United SWes
Bwironmental Protection
Agency
Office of Air Qvafity
Ramno, and Standards
Research Triangle Park NC 27711
EPA-456/R-9S001
April 1996
Air
EPA
Used Oil Analysis and
Waste Oil Furnace
Emissions Study
State of Vermont
Department of Fish and Wildlife
Department of Forests, Parks and Recreation
Department of Environmental Conservation
State Geologist
Natural Resources Conservation Council
control * technology center
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EPA-456/R-95-001
Used Oil Analysis and
Waste Oil Furnace
Emissions Study
CONTROL TECHNOLOGY CENTER
Sponsored by:
Information Transfer & Program Integration Division
Office of Air Quality Planning & Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Air & Energy Engineering Research Laboratory
Office of Research & Development
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
AND
Vermont Agency of Natural Resources
Department of Environmental Conservation
Air Pollution Control Division and
Hazardous Materials Division
Waterbury, Vermont 05671
April 1995
U.S. Env'r?hmpnlj! ^-ote^tlon Apency
Region E, :, -..,.-, :., -^:,
77 West Jdc-o .-, n,',,.^ .', ,,.f f
Chicago. II :! ;,,' - V' ^ r'Jf
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EPA REVIEW NOTICE
This report has been reviewed by the U.S. Environmental
Protection Agency and approved for publication. Approval does
not signify that the contents necessarily reflect the views and
policy of the Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for
use.
This document is available to the public through the
National Technical Information Service, Springfield, Virginia
22161, (800) 553-6847.
VI
111
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ACKNOWLEDGEMENTS
Funding for this project was provided by the Control
Technology Center, Vermont Agency of Natural Resources, American
Petroleum Institute, National Automobile Dealers Association,
Vermont Automobile Dealers Association, and Waste Oil Heaters
Manufacturers Association. This report does not necessarily
reflect the views of these organizations and no official
endorsement should be inferred.
This project was managed by Cedric Sandborn and Marc Roy,
Hazardous Materials Management Division, Vermont Agency of
Natural Resources. The success of this project resulted from the
cooperation, dedication and expertise of the Vermont Hazardous
Material Management Division, the Air Pollution Control Division,
and laboratory staffs.
The field testing portion of this effort was managed by
Solomon Ricks, Emissions, Monitoring & Analysis Division,
Environmental Protection Agency, under Contract No. 68D20165,
Work Assignment No. 1-28, with Midwest Research Institute (MRI).
Field testing was conducted under the leadership of Slawomir
Szydlo of MRI's Engineering and Environmental Technology
Division.
In addition, the cooperation and understanding of the
following small businesses which allowed on-site testing of their
waste oil furnaces is greatly appreciated: Clarke's Sunoco; Green
Mountain Kenworth; Walker Motors; Barre Sunoco; Bayview Cadillac;
and Cody Chevrolet.
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PREFACE
The Control Technology Center was established by the U.S.
Environmental Protection Agency's (EPA's) Office of Research and
Development (ORD) and the Office of Air Quality Planning and
Standards (OAQPS) to provide technical assistance to State and
local air pollution agencies. Several levels of assistance can
be provided when appropriate. These include the following:
• CTC HOTLINE provides quick access to EPA expertise,
information, and assistance on matters relating to
control technology (919/541-0800).
• Engineering Assistance Prelects provide more in-depth
assistance to State and local agencies when needed to
address a specific pollution problem or source.
• Technical Guidance Projects address problems or source
categories of regional or national interest by
developing technical guidance documents, computer
software, or presentation of workshops on control
technology issues.
coordinates efforts among EPA centers participating in
the Federal Small Business Assistance Program to assist
State SBAPs.
• International Technical Information Center for Global
Greenhouse Gases provides information on global
greenhouse gas emissions and available prevention,
mitigation, and control technologies and strategies.
• RACT/BACT/LAER Clearinghouse (RBLC) bulletin board
system (BBS) provides access to more than 3,100
pollution prevention (P2) and control technology
determinations addressing over 200 pollutants. Select
the RBLC from the technical BBS menu on the OAQPS
Technology Transfer Center (TTN) BBS (919/541-5742).
• CTC BBS on the OAQPS TTN provides around-the-clock
access to all CTC services, including downloadable
copies of many CTC products. Select CTC from the TTN
BBS Technical BBS menu (919/541-5742).
• CTC NEWS is a quarterly newsletter published by the
CTC. It contains updates on all CTC activities
including the RBLC and Federal SBAP. Call or write the
CTC to get on the CTC NEWS mailing list.
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This CTC project was initiated by the State of Vermont,
Department of Environmental Conservation (DEC), Hazardous
Materials Management Division. The DEC had been directed by the
Vermont General Assembly to conduct a study to characterize the
constituents and properties of used oil generated in the State
and resultant emissions and ambient impacts associated with the
combustion of these oils in small waste furnaces. The results of
this study are to be used in evaluating compliance with and
determining the need to change current State regulations
concerning the combustion of waste oils. The CTC was asked to
participate in this effort by providing stack testing at selected
waste oil furnaces in Vermont and analysis of resultant samples.
The DEC and other supporting groups were responsible for sampling
and characterizing waste oil generated in Vermont, identifying
and selecting furnaces for on-site testing, air modeling and
analysis of ambient impacts, and overall project management.
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REPORT ORGANIZATION
This report is divided into two parts. Part One, "Vermont
Used Oil Analysis and Waste Oil Furnace Emissions Study," is a
reproduction of the report prepared by the Vermont Department of
Environmental Conservation (DEC) for the Vermont General
Assembly. Part Two, "Vermont Used Oil Study Report," summarizes
field test activities and was prepared by EPA's contractor,
Midwest Research Institute (MRI).
Part One provides the following: an excellent summary of the
overall project; data characterizing waste oil and stack
emissions from waste oil combustion; and conclusions and
recommendations concerning policy on the use and combustion of
waste oil in Vermont. Other State and local agencies may find
this part of the CTC report extremely useful as they assess their
own policy on this topic.
Part Two provides the following: a summary of the test
program; facility and sampling location descriptions; test
results; information on sampling and analytical procedures; and
the quality assurance/quality control report. Only Appendices A
and B, List of samples collected and Metal emission results per
facility, respectively, are included in this document.
Appendices C - Sampling data, D - Particulate analysis data,
E - Metals analysis report, F - HCL analysis results,
G - Traceability forms, H - Equipment calibration forms, and
I - Modified Method 5 calculations, are not included in this
document. For the most part, these appendices are copies of
handwritten sampling, laboratory analysis, and calculation forms.
If you need to access the information in Appendices C through I,
call the CTC HOTLINE to request specific appendices.
VII
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PART ONE
VERMONT USED OIL
ANALYSIS AND WASTE OIL
FURNACE EMISSIONS STUDY
Prepared by:
Vermont Agency of Natural Resources
Department of Environmental Conservation
September 1994
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VERMONT USED OIL ANALYSIS
AND WASTE OIL FURNACE EMISSIONS STUDY
September 1994
Prepared by:
Vermont Agency of Natural Resources
Department of Environmental Conservation
Air Pollution Control Division and
Hazardous Materials Management Division
Waterbury, Vermont 05671
With the support of:
U.S. Environmental Protection Agency
Control Technology Center
RTP, North Carolina 27711
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emissions Measurement Branch
RTP, North Carolina 27711
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TABLE OF CONTENTS
List of Tables iii
Executive Summary ,.. iv
1.0 Introduction 1
2.0 Literature Search 2
3.0 Used Oil Sample Collection and Analysis 5
3.1 Used Oil Analysis Results 5
3.2 Conclusions , 7
4.0 Stack Emission Testing... 7
4.1 Stack Emission Sampling Methods 7
4.2 Stack Emission Testing Results 8
4.3 Comparison to Regulatory Levels Under §5-261 of the APCR 9
4.4 Conclusions 13
5.0 Policy Analysis and Conclusions..... 13
6.0 Recommendations 15
Appendices...., , Al
Table A Waste Oil Constituent and Property Regulatory Limits A2
Table B Use Oil Sample Analytical Results (by facility) A3
Table C Waste Oil Furnace Specifications A5
Table D Used Oil Sample Analytical Results from Stack Test Sources. A6
Table E Emission Testing Actual Results for Each Test Run (mg/min) A7
Table F Emission Testing Standardized Results (Ibs/MMBtu) A8
Table G Waste Oil Furnace Operating Parameters , A9
11
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LIST OF TABLES
Table 1 Used Oil Samples Average Analytical Results 6
Table 2 Emission Testing Actual Results (mg/min) 9
Table 3 Comparison to Regulatory Action Levels 10
Table 4 Comparison to Regulatory Hazardous Ambient Air Standards 12
Funding for this study was provided by the U.S. Environmental Protection Agency,
American Petroleum Institute, National Automobile Dealers Association, Vermont
Automobile Dealers Association, Waste Oil Heater Manufacturers Association, and die
Vermont Agency of Natural Resources. Tins report does not necessarily reflect the views
of these organizations and no official endorsement should be inferred.
ui
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Executive Summary
In response to regulatory changes in 1993 and at the direction of the Vermont General
Assembly, the Agency of Natural Resources Department of Environmental Conservation
proposed to conduct a study to characterize the constituents and properties of used oils generated
in the state and the resultant emissions and ambient impacts associated with the combustion of
these used oils in small waste oil furnaces. The study results were intended to determine
whether the combustion of used oil in air atomizing space heaters complied with existing Air
Pollution Control and Hazardous Waste Management Regulations. Based on the results of the
study, the Agency was to make recommendations for any necessary changes in the laws and
regulations.
Used oil samples from 21 sites, including gasoline and diesel vehicle maintenance facilities as
well as do-it-yourself drop off sites, were collected and analyzed to determine the concentrations
of several contaminants known or suspected to be present in used oils. The majority of used oil
samples were collected from gasoline maintenance faculties. These facilities are believed to
represent the largest sector of used oil generation and subsequent burning in the state. The
results of the used oil sample testing revealed higher levels of several contaminants over levels
found in No. 2 home heating fuel oil, including barium, cadmium, chromium, lead, zinc, ash
and halogens such as chlorine and bromine. Some of these contaminants are also found in the
virgin lubricating oil as a result of performance additives and are not necessarily the result of
contamination through the use of the oil. The majority of the used oil samples complied with the
existing waste oil constituents and properties limitations contained in the Vermont Air Pollution
Control (Table A, §5-221(2) APCR) and Hazardous Waste Management Regulations (Table i, §7-606(4)
HWMR).
Stack emissions testing was conducted on several waste oil furnaces to more accurately assess
the emissions from used oil combustion and determine compliance with the recently amended
Control of Hazardous Air Contaminants Rule of the Vermont Air Pollution Control Regulations
(§5-261). Testing was conducted for the following pollutants determined to be of most concern:
hydrochloric acid, total particulates, arsenic, cadmium, chromium, and lead. Stack emission
samples were collected from five atomizing waste oil furnaces currently in service and one No.
2 fuel oil furnace. These waste oil furnaces represent the latest generation of improved units
that are presently in the marketplace. A sample of the fuel being combusted at each site during
the emission testing was also collected and analyzed.
Stack emissions testing results indicated higher levels of several contaminants over that of No.
2 fuel oil. Emissions of hydrochloric acid, total particulates and lead were all higher from the
combustion of the used oils than No. 2 fuel oil. The emission results from these specific units
tested were determined through atmospheric dispersion modeling to comply with their respective
ambient air quality standard contained in the Vermont Air Pollution Control Regulations.
Emissions of chromium were also higher from the combustion of used oil than No. 2 fuel oil
and again were determined to comply with the total chromium ambient standard. Compliance
iv
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or noncompliance with the hexavalent chromium, arsenic, and cadmium ambient standards could
not be demonstrated due to the difficulties with accurately quantifying contaminant
concentrations at the levels necessary. Since the used oil fuels had higher levels of these
contaminants than the virgin fuel, empirically it can be assumed that with similar burning
characteristics there will be higher emissions of these metals from used oil combustion.
However, since the values for most of these metals for both fuels were below detection limits
there does not appear to be definitive justification to treat these fuels in different regulatory
manners with respect to these contaminants.
The fuel analyses and emissions testing clearly shows that used oil combustion has higher
emissions than No. 2 fuel oil combustion for several contaminants. A prohibition on the burning
of used oils would thus have an air quality benefit near facilities currently burning these oils.
However, the emissions from these waste oil furnaces were either able to demonstrate
compliance with the ambient standards or were similar to No. 2 fuel oil in that the contaminants
were present at levels presenting analytical problems with their detection and quantification.
Conversely, a prohibition would also have an adverse economic impact on the facilities currently
burning their used oil for energy recovery. It would also eliminate the incentive for these
facilities to collect do-it-yourselfer oil.
