United States       Office of Air Quality        EPA-340/1 -85-013b
Environmental Protection  Planning and Standards      December 1984
Agency         Washington, D.C. 20460

Stationary Source Compliance Series
Field Inspection
Notebook for
Monitoring Total
Reduced Sulfur
(TRS) from
Kraft Pulp  Mills

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                                     EPA-340/1-85-013b
       Field Inspection  Notebook for
Monitoring Total Reduced Sulfur (TRS)
             from Kraft Pulp Mills
                        Prepared by
                     William T. Winberry, Jr.
                      Engineering-Science
                      501 Willard Street
                   Durham, North Carolina 27701
                    Contract No. 68-02-3960
                    Work Assignment No. 53
                  EPA Project Manager: John Busik
            EPA Work Assignment Manager: Sonya M. Stelmack
              U.S. ENVIRONMENTAL PROTECTION AGENCY
                Stationary Source Compliance Division
               Office of Air Quality Planning and Standards
                    Washington, D C 20460

                       December 1984

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                                DISCLAIMER
    This report was furnished to the Environmental  Protection Agency by
Engineering-Science, 501 Willard Street, Durham, N. C., 27701 in fulfill-
ment of Contract No. 68-02-3960, Work Assignment No. 53.   The opinions,
findings, and conclusions expressed are those of the author and not
necessarily those of the U. S. Environmental  Protection Agency.  Mention
of company or product names is not to be considered as an endorsement by
the Environmental Protection Agency.
                                    11

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                                  TABLE
                                    OF
                                 CONTENTS
                                                                   Page
         Subject                                                  Number
Introduction	    1
Field Inspection Notebook Objective	    2
Inspection Procedures	    5
       Level I	    7
       Level II	,	,.	,	.,,..,,	   11
       Level III	   29
           Monitor Specific Inspection Procedures	   33
             Sampling Technology Inc	   35
             Barton Titrator	,.,,,,..,,,,,..,	,,<	   43
             Bendix TRS CEM System	   51
       Level IV.,		   61
           Reference Method 16 Observation  Checklist	   63
           Reference Method 16A Observation Checklist	   83
Abbreviated Inspection Procedures	,	   97
Appendix,	,	,	,	,	,	109

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                        FIELD INSPECTION  NOTEBOOK
                           TOTAL  REDUCED  SULFUR
                  CONTINUOUS EMISSION MONITORING SYSTEM
                               INTRODUCTION

     This notebook is intended to assist  the field  inspector  in  the  inspec-
tion of total  reduced sulfur (TRS)  continuous  emission  monitoring  systems
(CEMs).  Contained in the notebook  are checklists  and data  entry tables
covering preparation for the inspection,  preliminary  review of  records,
preliminary on-site meeting with source personnel,  and  general  guidelines
for inspection of any type TRS CEM  system.   Specific  audit  procedures  for
three of the most common models of  TRS CEMs:

     - Sampling Technology Inc.  Model 100  TRS CEM  System  (pg.  35);
     - Barton Titrator TRS System (pg. 43); and
     - Bendix Gas Chromatograph TRS System  (pg. 51)

are provided as sectional inserts.   In auditing these monitors  the inspector
should follow the specific procedure rather than the  general  guidelines
given in the body of the field notebook.

     Conscientious use of this notebook will  aid the  inspector  in  conducting
a thorough audit of the TRS CEM system and  provide  a  comprehensive original
record of all  phases of the inspection.

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                   FIELD INSPECTION NOTEBOOK OBJECTIVE


     This notebook is designed to provide a complete unit  checklist  for
inspection of an TRS CEM system.  The inspection procedures follow the
control  agency inspection program, dealing with the "phase" and "level"
approach.

     The "phase" process consists of administrative activities involved
with initial  CEM system application, performance testing and final  approval
This enables  the state agency to approve the monitoring system through es-
tablished certification procedures.  The type of activities at each  phase
are:

     Phase I  - Control agency initial approval  of CEM application as
     required through source permit;

     Phase II - Control agency observation of performance  specification
     testing  (PST) of the installed CEM system; and

     Phase III - Control agency review of the PST report,  with final
     approval or disapproval.

     The "level" approach begins after completion of the "phase" evalua-
tion.  The levels of CEM system inspection extend from agency source
records  review (lowest level) to stack test compliance determination
(highest level).  The inspection determines or confirms compliance and
identifies causes of excess emissions.  The types of activities at each
level are:

     Level I  - Control agency records review including  excess emission
     reports, previous inspection reports, source "working" file and
     and permits;

     Level II - On-site inspection involving review of  monitor record-
     keeping  (maintenance, monitor and control  equipment logs), monitor
     fault indicator, monitor internal zero/span check, strip chart
     review and electronic checks;

     Level III - Evaluation of installed CEMS through external audit
     evaluation involving neutral density filters for opacity monitors
     and gas  cylinders/permeation tubes for gas monitors;

     Level IV - Comparative evaluation of installed CEMs through perform-
     ance testing utilizing Federal Reference Methods or portable CEMs.

     The "phase" and "level" audit procedure has been designed so that
each activity indicates whether or not the CEM system has  achieved the
necessary level of compliance before starting the next  phase.

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     The main objective,  of this notebook  is  to cover in  detail  the  inspec-
tion procedure covering the "level" section  of  a  control  agency CEM system
inspection program.  During the inspection the  inspector  may  need  to add
comments, explanations or  • her notes to the  notebook.  To aid  in  referenc-
ing these comments, a colum,, under the heading  of  Check or Comment has  been
provided along the right  margin of all pages  containing inspection data.
These blank lines may be  used to indicate  action items  or to  enter code
numbers referencing entries elsewhere in the  notebook.

     Once a thorough evaluation of the TRS CEM  system has been  accomplished,
control agency personnel  may want to perform the next inspection on  a less
compreshensive basis.  To assist the control  agency personnel,  an  abbre-
viated inspection procedure checklist has  been  developed.  The  abbreviated
checklist is applicable to all  TRS CEM systems.  It does  not  address moni-
tor specific inspection points, but does evaluate  the TRS monitor  on a
system audit basis.  The  checklist is divided into three  major  areas:

            o  Control agency records review;
            o  Control agency records update; and
            o  Source TRS CEM system review.

     The control  agency records review consists of a review of  permits  and/
or any current enforcement actions to determine the purpose of  the CEM.
In addition, a review of  the PST report and current EER  is conducted to
verify conformance with the appropriate performance specification  and re-
porting requirements for EERs.

     The control  agency records update is  conducted by telephone to verify
that the records  in agency files correctly describe the  current CEM status.

     Finally, the source TRS CEM system review evaluates  a source's record-
keeping, data reduction procedures, monitor evaluation through  zero/span
checks and  overall system review.

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                          INSPECTION PROCEDURES
     Concurrent with the "level" approach philosophy, the CEM inspection
begins with a "thorough" working knowledge of the facility by reviewing
the "permanent" and "working" file of the source in the agency office.
Next, the inspection proceeds to the facility where other information is
gathered to support the records review activity.  While on the premises,
the inspector reviews all records which would provide information associated
with the monitoring system.  Then, a review of the monitoring system is in
order.

     For a TRS extractive system, heat tracing, insulation, weather pro-
tection, transport lines, and connection material should be inspected.  The
field inspector should evaluate monitor location for ease of maintenance,
representative sampling, and environmental factors such as vibration and
temperature.  The calibration gas interface with the sample system should
be inspected and their relative proximity noted.  The inspector should
verify that during calibration the pressure of the calibrator gas at the
interface is approximately equal to its pressure during sampling.

     The inspector should observe CEM calibration procedures to confirm
calibration reference values and provide a spontaneous quality assurance
check.  Documentation of calibration gas values by Protocol 1 traceability
or triplicate reference method analysis should be available in plant
records and verified during the field inspection.

     Finally, the CEM control unit and signal recording device should be
inspected.  The inspector should review previous 24-hour emissions and
zero/span check.   He should initiate a zero/span check and compare to
recorded values.

     To assist the inspector, the front part of the notebook covers
Levels I, II, III, and IV inspection procedures.  These are generic in
nature, adaptable to any TRS CEM system.  The latter part of the notebook
covers specific TRS CEM inspection procedures.

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                        FIELD INSPECTION NOTEBOOK
                           TOTAL REDUCED SULFUR
                  CONTINUOUS EMISSION MONITORING SYSTEM
                         1.0    LEVEL I CHECKLIST

1.1    SOURCE IDENTIFICATION

Company Name 	
Mailing Address
Location of Facility
       (Include County or Parish)


Personnel

                               Name              Title         Phone

o  Facility Manager     	  	  	

o  Environmental  Manager	  	

o  Facility Contact     	  	  	
o  Confidentiality State-
   ment Requi red
1.2     PREPARATION FOR INSPECTION

1.2.1   Source Notification

        o  Has the appropriate representative of the source been notified
           of the time and date of auditor's intended visit?  Yes    No
             By phone

             By letter
             Name of Representative

             Date contacted
             Record of notification filed

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1.2.2   Review of Source's Permit to Operate

        o  Permit information pertinent  to the CEM audit  is  contained  in  the
           followi ng checkli st.

        CEM requirement due to:   Permit                       	

                                 NSPS                        	

                                 SIP	

                                 Enforcement Action
           Date CEM installation completed

           Date CEM started up _____ _____
           Gases monitored  TRS	Opacity	0;?_

           Allowable emission rates   TRS
                                     0 p a c i ty	

1.2.3   CEM Equipment Summary

                           Pollutant    Manufacturer  Model/Type  Process

        Monitor/Analyzer   _____	

        Data Recorder	

        Data Processor
1.2.4   Review of Performance Specification Test Report

        o  A CEM Performance Specification Test (PST)  report should be on
           file.  Information to be reviewed is contained in the following
           checkli st.

           Dates of Operational  Test Period (OTP) (<30 days after perform-
             ance test) 	

           Date PST report submitted (<60 days after OTP)	
           Date of process startup (<180 days prior to OTP)_
           Date of initial  full-load operation (<60 days prior to OTP)

           Emission rate conversion formula(s)	

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        o  PST Summary Results
TRS
Relative Accuracy
02
NA
Opacity
NA
Response Time
           24 Hr.  Span Drift
           24 Hr.  Zero Drift
1.2.5   Review of Excess Emissions  Reports

        o  The following checklist  summarizes  pertinent information  to  be
           obtained from excess  emissions  reports.

              Months covered by  reports  	     	
              Did each excess  emission  report  document:

              Date, time, and  duration  of excess emissions?   Yes	No

              Magnitude of excess  emissions?                  Yes	 No

              Reason for excess emissions?                    Yes	 No

              Corrective action taken to reduce  emissions?    Yes	 No_

              Conversions factor/formula?                     Yes	 No

        Method for determining conversion or correction  factors
        used in calculating emission rate.
        Process downtime	None

        Monitor downtime                                 None
        If significant monitor downtime  occurred, briefly discuss  corrective
        action taken to return monitor to operation.

