J

C-6


-------
APPENDIX D
Pre-Test Makeup Natural Gas Analysis Data

D-l


-------
Appendix D-l. Pre-Test Makeup Natural Gas Analysis

EMPACT ANALYTICAL SYSTEMS, INC

997 US HI WAY 85
BRIGHTON, CO 80603
(303) 637-0150

EXTENDED NATURAL GAS ANALYSIS (*DHA)

PROJECT NO. : 0302069



ANALYSIS NO. :

01



COMPANY NAME : SRI



ANALYSIS DATE:

FEBRUARY 28, 2003



ACCOUNT NO. : P.O. RD307I2

SAMPLE DATE :

FEBRUARY 26,2003



PRODUCER :



TO:





LEASE NO.



CYLINDER NO. :

205



NAME/DESCRIP : MAKE-UP GAS #3 @ 13:16







***FIELD DATA***









SAMPLED BY: RGR



AMBIENT TEMP.:





SAMPLE PRES. :



GRAVITY :





SAMPLE TEMP. :









COMMENTS















GPM@ GPM@

COMPONENT

MOLE %

MASS %

14.65

14.73

HELIUM

0.016

0.003

...



HYDROGEN

0.000

0.000

...



OXYGEN/ARGON

0.000

0.000

...



NITROGEN

0.386

0.502

...



C02

3.013

6.160

...



METHANE

76.906

57.315

—



ETHANE

11.841

16.541

3.1498

3.1670

PROPANE

4.323

8.855

1.1847

1.1911

I-BUTANE

0.816

2.203

0.2655

0.2669

N-BIJTANE

1.422

3.844

0.4461

0.4485

I-PENTANE

0.499

1.672

0.1816

0.1826

N-PENTANE

0.361

1.209

0.1301

0.1308

HEXANES PLUS

0.417

i.696

0.1648

0.1653

TOTALS

100.000

100.000

5.5226

5.5522

BTEX COMPONE> MOL WT%

(CALC: GPA STD 2145-94 & TP-17 %14.696 & 60 F)

BENZENE 0.019 0.070

BTU %

14.65

14.73

ETHYLBENZENE 0.000 0.000

GROSS DRY REAL :

1222.56

1229.24

TOLUENE 0.007 0.029

GROSS WET REAL :

1201.19

1207.87

XYLENES 0.000 0.001



DENSITY (AIR=1):



0.7454

TOTAL BTEX

0.026 0.100

COMPRESSIBILITY FACTOR

0.99648

*DHA (DETAILED HYDROCARBON ANAL YSIS/NJ1993) ; ASTM D6730

THIS DATA HAS BEEN ACQUIRED THROUGH APPLICATION OF CURRENT STATE-OF-THE-ART AN ALYTICAL TECHNIQUES.
THE USE OF THIS INFORMATION IS THE RESPONSIBLE OF THE USER. EMPACT ANALYTICAL SYSTEMS, ASSUMES NO
RESPONSIBLITY FOR ACCURACY OF THE REPORTED INFORMATION NOR ANY CONSEQUECES OF ITS APPLICATION.

EMPACT ANALYTICAL SYSTEMS, INC

997 US HI WAY 85
BRIGHTON, CO 80603
(303) 637-0150

EXTENDED NATURAL GAS ANALYSIS (*DHA)

PROJECT NO. :
COMPANY NAME :

0302069
SRI

ANALYSIS NO. :
ANALYSIS DATE:

FEBRUARY 28. 2003

COMPONENT

HELIUM

HYDROGEN

OXYGEN/ARGON

0.016
0.000
0.000

MASS %

0.003
0.000
0.000

GPM

14.65

D-2


-------
Appendix D-l. Pre-Test Makeup Natural Gas Analysis, Cont.

NITROGEN



0.386

0.502

...

...

C02



3.013

6.160

...

—

METHANE

P1

76.906

57.315

—

...