In consideration of these factors, the Agency recommends a policy to conditionally allow the
burning of used oils in small waste oil furnaces. The Agency recommends that used oil
combustion be excluded from the air toxics demonstration for all contaminants except
hydrochloric acid, since, as with No. 2 fuel oil combustion, compliance can not be readily
determined for many of these contaminants. This exclusion would be similar to that already in
existence for virgin fuel oils. Permits would be in the form a general permit for specific makes
and models of waste oil furnaces and would be issued after that specific make and model (not
each installation) has been demonstrated to meet certain requirements, including possible
paniculate and hydrochloric acid compliance testing and being equipped with an air atomizing
burner. Conditions may also be placed on the size of the units, number of units at a facility,
amount of fuel consumed per year, contaminant concentrations and recordkeeping and reporting
requirements. The Agency will also review all current Department regulations and amend
them in one combined rulemaking to ensure there are no longer any inconsistencies between
program regulations. The allowed contaminant concentrations would be reviewed and revised
if necessary. Finally the Agency recommends enhanced information and education outreach
programs be conducted to minimize the contamination of the used oil fuel and to promote the
voluntary re-refining of used oils back into usable lubricating oils.
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1. INTRODUCTION
The environmental benefits and consequences of the combustion of used oils in waste oil
furnaces has been the subject of contentious debate in the state and elsewhere over the past
years. Waste oil combustion is regulated under both the Air Pollution Control Regulations
(hereinafter "APCR") and the Hazardous Waste Management Regulations (hereinafter "HWMR"). The
HWMR (§7-606 through §7-610 HWMR) restrict the burning of waste oils for energy recovery if they
are mixed with hazardous wastes; requiring it to be managed in accordance with federal
regulations (40 CFR §226.30-226.35) unless the waste oil is hazardous solely due to ignitability,
corrosivity, reactivity, or toxicity or if it contains hazardous waste generated only by a
Conditionally Exempt Small Quantity Generator as defined in the HWMR. Waste oil not
restricted by the above is then classified as either specification or off-specification waste oil in
accordance with Table 1 of §7-606 (see Table A of Appendices) which establishes allowable
levels for arsenic, cadmium, chromium, lead, flash point and total halogens in the waste oil.
However, specification and off-specification waste oils may be burned for energy recovery in
small waste oil furnaces less than 500,000 btu per hour.
The APCR prohibit the combustion of waste oils not meeting the constituent and property
limitations as set forth in Table A of §5-221 (see Table A of Appendices). Table A establishes
allowable levels for PCBs, total organic halogens, total inorganic chloride, lead, net heat of
combustion and flash point. In addition, as a result of increasing concerns and a general lack
of detailed information regarding the air quality impacts from the combustion of used oils in
waste oil furnaces, the APCR were amended in January of 1993 making these units also subject
to the Control of Hazardous Air Contaminant rule (§5-261 APCR). The Vermont General
Assembly subsequently passed a bill, S.107, in the spring of 1993 which provided for the
curbside collection of used oils and exempted waste oil furnaces from the Control of Hazardous
Air Contaminant rule. This bill was vetoed by the Governor due in part to concerns over air
quality. The Agency of Natural Resources Department of Environmental Conservation (hereinafter
"Agency") was then directed to study the issue and report on its findings.
During the following 1994 legislative session, bill S.335 was passed and signed into law by the
Governor. This bill exempted small waste oil furnaces from regulation under the Control of
Hazardous Air Contaminant rule (§5-261 APCR) if they were installed prior to January 21, 1994.
The bill did, however, prohibited the sale and use of vaporizing waste oil furnaces or "pot
burners" effective July 1, 1997. The Agency was directed to develop rules creating a general
permit allowing for used oil combustion in small waste oil furnaces and to consider the full
environmental and economic impacts of various options for used oil management. Finally, the
Agency was required to report to the natural resources and energy committees of the House and
Senate the results of this used oil testing program and any recommendations for rules governing
the burning of used oil in small waste oil furnaces.
As a result of the regulatory changes to the APCR in 1993 and at the direction of the General
Assembly, the Agency proposed in August of 1993 to conduct a study to characterize the
constituents and properties of used oils generated in the state and the resultant emissions and
1
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impacts associated with the combustion of these used oils in small waste oil furnaces. The study
results were intended to determine whether the combustion of used oil in these space heaters
complied with existing Air Pollution Control and Hazardous Waste Management Regulations.
The study was divided into three separate phases. The first phase involved a literature search
to identify the contaminants of concern and determine their respective concentrations in used
oils. Due to the highly variable nature of contaminants and their respective concentrations in
used oils and limitations in available existing data, the second phase of the study involved a used
oil sample collection and analysis survey of the used oil streams in the state. The third phase
of the study involved stack emissions testing of several waste oil furnaces to determine the actual
emissions of those contaminants determined to be of greatest concern.
2. LITERATURE SEARCH
The Agency tried to concentrate the literature search on recent studies and reports relating to
waste oil contaminant concentrations and the resultant combustion emissions. A substantial
amount of information was available from the late 1970's and early 1980's. The Agency felt
this data was of limited use, however, due to changes in the waste oil furnaces themselves as
well as waste oil characteristics since that time, such as the gradual phase out of lead in gasoline
and the discontinued use of PCBs in oils as a result of legislation including the 1976 Toxic
Substances Control Act. While the specific data and results of these studies were dated, the
Agency was able to identify potential contaminants of concern that could be addressed in the
next stage of this study.
The literature indicated that the constituents and properties of waste oils can vary considerably
from source to source. Whereas some contaminants in fuel oils and lubricating oils are present
in the virgin stock, waste lubricating oils are often contaminated as a result of their specific use.
Lead levels in waste crankcase oils are attributable mainly to piston blow-by in engines using
leaded gasoline. Arsenic, cadmium and chromium are believed to be largely a result of engine
wear. In addition to being contaminated through use, hazardous wastes such as degreasing
solvents may also be mixed with the waste oils. Lubricating oils also typically have performance
enhancing additive packages such as detergents, dispersants, extreme pressure additives and anti-
wear additives blended into the oils before use. Gasoline and oil additives are also added by the
consumer. Barium, phosphorus, zinc and some chlorine and bromine compounds are present
in lubricating oils in significant concentrations as a result of additives. Numerous other
inorganic compounds are present in used oils such as nitrogen, sulfur, aluminum, calcium,
copper, iron, magnesium, manganese, potassium, silicon, sodium and tin. Many of these
compounds are not generally given much attention due to their low levels and low toxicity.
A private laboratory in the state was able to provide the Agency with copies of the actual results
of waste oil analysis they had performed for facilities over the past several years. While the
constituents and properties analyzed for were limited in scope to those required under the APCR
and HWMR, the data was useful in that it provided current compliance information with respect
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to the waste oil constituent and property limitations contained in the APCR (Table A, §5-221(2)
APCR) and HWMR (Table i, §7-606(4) HWMR). The information indicated that most of the oil
submitted for analysis met the requirements for burning outlined by these regulations. However,
the analyses did not provide information that could be used to determine if burning the used oil
would generate emissions that would comply with the ambient air standards contained in the
Control of Hazardous Air Contaminant rule (§5-261 APCR). This is because the results were often
reported as simply being less than the allowable constituent limitation in Table A or Table 1 of
the applicable regulation and constituent concentrations at that level would not necessarily
comply with the ambient standards. Preliminary modeling using the current allowable
constituent levels indicate that very small amounts of contaminants present in the used oil may
result in emissions that exceed the limit set in the Control of Hazardous Air Contaminants rule.
Another source of information for this phase of the study was the promotional material
developed by the waste oil heater manufacturers. Several news releases and magazine articles
were utilized as sources of information. These articles and releases document the falling lead
concentrations in used oil in the past ten years, due to the phase-out of leaded gasoline.
Based on a review of the available literature, the final list of contaminants in used oil that would
be sampled for in the second phase of this study was compiled. This list consists of the
following:
Metals: arsenic, barium, beryllium, cadmium, chromium, lead, nickel, zinc
Others: Total halogens (HCI formation), total organic halogens (HCI formation), sulfur,
nitrogen, PCBs, and ash.
Arsenic is identified in the HWMR as a regulated contaminant in used oils. The source of
arsenic and the potential concentrations of the contaminant in used oils was not able to be
determined from the literature search that was completed. Therefore, in an effort to obtain more
reliable data on the concentration of arsenic in the Vermont used oil stream and to determine
compliance with the arsenic constituent level in the HWMR, arsenic was selected to be analyzed
for in the second phase of this study. Barium and zinc were identified as possible additives in
lubricating oils and were also selected to be analyzed for in the second phase of the study to
determine their respective concentrations in used oils. Beryllium and nickel are trace metals
found in low concentrations in most oils. No information was available on their concentrations
in used oils therefore these contaminants were also determined to require further analysis in the
next phase of the study. Cadmium is also identified in the HWMR as a regulated contaminant
in used oils and is believed to be mainly from engine wear. Cadmium was analyzed for in the
next phase of the study to determine its concentration in used oils and to determine compliance
with the constituent level in the HWMR.
Chromium is also identified in the HWMR as a regulated contaminant in used oils. The toxicity
of chromium is dependant on the form in which it is present. Chromium may be present in eight
different oxidation states ranging from Cr2 to Cr*6. The most stable and therefore important
forms of chromium are the trivalent (Cr+3) and the hexavalent (Cr+6) forms, respectively.
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Hexavalent chromium is considered the most toxic form of chromium and rarely occurs naturally
but rather is produced by anthropogenic sources such as chrome electroplating and cooling
towers. Hie relevant concentration of trivalent and hexavalent chromium in waste oils was not
determined from the literature search and is of limited value since the combustion of the fuel
would be expected to alter the percentages of each. In addition, since chromium compounds can
be readily oxidized or reduced to other forms under certain conditions, special sampling and
analytical techniques would be required to ensure accurate results. Therefore, only total
chromium was analyzed for in the next phase of the study. These results will be used to
determine compliance with the total chromium constituent level in the HWMR and to determine
if chromium is present in the used oil in high enough concentrations to warrant further study
under the emission testing phase of this study.
Total halogens are regulated under the HWMR and total organic halogens and total inorganic
chloride are regulated under the APCR. The halogens include bromine, chlorine and fluorine.
Chlorine is believed to be the halogen of highest concentration in used oils as a result of
additives to the oil and gasoline. Chlorine is of concern when it is combusted due to the
formation of hydrochloric acid. Total halogens and total organic halogens will be analyzed for
to determine compliance with the constituent levels in the HWMR and APCD. The results will
also give an indication of the chlorine concentration in used oils and therefore the hydrochloric
acid emission potential when burned. A direct analysis for chlorine was not required since it
is not directly regulated as a constituent.
Sulfur and nitrogen in fuels form sulfur oxides and nitrogen oxides respectively when burned,
both of which are regulated air pollutants under the APCR. The sulfur and nitrogen contents
of the used oil and virgin fuel oil samples will be analyzed for in the next phase of the study to
determine if there is any notable difference between the fuels.
Even though PCBs are not expected to be present in the general used oil stream due to their
discontinued use, they will be tested for to verify this assumption. Any electrical transformer
oils thought to still contain PCBs would be expected to be handled separately from the used oil
stream being combusted in small waste oil furnaces. Therefore no transformer oil samples were
collected as part of this study.
The ash content of a fuel refers to the mineral matter that is noncombustible. This would
include silica, iron, other metals, dirt, etc. that may be present in the oils. The ash content
would contribute directly to particulate matter emissions when the fuel is burned. The ash
content will be analyzed for in the next phase to determine if any notable difference exists
between the fuels.
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3. USED OIL SAMPLE COLLECTION AND ANALYSIS
Used oil samples from 21 locations, including gasoline and diesel vehicle maintenance facilities
as well as do-it-yourself drop off sites, were collected and analyzed to determine the
concentrations of the contaminants identified in the previous phase of the study. Since gasoline
vehicle maintenance facilities are believed to represent the largest sector of used oil generation
and subsequent burning, the majority of used oil samples were collected from these facilities.
The facilities included IS automobile service/sales operations, four diesel equipment operations
and two do-it-yourself drop off sites. In addition, virgin lubricating oil samples were purchased
off the shelf, and a sample of No. 2 home heating fuel oil as well as No. 4 fuel oil were
obtained from a commercial facility using these virgin fuels. The sample collection methods are
described in the study proposal dated August 1993.
3.1 Used Oil Analysis Results
Average results of analysis of used oil samples are listed in Table 1. More detailed results for
individual samples are contained in Table B of the Appendices. The table is arranged so that
contaminants in used oil can be readily compared to contaminants in the virgin fuel and
lubricating oil. Samples of virgin lubricating oil were analyzed to determine if contaminants
were present in the oil before use in a vehicle engine. The only metal discovered in substantial
quantity in the virgin lubricating oil was zinc, which is an additive. Barium, cadmium,
chromium, lead, and nickel and ash all appear in higher concentrations in the used oil than the
unused lubricating oil as a result of its use in the engine. These same contaminants as well as
zinc and halogens were all notably higher in the used oil than the fuel oils, with the exception
of the No.4 fuel oil ash content which was comparable to the used oil. There we no notable
differences in sulfur or nitrogen contents between the various oil types. Arsenic and beryllium
were not present in either the virgin oils or used oils in quantities sufficient for reliable
measurement. All samples were analyzed for PCBs, however no PCBs were detected at the
minimum detection limit of the analytical equipment (5 ppm).