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   What percent availability did the CEM system achieve?
     % availability = Hours of monitor operation
                      Hours of process operation

o  Select one excess emission event and record:

     Date                	

     Time                	

     Magnitude           	

     Reason              	

     Corrective Action   	

This information is intended for use during Level  II evaluation.
                               10

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                         2.0  LEVEL  II  CHECKLIST


2.1  PRE-INSPECTION MEETING

     Before the CEM inspection,  the  inspector should  arrange  to  meet  with
source representatives directly  responsible  for CEM operation and  mainte-
nance, compliance, records and reports.  The purpose  of  the opening con-
ference is to inform facility official(s) of the  purpose of the  inspec-
tion, the authority under which  it wil  be conducted,  and the  procedures
to be followed, and answer any questions  they may have.   The  opening  con-
ference also offers the inspector the opportunity to  completely  discuss
agency policy and inspection procedures,  and to provide  relevant informa-
tion and other assistance.  The  inspector's  effective execution  of the
opening conference often sets the tone  of the remainder  of the inspection.

     During the opening conference,  the discussion should cover  the
fol1owing items:
                                                      COVERED

                 o  Inspection objectives               	

                 o  Inspection agenda                   	
                 o  Facility Information
                    verification

                 o  Review of records

                        o  Maintenance

                        o  CEM Operation  Logbook

                        o  Strip Charts

                        o  Data Log

                        o  Control  Equipment Records

                        o  Excess Emission Reports

                        o  Source Permit

                 o  Safety Requirements

                 o  Scheduling of Source
                    Personnel  Interviews

                 o  Inspection Techniques to Be Used

                 o  Scheduling of Copying Needed
                    Documentation

                 o  Any Questions


                                    11

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     In particular,  the inspector should  develop  his  or  her  understanding
of the operation/maintenance of  the  audited  system to ascertain whether
the TRS CEM system has been operated according  to permit  condition  since
the last inspection.  The inspector  should  be able to support  any conclu-
sions by:

              o  Examination of  CEM  maintenance records;

              o  CEM span and zero calibration  checks over previous
                 quarter;

              o  Reviewing the CEM program;

              o  Records comparison, i.e.,  correlation of excess emission
                 reports, strip  chart records,  operations and  maintenance
                 records, and computer printouts  ( if available); and

              o  Reviewing files to  identify missing  documents (if  any).

     The following checklists are provided  to assist  the inspector  in
conducting the preliminary meeting.

2.1.1  Personnel In Attendance

                                                              Phone
    Name	Affi liation	Title/Responsi bi 1 ity	Number	
                                    12

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2.1.2  Review of CEM Maintenance Records.

       o  Describe significant CEM maintenance since last  audit.

                                                                Date/time
       Description	Type*	Performed
       *Routine, Preventive, Emergency, etc.

       o  Recurring Maintenance Problems (Last 12  Months)
2.1.3  Review of Calibration Frequency
                                                  Calibration   Relative
                                     Zero   Span     Error*      Accuracy*
       Estimate of
       Calibration Frequency
       *0ptional

       o  Describe Unusual  or Persistent  Monitor  Calibration  problems
                                    13

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2.1.4  General Review of CEM Program

       o  Is an alarm connected to CEM control  panel  or
          annunciator panel  in process control  room to
          signal  excess emissions?                        Yes    No
       o  How often is CEM strip chart or computer output checked hy an
          operator?
       o  What procedures are implemented during an excess emission in-
          cident to reduce emissions?
       o  Do records contain process data needed for
          conversion of CEM output to units  of the
          standard (i.e.,  moisture, velocity,  oxygen
          correction)?                                    Yes    No
       o  Are process data measurements conducted?        Yes_	No_

       o  Do records contain current information on
          calibration reference materials  (gases,
          permeation tubes, cells,  filters)?               Yes	 No
       o  Are entries into Maintenance and Operations
          Logs made on monitor:

            Malfunction?                                  Yes    No_

            Calibrations?                                 Yes	 No_

            Maintenance?                                  Yes    No
            QA Checks?                                    Yes	 No_
       o  Are charts/printouts for the past two years
          filed and readily retrievable?                  Yes	 No_
                                     14

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2.1.5  Internal  Consistency of Records and Reports

     It should be possible to relate the emission excursions  reported  in
the Excess Emissions Report with the recorded CEM data showing the occur-
rence of excess  emissions.  Such excursions should  also be documented  in
the CEM Log, which should include a report of the incident and the correc-
tive action taken by the source.  In those cases where a mechanical  problem
is cited as the  cause of the excess emissions,  maintenance records should
show corrective  action taken by the source.  The inspector should try  to
determine the time between the measured excess  emissions incident and  the
initiation of corrective action.

  o  Report of Excess Emissions (Enter data from Level I Review)

                   Time
     Date       From   To     Pollutant         %02          Magnitude
                                                              (ppm)
  o  Description of Excess Emissions from CEM or operating Log on above
     date.
   o  Identification of Excess Emissions Incident in Chart Record

                              Last       Last                Calculated
      Above                   Zero       Span    Average     equivalent
      Date         Time       Check      Check    (ppm)        (ppm)
                                                               corrected)
   o  Subsequent Corrective Action Described in Maintenance Log (if appli
      cable), and date and time initiated
      Are dates and times of above records consistent in recording this
      excess emission event?                                 Yes	 No_
   o  If No, explain
                                    15

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2.2  TRS CEM FIELD INSPECTION

     The general inspection procedures presented on the following pages
cover extractive TRS CEM systems.  These procedures should be followed
when a monitor-specific procedure is unavailable.

                                                               Check
                                                                 or
                                                              Conment
2.2.1  TRS CEM Operational Environment

     o  Is the process monitored by the TRS CEM
        operating within normal limits as com-
        pared to the source performance test?  Yes	 No	   	
        (If process is not operating within normal  limits,
        Inspector should delay any part of audit which
        requires normal process conditions.)

     o  Process Capacity 	

     o  Process Rate 	

     o  Stack Gases  TRS	   Opacity	
        Monitored:
        (Avg. Cone.) 02	

     o  Stack Gas Temperature	 	°F
     o  Pollution Control Device
     o  Is the analyzer unit subject to excessive heat?
          Yes	No 	

     o  Is the analyzer unit subject to excessive
          vibration?   Yes	 No 	
       [Note:  Excessive heat/vibrations are meaningful only
       if system (1) fails to satisfy the operations specified
       by vendor or (2) fail to meet PST 5.]

     o  Frequency of sampling:  	per hour	
2.2.2  Measurements and Data Handling

     The following checklists are intended to assist the inspector in an
analysis of the source's data handling and data reduction practices.

     At some facilities data reduction is done by a computer programmed
to convert stack gas concentrations directly and continuously to the
units of the applicable emission standard.  At other facilities manual
calculations of emissions in units of the standard are only done for
periods of excess emissions.
                                    17

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2.2.2.1  Data Handling

  o  How is data reduction  handled?  Manually
                                     Electronically
  o  How many data  points  are  used  to  calculate each
     average?	

  o  Are these data points taken  at  equally spaced time
     intervals?                          Yes     No
  o  If yes,  what  is  that  time  interval?
  o  If data reduction  is  manual,  how  often  is  it done?
                                                              Check
                                                               or
                                                             Comment
  o  Who performs  manual  data  reduction?
  o  Are the data adjusted  to  account  for zero drift
     measurements?	Yes 	 No

  o  Are the data corrected to account  for  calibration
     (span)  drift measurements?	Yes  ___ No ___

  o  Does the source arbitrarily  edit  the data before
     reduction?	Yes 	 No  	

  o  If yes, what criteria  is  used  to  edit?   ________
2.2.2.2  Electronic Data  Reduction:

  o  Who wrote the program for calculating  averages?
  o  Is the source's data processing system time  shared
     or dedicated?  	

  o  Was it installed with the monitoring  system  or  added
     at a later date?	___

                                  18

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o  Who installed the data processing system?
                                                             Check
                                                               or
                                                            Comment
o  At what interval  does the data logger acquire  CEM
   measurements?
o  Does the system include a data recorder as  well  as
   a chart?                               Yes      No
o  If yes, indicate which kind.  Magnetic tape
                                 Paper tape
                                 Paper print-out
o  If both automated data processing and chart  recording
   are done, does the CEM value from the automated  data
   processor agree with the value recorded on the  chart?
                                          Yes 	  No 	

o  If no, explain.  	
o  Indicate which functions the automated data processing
   system performs.
        Data recording

        Data storage 	
        Averaging Period

        Hourly summary 	

        Daily summary 	
        Other summary (explain)
        Identification of excess emissions

        Display instantaneous value 	

        Alarm
                                  19

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                                                               Check
                                                                 or
                                                              Comment
          Records process equipment malfunction  codes	

          Records pollution control equipment  malfunction
          codes
          Records excess emission codes

2.2.2.3  Internal Zero/Span Check
     o  Write date and time on chart or data  processor at
        start of inspection
     o  Record current emissions
          Current Emissions
                                TRS
                               (ppm)
           Opacity
     o  Request internal  zero and upscale calibratrion,  enter results
        below, and compare results to typical  previous values.

                   Monitor
                    Response	
                       Zero

                       Span

                Calibration
                   Value
                        Zero

                        Span
     o  Review previous day's recording for typical emissions,
        repeated zero/span checks, etc.
                                  Yes
No
          Emissions normal

          Calibration normal

          Exceedances above
           the standard

          Calibrations noted
           on data processor
           and reviewed

          Operator aware
           of emission limits
                                    20

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                                                              Check
                                                                or
                                                             Comment
2.2.3  Inspection of Monitor Control  Unit
     Although instrumentation  differs  among the  various types and models
of TRS CEM's, many will  incorporate  some  or all  of these control indi-
cators or switches.  The inspector should locate those in use and enter
their position/status below.

                                  TRS      02      Opacity
       o  Reference
       o  Calibration	    __

       o  Alarm	    	

       o  Temperature	   		    	

       o  Sample gas	     	

       o  Stack gas           _______   _______	    	

       o  Heater              		

       o  Backpurge		

       o  Request Calibration	    	

       o  Operating Range	

       o  Recorder Readout	    	

       o  Operate	

       o  Sample Flow Rate	    	

2.2.4  Calibration Gas System

       o  If system uses  compressed  gases to  routinely  calibrate
          system, note following  gas  cylinder information:

            Gas Cyli nder  1

                 Pollutant
                 Concentration
                 Certification  Date

                 Cylinder Number 	
                 Cylinder Pressure (psi)	primary    (>150psi)

                                         	secondary  (> 15psi)


                                    21

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Gas Cyli nder 2

     Pollutant
     Concentration
     Certification Date

     Cylinder Number
     Cylinder Pressure (psi)
primary   (>150psi)
secondary (> 15psi)
Gas Cylinder 3

     Pollutant
     Concentration
     Certification Date

     Cylinder Number
     Cylinder Pressure (psi)
primary   (>150psi)
secondary (> 15psi)
Gas Cylinder 4

     Pollutant
     Concentration
     Certification Date

     Cylinder Number
     Cylinder Pressure (psi)
primary   (>150psi)

secondary (> 15psi)
                        22

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                                                              Check
                                                                or
                                                             Comment
2.2.5  Sample Transport  System

       o  Type of tubing 	
       o  Internal  diameter  of  tubing 	 inches

       o  Enter the distance from sample
          point to  analyzer	feet

       o  Is transport  line  heat  traced?	Yes	 No

       o  If yes,  how is  temperature monitored?	
       o  Enter the temperature  of  the  transport  line:
2.2.6  Sample  Conditioning/Extractive  Systems

     For extractive systems  the  following  checklists
     describe  the sampling point,  transport  system,
     and sample  conditioning system.