ETHANE

P2

11.841

16.541

3.1498

3.1670

PROPANE

P3

4.323

8.855

1.1847

1.1911

I-BUTANE

14

0.816

2.203

0.2655

0.2669

N-BUTANE

P4

1.416

3.823

0.4440

0.4464

2,2 DIMETHYLPROPANE

15

0.006

0.021

0.0021

0.0021

I-PENTANE

15

0.499

1.672

0.1816

0.1826

N-PENTANE

P5

0.361

1.209

0.1301

0.1308

2,2 D1METHYLBUTANE

16

0.011

0.042

0.0046

0.0046

CYCLOPENTANE

N5

0.014

0.046

0.0041

0.0041

2,3 DIMETHYLBUTANE

16

0.023

0.091

0.0094

0.0094

2 METHYLPENTANE

16

0.091

0.366

0.0376

0.0378

3 METHYLPENTANE

16

0.050

0.199

0.0203

0.0204

N-HEXANE

P6

0.092

0.370

0.0376

0.0378

2,2-DIMETHYLPENTAN£

17

0.002

0.011

0.0009

0.0009

METIIYLCYCLOPENTANE

N6

0.033

0.128

0.0117

0.0117

2,4 DIMETHYLPENTANE

17

0.004

0.018

0.0019

0.0019

2,2,3 TRIMETHYI.BUT AN F.

17

0.001

0.003

0.0005

0.0005

BENZENE

A6

0.019

0.070

0.0053

0.0053

3,3 DIMETHYLPENTANE

17

0.001

0.004

0.0005

0.0005

CYCLOHEXANE

06

0.022

0.085

0.0075

0.0075

2 METHYLHEXANE

17

0.009

0.042

0.0042

0.0042

2,3 DIMETHYLPENTANE

17

0.003

0.012

0.0014

0.0014

I,I DIMF.THYLCYCLOPENTANE

N7

0.002

0.010

0.0008

0.0008

3 METHYLHEXANE

17

0.008

0.035

0.0037

0.0037

LC 3 DIMETHYLCYCLOPENTANE

N7

0.002

0.010

0.0008

0.0008

1 ,T 3 DIMETHYLCYCLOPENTANE

N7

0.002

0.008

0.0008

0.0008

3 ETHYLPENTANE

17

0.000

0.002

0.0000

0.0000

1 ,T 2 DIMETHYLCYCLOPENTANE

N7

0.003

0.012

0.0012

0.0012

N-HEPTANE

P7

0.008

0.037

0.0037

0.0037

METHYLCYCLOHEXANE

N7

0.010

0.045

0.0040

0.0040

2,2-DlMETHYLHEXANE

18

0.000

0.002

0.0000

0.0000

ETHYLCYCLOPENTANE

N7

0.000

0.001

0.0000

0.0000

2,5-DIMETllYLHEXANE

18

0.000

0.001

0.0000

0.0000

2,4-DIMETHYLHEXANE

18

0.000

0.001

0.0000

0.0000

1C,2T,4-TRIMETHYLCYCL0PENTANE

N8

o.ooo

0.001

0.0000

0.0000

3,3-DlME 1HYLHEXANE

18

0.000

0.001

0.0000

0.0000

1T,2C,3-TRIMETHYLCYCL0PENTANE

N8

0.000

0.001

0.0000

0.0000

TOLUENE

A7

0.007

0.029

0.0023

0.0023

2,3-DIMETHYLHEXANE

18

0.000

0.001

0.0000

0.0000

2-MF.THYI.HEPTANE

18

0.000

0.002

0.0000

0.0000

4-ME I'HYLHEP f ANE

18

0.000

0.00 L

0.0000

0.0000

3-METHYLHEPTANE

18

0.000

0.001

0.0000

0.0000

1 C,2T,3-TRIMETH YLCYCLOPENTANE

N8

0.000

0.002

0.0000

0.0000

1T.4-DIMETHYLCYCI.OHEXANE

N8

0.000

0.001

0.0000

0.0000

1,1-DIMFTHYLCYCLOHEXANE

N8

0.000

0.001

0.0000

0.0000

IT,2-DIMFTHYLCYCLOHEXANE

N8

0.000

0.001

0.0000

0.0000

N-OCTANE

P8

0.000

0.002

0.0000

0.0000

I,3-D1METHYLBENZENE (M-XYLENE)

A8

0.000

o'ooi

0.0000

0.0000

TOTALS



100.000

100.000

5.5226

5.5522

EMPACT ANALYTICAL SYSTEMS, INC

997 US HIWAY 85
BRIGHTON, CO 80603
(303) 637-0150

EXTENDED NATURAL GAS ANALYSIS (*DHA)

PROJECT NO. : 0302069
COMPANY NAME: SRI
ACCOUNT NO. : P.O. RD30712

ANALYSIS NO.: 02

ANALYSIS DATE: FEBRUARY 28,2003

SAMPLE DATE : FEBRUARY 26, 2003

D-3


-------
Appendix D-l. Pre-Test Makeup Natural Gas Analysis, Cont.