The only average contaminant concentration in excess of current constituent standards is the
cadmium in diesel fuel (2.34 ppm; HWMR standard 2.0 ppm). It should be noted that this average is
based on only four diesel samples, and that one sample had a cadmium concentration of 6.61
ppm and the three remaining diesel crankcase oil samples all complied with the 2.0 ppm limit.
Examination of individual results also show that a total of four gasoline crankcase oil samples
also exceed the HWMR cadmium standard of 2.0 ppm. These exceedances simply mean that
the oil would be classified as off-specification oil and not prohibited from being combusted in
a waste oil furnace for energy recovery.
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Table 1
Used Oil Samples Average Analytical Results
contAiuiDJtot
arsenic (ppm)1
barium (ppm)
beryllium (ppm)
cadmium (ppm)
chromium (ppm)
lead (ppm)
nickel (ppm)
zinc (ppm)
ash (% w/w)
PCBs (ppm)
total halogens (ppm)
total organic
halogens (ppm)
flash point (°F)
sulfur (% w/w)
nitrogen (% w/w)
gasoline engine
oil
—
2.73
<0.02
<1.51
3.19
47.23
<1.40
1161
0.54
<5
<350
<301
>200
0.36
0.04
diesel engine
oil
—
3.39
<0.02
2.34
3.91
57.00
1.85
1114
0.46
<5
<234
<217
>200
0.25
0.02
virgin engine
oil
-
<1.00
<0.02
<0.25
<2.00
< 20.00
<1.20
1210
0.135
<5
<300
<292
>200
0.36
0.02
No. 2 fuel oil
-
<1.00
<0.02
<0.25
<2.00
< 10.00
<1.20
5.00
0.13
<5
<200
<200
>200
0.12
<0.01
No. 4 fuel oil
-
<1.00
<0.02
<0.25
<2.00
< 10.00
8.34
9.05
0.55
<5
<200
<200
>200
0.19
0.03
1 arsenic concentrations are not reported due to analytical difficulties with accurately determining arsenic
concentrations at the necessary levels. While the laboratory can quantify arsenic concentrations in oil greater
than 250 ppb, under the procedures of method 3050 some organic arsenic compounds are lost through
volatilization, resulting in poor spike recoveries and the possibility of false negative results. Only one sample
had an arsenic concentration >250 ppb and that concentration was reported as >2 ppm.
The only other constituent standard to be exceeded by an individual sample was lead. In this
case two gasoline crankcase oil samples exceeded the 100 ppm HWMR limit but not the 200
ppm APCR limit, thus the oil would not be prohibited from being burned and would be
considered in compliance. Concentration of the contaminants in the individual samples ranged
as follows: barium < 1.0 ppm to 6.9 ppm; cadmium < 0.25 ppm to 6.6 ppm; chromium <2.0
ppm to 6.8 ppm; lead <20 ppm to 146 ppm; nickel < 1.2 ppm to 3.0 ppm; halogens <200
ppm to 877 ppm.
-------
3.2 Conclusions
The used oils sampled largely demonstrated compliance with the waste oil constituent and
property limitations governing the burning of used oils. In addition, the contaminants barium,
beryllium, nickel, zinc, PCBs, nitrogen and sulfur were not found to be of significant concern
with respect to potential air emissions based on their reported concentrations and respective
toxicity levels. The toxicity of arsenic and the difficulty in obtaining accurate and reliable data
on its concentration in the used oils warrants further study of this contaminant in the next phase
of the study. The concentrations of lead and halogens in the used oils are also high enough to
warrant further study of the potential emissions and impacts on air quality. Cadmium and
chromium concentrations were high enough such that projected emission and ambient impacts
would not comply with the ambient air standards contained in the Control of Hazardous Air
Contaminant rule (§5-261 of the APCR).
4. STACK EMISSION TESTING
Stack emissions testing was conducted on several waste oil furnaces for the contaminants of most
concern. These contaminants were identified from the concentration of contaminants found in
the previous phase of the study and their relative toxicity; these being hydrochloric acid, total
particulates, arsenic, cadmium, chromium, and lead. Volatile and semi-volatile organics were
not considered in this study. Stack emission samples were collected from five existing atomizing
waste oil furnaces currently in service at the selected facilities and one No. 2 fuel oil furnace.
Four of the used oil sites burned predominately waste automotive crankcase oils and the fifth
burned exclusively diesel waste crankcase oils. The units were all of similar size, ranging from
185,000 Btus to 280,000 btus. All units were of the air atomizing type. No vaporizing burners
were tested. The specifications of the units tested are presented in Table C of the Appendices.
Samples of the fuels being combusted were also collected and analyzed for each of the sites and
these results are presented in Table D of the Appendices. Caution should be used in attempting
to correlate used oil contaminant concentrations with emission test results due to the non-
homogenous nature of waste oils and the difficulty in obtaining the exact contaminant
concentrations entering the burner over the test period.
4.1 Stack Emission Sampling Methods
Stack emission samples were collected from the outlet stack for each facility. EPA stack
sampling requirements specify that samples must be collected from a location a minimum of four
stack diameters downstream and one stack diameter upstream of any stack flow disturbance. An
eight inch in diameter by three foot long galvanized stack extension pipe was added to each of
the used oil heater stacks to ensure compliance with this requirement.
Stack emission samples for hydrochloric acid, particulates and metals were all collected in
accordance with EPA's modified method 5 for multiple metals sampling method (MM5-MM,
-------
Draft EPA Method 29 and 0050). Stack gas moisture content, temperature and velocity were
also determined in accordance with this EPA sampling method. EPA method 3B was used for
the determination of stack gas oxygen and carbon dioxide content. Table G of the Appendices
presents the waste oil furnace operating parameters.
To account for the potential cycling of the burner on and off during the test run, the units (which
were all thermostatically controlled) were turned on by setting the thermostat to a point where
the unit would not shut off during the testing. The units were periodically monitored to ensure
that they were running constantly during the testing. The fact that the units would not run
continuously during normal operation and therefore would not have as high of emissions due to
shut-off periods is accounted for in the estimation of ambient impacts discussed later in this
report. A burner that cycles on and off frequently would be expected to have a slightly lower
combustion efficiency than a unit that runs for longer periods of time. However, with respect
to metal emissions and hydrochloric acid formation, this would not be expected to significantly
alter the results. Combustion efficiency would have a more significant effect on organic and
semi-organic emissions which are not addressed in this study. Total particulates could also be
expected to increase slightly with lower combustion efficiency.
Standard stack emission compliance testing requires three one-hour samples runs where the three
runs are averaged to determine compliance. However, due to the relatively small size of waste
oil furnaces in general, the stack sample collection times were extended to ensure an adequate
sample size was collected for analysis. Stack sampling times were extended to four-hours each
and reduced to only two runs per facility. Only facility WO/1 had sample collection times less
than four-hours (two-hours and three-hours respectively). This was due to an increase in the vacuum
pressure required for sampling and a visual inspection of the sampling nozzle which indicated
heavy paniculate loading.
4.2 Stack Emission Testing Results
Average results for the stack emission testing are presented in Table 2. Additional tables
containing the results for each test run for each facility and standardized results in pounds per
btu of fuel combusted for each facility are presented in Tables E and F of the Appendices
respectively. As indicated in Table 2, emissions of hydrochloric acid, particulates and lead were
all significantly greater from the used oil combustion than the No. 2 fuel oil combustion. The
average hydrochloric acid emissions from the used oil combustion were IS times higher than the
No. 2 fuel oil combustion. Lead emissions were 74 times higher from used oil combustion than
No. 2 fuel oil combustion. Paniculate emissions were also much greater from the used oil
combustion, averaging 466 mg/min verses no quantifiable amount of particulates from No. 2 fuel
oil combustion. These results are not unexpected given the contaminant concentrations of
chlorine, lead and ash in the used oils. In addition, the higher molecular weights of the
lubricating oil hydrocarbon chains could be more difficult to completely combust and thus could
result in increased total paniculate emissions.
-------
Table 2
Emission Testing Actual Results (mg/min)
Facility
No. 2 oil
WO/1
WO/2
WO/3
WO/4
WO/5
high2
average2
low2
HC1
(mg/mm)
22.06
556.74
166.48
453.27
192.01
362.73
556.74
346.25
166.48
Paniculate
(mg/min)
0
416.5
333.0
499.5
666.0
416.5
666.0
466,0
333,0
Arsenic1
(mt/min)
< 0.1575
< 0.3577
< 0.1808
< 0.2326
< 0.3821
< 0.1862
<0.3821
<0.2679
<0,1808
Cadmium1
(mi/mm)
< 0.2600
< 0.7070
< 0.3163
< 1.2598
< 0.7941
< 0.6366
< 1.2598
<0.7428
<0.2600
Chromium
(mg/min)
0.2076
1.3235
1.1472
2.1205
2.3153
1.3211
2.3153
1.6455
1.1472
Lead
(fDf/min)
0.2861
15.4974
13.1789
25.7692
27.2374
22.4792
27.2374
20.8314
13.1789
1 Anemic and cadmium results are all reported as mm detectable. The values presented represent the varying levels of
detection for each specific sample collected which is a function of the sample mass.
2 Values are for waste oil testing results only.
Emissions of arsenic and cadmium where not detected in any of the samples despite the
increased sample collection times. The values presented in Table 2 for arsenic and cadmium are
the detection limits for the specific samples collected and vary from sample to sample since the
detection limit is a function of the sample mass and is not a fixed analytical number. Emissions
of chromium were detected in all sample runs, including those for the No. 2 fuel oil, again with
the used oil combustion having higher emissions.
4.3 Comparison to Regulatory Levels Under §5-261 of the APCR
In order to determine compliance with the Control of Hazardous Air Contaminant rule (§5-261
of the APCR), emissions from the waste oil furnaces must first be compared to the regulatory
Action Level for the respective pollutants. These Action Levels are listed in Appendix C of the
APCR and are used to determine applicability to the rule. If emissions of a contaminant exceeds
its respective Action Level, then that contaminant is subject to the rule. Once a pollutant is
subject to the rule its emissions must be demonstrated to be reduced to the Hazardous Most
Stringent Emission Rate ("HMSER"). HMSER is defined in the APCR as the lowest rate of
emissions that the Agency determines is achievable for the source, taking into account
-------
economics. HMSER may be achieved through the application of pollution control equipment,
equipment design changes, operating practice changes or even product substitution. For the
purposes of this study, it was assumed that HMSER would not prohibit the combustion of used
oil in favor of virgin oil. Once HMSER is determined, the source must demonstrate compliance
with the Hazardous Ambient Air Standard if the emissions are still over the Action Level aiiter
achieving HMSER. These standards are also presented in Appendix C of the APCR.
The average milligrams per minute emission results presented in Table 2 above for hydrochloric
acid, chromium and lead were converted to emission in pounds per eight hours for comparison
to the regulatory Action Levels and are presented in Table 3 below. Emissions of particulates
are not compared to an Action Level since particulates are not regulated under the Control of
Hazardous Air Contaminant rule. Emissions of arsenic and cadmium are also not listed in Table
3 since these contaminants were not detected in the samples.
Table 3
Comparison to Regulatory Action Levels
Facility
No. 2 oil
WO/1
WO/2
WO/3
WO/4
WO/5
average3
Action
Level
(Ibt/8hr*)
HC1
(B>/«hr)
0.03
0.59
0.18
0.48
0.21
0.39
0.37
0.87
Paniculate
0b/«hr)
—
—
—
—
—
—
—
—
Arsenic1
-------
As evidenced by the results in Table 3, emissions of hydrochloric acid for all the units tested
did not exceed the regulatory Action Level. The average hydrochloric acid emission from the
waste oil furnaces was approximately one-half the Action Level. Emissions of lead from all the
used oil furnaces did exceed the lead Action Level while lead emissions from the No. 2 fuel oil
furnace did not. Chromium emissions from all the units tested did not exceed the total
chromium Action Level. The hexavalent chromium percentage of the total chromium value was
not determined. According to the U.S. Department of Health's Toxicological Profile for
Chromium (Update) (USDH 1993. lexicological Profile for Chromium (Update). U.S. Department of Health
& Human Services, Agency for Toxic Substances and Disease Registry, Atlanta, GA.) Special Sample Collection
and analytical procedures are required to accurately quantify concentrations of trivalent and
hexavalent chromium in air samples, especially when present at concentrations below 1 ug/m3.
This document indicated that chromium emissions from the combustion of coal and virgin oil
are believed to be emitted predominantly in trivalent forms, however minor amounts of
hexavalent chromium, in the range of 0.2 percent of the total chromium, is also believed to be
emitted. A separate unidentified emission test of an unknown sized multi oil furnace reported
the hexavalent chromium percentage to be approximately 6 percent. If greater than 0.4 percent
of the total chromium is assumed to be in the hexavalent form, the average emission from the
waste oil furnaces tested would exceed the hexavalent chromium Action Level.