2.2.6.1  Sampling Point  -

       o  Location:   Stack
                     Duct  Horizontal

                     Duct  Vertical
       o  Is  it  downstream  of  pollution  control
          device?              Yes 	 No 	

       o  Type  pollution  control  device(s) 	
       o  Estimate distance  from  nearest  flow  disturbance
          and  record  below.

                     Downstream:	feet

                     Upstream:  	feet

       o  Sketch  the  cross-section  of  the duct/stack at
          the  sampling  point  and  show  the location of the
          sampling probe  of  CEM.   Indicate dimensions.
                                    23

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             Sketch  of Duct/Stack  and  Sampling  Probe  Location
                                                               Check
                                                                 or
                                                              Comment
       o  On the following blank  page  sketch  the  components
          of the Extractive CEM,  including  the  probe,  filter,
          calibration gas  interface,  pump,  moisture  removal
          system,  SO? scrubber system (where  applicable),  and
          analyzer.

2.2.6.2  Sample Probe -

       o  Type Material:	
       o  Singular or multi-point sampling? 	

       o  If multi-point sampling,  enter number of
          sampling points 	
       o  Distance of each point from the wall:

       Point No.    1     2     3     4     5     6

       Inches
       from wal1
       o  If single point, enter distance from wall:   	inches
                                    24

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Sketch of the Components of the Extractive CEM,  Including the
Probe, Filter, Calibration Gas  Interface, Pump,  Moisture Removal
System, S02 Scrubber System (where  applicable),  Analyzer, and
Calibration System.
                            25

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                                                              Check
                                                                or
                                                             Comment
2.2.6.3  Filter -

     o  Type:   Internal  	  External

     o  Condition:
     o  Is there a back  purge  on  the  sampling  system
        to clean the probe?  	 Yes     No
     o  If yes,  how often  is  it  activated?
     o  Is the purge air dried  prior  to  use?  Yes     No_

     o  Frequency of Replacement:	
     o  Typical  pressure  drop  across  filter
        (if monitored):      	
     o  Current pressure  drop  across  filter
        (if monitored):      	  	
2.2.6.4  Moisture Removal  (if  applicable):  -

     o  Type of moisture removal  equipment?
          Refrigerated or tube  type  condenser

          Permeation dryer 	

     o  Location:
     o  Sample Gas Temperature at  Outlet  During Audit:


2.2.6.5  Sample Pump -

     o  Type:	

     o  Location: 	

     o  Flow Rate:                              	
2.2.6.6  Heater/Oven (if applicable) -

     o  Location:               	
     o  Temperature of Gas at Outlet
          During Audit (if monitored)
                                    26

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                                                               Check
                                                                 or
                                                              Comment
2.2.6.7  $02 Scrubber System

     o  Location:
     o  Type:
     o  Frequency of change
2.3  CLOSING CONFERENCE

     The closing conference enables the inspector to
"close-out" the inspection with  plant  personnel.  At
this time, questions can also be answered  relating to
results of the inspection.  In general, the  following
elements should be covered in the closing  conference:

     o  Review of Inspection Data  	

     o  Inspection Discussion	

     o  Confidential Information
     o  Deficiencies  in monitoring
        program

     o  Recommendations
                                    27

-------
                         3.0  LEVEL III  CHECKLIST
3.1  INTRODUCTION

     The Level  III inspection,  for the State inspector,  is  the  most
costly and labor intensive.   Level III inspection  becomes necessary  only
when the Level  II inspection indicates deficiencies  in the  CEM  system.
The Level III inspection involves a complete evaluation  of  the  monitoring
system through  a dynamic calibration procedure.  Multiple concentration
gases are injected, as close to the probe tip as possible,  and  the monitor
response is compared to the  certified gas values.   From  this  evaluation,
a calibration error is determined.  If the error falls outside  calibration
drift performance specification values,  then the monitoring system is
"out-of-control."  This would necesitate some form of corrective  action.
3.2  CYLINDER GAS AUDIT

3.2.1  Attach the proper gas line from the certified  gas
       cylinder to as close to the probe tip as  possible.
       Properly adjust the flow rate to manufacturers'
       specifications.
                                   Check
                                     or
                                  Comment
3.2.2  List Certified Gases

       Gas Mixtures:



       Gas A	ppm/%
                   Pollutant

               TRS   02   Other
       Cylinder No.
       Certification Date

       Pressure (psi)
                         Initial
          Final
       Gas B
ppm/%
       Cylinder No. 	
       Certification Date

       Pressure (psi)
                         Initial
          Fi nal
                                    29

-------
       Gas C	

       Cylinder No.
  __ppm/%
       Certification  Date

       Pressure (psi)
                         Initial
               Final
                                                               Check
                                                                  or
                                                              Comment
3.2.3  Inject each gas into the monitoring system,  as  close
       to the probe tip as  practical.   Record  monitor  response
       on Level  III Field Data  Sheet.

3.2.4. Calculate % Difference for each  calibration  gas  by  the
       following equation:
      % Difference =
(Avg.  Monitor  Response)  -  (Audit  value^
            (Audit  Value!
x 100
                                      30

-------
           LEVEL III
        FIELD DATA SHEET
PERCENT DIFFERENCE DETERMINATION
Person Conducting Audit Analyzer Manufacturer
Affiliation Model/Serial No.
Date
Location

Audit Gas Concentration Pollutant Certification Date Expiration Date

Low-Range
Mid-Range
High-Range

Run
Number
1-Low
2-Mid
3-High
4-Low
5-Mid
6-High
7-Low
8-Mid
9- High
10-Low
11 -Mid
12-High
13-Low
14-Mid
15-High


Audit Gas
Concentration
















Instrument
Response
















Arithmetic Mean
Arithmetic Difference
Low

' -
-

-
-

-
-

-
-

-
-

Mid
-

-
-

-
-

-
-

-
-

-

High
-
-

-
-

-
-

-
-

-
-
-


-------
3.3  MONITOR-SPECIFIC INSPECTION PROCEDURES

     If calibration gases are not available,  the  inspector  can  evaluate the
installed TRS CEM system through monitor-specific inspection  procedures.
This involves observing various  operating parameters  as  indicated  by  valves,
meters, pressure gauges or switches.   Observed  values  are then  referenced
to the "baseline" values established  during  monitor certification.

     To assist the inspector, monitor-specific  inspection procedures  have
been developed for three commercially available TRS monitoring  systems.
They are:

     o  Sampling Technology Inc. TRS  CEM Model  100;

     o  Barton Titration TRS CEM System; and

     o  Rendix Gas Chromatograph TRS  CEM System.

     To insure that all information is obtained in an  orderly fashion,
the procedures are presented in  the order they  are normally encountered
in the field, i.e., analyzer/computer system; calibration system,  transfer
system and probe/conditioning system.
                                    33

-------
3.3.1  SAMPLING TECHNOLOGY INC.  TRS CEM SYSTEM INSPECTION  PROCEDURES

3.3.1.1  Analyzer Evaluation

                       Pulse Flourescence  Analyzer
     o  Observe reading of S02 as  displayed  in
        window (reading is  % of monitor range).
            ire to CRT display and computer  printout.
              ti diagram for inspection  points)
                                                          Check    Comment
       ©
           STI
                                                                (Q)
        o  Observe  that  "on"  light  is  illuminated.

        o  Check  positions  of  zero/span  pots
           (potentiometer)  and  compare to
           maintenance  logs.

                               0? Analyzer

        o  Observe  meter display and compare  to  CRT and
           computer printout.

        o  Note position of "Range" switch.
                       Range

        o  Note  "sample flow"  as  indicated  by  rotameter.
           (Should  be  between  400-500  cc/min).
                       cc/min
                                    35

-------
                                                       Check   Comment

Computer

     o  Observe that power light (yellow)  on key
       board is flashing.
     o  Observe that power light (red)  on  screen
       display is on.

     o  Observe that printer "power on  light"
       is illuminated.

     o  Observe that screen "format" is updated
       every 4-!S seconds.

     o  Observe last computer readouts  of  TRS and
       02 and compare  to instantaneous values as
       displayed on nonitor meters.

                 TRS            02
              meter            meter

     o   Observe previous  12 hour report (see  sample).     	


        «»»«f«S«*»*»*S*t**«**»*****t***********************

        TRS 12  HOUR  REPORT -   12:CO:48    JULY   11   1984

        12 HOUR CTRS/O2 CORRECTED3 AVERAGE VALUE  (PPM)
        RCVY  BLR  TRS                         TBS         O2
        CO:CO TO  O1:OO                       .3      5.2
        01:00 TO  O2:OO                       .3      5.0
        02:OQ TO  O3:00                       .3      5.O
        03:OO TO  O4:OO                       .3      4.8
        04:00 TO  O5:OO                       .3      4.7
        O5:00 TO  06:00                       .2      5.2
        O6:OO TO  07:00                       .2      5.2
        O7:OO TO  08:OO                       .3      5.7
        O8:OO TO  O9:OO                      O.O      0.O
        O9:OO TO  10:OO                      0.0      0.0
        1O:OO TO  11:OO                      2.3      6.9
        11:00 TO  1?:00                       .1      14.8
        UNCORRECTED  TRS AVERAGE             ,5
        O2 CORRECTED TRS  AVERAGE           .4
        02 AVERAGE                           6.2
                                  36

-------
where:
           = tne average concentration corrected
             for oxygen;
     Cmeas = the average concentration unconnected
             for oxygen for previous 12-hours;
     X     = the volumetric oxygen concentration in
             percentage to be corrected to (8 percent
             for recovery furnaces and 10 percent for
             lime kilns, incinerators, or other devices);  and
     Y     = the measured 12-hour average volumetric
             oxygen concentration.
                                                          Check   Comment
        Review previous 24-hour printouts observing
        stack gas concentration variation and
        consistency.

        Review previous 24 hour calibration drift
        report and compare to plant standard.
        (See printout below).
     o  Initiate an internal  "zero/span" check or
        monitor system.  Compare to gas cylinder
        \/^il \tr\e*
        valves.

              TRS                  02.
          Gas cylinder        Gas cylinder
             valves              valves
         Monitor response    Monitor response
              % Off                Off

     o  Request "Limits Factors" and compare to
        plant limits.

                o  02  STD	
                o     TRS
                o  02 cal  gas valve


                                   37

-------
                                                         Check   Comment

Dilution Air Conditioning System

        o  Open cabinet door.

        o  Insure pump is running with 30 Ibs  pressure.   	   	

        o  Air pressure regulator should indicate
           60 Ibs pressure.
        o  Listen to insure regenerative dryer
           working properly.

Calibration Gas Cylinder

        o  Check certification of gas cylinders  valves
           and compare to maintenance logs  and computer
           printout.

        o  Check cylinder numbers and compare  to
           certification sheets.

        o  Observe primary/secondary pressure  gauge
           and note setting.   (Normal settings should
           be   300 psi  primary and   40 psi secondary).