PRODUCER :



TO:





LEASE NO.



CYLINDER NO. :

265



NAME/DESCRIP :

MAKE-UP GAS U\ @ 12:58







***FIELD DATA ***









SAMPLED BY:

RGR

AMBIENT TEMP.:





SAMPLE PRES. :



GRAVITY





SAMPLE TEMP. :









COMMENTS :





GPM@

GPM®

COMPONENT

MOLE %

MASS %

14.65

14.73

HELIUM

0.016

0.003

—

...

HYDROGEN

0.000

0.000

—

...

OXYGEN/ARGON

0.000

0.000



...

NITROGEN

0.376

0.489

...

...

C02

3.024

6.182

...

...

METHANE

76.962

57.345

...

...

ETHANE

11.819

16.508

3.1439

3.1611

PROPANE

4.271

8.749

1.1704

1.1768

l-BUTANE

0.808

2.180

0.2629

0.2643

N-BUTANE

1.405

3.797

0.4408

0.4432

l-PENTANE

0.502

1.681

0.1827

0.1837

N-PENTANE

0.367

1.229

0.1322

0.1329

HEXANES PLUS

0.450

1.837

0.1784

0.1789

TOTALS

100.000

100.000

5.5113

5.5409

(CALC: GP.4 STD 2145-94 & TP-17%14.696 & 60 F)
BTU %	14.65 	14.73

GROSS DRY REAL : 1222.61	1229.29

GROSS WET REAL: 1201.24	1207.92

DENSITY (AIR=1):	0.7456

COMPRESSIBILITY FACTOR :	0.99651

BTEX COMPONEP MOL: WT%

BENZENE	0.019 0.068

ETHYLBENZENE 0.000 0.001
TOLUENE	0.011 0.045

XYLENES	0.001 0.006

TOTAL BTEX 0.031 0.120

*DHA (DETAILED HYDROCARBON ANAL YSIS/NJ1993) ; ASTM D6730

THIS DATA HAS BEEN ACQUIRED THROUGH APPLICATION OF CURRENT STATE-OF-THE-ART ANALYTICAL TECHNIQUES.
THE USE OF THIS INFORMA TION IS THE RESPONSIBLITY OF THE USER. EMPACT ANALYTICAL SYSTEMS, ASSUMES NO
RESPONSIBLITY FOR ACCURACY OF THE REPORTED INFORMATION NOR ANY CONSEQUECES OF ITS APPLICATION.

EMPACT ANALYTICAL SYSTEMS, INC

997 US HI WAY 85
BRIGHTON, CO 80603
(303) 637-0150

EXTENDED NATURAL GAS ANALYSIS (*DHA)

PROJECT NO. :

0302069





ANALYSIS NO. :

02



COMPANY NAME :

SRI





ANALYSIS DATE:

FEBRUARY 28, 2003











GPM

GPM

COMPONENT



PIANO #

MOLE %

MASS %

14.65

14.73

HELIUM





0.016

0.003





HYDROGEN





0.000

0.000

...



OXYGEN/ARGON





0.000

0.000

...

...

NITROGEN





0.376

0.489

...

...

C02





3.024

6.182

...

...

METHANE



P1

76.962

57.345

...



ETHANE



P2

11.819

16.508

3.1439

3.1611

PROPANE



P3

4.271

8.749

1.1704

1.1768

l-BUTANE



14

0.808

2.180

0.2629

0.2643

N-BUTANE



P4

1.399

3.776

0.4387

0.4411

2,2 D1METHYLPROPAN E



15

0.006

0.021

0.0021

0.0021

l-PENTANE



15

0.502

1.681

0.1827

0.1837

N-PENTANE



P5

0.367

1.229

0.1322

0.1329

2.2 DIMETHYLBUTANE



16

0.011

0.042

0.0046

0.0046

D-4


-------
Appendix D-l. Pre-Test Makeup Natural Gas Analysis, Cont.