If arsenic and cadmium emissions were assumed to be present in the samples at levels just below
the minimum detection limits reported, emission of these contaminants would also exceed their
respective Action Levels by approximately one order of magnitude.
The actual ambient impacts associated with a given emission rate of a contaminant must be
predicted or estimated through the use of atmospheric dispersion models for comparison to the
applicable Hazardous Ambient Air Standard. The atmospheric dispersion modeling requires
certain assumptions in order to estimate ambient impacts from the reported mass per unit time
emission rates determined from the testing. The model inputs include the contaminant emission
rate in grams per second, the stack height and diameter, exhaust gas flow rate, velocity, and
temperature, and the building dimensions where the stack is located. Since the model is used
to estimate the average ground level ambient impact over a period of time equivalent to the
averaging period for the contaminants respective Hazardous Ambient Standard (HC1 24-hours,
lead 3-months, arsenic, cadmium and chromium 1-year), an assumption as to how much fuel
is burned over a given period of time must be made since the units do not operate continuously
at full capacity. The assumption used here is 3,000 gallons of used oil is burned by a facility
in a year and potentially in a three month period as well. It is also assumed that the unit could
operate continuously for a 24-hour period.
The stack parameters used in the modeling are taken from the average stack parameters
determined from the emissions testing and are given in Table G of the Appendices. Since
"building dimensions vary from facility to facility, two different building dimension scenarios
were analyzed. One building was assumed to have dimensions of 40 feet wide, 60 feet long and
IS feet high with a stack 5 feet above the roofline. The second building was assumed to have
dimensions of 40 x 60 and 25 feet high with a stack height again 5 feet above the roofline.
11
-------
The U.S. EPA Screen2 Model was used to predict the ambient impacts. A maximum one-hour
concentration of 4,597 ug/m3 was calculated using the above parameters and assuming an
emission rate of 1 g/sec. This value was then scaled for the various contaminant emission rates
and averaging tunes. The results are presented in Table 4.
Table 4
Comparison to Regulatory Hazardous Ambient Air Standards
Facility
No. 2 oil
WO/1
WO/2
WO/3
WO/4
WO/5
average4
HAAS
(ug/m3)
HC1
(ue/m>)
0.8
i?.r
10.1
13.9
6.0
11.2
11.6
16.7
Paniculate1
(ue/m")
0/0
0.3/12.8
0.2/10.2
0.4/15.3
0.5/20.4
0.3/12.8
0.3/14.3
50/150
17/30
Arsenic2
(nt/m*)
ND
ND
ND
ND
ND
ND
ND
0.00023
Cadmium2
(as/m1)
ND
ND
ND
ND
ND
ND
ND
0.00057
Chromium3
(««V>
0.000151
0.000964
0.000836
0.001545
0.001687
0.000963
0.001199
0.12 (total)
0,000085 +6
Lead
OH/m')
0.00
0.07
0.06
0.12
0.12
0.10
0.09
0.25
1 Particulate matter emissions are regulated separately from the hazardous air pollutants under the Vermont Air
Pollution Control Regulations. There is an annual and 24 hour averaging period National Ambient Air Quality
Standard for paniculate matter (PM10). The values given in the left and right side of the column represent
annual and 24 hour impacts respectively with the NAAQS and full PSD increments given in the bottom row.
2 Arsenic and cadmium results were all reported as non detectable,
5 Chromium results all comply with the total chromium HAAS, however since the actual percentage of
hexavalent chromium is not known, compliance with the hexavalent chromium HAAS can not be determined.
4 Values are for waste oil testing results only.
* Value exceeds HAAS.
The results indicate that emissions of hydrochloric acid from the waste oil furnaces on average
comply with the Hazardous Ambient Air Standard, however one facility (WO/1) did not comply.
The results also indicate that all the facilities complied with the lead Hazardous Ambient Air
Standard. Chromium emissions from all the units complied with the total chromium Hazardous
Ambient Air Standard. However since the actual hexavalent chromium percentage is not known
with any certainty, compliance or noncompliance with the hexavalent chromium Hazardous
Ambient Air Standard can not be demonstrated. If less than 7 percent of the total chromium is
12
-------
assumed to be in the hexavalent form, the average emission from the waste oil furnaces tested
would comply with the hexavalent chromium ambient standard.
If it is again assumed that arsenic and cadmium were present in the emission testing samples at
levels just below the minimum detection limits, WO/1 and WO/4 would exceed the arsenic
Hazardous Ambient Air Standard by a factor of 1.1 and 1.2 respectively and WO/3 and WO/4
would exceed the cadmium Hazardous Ambient Air Standard by a factor of 1.6 and 1.02
respectively. Since it is not known what concentrations these contaminants are actually present
at below the minimum detection limits, compliance or noncompliance with the respective
ambient standards can not be determined.
Paniculate emissions from the combustion of waste oil are not regulated under the Control of
Hazardous Air Contaminant rule, however these emissions are regulated under a separate section
of the APCR. Paniculate emissions from small fuel combustion sources are regulated under §5-
231(3)(a)(i) of the APCR which limits emissions to 0.5 pounds per hour per million Btu. All
of the units tested demonstrated compliance with this limitation as shown in Table F of the
Appendices. Paniculate matter ambient impacts are also limited for each source in accordance
with the National Ambient Air Quality Standards (§5-304 through §5-306 of the APCR) and the
Prevention of Significant Deterioration increments (Table 2 of the APCR). The paniculate matter
ambient impacts from the units tested demonstrated compliance with these standards and
increments.
4.4 Conclusions
The results of the emission testing show that the combustion of these used oils in small waste
oil furnaces have higher emissions of several contaminants than the combustion of No. 2 home
heating fuel oil. Emissions of hydrochloric acid, particulates and lead were all notably greater
from used oil combustion than No. 2 fuel oil combustion. Despite these elevated levels, the
average results of the emissions testing on these specific units for these three contaminants
demonstrated compliance with the applicable ambient standards. Chromium emissions from all
the units tested demonstrated compliance with the total chromium ambient standard. However
since the actual hexavalent chromium percentage is not known with any certainty, compliance
or noncompliance with the hexavalent chromium ambient standard can not be demonstrated.
Similarly for arsenic and cadmium, compliance or noncompliance with the respective ambient
standards can not be determined.
5. POLICY ANALYSIS AND CONCLUSIONS
The policy decision to allow the continued use of used oil fuel in space heaters is based on an
analysis of the emission testing results, the economic impact to the generators and users of used
oil, and alternative disposal methods available to generators of used oil.
The fuel analyses and emissions testing clearly shows that used oil combustion has higher
13
-------
emissions than No. 2 fuel oil combustion for several contaminants. A prohibition on the burning
of used oils would thus have an air quality benefit near facilities currently burning these oils.
However, since the emissions from these waste oil furnaces were either able to demonstrate
compliance with the ambient standards or were similar to No. 2 fuel oil in that heavy metal
contaminants (except lead) were present at levels presenting analytical problems with their
detection and quantification, it would not be prudent public policy to regulate these fuels
differently based on these emissions. It is extremely difficult to quantify the overall impact of
used oil combustion since the number and distribution of used oil furnaces currently operating
in the state is unknown. While an adverse impact to air quality does occur, the on-site
management of used oils for energy recovery reduces the potential for other environmental
impact caused by spills, improper disposal, and vehicle emissions generated during transport of
the used oil off-site.
Economic impact to burners is possible to quantify, using assumptions about costs for disposal
of used oil, costs for virgin fuel oil, and the amount of oil generated by a facility. For
example, a facility that generates 1000 gallons of used oil per year and burns that oil on-site
could save $900 in fuel costs, and $200 in disposal costs per year (assuming the cost of virgin
fuel oil at $.90/gallon and disposal costs of $.20/gallon). In contrast, if a facility that currently
bums used oil on-site has to discontinue the practice, they would incur costs of $1100 in fuel
and disposal costs in addition to their operating expenses. In addition, there is a potential risk
that generators may improperly dispose of their used oil if they are unwilling or unable to accept
the financial responsibility of proper disposal.
The economic benefit to used oil burners may be an incentive for facilities to accept used oil
from do-it-yourselfers (DIY). Facility acceptance of used oil as "free fuel" provides a disposal
option to DIY, and may reduce improper disposal of DIY oil.
There are currently three primary disposal options available to generators of used oil in
Vermont. The disposal method used by most generators (384,000 gallons in 1993) is shipment
out of state for fuel blending and subsequent burning for energy recovery by industrial facilities.
The second option is shipment to a re-refinery. In 1993 approximately 20,000 gallons were
collected and shipped to out of state re-refineries in either Illinois or Ontario, Canada. The final
disposal option available is on-site burning for energy recovery. The amount of used oil
disposed of in this manner is currently unknown as there are no accurate records of the number
of these facilities or how much each facility generates.
Based on the current market distribution of used oils being disposed of, a prohibition of on-site
burning would likely result in only a small increase in the amount of used oil being re-refined
if the market share proportions were assumed to remain unchanged between out of state shipment
to industrial facilities and re-refining. Mandating re-refining with the intent of attracting a re-
refinery to the area may not be practicable without governmental assistance or incentives given
the relatively small amount of used oil generated in Vermont.
14
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6. RECOMMENDATIONS
In consideration of the level of emissions resulting from used oil combustion, the economic
impacts to the facilities currently burning their used oil, and current disposal practices and their
respective share of the used oil disposal market, the Agency recommends a policy to
conditionally allow the burning of used oils in small waste oil furnaces. The Agency offers the
following recommendations for achieving this end.
A. Issue general permits for specific makes and models of waste oil furnaces after
the units have been demonstrated to meet certain minimum requirements,
including paniculate and hydrochloric acid air toxic compliance testing and being
equipped with an air atomizing burner. Used oil combustion would be excluded
from all other air toxics demonstrations, since, as with No. 2 fuel oil combustion,
compliance can not be readily determined for many of these contaminants. This
exclusion would be similar to that already in existence for virgin fuel oils.
Conditions may also be placed on the size of the units, number of units allowed
at a facility, amount of fuel consumed per year, contaminant concentrations and
recordkeeping and reporting requirements.
B. Amend current rules regulating used oil through one combined rulemaking to
assure that there are no contradictions between Federal and State rules; and so
there are no contradictions in rules within the Department of Environmental
Conservation (DEC). Currently, there are three separate Divisions within DEC
that regulate used oil (Air Pollution Control Division, Hazardous Materials
Management Division, and Solid Waste Management Division). These
amendments include, in part, an examination of the current allowable contaminant
levels for oil that is burned. The goal of this examination is to determine if
current levels should be reduced for selected contaminants. The allowed levels
will be set to ensure compliance with air quality goals while facilitating
compliance with material standards.
C. Enhance information and education outreach programs to generators of used oil,
to ensure that the oil is not contaminated with hazardous constituents and to
promote the voluntary re-refining of used oils back into usable lubricating oils.
This includes the development of specific quality assurance plans to be used
where oil is collected for combustion.
15
-------
APPENDICES
Table A: Waste Oil Constituent and Property Regulatory Limits
Table B: Used Oil Sample Analytical Results (by facility)
Table C: Waste Oil Furnace Specifications
Table D: Used Oil Sample Analytical Results from Stack Test Sources
Table £: Emission Testing Actual Results for Each Test Run (mg/min)
Table F: Emission Testing Standardized Results (Ibs/MMBtu)
Table G: Waste Oil Furnace Operating Parameters
Al
-------
Table A
Waste Oil Constituent and Property Regulatory Limits
oil constituent/property
unit size
PCBs
halogens
total organic halogens
total inorganic chloride
total halogens
lead
net heat of combustion
flash point
arsenic
cadmium
chromium
APCR
1 MMBtu (max)
50 ppm (max)
500 ppm (max)
1,000 ppm (max)
200 ppm (max)
8,000 btu/lbs (min)
140°F (min)
—
—
—
HWMR
no limit for spec oil
500,000 Btu off-spec (max)
50 ppm (max)
4,000 ppm (max-spec)
100 ppm (max-spec)
—
100°F (min-spec)
5 ppm (max-spec)
2 ppm (max-spec)
10 ppm (max-spec)
A2
-------
s-
used oil
type
diesel
diesel
diesel
diesel
duplicate
diesel
gasoline
gasoline
gasoline
gasoline
gasoline
gasoline
duplicate
gasoline
gasoline
gasoline
gasoline
gasoline
gasoline
gasoline
DIY
arsenic
(ppm)
-
>250
-
-
-
-
.
.
.
.
-
-
-
.
.
.
.
.