              Gas Cylinder #1

                      Concentration
                      Certificate  date	
                      Gauge settings

                             P r i ma ry	
                             Secondary	

              Gas Cylinder #2

                      Concentration	
                      Certificate  date	
                      Gauge settings

                             P r i ma ry	
                             Secondary	

Recorder

        o  Observe emissions over  previous  day.

        o  Inspect previous zero/span readings  and
           compare to gas cylinder valves.
                                    38

-------
                                                              Check   Comment
3.3.1.2  SO? Scrubber System (located behind  monitor  racks)

              o  Check moisture level in reservoir.

              o  Observe that  scrubber is regenerating
                 in a timely fashion (  15 minutes).

              o  Review maintenance logs for  possible drift
                 problems associated with scrubber  system.

                    Positive Drift  - Release  of  S02
                       from packi ng.

                    Negative Drift  - Retention of SO^
                      during daily  zero/span  check.

              o  Review maintenance logs for  periodic
                 changing scrubber  sieves (   30  day
                 intervals).

      Thermal  Oxidizer

              o  Check temperature  display on front of  panel.
                 Should be between  1500-1600°F.  (825-875°C).

              o  Observe that  power light is  on.

              o  Review maintenance logs for  periodic
                 adjustments of thermal  oxidizer temperature.

      Analyzer Rack

              o  Check for power on.

              o  Check all  pressure regulators and relate
                 setting to initial  monitor certification
                 setting in maintenance  logs.

              o  Check sample  by-pass rotameter  (should be
                 1-2 1pm.   However,  this number  depends
                 upon length of sample line.  Initial valve
                 should be recorded  in log book during  certi-
                 fication testing).

      Switch Central  Panel

              o  Check to see  all switches are in "auto"
                 position.

              o  Observe if any red  lights are lit
                 indicating operating mode.

                                          39

-------
                                                                    Check  Comment
        3.3.1.3   Probe/Conditioning  System

              The inspection of the  probe/conditioning  system
        involves both a review of the  maintenance logs  and a
        physical  inspection of the  unit itself.  (Refer to the
        following diagram for inspection points).
 AIR
SUPPLY

 «
                 n-A
                                      .AIR PRESSURE SWITCH
           Jr-7-_	PRESSURE
           TV      KE6ULATOR
         -c^6	
IDUCTOR
                    SUPPLY
   CALIBRATION     VENT
   &Ai TJJLET
                                               40

-------
                                                 Check   Commemt

o  Observe overall  condition  of system.           		

      Vibration Problems                         	  	
      Temperature Problems                       	  	
      Other
   Open cabinet and observe internal
   housekeeping.

      Loose wires
      Condenser di rty
      Other
o  Cal  gas introduced at probe.

o  Observe "back-purge" if applicable.
   Check drain for air/water.

o  Observe automatic calibration cycle.
   (during automatic calibration cycle,  the
    cal  gas is under positive  pressure to probe)
   If a leak in the system occurs,  then  the
   02 valve will  never reach zero.

o  Check "Fault Indicators" on probe
   controller box.  Note.  (Refer to
   following diagram for fault indicator
   location).

      Indication     On/Off

      Power
      Enclosure
      Temperature

      Vaporizer
      Temperature

      Probe
      Restriction

      Air
      Pressure
                            41

-------
8
O
®
PROBE CONTROLLER
O
O
O
O
O
,,
Of
-
POWER
ENCLOSURE
TEMPERMURE
TEMPERATURE
RESTRVCTIDN
AlR
PRESSURE
e
                                                 Check  Comment
o  Check water level  in liquid resevoir,  (should
   not be greater than one-fourth of bowl).

o  Check steam panel  regulator (should be
   between 20-30 psi).

o  Check maintenance records for periodic
   maintenance on system.

      o  Inertial filter changes_
              Lime Kiln (2-4 weeks)
              Recovery Boiler (monthly)

      o  Eductor removed/cleaned
         periodical ly
                            42

-------
 3.3.2  ITT BARTON TITRATION TRS CEM SYSTEM INSPECTION  PROCEDURES

 3.3.2.1  Sampling Module  (Refer to following figure for inspection
 points).
HEAT TRACED
SAMPLE LINE
                                       SAMPLING MODULE
VENT
                                                                   SAMPLE
                                                                  250 CC/tfMN
                                  AMBIENT
                                    AIR
                                 43

-------
                                                         Check  Comment
        o  Observe pressure of condensate resevoir
           regulator.
                       15 psi

        o  Observe LED is lit on panel  of heat trace
           line controller.                               	  	

        o  Observe "reading" of heat-trace line
           controller as displayed by meter.             	  	
           (Temperature indication should be 10-20°F
            higher than the  dew point of the sample gas).

Titration Module (Refer to following figure for inspection points).
       SAMPLE
      250 CC/MIN
                                      TITRATION MODULE
                                                               •CAL. 3AS
                                                                VENT
                                     44

-------
                                                         Check   Comment
        o  Insure the S02 scrubber solution  is  at
           the 5UO ml  mark.

        o  Insure the titration  cell  reservoir  is
           between stamped lines on cell.

        o  Observe following setting of regulators.

              o  Vortex tube supply
                                     80-120 psi
              o  Aspirator Pressure	
                                     35-50 psf

              o  Purge pressure regulator 	     _
                                         "5-TO" psi

        o  Check high volume pump operation by observing
           flow at pump vent point.

        o  Verify heater operation by observing orange
           glow of the element through the observation
           poi nt.

        o  Observe flowmeter setting and compare to
           calibration sheet to insure sample flow
           of 250 cc/mm.
Control  Module  (Refer to following figure for inspection  points).
                                    45

-------
                                                         Check   Comment
        o  Observe range switches.
           is on.
                            Note range monitor
                      Range

        o  Note settings from zero/span/blank.
           Compare to historical  data.

              Zero
              Span
              Blank
                ADJ
                      present
                      present
                      present
           Observe mode switches,
           is illuminated.
                                previous


                                previous



                                previous

                           Note which  mode  switch
                      Mode

     The mode switches (TRS,  BLK,  CELL  CAL  and  AUTO  ) determine the
characteristics of the sample reaching  the  detector  cell.  The mode
switch functions are listed  in the following  Table.
   SWITCH
                  SAMPLE  CHARACTERISTIC
  PWR OFF
  TRS

  BLK
  CAL
  CELL CAL
  AUTO
      Instrument power ON/OFF.
      Sample gas passes through  S02  scrubber,  remainder
      oxidized to S0£.
      Ambient air passes through the charcoal  filter.
      Calibration gas injected  at probe.
      Calibration gas injected  just  before  cell.
      Automatically cycles instrument  through  modes.
        o  Press RAW DATA switch  and  REC  CHK  switch
           simultaneously.   The recorder  should  go to
           min-scale. (Failure to do  so indicates the
           existence of a program in  either the  recorder
           or the control power supply).
RAW DATA Function
        o  Measure the raw data value  in the BLANK  mode.
              RAW DATA

o  Is it within value range?
                 No
                                       Yes
                                   46

-------
                                                 Check  Comment
o  Measure the raw data values in either the
   TRS or CAL mode.
               TRS/CAL
                value

o  Subtract the lowest from the highest value.

o  Observe range switch setting.

o  From the following Table, obtain SO?
   conversion factor.

                  Conversion Factor Data

RANGE
SWITCH
1
2
3
4
5
6
7
S02
CONVERSION
FACTOR
0.035
.82
.26
.75
2.5
7.1
23.

UNITY GAIN
FULL SCALE
3.5
8.2
26.
75.
250.
710.
2300.

FULLSCALE
RANGE
1.0-5.0
5-15
15-50
50-150
150-500
500-1000
1000-3000

RAW DATA
BLANK READING
20 + 8
12 + 4
6 + 3
3 + 1.5
2 + .5
1.5 + .8
0.7 + .4
o  Calculate concentration by multiplying  difference
   between sample and blank values by the  SO?
   conversion factor.
   ppm = (Sample Raw Data - Blank Raw Data)  X  Conversion  Factor
       = (                 -               )  X  (                 )
          Value determined should be within _+  15%.

o  Press CELL CAL mode switch.
o  Note monitor response and compare to gas
   cyli nder value.
      Monitor Response           Gas  Cylinder Value

o  Calculate   % calibration error by the following  equation.

      (Monitor Response)  - (Gas Cylinder Response)
              (Gas Cylinder Response)

o  Calculated value should be _+ 15%.

                           47
X100

-------
3.3.2.2  Probe/Conditioning  System

     The inspection of the probe/conditioning  system involves both a
review of the maintenance  logs  and a  physical  inspection of the unit
itself.  (Refer to following diagram  for  inspection points).
           PROBE
      HtCOVCtr STACK
                                             "I
                               SOLID
                               STATE
                               RELAY
                                                      CAL OAS
                                      NC
                                 1	J
                                              T
                                                 HEAT TRACED
                                                	SAMPLE LINE
                                  THERMOSTAT
                        I          THERMO!

-]--
                                 PROBE
                                   MODULE
                                CONDENSATE
                                  TRAP
                                                        Check  Comment
        o  Observe  overall  condition  of  system.
             Vibrational  Problems
             Temperature  Problems
             Other
        o  Open  cabinet  and  observe  internal
           housekeeping.
                                    48

-------
                                                 Check   Comment
       Loose wires	
       Condenser trap dirty
       Other
o  Observe condensate reservoir,  if possible
   Observe emptying of condensate trap  during
   "blank" mode of operation.

o  During calibration mode,  insure that
   calibration gas injection solenoid  valve
   opens.

o  Is condensate trap frozen?

o  Observe that system back  purges
   periodical ly.

o  Note whether sample line  is  heat traced.
                          49

-------
3.3.3  BENDIX TRS CEM SYSTEM INSPECTION PROCEDURES

3.3.3.1  Analyzer/Calibration Assemblies

     The inspection of the above assemblies  involves  observing  gauges/
flowmeters and comparing their indicated values  to their "baseline"
values.  The observed values may change from week  to  week;  but,  reference
should be made back to the "baseline" value.  The  following figure  illus-
trates the assemblies we will be inspecting.





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                                    51

-------
                                                         Check   Comment

Calibration Gas Cylinder

        o  Check certification of gas cylinders  values
           and compare to maintenance logs and computer
           printout.
        o  Check cylinder numbers and compare to
           certification sheets.

        o  Observe primary/secondary pressure gauge  and
           note setting.  (Normal settings should be
           ^ 300 psi  primary and  ^ 40 psi  secondary).

        o  Note following information on each gas
           cyli nder.

              Gas Cylinder #1

                      Pollutant	
                      Concentration
                      Certificate date_
                      Gauge settings

                             Primary	
                             Secondary_

              Gas Cylinder #2

                      Pollutant	
                      Concentration	
                      Certificate date_
                      Gauge settings

                             P ri ma ry	
                             Secondary_

              Gas Cylinder #3

                      Pollutant	
                      Concentration	
                      Certificate date_
                      Gauge settings

                             Primary	
                             Secondary_

              Gas Cylinder #4

                      Pollutant	
                      Concentration	
                      Certificate date_
                      Gauge settings

                               Primary
                               Secondary_

                                    52

-------
               Gas Cylinder #5
                       Pol 1utant	
                       Concentration	
                       Certificate date_
                       Gauge  settings

                               Primary	
                               Secondary
Support Assembly

     Observe  the following  gauges/me^e-"-. as part  of the Support  Assembly.
All observations should be  reference, -.0 "baseline" values.   (Refer to
diagram for  "p^pection points).