METHANOL

X1

0.003

0.005

0.0004

0.0004

CYCLOPENTANE

N5

0.014

0.045

0.0041

0.0041

2,3 DIMETHYLBUTANE

16

0.022

0.090

0.0090

0.0090

2 METHYLPENTANE

16

0.091

0.365

0.0376

0.0378

3 METHYLPENTANE

16

0.050

0.198

0.0203

0.0204

N-HEXANE

P6

0.093

0.371

0.0380

0.0382

2,2-DIMETHYLPENTANE

17

0.002

0.011

0.0009

0.0009

METHYLCYCLOPENTANE

N6

0.033

0.128

0.0117

0.0117

2,4 DIMETHYLPENTANE

17

0.004

0.019

0.0019

0.0019

2,2,3 TRIMETHYLBUTANF

17

0.001

0.004

0.0005

0.0005

BENZENE

A6

0.019

0.068

0.0053

0.0053

3,3 DIMETHYLPENTANE

17

0.001

0.005

0.0005

0.0005

CYCLOHEXANE

06

0.023

0.088

0.0078

0.0078

2 MFTHYLHEXANE

17

0.011

0.050

0.0051

0.0051

2,3 DIMETHYLPENTANE

17

0.003

0.015

0.0014

0.0014

1,1 DIMETHYLCYCLOPENTANE

N7

0.002

0.011

0.0008

0.0008

3 METHYLHEXANE

17

0.009

0.044

0.0041

0.0041

l.C 3 DIMETHYLCYCLOPENTANE

N7

0.003

0.012 •

0.0012

0.0012

1 ,T 3 DIMETHYLCYCLOPENTANE

N7

0.002

0.010

0.0008

0.0008

3 ETHYLPENTANE

17

0.001

0.003

0.0005

0.0005

1,T 2 DIMETHYLCYCLOPENTANE

N7

0.003

0.015

0.0012

0.0012

N-HEPTANE

P7

0.013

0.059

0.0060

0.0060

1,C 2 DIMETHYLCYCLOPENTANE

N7

0.000

0.001

0.0000

0.0000

METIIYLCYCLOIIEXANE

N7

0.014

0.066

0.0056

0.0056

2,2-DIMETHYLHEXANE

18

0.001

0.004

0.0005

0.0005

ETHYLCYCLOPENTANE

N7

0.000

0.002

0.0000

0.0000

2,5-DIMF.THYLHEXANE

18

0.001

0.003

0.0005

0.0005

2,4-DlMETHYLHEXANE

18

0.001

0.003

0.0005

0.0005

1C,2T,4-TRIMETHYLCYCL0PENTANE

N8

0.000

0.002

0.0000

0.0000

3,3-DIMETHYLHEXANE

18

0.000

0.001

0.0000

0.0000

1T,2C,3-TRIMETHYLCYCL0PENTANE

N8

0.000

0.001

0.0000

0.0000

TOLUENE

A7

0.011

0.045

0.0037

0.0037

2,3-DIMETHYLHEXANE

18

0.000

0.002

0.0000

0,0000

2-METHYLHEPTANE

18

0.001

0.007

0.0005

0.0005

4-METHYLHEPTANE

18

0.001

0.003

0.0005

0.0005

3-METHYLHEPTANE

18

0.001

0.005

0.0005

0.0005

1C,2T,3-TRIMETHYLCYCL0PENTANE

N8

0.001

0.005

0.0005

0.0005

1T,4-DIMETHYLCYC1.0HFXANE

N8

0.001

0.003

0.0005

0.0005

1,1-DIMETHYLCYCLOHEXANE

N8

0.000

0.001

0.0000

0.0000

1T.2-DIMETHYLCYCLOHEXANE

N8

0.000

0.002

0.0000

0.0000

N-OCTANE

P8

0.002

0.009

0.0010

0.0010

2,3,5-TRIMETHYLHEXANE

19

0.000

0,001

0.0000

0.0000

1,1,4-TRIMETHYLCYCLOHEXANE

N9

0.000

0.001

0,0000

0.0000

4,4-DIMETHYLHEPTANE

19

0.000

0.001

0.0000

0.0000

ETHYLCYCLOHEXANE

N9

0.000

0.001

0.0000

0.0000

2,5-DIMETHYLHEPTANE

19

0.000

0.001

0.0000

0.0000

ETHYLBENZENE

A8

0.000

0.001

0.0000

0.0000

1,3-DIMETHYLBENZENE (M-XYLENE)

A8

0.001

0.003

0.0004

0.0004

1,4-DIMETHYLBENZENE (P-XYLENE)

A8

0.000

0.002

0.0000

0.0000

1,2-DIMFTHYI,BENZENE (O-XYLENE)