-
Table B
Used Oil Sample Analytical Results (by facility)
barium
(ppm)
2.240
3.420
2.340
3.030
5.900
2.610
1.650
3.380
2.490
3.170
1.890
1.620
<1.00
1.890
4.480
1.400
1.940
4.980
6.990
beryllium
(ppm)
< 0.020
< 0.020
< 0.020
< 0.020
<0.020
<0.020
< 0.020
< 0.020
< 0.020
< 0.020
< 0.020
< 0.020
< 0.020
< 0.020
< 0.020
< 0.020
< 0.020
<0.020
< 0.020
cadmium
(ppm)
1.040
6.610
0.847
-
0.855
1.610
1.210
1.340
1.470
1.240
1.260
2.520
1.130
< 0.250
2.180
< 0.250
0.506
1.830
0.711
chromium
(ppm)
2.970
6.850
3.500
3.810
2.400
4.230
2.690
3.520
4.100
3.040
3.450
2.320
<2.00
2.870
3.000
2.120
3.000
4.210
3.020
lead
(ppm)
146.0
41.90
23.60
33.80
39.70
57.10
22.30
58.70
44.70
42.30
38.40
50.20
51.70
84.00
47.90
<20.
42.60
40.20
104.0
nickel
(ppm)
1.590
1.050
3.020
2.370
<1.20
1.430
1.190
1.600
<1.20
<1.20
<1.20
1.830
1.590
<1.20
1.500
<1.20
1.000
1.720
1.540
zinc
(ppm)
1120
2370
568
790
724
1160
1230
1150
1180
1180
1300
1100
1190
1310
1120
1150
1010
867
1090
ash
(% w/w)
0.461
0.370
0.406
0.516
0.523
0.592
0.685
0.517
0.521
0.473
0.399
0.870
0.417
0.528
0.317
0.533
0.834
0.486
0.457
PCBs
(ppm)
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
TX
(ppm)
226
<200
<200
<200
342
230
239
217
<200
309
297
877
<200
<200
622
<200
<200
<200
352
TOX
(ppm)
<200
<200
<200
<200
283
<200
<200
218
<200
<200
252
568
<200
<200
598
<200
<200
<200
240
flash
point
CF)
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
Sulfur
(*w/w)
0.411
0.224
0.212
0.133
0.260
0.345
0.395
0.445
0.396
0.303
0.448
0.460
0.331
0.359
0.334
0.337
0.406
0.287
0.250
N
(% w/w)
0.015
0.029
0.021
0.022
0.017
0.054
0.057
0.041
0.054
0.038
0.063
0.046
0.032
0.041
0.063
0.038
0.040
0.027
0.027
A3
-------
\
used oil
type
gasoline
gasoline
duplicate
DIY
gasoline
gasoline
duplicate
gasoline
v. lube
v. lube
No. 2
No. 4
high
•v««tf
avggas
avgdiet
tow
srsenk
(ppm)
.
-
.
.
-
-
..
.
-
-
.
*
-
.
-
barium
(ppm)
2.040
1.810
2.340
4.040
3.680
1.260
<1.00
<1.00
<1.00
<1.00
6.990
2.864
3,733
3.386
<1,00
beryllium
torn)
< 0.020
<0.020
< 0.020
< 0.020
< 0.020
<0.020
<0.020
<0.020
<0.020
< 0.020
<0.020
<0.020
<0.020
<0.020
<0.020
cadmium
(ppm)
3.330
2.720
0.490
2.640
2.410
1.190
< 0.250
< 0.250
< 0.250
<0.250
6.610
1.652
1.514
2.338
<0.250
chromium
(ppm)
3.980
3.130
2.820
2.910
3.620
3.760
<2.00
<2.00
<2.00
<2.00
6.850
3.333
3.190
3.906
<2.00
lead
(ppm)
41.30
35.80
57.50
40.20
34.70
31.00
<20.0
<20.0
<10.0
<10.0
146.0
49. IS
47.23
57.00
<20.0
nickel
(ppm)
1.290
1.800
1.320
1.400
1.780
1.000
<1.20
<1.20
<1.20
8.340
3.020
1.484
1.400
1.846
1.00
zinc
(ppm)
1140
1230
1240
1130
1130
1330
1270
1150
5.00
9.05
2370
1152
1161
1114
568
&sh
(* w/w)
0.516
0.486
0.432
0.556
0.616
0.627
0.151
0.119
0.125
0.549
0.870
0.525
0.543
0.455
0.317
PCBs
(ppm)
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
TX
(ppm)
577
799
216
432
424
<200
<200
400
<200
<200
877
<327
<3SO
<234
<200
TOX
(ppm)
586
591
202
454
301
<200
<200
385
<200
<200
598
<284
<301
<217
<200
flash
point
CF>
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
>200
sulfur
(*
W/W)
0.243
0.370
0.316
0.317
0.384
0.404
0.328
0.400
0.118
0.186
0.460
0.335
0,357
0.248
0.133
N
(% w/w)
0.041
0.019
0.040
0.052
0.047
0.055
0.019
0.016
<0.01
0.033
0.063
0.039
0.044
0.021
0,017
1 arsenic concentrations an not reported due to analytical difficulties with accurately determining arsenic concentrations at the necessary levels. While the laboratory
can quantify anenk concentrations in oil greater man 250 ppb, under the procedures of method 3050 some organic arsenic compounds are lost through volatilization,
resulting in poor spike recoveries and the possibility of false negative results. Only one sample had an arsenic concentration >250 ppb and that concentration was
reported as >2 ppm.
2 does not include virgin lube oil or virgin fuel oil samples.
-------
Table C
Waste Oil Furnace Specifications
Facility
No. 2 oil
WO/1
WO/2
WO/3
WO/4
WO/5
Make
Oneida Royal
Shenandoah
Clean Burn
Clean Burn
Clean Burn
Clean Burn
Model
0-224B-5
200
CB86AH
CB86BH
CB86BH
CB90AH
Burner
Beckett-AF AK-
076880
Shenandoah GB3.SO
Clean Bum CB85HS
Clean Bum CB85HS
Clean Burn CB8SHS
-
Size Input
(btu/hr)
280,000
235,200
185,000
280,000
280,000
185,000
gph
2
1.68
1.33
2.0
2.0
1.3
oilpsi
7
9
1
3.5
3
-
A5
-------
Table D
Used Oil Sample Analytical Results for Stack Test Sources
Facility
No.2 oil
WO/1
WO/2
WO/3
WO/4
WO/5
high1
average2
fcw*
arsenic1
(ppm)
.
.
»
.
.
-
•M
-
44
barium
(PP»)
<1.00
3.43
<1.00
1.75
(3.40
2.14
63.40
14.34
1.00
cadmium
(ppm)
<1.00
1.20
<1.00
1.75
<1.00
2.14
2.14
200
189
88
>200
91
>200
-
68
1 anenic concentrations an not reported due to analytical difficulties with accurately detennining arsenic concentrations at the necessary levels. While the laboratory can quantify
anenk concentrations in oil greater than 250 ppb, under the procedures of method 3050 some organic arsenic compounds are lost through volatilization, resulting in poor spike
recoveries and the possibility of false negative results.
2 Values are for waste oil testing results only.
3 The waste oil samples were analyzed by two separate laboratories for flash point.
A6
-------
Table E
Emission Testing Actual Results For Each Test Run (mg/min)
Facility
No. 2 oil
WO/1
WO/2
WO/3
WO/4
WO/5
Mgtf
average1
low2
HC1
(mg/min)
25.59
18.54
527.54
585.94
187.20
145.76
689.45
217.10
205.20
178.83
403.29
322.17
689.45
346.25
145.76
Paniculate
(mg/mm)
0
0
500
333
333
333
666
333
666
666
500
333
666
466
333
Arsenic1
(nog/mm)
< 0.1440
<0.1711
< 0.4821
< 0.2334
< 0.2086
< 0.1530
< 0.2729
< 0.1923
< 0.5 146
< 0.2496
<0.1816
< 0.1908
ND
ND
ND
Cadmium1
(mg/min)
< 0.1898
< 0.3303
< 0.6746
< 0.7394
< 0.3539
< 0.2787
< 1.8823
< 0.6374
< 0.9082
< 0.6800
< 0.6846
< 0.5886
ND
ND
ND
Chromium
\D|/IDID.)
0.1799
0.2353
1.5058
1.1412
1.2877
1.0067
3.3122
0.9288
2.7568
1.8738
1.4720
1.1702
3.3122
1.6455
0.9288
Lead
(mg/min)
0.2678
0.3044
15.7770
15.2179
14.7055
11.6523
38.2937
13.2447
29.1728
25.3021
25.9929
18.9555
38.2937
20.8314
11.6523
1 Arsenic and cadmium results are all reported as non detectable. The values presented represent the varying levels of
detection for each specific sample collected which is a function of the sample mass.
2 Values are for waste oil testing results only.
A7
-------
Table F
Emission Testing Standardized Results (Ibs/MMBtu)
Facility
No. 2 oil
WO/1
WO/2
WO/3
WO/4
WO/5
high*
average1
tow2
HC1
Gbs/mmbtu)
0.0170
0.2768
0.1807
0.3314
0.1404
0.2594
0.3314
0.2378
0.1404
Paniculate
(Ibs/mmbtu)
0
0.2071
0.3621
0.3654
0.4872
0.2766
0.4872
0.3397
0.2071
Anenic1
(Ibs/mmbtu)
<0.00012
<0.00018
< 0.00020
<0.00017
< 0.00027
< 0.00013
ND
ND
ND
Cadmium'
(Ibs/mmbtu)
<0.00017
< 0.00036
< 0.00030
<0.00091
< 0.00057
<0.00045
ND
ND
ND
Chromium
(Ibs/mmbtu)
0.00016
0.00066
0.00125
0.00154
0.00169
0.00094
0.00169
0.00120
0,00066
Lead
(Ibs/mmbtu)
0.00022
0.00771
0.01434
0.01884
0.01992
0.01606
0.01992
0.01530
0.00771
1 Arsenic and cadmium results are all reported as non detectable. The values presented represent the varying
levels of detection for each specific sample collected which is a function of the sample mass.
2 Values are for waste oil testing results only.
A8
-------
Table G
Waste Oil Furnace Operating Parameters
Facility
No. 2 oil
WO/1
WO/2
WO/3
WO/4
WO/5
average1
Temp
(°F °C)
446/230
479/248
516/269
475/246
274/134
426/219
470/243
618/326
358/181
385/196
287/142
305/152
411/210
Moisture
(%by
vol)
9.0
9.1
2.2
2.0
1.9
3.1
7.6
8.8
4.6
0.1
4.4
5.1
4.0
Flow Rate
(acfin
acmm)
160/5
154/4
267/8
285/8
258/7
212/6
177/5
111/3
288/8
253/7
205/6
151/4
221/6.2
Velocity
(ft/min
m/jnin)
457/139
440/134
766/233
816/249
740/226
608/185
507/155
317/97
826/252
725/221
587/179
434/132
633/193
Oxygen
(%by
vol)
8.2
8.2
9.0
2.6
11.2
11.3
11.4
11.0
15.2
15.2
11.4
10.8
10.9
Stk
diam.
(in m)
8/0.203
ff
M
II
ft
*t
ft
m
m
«
it
M
8/0.203
unit size
(Mbtu/hr)
280
235
185
280
280
185
Values are for waste oil testing results only.
A9
-------
PART TWO
VERMONT USED OIL STUDY
REPORT
Prepared by:
Midwest Research Institute
Prepared for:
Control Technology Center
U.S. Environmental Protection Agency
NOTE: Appendices C - Sampling data, D - Particulate analysis
data, E - Metals analysis report, F - HCL analysis results,
G - Traceability forms, H - Equipment calibration forms, and
I - Modified Method 5 calculations, are not included in this
document. For the most part, these appendices are copies of
handwritten sampling, laboratory analysis, and calculation
forms. If you need to access the information in Appendices
C through I, call the CTC HOTLINE (919/541-0800) to request
specific appendices.
-------
Vermont Used Oil Study
Report
Prepared for
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Technical Support Division (MD-19)
Emission Measurement Branch
Research Triangle Park, NC 27711
Attn: Mr. Solomon Ricks
EPA Contract No. 68-D2-0165
Work Assignment No. I-28
MRI Project No. 3801-M(28)
July 20,1994
-------
PREFACE
This report was prepared by Midwest Research Institute (MRI) for the U.S.
Environmental Protection Agency (EPA) under EPA Contract No. 68-D2-0165,
Work Assignment No. (-28. Mr. Solomon Ricks was the EPA Work Assignment
Manager (WAM) for the EMB. The report contains summary of test results,
description of field activities, and QA/QC procedures, as well as analytical results
and copies of pertinent calculations.
The project was conducted under the leadership of Mr. Slawomir Szydlo of
MRI's Engineering and Environmental Technology Department.