                                   Support A««mo»v
              SotaMMd Onur &rd
              Flow Switch
                                            SwwpAir Ftow
                                            Control Alterably
                                 Ptont Air Souroi
                                 Flow Contra! AMrnbn/
                                                      Baseli ne
                                                        Value
               Sweep Air Flowmeter (A)

               Sweep Air Pressure  Gauge (B)

               Plant Air Pressure  Gauge (C)
Observed
  Value
                                      53

-------
 Calibration Assembly

     Observe the following gauges/meters as part of the Calibration
Assembly.  All  observations should be referenced to "baseline"  values.
(Refer to diagram for inspection points).
                      Zero Air Pressure Gauge
                      Nitrogen Pressure Gauge
                      Calibration Gas Pressure
                      Gauge
                      Oxygen Pressure Gauge
                      Dilution Pressure Gauge
                      Other
                                                   Baseline   Observed
                                                    Value       Value
                                    54

-------
Sample Transport Assembly

        Observe the following gauges/meters  as  part  of  the  Sample
Transport Assembly.  All  observations  should be referenced  to  "baseline"
values.  (Refer to diagram for inspection points).
g—w	M—H	w—M—M—M  M—Ti	H   H   M M"
               So OB    QOOOOO    O   Q oO S,
                   (Dual Gas Stream System Illustrated)
                                                   Baseline
                                                     Value
                      Oxygen Sample Flowmeter (D)

                      Gas Chromatograph Sample
                        flowmeter (E)
Observed
  Value
                                    55

-------
Analyzer Controls and Indicators

     Observe the following gauges/meters as part of the Analyzer Controls
and Indicator Assembly.  All  observations should be referenced  to "base-
line" values.
                                                   Baseline
                                                     Value
                            Observed
                              Value
                      Detector Purge Gauge
                      Plant Air Supply Gauge
                      Heater Air Pressure Gauge
                      S/P Valve Switch On
                      Hydrogen Supply Gauge
                      Column #1 Pressure Gauge
                      Column #2 Pressure Gauge
                      Analyzer Oven Temperature
                      Gauge
                      Calibration Pump Gauge
                      Other
                      Other
Gas Chromatograph System

Type:	
Detection Technique:
Column 1.

       2.

       3.
Column Temperature ( _+ 1°C)  1 ._

                             2.
Sample Column Size:
Detection Temperature:_

Attenuation:
Data Processor/Recorder

        o  Observe emissions over previous day.

              o  Consistent values?
                       Check  Comment
              o  Exceedances?_
              o  Problems?
        o   Inspect previous zero/span calibration
            readings and compare to gas cylinder values,

                                    56

-------
                                                        Check  Comment
        o   Initiate  an  internal  "zero/span" check of
           the  monitor  system.
           Compare to  gas  cylinder  values.
           Cylinder
            Values
Monitor
Response
% Calibration
    Error
      H2S  	

    CH3SH  	

   (CH3)2S  	
   (CH3)2S2_
           (Are  the  calculated  calibration  errors  <  20%?)
(A typi;al  chromatograph  of  a  zero/span  check  is  illustrated  below)
                                    57

-------
          During  the calibration, observe software  report  as  recorded by
     the Data  Printer.  A "typical" printout follows:

          TftS       TRS      H2S      CH3SH   PMS      DMDS     02     OPACIT)
          COP     flEAS
         ,-pc.j-j)    c='PM>     -PPM)   (PPh>      (PPh'J    (PPrt)    <•/£>      (A)
     :i<  *i
      iNt'F;- (•(-•i.A'-n  ?:•
          TOO.      190.     100,     33.00   3? 4 00    54,00    J 0 » 3     J :"< . 6
      v VL.r.'  < f^.^WT  2>
          1^9.      IS*.     10C-.      3?. 00 -  33,00    34,00    10.1    PI,.'
(•I  CALTF:fATln,-i KtT'O^'T

0 M T E I / 2 I / " 9   o -.">; 0 * ; O ^

[i'JJT 0001      S'ACK t1

i - M P i     i\ r       ui.it rv F   <•} e: u  F-: F     •. R F ) % y A K   r c     % J:i RI F T

H2S      ISC      1.65     t-^4        .v^^         27      ,sx
CH3.SH    220      3,87     X,S5        ,f.:^         27
I'MS      1-'90      5..->8     S.63         OX         27
OrtDS     -410       '.12     7.13        .Oiv       ->7
            o  Observe if any hardware/software  alarms have been observed
     over  the previous 24 hours.

     Typical hardware alarms include the following:

            o  Low Zero Gas
            o  Low TRS Span Gas
            o  Low 02 Span Gas
            o  Low Plant Air
            o  Low Sweep Air
            o  Probe Restriction

     Chromatograph related hardware alarms  are:

            o  Low Carrier Gas
            o  Low hydrogen
            o  Oven Hi
            o  Oven Lo
            o  Low Purge Air
            o  Flameout

     Optional system alarms are:
            o  Low Sample Flow
            o  Low Sample Pump Vacuum


                                        58

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                                                         Check   Comment
3.3.3.2  Probe/Conditioning Assembly

        o  Observe overall  condition of system.

              Vibration Problems
              Temperature Problems
              Other 	

        o  Open cabinet and observe internaj
           housekeeping.

              Loose wi res
              Condenser dirty_
              Other
        o  Cal  gas introduced  at  probe?

        o  Observe "back-purge"  if applicable.
           Check drain for air/water.
        o  Observe automatic calibration  cycle,  (during
           automatic calibration cycle, the cal  gas  is under
           positive pressure to probe.  If  a  leak  exists,  then
           the 02 valve will never reach  zero during  cal  gas
           introduction.                                	

        o  Listen for air flow to heat exchanger.        	
        o  Observe reading of Dew Point  meter,  if
           applicable.

        o  Go to opposite side of port and  observe  probe.
                                    59

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                         4.0  LEVEL IV CHECKLIST
4.1  Introduction

     A Level IV evaluation involves a recertification of the installed
GEM system utilizing Performance Specification Test 5 and 3.  The role
of the inspector during this level is to observe that proper sampling
and computation of emissions from the source during testing occurs.  At
this time, additional "baselining" of the control equipment and continuous
emission monitoring system can be performed.

     To assist the inspector, observation checklists have been developed
for both Federal Reference Method 16 and 16A.  The inspector should use
these checklists when performiong a Level IV evaluation.
                                    61

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Federal  Reference Method 16
   Observation Checklist
             63

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                                                         Page	of_


                                                           In i t i aT
                      Federal Reference Method 16
                         Observation Checklist
1.0  BACKGROUND INFORMATION

     1.1  Source Name:	

     1.2  Location:
     1.3  Affected Facility:_

     1.4  Test Dates:	

     1.5  Test Team:	

          Leader:
          Members:
     1.6  Plant Contact:
     1.7  Corporate Contact:

            Phone #	

            Title
2.0  PROCESS DATA

     2.1   Process Tested:
     2.2  Process Description:
     2.3  Process Operating Data:
3.0  TEST EQUIPMENT

     3.1   Sketch system used for sampling and analysis (including
          calibration system).
                                    65

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                                                   Page	of_





                                                     Initial
3.2 - TEST EQUIPMENT DESCRIPTION



      3.2.1   Probe/S02 Scrubber System



      3.2.1  Probe



              Length:	ID:



              Material of Construction:
              Filter Device:   Out-of-stack_



                        In-Stack	



                        Material	



                        Heated?	



      3.2.1.2 SC>2 Scrubber



              Impinger Technique:	



              Solution:
              pH of Solution:
      3.2.2 Sample Lines/Pump



              3.2.2.1 Lines:



                     I.D.:	O.D.:_



                     Material of Construction:	



                     Heated?	



      3.2.2.2 Pump



              Type:	
              Material of Construction:



              Heated:
3.2.3 - Dilution System



              Technique:_
              Dilution Ratio:    1.	 2.	  3.



              Dilution Gas:	



              Heated?	
                            66

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                                                        Page	 of

                                                           Initial

   3.2.4  -  Gas  Chromatograph System

           Type:	___Detection Technique:	

           Column  1. 	

                  2.
           Column  Temperature  (_+ 1°C)   1.
           Sample  Column  Size:
          Detection Temperature:

          Attenuation:	

          Gas Flow:
                     H2 Flow:	
                     Air Flow:

                     N£ Flow	

          Accuracy Range:	
          Detect 0.5 ppm for H2S, MeSH, DMS and DMDS?_
  3.2.5 - Calibration System

  3.2.5.1 - Permeation Technique

  Pollutant    Certification    Permeation    Certification   Traceability
                 Number            Rate         Temperature     Technique
   H?S          	     	    	    	

   MeSH
   DMS
   DMDS
  Analysis  Date              Vendor
H2S = Hydrogen Sulfide; MeSH = Methyl Mercaptan; DMS = Dimethyl Sulfide;
DMDS = Dimethyl Disulfide

                                     67

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                                                          Page	of_
                                                            Initial
        Remarks:
        Constant Temperature Bath  (_+ 1°C)  of  Permeation Tube Certification
        Sheet
        Flowmeter Calibrated?_

                      Date
                      Calibration  Curve
        Flow of Calibration  System greater  than  demand  of Analytical
        System?	

        Bubble Meter used to monitor  flow?	

        Temperature indicator calibrated?	

        Carrier gas prepurified?	^	
        Di scuss
        Diluent Gas -  50ppb S  compounds?	

              lOppm each  of H20 and  HC:	

              Heated prior to mixing?	

3.2.5.2 - Cylinder Gases

        Pollutant    Concentration   Traceability   Analysis    Expiration
        ( in Air)                     to NBS  Per-      Date         Date
                                      meation tube
        Remarks
                                    68

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                                                            Page	of_





                                                             Initial
Greater than 200 psi in gas cylinders?



Vent valve utilized?
3.2.6 - Integrator or Recorder



      Type:	
      Averagi ng Tine:



      Attenuation:
      Last calibration:
4.0 - SAMPLE PORT LOCATION




      Stack/Duct Conditions (leaks, particle build-up, corrosion):










Number of stack diameters upstream from flow disturbance:
Number of stack diameters downstream from flow disturbance:



Velocity Traverses Performed:	__	



       Number of points	



       Locati on	



       Avg. Ap	



       Pitot tube calibration factor	



       Date Calibrated	



       Avg. Velocity	
Stack Temperature Sensor:



      Type:	Range:_



      Location in Stack:
      Date Calibrated:	Calibration Papers Rec'd_



Remarks:
                                    69

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                                                            Page	of_


                                                             Initial
Location of CEM in reference to Sample Port  Location:
5.0   PRE-TEST ACTIVITIES

        System set-up properly?
        System leak check (optional)
             2 inches Hg Vacuum for 1  minute
             Pass	Failed

        All  components operating properly	

        Di scussion:
        Pre-Test Recovery Determined (optional)

        Discussion:
5.1   Interference Determination

        Chromatograph submitted of calibration gases  with/without
        10% C02?	

        Agreement within 5%	
        Chromatograph submitted showing separation of S0.2 from other
        peaks?	.