A8

0.000

0.001

0.0000

0,0000

N-NONANE

P9

0.000

0.002

0.0000

0.0000

TOTALS



100.000

100.000

5.5113

5.5409

EMPACT ANALYTICAL SYSTEMS, INC

997 US HI WAY 85
BRIGHTON, CO 80603
(303) 637-0150

EXTENDED NATURAL GAS ANALYSIS (*DHA)

PROJECT NO. : 0302069	ANALYSIS NO. : 03

COMPANY NAME : SRI	ANALYSIS DATE: FEBRUARY 28, 2003

ACCOUNT NO. : P.O. RD30712	SAMPLE DATE : FEBRUARY 26, 2003

D-5


-------
Appendix D-l. Pre-Test Makeup Natural Gas Analysis, Cont.

PRODUCER :
[.EASE NO. :
NAME/DESCRIP :
* * "FIELD DATA**
SAMPLED BY:
SAMPLE PRES. :
SAMPLE TEMP. :
COMMENTS

MAKE-UP GAS #2 @ 13:09

TO:

CYLINDER NO. :

AMBIENT TEMP.:
GRAVITY :

GPM@

COMPONENT





MOLE %

MASS %

14.65

14.73

HELIUM





0.022

0.004





HYDROGEN





0.000

0.000



—

OXYGEN/ARGON





0.006

0.009



...

NITROGEN





0.388

0.506





C02





3.021

6.182



...

METHANE





76.928

57.378



...

ETHANE





11.842

16.557

3.1500

3.1672

PROPANE





4.300

8.817

1.1784

1.1848

l-BUTANE





0.813

2.196

0.2645

0.2659

N-BUTANE





1.422

3.850

0.4461

0.4485

[-PENTANE





0.499

1.673

0.1816

0.1826

N-PENTANE





0.367

1.230

0.1322

0.1329

HEXANES PLUS





0.392

1.598

0.1543

0.1548

TOTALS





100.000

100.000

5.5071

5.5367

BTEX COMPONE^

mol;

WT%



(CALC: GPA STD 2145-94

& TP-17 @14.

696 & 60 F)

BENZENE

0.017

0.062



BTU @

14.65

14.73

ETIIYLBENZENE

0.000

0.001



GROSS DRY REAL :

1221.04

1227.71

TOLUENE

0.006

0.025



GROSS WET REAL :

1199.70

1206.37

XYLENES

0.000

0.003



DENSITY (AIR=I):



0.7447

TOTAL BTEX

COMPRESSIBILITY FACTOR

*DHA (DETAILED HYDROCARBON ANAL YSIS/NJ1993) ; ASTM D6730

THIS DATA HAS BEEN ACQUIRED THROUGH APPLICATION OF CURRENT STATE-OF-THE-ART ANALYTICAL TECHNIQUES.
THE USE OF THIS INFORMATION IS THE RESPONSlBLlTY OF THE USER. EMPACTANALYTICAL SYSTEMS, ASSUMES NO
RESPONSIBLITY FOR ACCURACY OF THE REPORTED INFORMATION NOR ANY CONSEQUECES OF ITS APPLICA TION.

EMPACT ANALYTICAL SYSTEMS, INC

997 US HIWAY 85
BRIGHTON, CO 80603
(303) 637-0150

EXTENDED NATURAL GAS ANALYSIS (*DHA)

PROJECT NO. :

0302069





ANALYSIS NO. :

03



COMPANY NAME :

SRI





ANALYSIS DATE:

FEBRUARY 28. 2003











GPM

GPM

COMPONENT



PIANO n

MOLE %

MASS %

14,65

14.73

HELIUM





0.022

0.004



...

HYDROGEN





0.000

0.000



...

OXYGEN/ARGON





0.006

0.009



—

NITROGEN





0.388

0.506

...

...

C02





3.021

6.182

...



METHANE



P1

76.928

57.378

...

...

ETHANE



P2

11.842

16.557

3.1500

3.1672

PROPANE



P3

4.300

8.817

1.1784

1.1848

I-BUTANE



14

0.813

2.196

0.2645

0.2659

N-BUTANE



P4

1.416

3.828

0.4440

0.4464

2,2 DIMETHYLPROPANE



!5

0.006

0.022

0.0021

0.0021

l-PENTANE



15

0.499

1.673

0.1816

0.1826

N-PENTANE



P5

0.367

1.230

0.1322

0.1329

2,2 DIMETHYLBUTANE



16

0.010

0.041

0.0042

0.0042

D-6


-------
Appendix D-l. Pre-Test Makeup Natural Gas Analysis, Cont.