MIDWEST RESEARCH INSTITUTE
John M. Hosenfeld
Program Manager
Approved:
Charles F. Holt, Ph.D., Director
Engineering and Environmental
Technology Department
July 20, 1994
iii
-------
CONTENTS
Preface Hi
List of Figures vii
List of Tables vii
1. Introduction 1-1
1.1 Summary of test program 1-1
1.2 Key personnel 1-1
2. Facility and Sampling Location Descriptions 2-1
2.1 Facility descriptions 2-1
2.2 Sampling locations 2-1
3. Test Results 3-1
3.1 Objectives and test matrix 3-1
3.2 Field test changes and problems 3-1
3.3 Summary of results 3-4
4. Sampling and Analytical Procedures 4-1
4.1 Particulate matter, HCI, and metals emissions
testing method 4-1
4.2 Emission calculations 4-9
5. QA/QC Report 5-1
Appendices
A. List of samples collected A-1
B. Metals emission results per facility B-1
C. Sampling data C-1
D. Particulate analysis data D-1
E. Metals analysis report E-1
F. HCI analysis results F-1
G. Traceability forms G-1
H. Equipment calibration forms H-1
I. Modified Method 5 calculations 1-1
MRMMOB01-28
-------
LIST OF FIGURES
Number Page
1-1 Organizational chart 1-2
2-1 Location of sampling ports and isokinetic points 2-2
4-1 Modified Method 29 Sampling Train 4-2
4-2 Analysis Scheme for Sampling Train Components 4-7
LIST OF TABLES
Number Page
3-1 Summary of sampling and analysis parameters and methods 3-2
3-2 Times and locations of sampling runs 3-3
3-3 HCI emission rates 3-5
3-4 Summary of metals emission rates 3-6
3-5 Summary of particulate emissions 3-7
MRMWO801-28 VII
-------
SECTION 1
INTRODUCTION
1.1 SUMMARY OF TEST PROGRAM
The U.S. Environmental Protection Agency (EPA), in cooperation with the
Air Pollution Control Division and the Hazardous Materials Management Division
of the State of Vermont Agency of Natural Resources (ANR), conducted a joint
study to characterize the constituents and properties of used oils generated in
the State and the resultant emissions from the combustion of used oil in small
space heaters. The study results are intended to provide the information neces-
sary to gauge compliance of burning used oil in these heaters with existing Air
Pollution Control Regulations and Hazardous Waste Management Regulations.
The study results will be used to assess the environmental impact of current
used oil combustion practices versus alternative management practices such as
more stringent burning regulations, re-refining, or fuel blending in order to provide
the basis for developing a used oil management policy.
This report summarizes the results of stack testing performed at six
facilities operating used oil burners. The testing was performed by MRI from
April 18 to 29, 1994. The tests were performed to determine the following:
• the emission rate of HCI in the exhaust gas from the used oil space heaters,
• total particulate matter (TPM),
• the emission rate of arsenic, cadmium, chromium, and lead in the exhaust gas
from the used oil space heaters.
Section 2 provides a brief description of the facilities tested. Section 3 of
this report contains a summary of the test objectives and results. It also
describes changes and modifications implemented during field testing. The
sampling equipment used is described in detail in Section 4. Section 5 presents
the quality assurance activities.
1.2 KEY PERSONNEL
The key personnel who coordinated the test program and their phone
numbers are presented in Figure 1-1.
MM-MR3B01-28 1-1
-------
Quality
Assurance/Control
Dennis Hooton
(816)753-7600 ExL1198
EPA/Emission
Measurement Branch
Work Assignment Manager
Solomon Ricks
(919)541-5242
Field Sampling
Task Leader
Miro Szydlo
(816) 753-7600 Ext. 1424
MRI Work
Assignment Leader
Miro Szydlo
(816)753-7600 Ext. 1424
Sample Custodian
Brad Deck
(816)753-7600 Ext. 1269
State of Vermont
Technical Coordinator
Mark Ray
(802) 241-3840
Program Manager
John Hosenfeld
(816)753-7600 Ext. 1336
Metals Analysis
Task Leader
Avie Mainey
(816)753-7600 Ext 1714
Figure 1-1. Organizational chart.
MBI-MWM01.28
1-2
-------
SECTION 2
FACILITY AND SAMPLING LOCATION DESCRIPTIONS
2.1 FACILITY DESCRIPTIONS
The facilities tested included service stations, an automobile dealership,
and a diesel truck maintenance shop. At all facilities, used crankcase oil is
generated when servicing the vehicles. The used crankcase oil is stored for later
use in small space heaters during the cold months of the year.
None of the facilities tested had pollution control equipment installed on
the heaters.
2.2 SAMPLING LOCATIONS
Emission sampling was conducted on the outlet stack of all six facilities.
After installing the stack extension, all six sampling locations met the EPA criteria
of 4 diameters downstream and 1 diameter upstream. A schematic diagram of a
typical sampling location is presented in Figure 2-1.
Mn-MRaaoi-26 2-1
-------
Stack
Extender
Used
8'
T
16"
o --;:-
64"
\
Point
1
2
3
4
5
6
Distance (inch)
.35
1.18
2.36
5.64
8.82
7.65
94-42 SEV Of son 2 071994
Figure 2-1. Location of sampling ports and isokinetic points.
MfM-M«38Q1-28
2-2
-------
SECTION 3
TEST RESULTS
The purpose of this study was to characterize emissions from the
combustion of used oil in small space heaters.
3.1 OBJECTIVES AND TEST MATRIX
The specific objectives of this project were as follows:
• To collect and analyze stack samples for particulate matter, HCI, arsenic,
cadmium, chromium, and lead at five facilities utilizing used oil space heaters
and one facility utilizing a No. 2 (diesel) fuel space heater. The heater utilizing
No. 2 fuel was located at Barre Sunoco.
• To calculate emission rates of HCI, arsenic, cadmium, chromium, and lead for
each facility tested.
• To prepare a concise report containing testing and analytical results.
Table 3-1 summarizes the sampling and analysis matrix for the project.
The components and utilization of the sampling train are discussed in Section 4.
3.2 FIELD TEST CHANGES AND PROBLEMS
The changes instituted during the testing were related mainly to the length
of the sampling run. Since there were no previous tests done on these used oil
space heaters, the time required to collect appropriate amount of sample was
unknown. Thus, it was decided that a 4-h run should be necessary to collect
enough sample to meet detection limits of the analytical methods. However, if
there was evidence that enough sample was collected in a shorter period of time
(i.e., heavy particulate loading), the length of the run was reduced.
During the two sampling runs at Bayview Cadillac, visual inspection of the
sampling nozzle revealed very heavy particulate loading and a slight increase in
the vacuum pressure required for sampling. For that reason, the sampling time
for the first and second runs at Bayview Cadillac were shortened to 2 and 3 h,
respectively. All runs at other locations were 4 h in length. The lengths of
sampling runs and their corresponding locations are presented in Table 3-2.
MHH*R3801-28
-------
TABLE 3-1. SUMMARY OF SAMPLING AND ANALYSIS PARAMETERS AND METHODS
Sample
Stack gas
Sampling
frequency for
each run
2-h composite
per run
2-h composite
per run
Sampling
method*
MM5-MM" (Draft
EPA Method 29
and EPA
Method 0050)
EPA Method 3B
Sample size
60 to 100 ft3 c
-20L
Analytical
parameters
Metals"
Moisture
Temperature
Velocity
Particulate
HCI
Oxygen, carbon
dioxide
Preparation
method*
Acid digestion
(Draft EPA
Method 29)
NA
NA
NA
Desiccation
NA
NA
Analytical
method*
ICP (SW846,
601 OA)
Gravimetric
Thermocouple
Pitot tube
Gravimetric
(EPA Method 5)
Ion chromatog-
raphy (SW846,
9057)
Orsat
w
rb
* "SW846" refers to Test Methods for Evaluating Solid Waste. Third Edition, November 1986, and updates. 'EPA Method" refers to
New Source Performance Standards, Test Methods and Procedures, Appendix A, 40 CFR 60.
" MM5-MM m Modified Method 5 for multiple metals as specified in the draft EPA Method 29, "Determination of Metals Emissions from
Stationary Sources."
c Exact volume of gas sampled was dependent on isoklnetic sampling rate.
" Metals to be included in analysis were As, Cd, Cr, and Pb.
-------
TABLE 3-2. TIMES AND LOCATIONS OF SAMPLING RUNS
Location Run Time (h)
Clarke's Sunoco 1 4
Clarke's Sunoco 2 4
Bayview Cadillac 1 2
Bayview Cadillac 2 3
Barre Sunoco 1 4
Barre Sunoco 2 4
Walker Motors 1 4
Walker Motors 2 4
Green Mtn. Kenworth 1 4
Green Mtn. Kenworth 2 4
Cody Chevrolet 1 4
Cody Chevrolet 2 4
MRI-MW3601-26 3~3
-------
The flow rate of the flue gas during the first sampling run at Cody
Chevrolet was considerably different from the flow during the second run, with
the flow during the second sampling run being much lower. The difference in
flows between runs 1 and 2 was caused by a different fuel flow during each run.
Also, the average flue gas temperature during the first run was 148°F lower than
the average temperature during the second run. The difference in flow rates
between runs resulted in considerably different volumes collected during both
runs. The gas volume collected during the first run is approximately twice the
volume collected during the second run.
3.3 SUMMARY OF RESULTS
The emission rates of HCI for every facility tested are presented in
Table 3-3. The rates of HCI emissions from heaters burning used crankcase
oil vary widely from facility to facility, with the lowest emission rate of
1 .46 mg/min at Clarke's Sunoco and the highest of 68.90 mg/min at the Cody
Chevrolet. The emissions of HCI from No. 2 fuel were much lower with an
average value of 2.20 mg/min. For calculations used, see Section 4.1.
The metal emission rates were calculated for arsenic, cadmium,
chromium, and lead and are presented in Table 3-4. Some of the metal
emission rates are reported with "<" value because either the front-half
concentration or the back-half concentration was having concentrations below the
instrumental detection limit. The calculations of metal emission rates are
presented in Appendix B. The equations used for metals calculations are
presented in Section 4.2.
The emission rates of all metals from the first run at Cody Chevrolet are
roughly three times higher than the emission rates from the second run. The
difference in the emission rates was due to different operating conditions of the
used oil burner during the first and second run as noted previously.
All of the back-half blank concentrations were below the instrumental
detection limit. Except for cadmium, all of the front-half blank concentrations
were either below or very near the detection limit.
The front-half reagent blank for cadmium was 6.57 jig. The amount of
cadmium ranged from 17.1 to 142 mg. The contribution of cadmium blank
ranged from 5% to 38% for the total cadmium mass.
Because most of the blank values were below detection limit, and in the
case of cadmium the blank contribution was unusually high, the metal emissions
were not blank corrected.
The particulate emissions for each run are presented in Table 3-5.
MRI-M«3801-28
-------
TABLE 3-3. HCI EMISSION RATES
.ocation
Clarices Sunoco
Bayview Cadillac
Barre Sunoco (b)
Walker Motors
Green Mtn. Kenworth
Cody Chevrolet (c)
Run No.
1
2
1
2
1
2
1
2
r-.,,
2
~ f
2
HCI big/ml]
56
46
45 (a)
107
6.2
2.6
92
73
44
35
132
75
Implngers Vol. [ml]
303.6
336.4
486.8
404
482.5
734.3
388.5
373.8
402.1
479.9
427.6
376.6
Gas Vol. [dscm]
4.541
3.185
1.661
2.951
2.338
2.059
3.545
2.541
4.311
3.757
2.456
1.301
Gas Flow Rate
fdscm/mlnl
5
3
4
4
2
2
4
3
5 """"
4
1
HCI Cone. In Gas
(mo/dscml
3.7
4.9
13.2
14.6
1.3
0.9
10.7
4.5
21.7
HCI Emission Rate
fmo/mlnl
18.7
14.6
52.8
58.6
2.6
1.9
32.2
17.9
21.7
01
a. The HCI concentration for the first run conducted at Bayview Cadillac was adjusted for dilution factor.
b. Barre Sunoco heater utilized No. 2 fuel
c. See disc ussion In Section 3.2 regarding emission rate variability between runs.
M«-M\RM01-M
-------
TABLE 3-4. SUMMARY OF METALS EMISSION RATES
Location
Clarke's Sunoco
Bayview Cadillac
Barre Sunocoa
Walker Motors
Green Mtn. Kenworth
Cody Chevrolet
Run
No.
1
2
1
2
1
2
1
2
1
2
1
2
Emission rate (mg/min)
Arsenic
<0.02
<0.02
<0.05
<0.02
<0.01
<0.02
<0.02
<0.02
<0.05
<0.02
<0.03
<0.02
Cadmium
<0.04
<0.3
<0.07
<0.07
<0.02
<0.03
<0.07
<0.06
<0.09
<0.07
<0.19
<0.06
Chromium
0.13
0.10
0.15
0.11
0.02
0.02
0.15
0.12
0.28
0.19
0.33
0.09
Lead
1.47
1.17
1.58
1.52
0.03
0.03
2.60
1.90
2.92
2.53
3.83
1.32
" The heater operates on No. 2 fuel.