                              or

        S02 Scrubber System used to remove S0£ prior to GC analysis
                                    70

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                                                            Page	of
                                                             Initial
Chromatograph submitted showing resolution of Sulfur Dioxide ($02),
Hydrogen Sulfide (H2S), Methyl Mercaptan  (MeSH), Dimethyl Sulfide (DMS)
and Dimethyl Disulfide (DMDS):	
Discussion:
  5.2   Calibration of GC/FPD and Dilution System

  5.2.1   GC/FPD Calibration through S02 Scrubber
          Dilution System prior to calibration?
          Permeation tubes in bath  24 hours?
          Calibration Curve developed from three injections
          of three known concentrations of H£S, MeSH,  DMS,
          and DMDS?
          Calibration Curve developed in range data is being collected?
          Precisions of injections for each known TRS within
          + 5% of mean value?
          Temperature of bath +^ 0.1 °C of certification tube
          temperature	
          Calibration Curve Generated?	

  5.2.2   Dilution System

          Injection of H2S in front of Dilution System?_

          Three injections?	
          Precision of three injections _+ 5% of mean  value?_

          Dilution factor calibrated for each stage?	

                        Stage 1  Factor 	

                        Stage 2  Factor 	

6.0   STACK TEST

      Port closed around probe?	

                                  71

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                                                            Page	of
                                                             Initial

        Sample traversed at three  points  in  source  (16.7,  50.0  and  83.3%)
        of stack diameter?	

        Sampling System conditioned 15 minutes  prior  to  test?	
        Sample run consists of a min.  of  16  individual  injections  performed
        over a period of not less than 3  hours  or  more  than  6  hours?
Discussion:
Orsat collected during sample run?
Orsat collection technique and location
                     GAS CHROMATOGRAPH INFORMATION

                     Run  1                  Run  2              Run  3

Date                   	                 	           	

Time Began             	                 	           	

Time End
No. of Injections
or Analysis (min 16)

Ave H2S cone,  ppm

Ave MeSH Cone, ppm

Ave DMS cone,  ppm

Ave DMDS Cone, ppm

Ave TRS Cone,  ppm
as S02

Concentration of
   trace gas
Ave 02 Cone, %         	


                                   72

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                                                            Page	of_


                                                              Initial
7.0 - POST TEST PROCEDURES
        7.1  - Sample Line Loss  - Correction Factor Known  concentration  of
        H2S  injected as close to probe tip  as  possible?	
        Concentration of H2$ generated  at  level  of standard  (+_ 20%)?_
            Generated By:
                     Permeation System
                     Cylinder Gas Dilution_
          Recovery
               20%	(Sample run not to be used)

               20%	(Sample run corrected)


               Recovery Correction Factor	
       7.2 - Recalibration of GC/FPD and Dilution System

             7.2.1  - GC/FPD
                           Known concentration of H2S injected into
                           GC/FPD?                          	
                           Compared to original  calibration curve?_
                           Calibration Drift + 10%?
                           Highest sample values chosen if calibration
                           drift   10%
Discussion:
                                   73

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                                                            Page	of_


                                                             Initial
        7.2.2 -  Dilution System
              Known concentration  of H2S injected  into  front  of Dilution
              System?	

              Compared to  original  calibration  curve?	
              Calibration Drift + 10%?
7.3 - LEAK CHECK

              Sampling system leak checked?_

              Technique?	
8.0 - CALCULATIONS
           Individual concentrations of H2S, DMS, DMDS and MESH Recorded?
           (Oxygen Corrected)
                    Run 1                Run 2              Run 3
                  (avg. ppm)          (avg. ppm)          (avg. ppm)
H2S

MeSH

DMS

DMDS

Total
                                    74

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                                                        Page 	of	


                                                         Initial



9.0 - RELATIVE ACCURACY

        9.1  Calculation                      TRS (ppm)

                                      Run 1          Run 2       Run 3

        Reference Method              	
        TRS Cone. (%02 corrected)     ZHZ         ~HL       HZZ
        CEM TRS Cone.                 	                     '   ~
        (%C>2 Corrected)               	         	       	
        Difference
        Avg. Differences              ~~~
        9.2 % Relative Accuracy =  1x1  + C.I.i
                                    	"'"   xlOO
                                     [RMavg]
                                                        (   20%)
10.0 - SUMMARY
       Are final  results expressed in units  which  satisfy permit  or
       Agency requirements?	
      Does tester have documentation to support  emission  calculations
      (only required on smelt  dissolving tank  vents)?	
                                    75

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                                                        Page	of





                                                          Initial
Brief Summary of Test:
11.0 - AUTHORIZATION



        11.1 - Regulatory Observer



              Observer Signature	



              Title
              Organization_



              Address
              Telephone #  (	)_
        11.2 - Company Observer



                      Company Observer Signature_



                      Title
                      Telephone #	





                                    76

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Company

Address
                           TOTAL  REDUCED  SULFUR
                        FIELD CALIBRATION  DATA  SHEET
                        FEDERAL  REFERENCE  METHOD  16
                                        	Date

                                         Analyst
       	 Sampling  Location



Company Contact	


I.  Permeation Tube Information


                        	PoTTutant
   I_nfo rma t |p_n	J	H^S	J	C H ^ S H
  Tube I. D. #:

 Permeation Rate (PR)



 I •  Cal i brat j_gn_Cu_rye

 Po i n t Jfj_              	
                       j	Area
Time   	
FlowTQl	       1
Known Concentration
   (ppm)              2
H2S:	
CH3SH:	       3
        	
(CH3)2S2j	   Avg.
Poi_nt_£2_

Time    	
Flow fOT	      1
Known Concentration
   (ppm)              2
H2S:	
CH3SH:	      3
(CH3)2S2:	Avg.
                                     Area
                                     77

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Point #3
Time
Known Concentration
  (ppm)
H2S:	
CH3SH:	
(CH3)2S:  J	
                          1

                          2

                          3

                       Avg.
                                            Pollutant  Area
                              H?S
III.
            o n
                         c —
                                 /24.46/if/M-mo/eW T°K \/760 mm Hg
                             (PR)\(M) fJLg/fjL-mole/\^W°K/\P mm Hg
                                               f/min
         Where:     c = concentration, p?/ ( or ppm by volume
                    T = temperature  of the system, °K
                    P = pressure of the system,  mm Hg
                    PR = permeation rate,  fjLg/min
                    Q— total flow rate, liters /min
                    M- molecular weight of the permeating gas,
                    24 .46 = molar volume (V) of any gas at 25 °C & 760 mm Hg,
                                                                                -moli
IV.  Remarks:
                          c =  	
                                       78

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                                                 Page
of
                                                   Initial
V.  Graph Calibration Curve

     Using the graph paper below, graph either the peak area,
peak height or available integrator information for each of the
individual sulfur standards vs. concentration.  Draw the best
fit line through the plotted points and determine source sample
concentration from the established calibration curve.
          5  *  7 I » t
                                   79

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Federal  Reference Method IfiA
   Observation Checklist
              83

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                                                         Page	of	


                                                           Initial
                      Federal Reference Method 16
                         Observation Checklist
1.0  BACKGROUND INFORMATION

     1.1  Source Name:	

     1.2  Location:
     1.3  Affected Facility:

     1.4  Test Dates:	

     1.5  Test Team:	

          Leader:
          Members:
     1.6  Plant Contact:
     1.7  Corporate Contact:

            Phone #	

            Title
2.0  PROCESS DATA

     2.1  Process Tested:
     2.2  Process Description:
     2.3  Process Operating Data:
3.0  TEST EQUIPMENT

     3.1   Sketch system used for sampling and analysis (including
          calibration system).
                                    85

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                                                        Page	Of	

                                                          Initial
4.0   SAMPLE PORT LOCATION
      4.1   Stack/Duct  Conditions  (leaks,  particle build-up, corrosion):

      4.2   Number of stack  diameters  upstream  from  flow disturbance:
      4.3  Number of stack  diameters  downstream  from flow disturbance:
      4.4  Velocity Traverses  Performed:	
                Number of points	
                Locati on	
                Avg. Ap	
                Pitot tube  calibration  factor	
                Date Calibrated	„_____
                Avg. Velocity	__	
      4.5  Stack Temperature Sensor:
                Type:	__ Range:_
                Location in Stack:
                Date Calibrated:	 Calibration  Papers Rec'd_
      4.6  Remarks:	

       4.7  Location of CEM in reference to sample  port location	
5.0    SAMPLE TRAIN PREPARATION
       5.1 - Probe
                 Material  of Construction
                 Heated?	Temperature_
       5.2 - S02 Scrubber System
                 Type	
                 Citrate Acid Buffer Added?
                                   86

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                                                              Page	of





                                                               "TnTtiaT"
               pH of Solution	



               Location of Probe?
       5.3 - Oxidizing Furnace



               Type	
               Material  of Construction



               Tube Dimensions	



               Temperature  _
       5.4 - S02 Impinger Train



                Type
                Hydrogen Peroxide added to Impingers ?



                Qua n t i ty	



                Glass Wool  plug used?
       5.5 - Dry Gas Meter



                 Type	



                 Volume
                 Correction Factor	



                 Date Calibrated	



                 Calibration Papers Revised?	



                 Temperature Measured?	



6.0   PRE-TEST ACTIVITIES



      6.1  - Pre-test leak check (optional)



               6.1.1  Complete sampling train checked:
               6.1.2  Vacuum of 10 inches mercury?
                                       87

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                                                       Page	of
                                                         Initial

        6.1.3   Leak rate   40  cc/min?
        6.1.4  Pump leak checked?	
6.2 - System Performance Check

        6.2.1   Sketch sampling train and  gas  dilution  system.
         6.2.2   List  gases  available,  concentration, traceability,
                analysis  date,  expiration  date  and  gas  cylinder pres-
                sure  (include  information  in  both calibration  gas and
                dilvent gas).
                                88

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                                                           Page	_0f	


                                                              rhTtTal

Pollutant  Concentration  Traceabllity  Analysis    Expiration    Cylinder
                                          Date         Date       Pressure
        6.2.2.1  Dilvent gases contain 50 ppb total  sulphur compound  and
                    IQppm	
        6.2.2.2  Total  HC?
        6.2.2.3  Calibration gases verified by Reference Method  11,  GC/FPD
                 or zinc acetate technique	

        6.2.2.4  Rotometers used in dilution system calibrated?	__
        6.2.2.5  Dry gas meter used in Dilution System calibrated?
        6.2.2.6  Flows measures  by bubble meter?_
        6.2.2.7  Concentrations  generated?_
   6.2.3  System Performance Check Form

        6.2.3.1  Two thirty minute samples  taken?_
                 Date

                 Run I.D.

                 Time Began

                 Time Ended

                 Dry Gas  Meter Volume
                                    89

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                                                    Page	Of_


                                                      Initial
      Volume of Solution (mm 1)

      Volume of Solution
        Titrated (mm 1)

      Volume of Titrant (mm 1)

      Normality of Titrant

      Cone. H£$ Determined

      Cone. H2$ Generated

      % Recovery
6.2.3.2  Within +_ 15% of generated H2S_
6.2.3.3  Two 30-minute samples within + 5% of their mean value?
6.2.3.4  Notes/Remarks:
                                90

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                                                           Page	Of_


                                                              Initial
7.0   SAMPLING
       7.1  - General

               7.1.1   Leak  check  performed  after system performance  check?
               7.1.2  Sample extraction involving  either:  (1)  three  one  hour
                      samples at  20 liters/min?	
                      (2)  One three hour  sample  of  120  liters  intermittently
                          or continuous
               7.1.3  Sampling involves  traversing  stack?
               7.1.4  Oxidizing furnace  maintained  at  850°C?_
               7.1.5  Citrate  buffer solution  adequate?_
                      [Note:   The citrate  buffer  solution  volume  may  change
                      during  sampling  due  to  condensed  water  from sample
                      stream  and  gas  flow  rate.]
       7.2 - Field Data  Required?