METHANOL

X1

0.003

0.005

0.0004

0.0004

CYCLOPHNTANE

N5

0.012

0.041

0.0035

0.0035

2,3 DIMETHYLBUTANE

16

0.023

0.092

0.0094

0.0094

2 METHYLPENTANE

(6

0.089

0.355

0.0367

0.0369

3 METHYLPENTANE

16

0.047

0.190

0.0190

0.0191

N-HEXANE

P6

0.087

0.348

0.0356

0.0358

2,2-DIMETHYLPENTANE

17

0.002

0.010

0.0009

0.0009

METHYLCYCLOPENTANE

N6

0.030

0.118

0.0106

0.0106

2,4 DIMETHYLPENTANE

17

0.004

0.017

0.0019

0.0019

2,2,3 TRIMETHYLBUTANE

17

0.001

0.003

0.0005

0.0005

BENZENE

A6

0.017

0.062

0.0047

0.0047

3,3 DIMETHYLPENTANE

17

0.001

0.004

0.0005

0.0005

CYCLOHEXANE

06

0.019

0.076

0.0065

0.0065

2 METIIYLHEXANE

17

0.008

0.036

0.0037

0.0037

2,3 DIMETHYLPENTANE

17

0.002

0.011

0.0009

0.0009

1,1 DIMETHYLCYCLOPENTANF.

N7

0.002

0.008

0.0008

0.0008

3 METHYLHEXANE

!7

0.007

0.031

0.0032

0.0032

1,C 3 DIMETHYLCYCLOPENTANE

N7

0.002

0.009

0.0008

0.0008

1 ,T 3 DIMETHYLCYCLOPENTANE

N7

0.002

0.008

0.0008

0.0008

3 ETHYLPENTANE

17

0.000

0.002

0.0000

0.0000

1,T 2 DIMETHYLCYCLOPENTANE

N7

0.002

0.011

0.0008

0.0008

N-HEPTANE

P7

0.007

0.032

0.0032

0.0032

1,C 2 DIMETHYLCYCLOPENTANE

N7

0.000

0.001

0.0000

0.0000

METHYLCYCLOHEXANE

N7

0.008

0.038

0.0032

0.0032

2,2-DIMETIIYLHEXANE

18

0.000

0.002

0.0000

0.0000

ETHYLCYCLOPENTANE

N7

0.000

0.001

0.0000

0.0000

2,5-DIMETHYLHEXANE

18

0.000

0.001

0.0000

0.0000

2,4-DtMETHYLHEXANE

(8

0.000

0.001

0.0000

0.0000

1C,2T,4-TRIMETHYLCYCL0PENTANE

N8

o.ooo

0.001

0.0000

0.0000

IT,2C,3-TRIMETHYLCYCL0PENTANE

N8

0.000

0.001

0.0000

0.0000

TOLUENE

A7

0.006

0.025

0.0020

0.0020

2-METHYLHEPTANE

18

0.000

0.002

0.0000

0.0000

4-METHYLHFPTANE

18

0.000

0.001

0.0000

0.0000

3-METHYLHEPTANE

18

o.ooo

0.001

0.0000

0.0000

IC,2T,3-TRIME'l'HYLCYCLOPENTANE

N8

0.000

0.002

0.0000

0.0000

1T.4-DIMETIIYLCYCLOHEXANE

N8

0.000

0.001

0.0000

0.0000

1T,2-DIMETHYLCYCL0IIEXANE

N8

0.000

0.001

0.0000

0.0000

N-OCTANE

P8

0.001

0.003

0.0005

0.0005

1,1,4-TRIMETHYLCYCI.OHEXANE

N9

0.000

0.001

0.0000

0.0000

ETHYLBENZENE

AS

0.000

0.001

0.0000

0.0000

1,3-DIMETHYLBENZENE (M-XYLENE)

A8

0.000

0.002

0.0000

0.0000

1,4-DIMETHYLBENZENE (P-XYLENE)

A8

0.000

0.001

0.0000

0.0000

N-N'ONANE

P9

o.ooo

0.001

0.0000

0.0000
5.5367

TOTALS



100.000

100.000

5.5071

D-7


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