MRI-M«3B01-28
3-6
-------
TABLE 3-5. SUMMARY OF PARTICULATE EMISSIONS
Location
Clarke's Sunoco
Clarke's Sunoco
Bayview Cadillac
Bayview Cadillac
Barre Sunoco"
Barre Sunoco8
Walker Motors
Walker Motors
Green Mtn. Kenworth
Green Mtn. Kenworth
Cody Chevrolet
Cody Chevrolet
Run
1
2
1
2
1
2
1
2
1
2
1
2
(kg/h)
0.02
0.02
0.03
0.02
0.00
0.00
0.03
0.02
0.04
0.04
0.04
0.02
8 The facility bums No. 2 fuel.
MW-MWMOV28 3-7
-------
Similar to the metal emission rates, the HCI emission rates from the first
run at Cody Chevrolet are approximately three times higher than those from the
second run. Also, the sample collected from the first run at Bayview Cadillac
was diluted during recovery by a factor of 3. The concentration was readjusted
for the dilution factor.
Data on the usage of fuel was collected by representatives of the State of
Vermont.
MR1-MA3B01-Z8
3-8
-------
SECTION 4
SAMPLING AND ANALYTICAL PROCEDURES
Ordinarily, testing for TPM, HCI, and metals requires at least two separate
samplings. However, for this project, it was decided to utilize a modified
Method 5 train able to test for all of the three parameters of interest at the same
time.
4.1 PARTICULATE MATTER, HCI, AND METALS EMISSIONS TESTING
METHOD
The modified Method 5 train used in this study was designed to collect
TPM, HCI, and multiple metals simultaneously in the same train. This method is
applicable for the determination of TPM, HCI, Pb, Ni, Zn, P, Cr, Cu, Mn, Se, Be,
TL, Ag, SG, Ba, Cd, and As from various types of processes. In this particular
study, the test samples were analyzed only for As, Cd, Cr, and Pb. Particulate
emissions were based on the weight gain of the filter and the front half acetone
rinses of the probe, nozzle, and the front half of the filter holder. After the
gravimetric analyses were completed, the sample fractions were analyzed for the
target metals. During the recovery of the train, an aliquot of the impinger
solution was removed for HCI analysis.
4.1.1 Sampling Equipment for Total Particulate Matter. HCI. and Metals
This methodology used the sampling train shown in Figure 4-1. The
sampling train consisted of a quartz nozzle/probe liner followed by a heated filter
assembly with a Teflon* filter support, a series of six impingers, and the standard
EPA Method 5 meterbox and vacuum pump. The sample was not exposed to
any metals surfaces in this train. The first two impingers contained 100 mL of
0.1 N H2SO4 each. The third impinger was empty. The fourth and fifth impingers
contained 100 mL of 5 percent nitric acid (HNO^/IO percent hydrogen peroxide
(H2O2) solution, and the sixth impinger contained approximately 250 g of silica
gel. The impingers were connected together with clean glass U-tube connectors
and were arranged in an impinger bucket. Sampling train components were
recovered and analyzed in separate front and back half fractions.
MRMWBW1-28 4-1
-------
1. Front Half Acetone Rinse
2. Front Hall HNO3 Rinse
Thermometer,
Filter
Sample
Recovery
1. Combine Impinger 1 and 2 Contents
and Water Rinses
2. Remove AHquol lor HCI Analysis
Save Balance lor Metals Analysis
3. Rinse Impingers
1 and 2 with 0.1 N
HNO3 Save Rinses
for Metals Analysis
Quartz/Glass liner
Nozzle
rb
Thermocouple
r
Reverse - Type
Pilot Tube
1. Combine Impingers
3. 4 and 5 Contents
2. Then Combine
Impingers 3. 4 and
5 Rinses for
Analysis
1. Weigh Impinger
6 Gel and Discard
or Regenerate
Thermocouple
Check
.Valve
[Y) Greenburg-Smilh, 100 ml 0.1 N H2SO4
(2) Greenburg-Smilh. 100 ml 0.1 N H2SO«
f?) Modified Greenburg-Smith, Empty
[*) Modified Greenburg-Smilh. 100 ml 5% HNO,/10% H2O2
(s) Modified Greenburg-Smilh. 100 ml 5% HNO,/10% H2O2
(?) Modified Greenburg-Smilh, 200 G SiO2
Figure 4-1. Modified Method 29 Sampling Train.
-------
4.1.2 Equipment Preparation for Particulate Matter and Metals Sampling
4.1.2.1 Glassware Preparation—
Glassware was washed in hot, soapy water, rinsed 3 times with tap water
and then rinsed 3 times with deionized distilled water. The glassware was then
subjected to the following series of soaks and rinses:
• Soaked in a 10 percent HNO3 solution for a minimum of 4 h;
• Rinsed 3 times with deionized distilled water rinse; and
• Rinsed with acetone rinse.
The cleaned glassware was allowed to air dry in a contamination-free
environment. The ends were then covered with parafilm. All glass components
of the sampling train plus any other sample bottles, petri dishes, graduated
cylinders, and other laboratory glassware used during sample preparation,
recovery, and analysis were cleaned according to this procedure.
4.1.2.2 Reagent Preparation—
The sample train filters were Whatman QM-4 filters. The acids and H2O2
were Baker "Instra-analyzed" grade or equivalent. The H2O2 was purchased
specifically for this test site.
The reagent water was Baker "Analyzed HPLC" grade or equivalent. The
H2SO4 solution for HCI determination was prepared according to Section 3.3.1.5
of the 40 CFR, Part 266, Appendix IX, p. 559.
The HNCyH2O2 absorbing solution was prepared fresh daily according to
Section 3.1.4.2 of the 40 CFR, Part 266, Appendix IX, p. 530. The analyst wore
both safety glasses and protective gloves when the reagents were mixed and
handled. Each reagent had its own designated transfer and dilution glassware.
To avoid contamination, this glassware was marked for identification with a felt
tip glass-marking pen and used only for the reagent for which it was designated.
4.1.2.3 Equipment Preparation—
The remaining preparation included calibration and leak checking of all the
train equipment, which included meterboxes, thermocouples, nozzles, pitot tubes,
and umbilicais. Referenced calibration procedures were followed when available,
and the results were properly documented and retained. A discussion of the
techniques used to calibrate this equipment is presented below.
Standard Pitot Tube Calibration. The EPA has specified guidelines
concerning the construction and geometry of an acceptable standard pitot tube.
A pitot tube coefficient of 0.99 is used if the specified design and construction
guidelines are met. Information pertaining to the design and construction of the
standard pitot tubes meeting the required EPA specifications were used. Pitot
MW-MWS801-Z8 4-3
-------
tubes were inspected and documented as meeting EPA specifications prior to
field sampling.
Sampling Nozzle Calibration. Glass nozzles were used for isokinetic
sampling. Calculation of the isokinetic sampling rate required that the cross-
sectional area of the sampling nozzle be accurately and precisely known. All
nozzles were thoroughly cleaned, visually inspected, and calibrated according to
the procedure outlined in Section 3.4.2 of EPA Document 600/4-77-027b.
Temperature Measuring Device Calibration. Accurate temperature
measurements were required during source sampling. Thermocouple tempera-
ture sensors were calibrated using the procedure described in Section 3.4.2 of
EPA document 600/4-77-027b. Each temperature sensor was calibrated at a
minimum of two points over the anticipated range of use against an NBS-
traceable mercury-in-glass thermometer. All sensors were calibrated prior to field
sampling.
Dry Gas Meter Calibration. Dry gas meters (DGMs) were used in the
sample trains to monitor the sampling rate and to measure the sample volume.
All DGMs were calibrated to document the volume correction factor using the
procedure outlined in Section 3.3.2 of EPA document 600/4-77-207b.
4.1.3 Total Paniculate Matter. HCI. and Metals Sampling Operations
4.1.3.1 Preliminary Measurements—•
Before sampling began, preliminary measurements were required to
ensure isokinetic sampling. These included determining the traverse point
locations and performing a preliminary velocity traverse and moisture
determination. These measurements were used to determine an isokinetic
sampling rate from stack gas flow readings taken during sampling.
Measurements made during the pretest site survey were then checked for
accuracy. Measurements were made of the duct inside diameter, port nozzle
length, and the distances to the nearest upstream and downstream flow
disturbances. These measurements were used to verify sampling point locations
by following EPA Reference Method 1 guidelines. The distances were then
marked on the sampling probe using an indelible marker.
4.1.3.2 Assembling the Train—
Assembling the PM, HCI, and metals sampling train components was
initiated in the recovery trailer, and final train assembly was completed at the
stack location. First, the empty, clean impingers were assembled and laid out in
the proper order in the recovery trailer. Each joint was carefully inspected for
hairline cracks. After the impingers were loaded, each impinger was weighed,
and the initial weight and contents of each impinger were recorded on a recovery
MRI-I*R3801-2B
4-4
-------
data sheet. The impingers were connected together by clean glass U-tube
connectors and arranged in the impinger bucket. The height of all the impingers
was approximately the same to obtain a leak-free seal. The open ends of the
train were sealed with parafilm or teflon tape.
The second step was to load the filter into the filter holder in the recovery
trailer. The filter holder was then capped off and placed into the impinger
bucket. A supply of parafilm and joints was also placed in the bucket in a clean
plastic bag for use by the samplers. The train components were transferred to
the sampling location and assembled as previously shown in Figure 4-1.
4.1.3.3 Sampling Procedures—
After the train was assembled, the heaters for the probe liner and heated
filter box were turned on. When the system reached the appropriate tempera-
tures, the sampling train was ready for pretest leak checking. The filter skin
temperature was maintained at 120 ± 14°F (248 ± 25°F). The probe temperature
was maintained above 100°C (212°F).
The sampling trains were leak checked at the start and finish of sampling.
(EPA Method 5 protocol required posttest leak checks and recommended pretest
leak checks.) An acceptable pretest leak rate was less than 0.02 acfm (ftfVmin)
at approximately 15 inches of mercury (inHg).
To leak check the assembled train, the nozzle end was capped off and a
vacuum of 15 inHg was pulled in the system. When the system was evacuated,
the volume of gas flowing through the system was timed for 60 s. After the leak
rate was determined, the cap was slowly removed from the nozzle end until the
vacuum dropped off, and then the pump was turned off. If the leak rate
requirement was not met, the train was systematically checked by first capping
the train at the filter, at the first impinger, etc., until the leak was located and
corrected.
After a successful pretest leak check had been conducted, all train
components were at their specified temperatures and initial data were recorded
(DGM reading), the test was initiated. Sampling train data were recorded
periodically on standard data forms.
The leak rates and sampling start and stop times were recorded on the
sampling data terms. Also, any other events that occurred during sampling were
recorded on the task log such as prtot cleaning, thermocouple malfunctions,
heater malfunctions, or any other unusual occurrences.
At the conclusion of the test run, the sample pump (or flow) was turned
off, the probe was removed from the duct, a final DGM reading was taken, and a
posttest leak check was completed. (The posttest leak check procedure is
4*5
-------
identical to the pretest procedure; however, the vacuum should be at least
1 inHg higher than the highest vacuum attained during sampling.) An acceptable
leak rate was less than 4 percent of the average sample rate, or 0.02 acfm
(whichever was lower).
4.1.4 Particulate Matter. HCI. and Metals Sample Recovery
Recovery procedures began as soon as the probe was removed from the
stack and the posttest leak check was completed.
To facilitate its transfer from the sampling location to the recovery trailer,
the sampling train was disassembled into two sections: the nozzle/probe liner
and filter holder, and impingers bucket. Each of these sections was capped with
Teflon* tape or parafilm before being transported to the recovery trailer.
Once in the trailers, the sampling train was recovered as separate front
and back half fractions. Figure 4-2 is a diagram illustrating front half and back
half sample recovery procedures. No equipment with exposed metal surfaces
was used in the sample recovery procedures. The weight gain in each of the
impingers was recorded to determine the moisture content in the flue gas.
Following weighing of the impingers, the front half of the train was recovered,
which included the filter and all sample-exposed surfaces forward of the filter.
The probe liner was rinsed with acetone by tilting and rotating the probe while
squirting acetone into its upper end so that all inside surfaces were wetted. The
acetone was quantitatively collected into the appropriate sample bottle. This
rinse was followed by additional brush/rinse procedures using a nonmetallic
brush; the probe was held in an inclined position, and acetone was squirted into
the upper end as the brush was pushed through with a twisting action. All of the
acetone and particulate was caught in the sample container. This procedure was
repeated until no visible particulate remained and was finished with a final
acetone rinse of the probe and brush. The front half of the filter was also rinsed
with acetone until all visible particulate was removed. After all front half acetone
washes were collected, the cap was tightened, the liquid level marked, and the
bottle weighed to determine the acetone rinse volume. The method specifies
that a total of 100 mL of acetone must be used for rinsing these components.
However, a thorough rinse usually requires more reagent. For blank correction
purposes, the exact weight or volume of acetone used was measured. An
acetone reagent blank of approximately the same volume as the acetone rinses
was analyzed with the samples.