             Date

             Run  I.D.

             Time Began

             Time Ended

             Avg. Rotameter reading

             Avg. Dry  Gas  Temperature

             Dry  Gas Meter volume  (ft.)
               7.2.1   Sampling  rate  performed    2.0  liters/minutes  (_+  10%)?
               7.2.2   Post-Test  leak  check  performed?_
                                     91

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                                                           Page	Of_


                                                              Initial

          7.2.3  Impingers containing hydrogen peroxide recovered?

                   - sample recovery bottle labeled?
                   - fluid level indicated on side of bottle?
          7.2.4  Probe/Sample line to SC>2 scrubbers rinsed after each run?
 1.0 - SAMPLE RECOVERY TEST

     8.1 - General
          8.1.1  Was a leak test performed prior to the sample recovery
                 test?	

          8.1.2  Were SC>2 impingers re-charged with hydrogen peroxide?
     List gases available, concentration, traceability, analysis date,
expiration date, date and gas cylinder pressure (include information in
both calibration gas and diluent gas):

                                        Analysis   Expiration   Cylinder
Pollutant  Concentration  Traceability    Date        Date      Pressure
          8.1.3  Diluent gases contain < 50 ppb total sulfur compound?
          8.1.4  Calibration gases verified by Reference Method 11, GC/FPD
                 or Zinc Acetate technique?	

          8.1.5  Rotameters in dilution system calibrated? 	
          8.1.6  Dry gas meter in dilution system calibrated?
          8.1.7  Flows measured by bubble meter?
                                         92

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                                                              Page	of_
                                                                Initial
       8.2  Sample Recovery Test Field Data

            Date                     	

            Run I.D.                 	

            Time Began               	

            Time Ended               	

            Dry Gas Meter Volume(ft3)	

9.0 - ANALYSIS

       9.1  Source Sample
            Run Number
            Dry Gas Meter Volume (ft3)      "
            Volume of Solution (ml)
            Volume of Solution Titrated (ml)"
            Volume of Sample Titrant (ml)
            Normality of Titrant
            Volume of Blank Titrant

       9.2  Sample Train Recovery

            Run Number
            Dry Gas Meter Volume (ft3)
            Volume of Solution (ml)
            Volume of Solution Titrated (ml)
            Volume of Sample Titrant (ml)
            Normality of  Blank Titrant
            Volume of Blank Titrant
                                     93

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                                                             Page	Of	

                                                                TnTtTaT"
10.0  CALCULATIONS
       10.1  Calculate  the  volume of gas sampled corrected  to  standard
             conditions,  for each sample run utilizing  the  following
             equation  (for  Sample and Sample Train  Recovery):
 Where:  Vm(Jtrf) = volume of gas sample through the dry gas meter at standard
                  conditions, dscf
          Vm = volume of gas sampled through the dry gas meter, (cu.ft.)
          Tm = average dry gas meter temperature, (°R)( °F-I-460)
                                     (OR
                                   	
                                   in. Hg

                     528°R
                  29.92 in. Hg

          Y = dry gas meter calibration factor, dimensionless. For our source test,
              we will assume a dry gas meter calibration factor of Y = 1.
          ?6«r = barometric pressure, in. Hg
                                            [<	x	)]
                                            L    (	)    J
                                                 dscf.
                                         94

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                                                           Page    Of
                                                              Ini t ia 1
10.2  Calculate concentration (ppm)  of both  source  sample  and  Sample  Train
      Recovery utilizing the following equation:
                             -    N(V
                             —   	
Where:  C^QJ — emission rate of sulfur dioxide,  opm
         V, = volume of titrant required for sample (mL), Ba(ClO4)i
         Vr4 = volume of titrant required for blank (mL), Ba(ClO4)i
         N = normality of Ba(ClO4)t (meq/mL)
         V*>in = total volume of sample (mL)
         VM(«d) = volume of sample corrected to standard conditions (dscf)
         Va = volume of aliquot titrated (mL)
         K,=  424.30
                 424.30
                                       95

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                                                              Page	of


                                                              TniTTaT
10.0 - SUMMARY
        Are final  results  expressed  in  units which  satisfy permit on
        agency requirements?
        Does Tester have  documentation  to  support emission calibrations
        (only required  on smelt  dissolving  tank  vents)?
Brief Summary of Test
11.0 - AUTHORIZATION

       11.1   Regulatory Observer
               Observer Signature

                 Title	

                 Organization	

                 Address
       11.2  Company Observer^
                  Company Observer Signature
                       Title
                       Telephone #
                                       96

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      FIELD INSPECTION NOTEBOOK
         TOTAL REDUCED SULFUR
CONTINUOUS EMISSION MONITORING SYSTEM
  ABBREVIATED INSPECTION PROCEDURES
                  97

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                        FIELD INSPECTION NOTEBOOK
                          TOTALS REDUCED SULFUR
                  CONTINUOUS EMISSION MONITORING SYSTEM
                    ABBREVIATED INSPECTION PROCEDURES
     Once a thorough evaluation of the TRS CEM system has been accomplished,
control agency personnel may want to perform the next inspection on a less
comprehensive basis.  To assist the control, agency personnel, an abbreviated
inspection procedure checklist has been developed.  The abbreviated check-
list is applicable to all TRS CEM systems.  It does not address monitor
specific inspection points, but does evaluate the TRS monitor on a system
audit basis.  The checklist is divided into three major areas:
     o  Control  agency records review;
     o  Control  agency records update; and
     o  Source TRS CEM system review.
     The control agency records review consists of a review of permits
and/or any current enforcement actions to determine the purpose of the
CEM.  In addition, a review of the PST report and current EER is conducted
to verify conformance with the appropriate performance specification and
reporting requirements for EERs.

     The control agency records update is conducted by telephone to verify
that the records in agency files correctly describe the current CEM status.

     Finally, the source TRS CEM system review evaluates a source's record-
keeping, data reduction procedures, monitor evaluation through zero/span
checks and overall system review.
                                    99

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                                  ABBREVIATED INSPECTION PROCEDURES
                      TOTAL REDUCED SULFUR CONTINUOUS EMISSION MONITORING SYSTEM
                                     CONTROL AGENCY RECORD REVIEW
           SOURCE NAME	
           SOURCE ADDRESS	
           SOURCE CONTACT	
           SOURCE TELEPHONE NO.
           DATE
ACTION
REQUIRED*  1
- PERMIT REVIEW
Is CEM required by permit?
CEM requirement due to:
                                        NSPS
                                        SIP               '_
                                        Enforcement Action^
                                                                         Yes
                                                                   No
               Is CEM installed?
               CEM Installation/startup date	
               Allowable emission rate      	
               Date of source performance test
                                                            Yes
                                                                 No
           2 - CEM PERFORMANCE SPECIFICATION TEST (PST)  REPORT REVIEW

               Dates of PST (<30 days after performance  test)	
               Date PST report submitted (<60 days  after OTP^J~	
               Date of process startup (<180 days prior  to DTP)	
               Date of initial full-load operation  (<60  days  prior to
               Emission Rate Conversion formula
                                            CEM SUMMARY
                                 OPACITY
                                              TRS
               Analyzer
                 Manufacturer
                 Model
                 Serial
               Recorder
                 Manufacturer
                 Model
                 Serial
                 Type
                                         PST REPORT  REVIEW
                                 OPACITY
                                              TRS
               Relative Accuracy
               Calibration  Error
               Response Time
               24 Hr.  Span  Drift
               24 Hr.  Zero Drift
               1   OTP=  Operational  Test  Period
               2   Magnetic  Tape,  Strip Chart, Data  Logger,  Other  (describe)
                                                   101

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                              CALIBRATION  REFERENCE  MATERIAL  REVIEW
ACTION
REQUIRED
OPACITY
Full Span Value
Upscale Value
TRS 0?


Mid _Span Value
Calibration Value
           Gas Value Verification
             RM Triplicate Analysis/Date
             NBS Traceable (Protocol  1)
             Other
           Gas Cell  Value Verification
             Manufacturer/Date
             Comparison to Gas/Pate
             Agency Verification
             Other
           Was stratification evaluated?            Discuss
           Describe monitor locations  (diluent  and  pollutant'
       3 - EXCESS EMISSION REPORT REVIEW

           Months reported
           Did each excess emission report  document:
             Date, time, and duration of excess emissions            Yes	   No
             Magnitude of excess emissions                           Yes 	   No
             Reason for excess emissions                            Yes	   No
           Corrective action taken to reduce emissions               Yes  __   No
           Conversions factor/formula	 Yes 	   No
           Method for determing conversion  or correction  factors
             used in calculating emission rate.
             Moisture content	
             Gas velocity	
             Temperatue	^	
             Diluent gas concentration (Op)
             Corrective action taken to reduce emissions             Yes 	   No
             Briefly discuss corrective action	
             Process downtime                                       Yes 	  No
             Monitor downtime                                       Yes 	  No
             Corrective action taken to return monitor to operation Yes 	  No
             Briefly discuss corrective action	
             What percent availability did the CEM system achieve?_
             (2190 - # hrs. downtime) /2190 = % availability
                                               102

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                                CONTROL AGENCY RECORDS UPDATE
         FIELD REVIEW 	
         TELEPHONE REVIEW
         DATE
ACTION
REQUIRED
        1 - SYSTEM OPERATION 8, MAINTENANCE

            Is monitoring system currently operational?              Yes 	  No
            Is system calibration checked daily?     Automatic
             	Manual                                               Yes 	  No
            Are recommended maintenance schedules/procedures  provided
             by the CEM  manufacturer and followed?                   Yes 	  No
            What group or person is  responsible for CEM maintenance? ^^ ~~~^
            Is manufacturer's recommended spare parts  list  in  plant  inventory;  or  on
             order?                                                  Yes ___  No 	
            Are CEM system malfunctions  documented  to  identify recurring failures
             of components or subsystems?                            Yes 	  No 	

        2 - RECORDKEEPING AND DATA REDUCTION TECHNIQUES

            What are the engineering units  of the data  recorded  by the  CEM  system?
            What data reduction procedure is used in calculating emission rates?

            Over what time intervals are data averaged?
            Are chart  speed,  span  value,  date  and  time  documented?    Yes 	 No
            Where is this  data filed?   On site
                                       Home  office
                                       Other
            Is  the following information  filed  for  the  previous
             two years:
             All  system  calibrations                                  Yes	  No
             All  maintenance performed  on the CEM system              Yes 	  No
             All  CEM  system outages                                   Yes 	  No
             Span gas certified                                       Yes __  No
             Triplicate  reference  method  analysis of  span  gas         Yes 	  No
             PST reports                                              Yes ___  No
             Modifications  to the  CEM system                          Yes 	  No
             Excess Emission Reports                                  Yes 	  No
             Performance  Test Reports                                 Yes 	  No

            Does  span gas value  (gas cell  or neutral  density filter)
            correspond to appropriate subpart requirements?           Yes 	  No
            Are zero  and  span calibration checks performed daily?     Yes 	  No
            Are drift values within performance specification         Yes 	  No
             requi rements?
                                             103

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                                SOURCE TRS CEM SYSTEM REVIEW
        DATE                                SOURCE  CONTACT
        1 - Review records and update inspection procedures.
            Note all  items to which unsatisfactory responses  were  received.   Discuss
            each with source representative via telephone and note status  below.
        2 - Request copies of unreduced CEM system output  including  diluent  gas  and
            process parameter measurements necessary for conversion  to emission  rate
            which correspond to:
            o  an excess emission,
            o  a CEM system malfunction or outage, and
            o  an interval of time during which no excess  emission or CEM  system
               malfunction occurred as determined by the EER  review.

