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
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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
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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
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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
-
-
-
-
-
-
-
-
-
-
-
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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
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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
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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
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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.
fYlrS
fHO
^nJ
JUO
• a*
AWK
?n<$
JUO
BUST
:*tto«
^
JJO
M»M^
in.
rS
CAHKrta
***»
!
*
1
^
•*^ ;
L
t
f
:
,
. t
*i *—
r:
itf
i
t
i.
f\
.1
•r
'^'t^MtUMIMII
|L_ i-
£U»I«.MMM**
, 1
1
!
- •"—
•
•UTWMM ktMWMf
1 ' *
'— -
. L.
•MMM |MMM«I
i 1
— *
|
A
j
.
«
»
JL
NK
§ j
&
__ ,
R
U
—i
^f
'
i — i
. .I
: TYi
_/'
fi
__--l
I ^1
0
i
--^
!]•
^
A
"T
C
a
_-,_£
•^ypt
n, • J 4
ju
I"
1
11'
3.
•t
\-'
UlS-J
trf«
Ouu
1 •
*w
M.
•*rf
<+-l
1 **•
h
*«MM
i
. i- •
-.
, -T
1
.L
.[
-L
' n
:ri
1
1
i
l-:l
- 1.
* t
-*.*-
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
-------
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
-------
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
-------
Federal Reference Method 16
Observation Checklist
63
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
Page of
Initial
Chromatograph submitted showing resolution of Sulfur Dioxide ($02),
Hydrogen Sulfide (H2S), Methyl Mercaptan (MeSH), Dimethyl Sulfide (DMS)
and Dimethyl Disulfide (DMDS):
Discussion:
5.2 Calibration of GC/FPD and Dilution System
5.2.1 GC/FPD Calibration through S02 Scrubber
Dilution System prior to calibration?
Permeation tubes in bath 24 hours?
Calibration Curve developed from three injections
of three known concentrations of H£S, MeSH, DMS,
and DMDS?
Calibration Curve developed in range data is being collected?
Precisions of injections for each known TRS within
+ 5% of mean value?
Temperature of bath +^ 0.1 °C of certification tube
temperature
Calibration Curve Generated?
5.2.2 Dilution System
Injection of H2S in front of Dilution System?_
Three injections?
Precision of three injections _+ 5% of mean value?_
Dilution factor calibrated for each stage?
Stage 1 Factor
Stage 2 Factor
6.0 STACK TEST
Port closed around probe?
71
-------
Page of
Initial
Sample traversed at three points in source (16.7, 50.0 and 83.3%)
of stack diameter?
Sampling System conditioned 15 minutes prior to test?
Sample run consists of a min. of 16 individual injections performed
over a period of not less than 3 hours or more than 6 hours?
Discussion:
Orsat collected during sample run?
Orsat collection technique and location
GAS CHROMATOGRAPH INFORMATION
Run 1 Run 2 Run 3
Date
Time Began
Time End
No. of Injections
or Analysis (min 16)
Ave H2S cone, ppm
Ave MeSH Cone, ppm
Ave DMS cone, ppm
Ave DMDS Cone, ppm
Ave TRS Cone, ppm
as S02
Concentration of
trace gas
Ave 02 Cone, %
72
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Page of_
Initial
7.0 - POST TEST PROCEDURES
7.1 - Sample Line Loss - Correction Factor Known concentration of
H2S injected as close to probe tip as possible?
Concentration of H2$ 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
-------
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
-------
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
-------
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
-------
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
-------
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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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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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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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