        3 - Request a copy of CEM maintenance log corresponding to a  CEM  system
            malfunction and/or outage reported in EER.

        4 - Request copies of zero and span calibration (generally shown  on  strip
            chart) check.
            After receiving the requested information reduce  CEM data to  units of
            omission standard and compare to corresponding emission  rates  submitted
            on EER.  Refer to appropriate subpart of 40 CFR 60, 40 CFR 51  Appendix  P,
            operating permit or enforcement action for proper data reduction pro-
            cedure and conversion factor.  Review CEM output  during  reported process
            downtime, CEM calibration and monitor malfunction.
ACTION
REQUIRED

 ______      Are EER and agency calculated excess emission  rates     Yes 	  No  	
            the same?
            Do agency calculations of data not reported as excess
 	      emissions indicate compliance?                          Yes 	  No  	
 ~~Was CEM malfunction or outage caused by component or
 	      subsystem failure?                                      Yes ___  No  	
 ^^[^      Was CEM outage scheduled for preventive maintenance?    Yes 	  No  ____
            Do source maintenance and operating records indicate
 	      monitor status and corrective action during outage?     Yes 	  No  	
            Which if any of the following caused the outage:
              - Calibration gas supply,
              - Optical surface condition,
              - Conditioning system,
              - Ai r purge system,
              - Optical alignment,
              - Light source.
              - Other (describe)	


                                            105

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ACTION
REQUIRED
        5 - TRS CEM SYSTEM INSTALLATION INSPECTION

            Is CEM sampling point in a nonstratified  location  (for
            gas monitors)?                                          Yes 	  No
            If so, how was non-stratification verified?  	

            If stratification exists, does  sampling method  and
            location of diluent gas sampling interface provide
            measurement of representative sample?                   Yes ___  No
            Is R.M. sampling point as close as possible  to  CEM  sam-     ~~~
            pi ing point?                             ~               Yes	  No
            Describe access to sampling point.
            Are CEM sampling and analyzing components  free of  excessive
            vibration and extreme ambient temperatures?              Yes   _   No
            Describe location of calibration gas bottles  (if used).
            Are transport and conditioning systems designed  and  in-
            stalled properly to deliver sample which  meets  analyzer
            requirements (temperature, wet,  dry etc)?  Refer to
            manufacturer's operation/maintenance manual              Yes 	  No
            Is calibration gas introduced at or near  the sample
            interface at the proper pressure?                       Yes 	  No
            Are control panel and recorder located in a  controlled
            envi ronment?                                            Yes ___  No
            Is purge air supply clean and dry?                      Yes 	  No

            Transport line details - Conditioning System
            CEM SYSTEM OPERATION OBSERVATION

            Does calibration check indicate satisfactory drift?      Yes 	  No
            Is automatic zero compensation employed?                 Yes	  No
            If so, is zero compensation greater than  4%  (opacity    Yes 	  No
            only) or does reference indicator (if used)  show TRS CEM
            system zero signal to be within specified tolerance  of
            zero reference signal?                                  Yes	  No
            If calibration gases are used, are they introduced to
            the TRS CEM system at the sampling interface?           Yes 	  No
            Are calibration  references (gas cell, gas cylinder,      Yes 	  No
            neutral density filter) of the appropriate value?
                                              106

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ACTION
REQUIRED
            Is recorder span set at  value required  by  the  appropri-
            ate subpart of 40 CFR 60,  or by SIP?                      Yes 	  No
            Is pollutant concentration easily  determined from  record-
            ing device?                                              Yes 	_  No
            Is a zero offset employed?                               Yes 	  No
            If not, how is negative  zero drift quantified? ________

            Are any fault indications  displayed on  control panel?     Yes ___  No
            If so,  discuss.                	
        3 - CEM PROGRAM EVALUATION

            Is an alarm connected to TRS CEM control  panel  to  signal
            excess emissions?                                        Yes 	  No
            How often is CEM output checked  by an operator?	
            What procedures are implemented  during an excess emission
            incident to reduce emissions?
            Are process data measurements conducted  according  to  the
            methods described in applicable NSPS/SIP regulation or
            permit?                                                  Yes	No
            Are changes in calibration reference materials  (gas,
            cell, filter) documented?                                Yes 	  No
            How and how often is emission data reviewed  for validity
            by the source? .___	_	.	
            Are entries into Maintenance and Operations  Logs made in
            relation to monitor:
             Malfunctions                                            Yes 	  No
             Calibrations                                            Yes 	  No
             Maintenance                                             Yes 	   No
             QA Checks                                               Yes 	"  No
                                            107

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       Conversion Factors
International Metric System: Le Systeme International d'Unites (SI Units)
Base Units of the International Metric System (SI)
Quantity
Length
Mass
Time
Temperature
Amount of substance
Name of the Unit
meter
kilogram
second
Kelvin
mole
Symbol
m
kg
s
K
mol
Recommended decimal multiples and submultiples and the corresponding prefixes
and names.
Factor
1012
10'
10s
103
102
10
lO"
10-2
10"
10*«
10"
10-"
IO-"
10-"
Prefix
tera
giga
mega
kilo
hecto
deca
deci
centi
milli
micro
nano
pico
femto
atto
Symbol
T
G
M
k
h
da
d
c
m
f-
n
P
f
a
Meaning
One trillion times
One billion times
One million times
One thousand times
One hundred times
Ten times
One tenth of
One hundredth of
One thousandth of
One millionth of
One billionth of
One triliionth of
One quadrilliomh of
One quintillionth of
                           111

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Conversion from ppm to g/m3 at STP
       «< = 273.15°K
      ?„„=! atm
      g  _
               ppmxM.1
g-mole
                                           1
    dscm       Jiters  x 1(r.
               g-mole     KHL \ 273
293.1S°K\   1
273.15°K /
               x 10* ppm
      Atomic Weights and Numbers
Name
Arsenic
Barium
Cadmium
Carbon
Chlorine
Hydrogen
Iodine
Lead
Nitrogen
Oxygen
Phosphorous
Potassium
Sodium
Sulfur
Symbol
As
Ba
Cd
C
Cl
H
I
Pb
N
O
P
K
Na
S
Atomic
Number
33J
56:
48
6
17
1
53
82
7
8
15
19
11
16
Atomic
Weight
74.9216
137.34
112.40
12.01115
35.453
1.00797
126.9044
207.19
14.0067
15.9994
30.9738
39.102
22.9898
32.064
                             112

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 Volume
From\To
cm1
liter
mj
inj
ftj
cm'
1
1000
1x10-*
16.39
2.83x10-
liter
0.001
1
1000
0.01639
28.32
mj
1x10-
0.001
1
1.64x10-
0.02832
in'
0.06102
61.02
6.10xlO-4
1
1728
ft'
3.53x10-'
0.03532
35.31
5.79x10-
1
Temperature
°O5/9(°F-32)
"F = 9/5 "032
°K=°C + 273.2
°R=°F + 459.7
Conversion factors—ppm vs. /ig/m3.
\vDesired
~. ^vlWtt
Givea\^
unit ^v
Mg/mJ
mg/mj
Puts per million by volume
0,
5.10x10-
—
NO,
5.32 xlO-
—
SO,
3.83x10-
—
H,S
7.19x10-
—
CO
—
0.875
HC
as methane
—
1.53
N. Desired
_. \nnit
Given\^
unit \
ppm
Mg/nv1
0,
1960
NOi
1880
SO,
2610
H,S
1390
mg/m1
CO
1.14
HC
0.654
  To convert a value from a given unit to a desired unit, multiply the given
   value by the factor opposite the given units and beneath the desired unit.
                                      U3

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                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
"l. REPORT NO.

   340/l-85-013b
                                                             3. RECIPIENT'S ACCESSION NO.
 4. TITLE AND SUBTITLE
   Field Inspection  Notebook for Monitorinn
   Total Reduced  Sulfur (TRS)  from Kraft Pulp Mills
            5. REPOR.T DATE
             December  1984
            6. PERFORMING ORGANIZATION CODE
 . AUTHOR(S)

   William T.  "Jerry"  Winberry, Jr.
                                                             8. PERFORMING ORGANIZATION REPOI
19. PERFORMING ORGANIZATION NAME AND ADDRESS

\   Engineering-Science
\   501 Hi Hard Street
;   Durham, NC 27701
                                                             10. PROGRAM ELEMENT NO.
            11. CONTRACY/GRANt NO.'

              68-02-3960
 12. SPONSORING AGENCY NAME AND ADDRESS
   Stationary Source  Compliance Division
   Technical Service  Branch
   Waterside Mall, 401  M Street, S.W.
   Washington,  DC  20460       	
                                                             13 TyJJi OF,flSPORT-ANO PERIOD COVERED
            14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES                                                               /m™-v
   Supplements Technioal_Assistance Document for Monitoring Total Reduced  Sulfur (TRS)
   from Kraft Pulp~MTn.s7~EPA Task Manager-Sonya Stelmack, (202) 382-2851
 16. ABSTRACT
       Field performance audit procedures were  developed for three of the most  common
   total reduced  sulfur (TRS) continuous emission  monitorina systems (CEMS).  These
   procedures were  designed to assist state/federal  field inspectors, in the evaluation
   of TRS-CEMS.   Contained in the notebook are  checklists and data entry tables  covering
   preparation  for  the  inspection, preliminary  review of records, preliminary on-site
   meeting with source  personnel, and general auidelines for inspection of any  type  TRS-
   CEI^S.   Specific  audit procedures for three of the most common models of TRS  CEMS

       -   Sampling  Technology Inc. Model 100 TRS CEM System;
       -   Barton  Titrator TRS System; and
       -   Bendix  Gas  Chromatograph TRS System

   are provided as  sectional  inserts.  In auditing these monitors the inspector should
   follow  the specific  procedure rather than the neneral guidelines given in the body
   of the  field notebook.

       Conscientious  us'e of this notebook will  aid the inspector in conducting  a thorough
   audit of the TRS CEMS and provide a comprehensive original record of all phases of
   the inspection.
 17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                                b.lDENTIFIERS/OPEN ENDED TERMS
                                                                            c. COSATI Field/Group
   Air Pollution

   Monitoring

   Kraft Pulp Mills

   Continuous Emission Monitorina
Opacity Monitoring
  Systems
Audit Procedures

TRS Continuous  Emission
  Monitors
 18. DISTRIBUTION STATEMENT

   Release to  Public
TTncIassiflea
                                                             SS (This Repoi
                                                20. SECURITY CLASS (Thispage}
                                                  Unclassified
                          22. PRICE
                                 _12IL
 EPA F«» 2220-1 (R.v. 4-77)   *»KKVIOU« COITION it OBSOLETE

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