M3I-M«3801 28
4-6
-------
I Filter |
L
Dessicate
I
J
I Weigh | [
it Half
ne Rinse
i
Derate
ryness
i
eigh
P < „
tlubilize
HN03
1 Combine
Front Half
HN03 Rinse
f
I'
0.1 N H2S04
Impingers 1&2
I
I Remove Aliquot
for HCI Analysis
Analyze for HCI
by 1C
1
HNO3/H2O2
Impingers 3.4&S
Digest with
HNO3/H2O2
Impingers 1 & 2
0.1NHNO3 Rinse
Reduce Volume
to Dryness
_T
Digest wtth I
HN03/HF |
Fitter and Dilute I
to Known Volume |
Analyze tor Metals
by (CAP or GFAAS
Analyze for metals
by ICAP or GFAAS
Reduce Volume to
Near Dryness and
Digest with
HNO3/H2O2
Analyze for metals
by ICAP or GFAAS
Figure 4-2. Analysis Scheme for Sampling Train Components.
MR1-MW3801-2S
-------
The nozzle/probe liner and front half of the filter holder was rinsed 3 times
with 0.1 N HNO3, and the rinse was placed into a separate amber bottle. The
container was capped tightly, the weight of the combined rinse was recorded,
and the liquid level was marked on the bottle. The filter was placed in a clean,
well-marked glass petri dish and sealed with Teflon* tape.
Prior to recovering the back half impingers, the contents were weighed for
moisture content. Any unusual appearance of the filter or impinger contents was
noted in the logbook.
The contents of the first two impingers were recovered into a preweighed,
prelabeled bottle and combined with H2O rinses of the first two impingers. An
aliquot of the impingers' content was saved for HCI analysis. The impingers
were rinsed with 0.1 N HNO3, and the rinsate saved for metals analysis. The
remaining impingers and connecting glassware were rinsed thoroughly with 0.1 N
HNO3, the rinse was captured in the impinger contents bottle, and a final weight
was taken. Again, the method specifies a total of 100 mL of 0.1 N HNO3 be
used to rinse these components. The weight of reagent used for rinsing was
determined by weighing the impinger contents bottle before and after rinsing the
glassware. A nitric acid reagent blank of approximately the same volume as the
rinse volume was analyzed with the samples.
After final weighing, the silica gel from the train was saved for
regeneration.
A reagent blank was recovered in the field for each of the following
reagents:
Acetone blank
0.1 N HNO3 blank
5 percent HNCyiO percent H2O2 blank
Dionized water
Filter blank
0.1 N H2SO4
Each reagent blank was from the same lot used during the sampling program.
The liquid level of each sample container was marked on the bottle in
order to determine if any sample loss occurred during shipment. If sample loss
had occurred, the sample might have been voided or a method could have been
used to incorporate a correction factor to scale the final results depending on the
volume of the loss.
MRI-MR3801-2B
4-8
-------
4.1.5 Participate. HCI. and Metals Analysis
The analytical approach is shown schematically in Figure 4-2. The
general gravimetric procedure described in EPA Method 5, Section 4.3, was
followed. Both filters and precleaned beakers were weighed to a constant
weight. The same balance used for taring was used for weighing the samples.
The acetone rinses were evaporated under a clean hood at room
temperature to dryness in a tared beaker. The residue was desiccated for 24 h
in a desiccator containing fresh room temperature silica gel. The filter was also
desiccated to a constant weight under the same conditions. Weight gain was
reported to the nearest 0.1 mg. Each replicate weighing agreed to within 0.5 mg
or 1 percent of total weight less tare weight, whichever was greater, between two
consecutive weighings, and was at least 6 h apart. The metals analysis followed
the procedure of SW-846 Method 601 OA. Detailed description of metals analysis
can be found in Appendix D of this report: "Metals Analysis Report." The HCI
samples were analyzed according to Method 3057, 40 CFR, Part 266,
Appendix IX, pp. 573-575.
4.2 EMISSION CALCULATIONS
The sampling train used in this study was designed to collect TPM, HCI,
and metals. During the recovery of train after the testing, an aliquot of the
absorbing solution from the first two impingers was taken for HCI analysis. The
solution taken for HCI analysis was not analyzed for metals. Thus, in order to
achieve true representation of metal emissions, the missing volume of the aliquot
had to be accounted for. The following approach was used to calculate metal
emissions.
where: Vrn<«w) - Gas volume collected [dscm3]
VolA = Volume of impinger solutions before aliquot was
taken [ml]
VolB = Volume of impinger solution after [mL] aliquot was
taken
M4 = Constant [10"3 mg/ug]
MT = Total mass of metal (sum of front half and back
half analysis) fyig]
MTC = Corrected total mass of metal frig]
Cs = Metal emission rate [mg/dscm]
GR = Volumetric gas flow rate [dscm/min]
ER = Metal emission rate [mg/min]
The metal emissions are calculated as follows:
MV-MR3B01-28 4-9
-------
MTC = MT x (4-1)
(4-2)
x GB (4-3)
The HCI emissions were collected in the first two impingers containing
0.1 N H2SO4 solution. The HCI concentrations were analyzed from the aliquot
taken during the sampling which was only a fraction of the total impinger
solution. The total HCI were calculated as follows:
where: CHQ = Concentration of HCI [u,g/mL]
V, = Volume of solution in the impingers [ml_]
VM(..d) - Gas volume collected [dscm]
GR as Gas flow rate [dscm/min]
CRHCI - Concentration of the HCI in the gas [mg/dscm]
EHCI - Emission rate of HCI [mg/min]
K as Constant (10"3 mg/u.g)
= (K x GHO x V,)/Vm(rtd) (4-4)
EHC, ' CRHC, x GR (4-5)
MRI-MW3801-28
4-10
-------
SECTION 5
QA/QC REPORT
The subject report and appendices (in final draft form) were independently
reviewed by the project QA coordinator. Data for Run 1 from the Clarke's
Sunoco facility were audited versus the field sampling records and analytical
reports. Derived emission rates for Pb and HCI in this run were checked for
accuracy by manual calculation.
In addition, the metals data are supported by QC analyses of a NIST filter
(85% to 124% of certified values) and a spiked simulated matrix sample (102%
to 111% recovery of spiked amount) for the front and back half fractions,
respectively. Accuracy of the chloride data were demonstrated with an
independent check standard (102% accuracy) and a spiked matrix sample (102%
recovery). Gravimetric measurements for particulate data were monitored by
weighing control samples and a standard weight to within 2% tolerance.
Based on the review of representative sample and QC data described
above, test results were found to be complete, traceable, and correctly reported.
Minor editorial and significant figure reporting changes were recommended for
the final report.
5*1
-------
APPENDIX A
LIST OF SAMPLES COLLECTED
MW-MW3801-28 A~1
-------
The following represents samples collected in the field:
Front Half Acetone Rinse:
Samples: 1001, 2001, 3001, 4001, 5001, 6001, 7001, 8001, 9001,
10001, 11001, 12001
Front Half HNO3Rinse:
Samples: 1002, 2002, 3002, 4002, 5002, 6002, 7002, 8002, 9002,
10002,11002, 12002
Particulate Filter:
Samples: 1003, 2003, 3003, 4003, 5003, 6003, 7003, 8003, 9003,
10003, 11003, 12003
Galbright HCI Aliquot:
Samples: 1004, 2004, 3004, 4004, 5004, 6004, 7004, 8004, 9004,
10004, 11004, 12004
HNO3 Rinse of Impingers 1 and 2:
Samples: 1005, 2005, 3005, 4005, 5005, 6005, 7005, 8005, 9005,
10005, 11005, 12005
Condensate from Impingers 1 and 2 Plus H2O Rinse:
Samples: 1006, 2006, 3006, 4006, 5006, 6006, 7006, 8006, 9006,
10006, 11006, 12006
Condensate from Impingers 3, 4, and 5 Plus HNO3 Rinse:
Samples: 1007, 2007, 3007, 4007, 5007, 6007, 7007, 8007, 9007,
10007, 11007,12007
D1 H2O Blank—Sample 3012
0.1 N H2S04 Blank—Samples 3015
5% HNOg/10% H2O2 Blank—Sample 3016
Acetone Blank—Sample 3011
Filter Blank—Sample 3013
0.1 N HNO3 Blank—Sample 3014
MRHAR3M1-28
-------
APPENDIX B
METALS EMISSION RESULTS PER FACILITY
MRI-MWM01-28 B~1
-------
Meter Volume [dscm] 4.54
Average Meter Temp [deg C] 15.00
A* 303.60
B* 274.70
Gas Emission Rate fdscm/minl 5.00
Front Half
Back Half
Front Half + Back Half
Concentration [mg/dscm]
Concentration [mg/dscf]
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 1 -Clarices Sunoco
Arsenic
IMS]
7.99
< 9.15
< 18.94
< 0.00
0.00
< 0.02
Cadmium
Ipg]
28.00
< 1.08
< 32.14
< 0.01
0.00
< 0.04
Chromium
[MO]
103.00
< 2.82
116.95
0.03
0.00
0.13
Lead
IPO]
1190.00
< 18.42
1335.55
0.29
0.01
1.47
Tt» nkJM A 4 B «P» UMd to correct tor Iho rtquot MUKI tor HO •nolyi*. A ft B or* raoardod ki «•
-------
Meter Volume [dscm] 3.19
Average Meter Temp [deg C] 21 .00
A* 336.40
B* 311.80
Gas Emission Rate fdscm/min] 3.00
Front Half
Back Half
Front Half + Back Half
Concentration [mg/dscm]
Concentration [mg/dscf]
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 2-Clarkes Sunoco
Arsenic
lug]
< 5.93
< 9.15
< 16.27
< 0.01
0.00
< 0.02
Cadmium
Era)
25.90
< 1.57
< 29.64
< 0.01
0.00
< 0.03
Chromium
bo]
94.30
< -. 4.92
107.05
0.03
0.00
0.10
Lead
[ug]
1130.00
< 18.42
1239.03
0.39
0.01
1.17
nluf* A « 8 «f» UMd to eamet tet tx ««qunl Man to MO *#&*. A * 8 •» nceidio m th« fcM nuvnry tenm.
-------
Meter Volume {dscmj 4.31
Average Meter Temp [deg C] 21 .00
A* 402.10
B* 351.70
Gas Emission Rate rdscm/minl 5.00
Front Half
Back Half
Front Half + Back Half
Concentration [mg/dscm]
Concentration [mg/dscf]
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 1 -Green Mtn. Kenworth
Arsenic
[Ml
< 29.65
< 9.15
< 44.36
< 0.01
0.00
< 0.05
Cadmium
[Pd
66.80
< 1.68
< 78.29
< 0.02
0.00
< 0.09
Chromium
Ira)
203.00
< 4.85
237.64
0.06
0.00
0.28
Lead
[ug]
2180.00
< 19.50
2514.70
0.58
0.02
2.92
T)w vMM* A A BMWUMd to comet tar ttw Mquot toten tor
A * B *n ncantod In «w 4Wd <
-------
Meter Volume [dscm] 3.76
Average Meter Temp [deg C] 29.00
A* 479.90
B* 429.80
Gas Emission Rate fdscm/min] 4.00
Front Half
Back Half
Front Half + Back Half
Concentration [mg/dscm]
Concentration [mg/dscf]
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 2 -Green Mtn. Kenworth
Arsenic
Ing]
< 11.86
< 9.15
< 23.46
< 0.01
0.00
< 0.02
Cadmium
[Mfl]
54.80
< 2.45
< 63.92
< 0.02
0.00
< 0.07
Chromium
lug]
153.00
< . 4.75
176.14
0.05
0.00
0.19
Lead
iPfl]
2110.00
< 20.10
2378.40
0.63
0.02
2.53
Tb» vtfra A t B *ra n»i to comet for «w Mq»ot taten for HO •n«fy»t». A t B *ra recorded ki tw fWd notxnry farm.
-------
Meter Volume [dscm] 3.55
Average Meter Temp [deg C] 30.00
A* 388.50
B* 363.50
Gas Emission Rate fdscm/min] 4.00
Front Half
Back Half
Front Half + Back Half
Concentration [mg/dscm]
Concentration [mg/dscf]
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 1 -Walker Motors
Arsenic
b>g]
< 5.93
< 9.15
< 16.12
0.00
0.00
< 0.02
Cadmium
[M9l
55.30
< 1.55
< 60.76
< 0.02
0.00
< 0.07
Chromium
[POl
119.00
< 3.23
130.64
0.04
0.00
0.15
Lead
lP9l
2140.00
< 18.42
2306.87
0.65
0.02
2.60
Th«
A & B »• uMd to eonM tor the akquot Man for HO mlyito. A « B m raoorfed In «» IWd neet
-------
Meter Volume [dscm] 2.54
Average Meter Temp [deg C] 16.00
A* 373.80
B* 349.00
Gas Emission Rate [dsctn/min] 3.00
•
Front Half
Back Half
Front Half + Back Half
Concentration [mg/dscm]
Concentration [mg/dscf]
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 2-Walker Motors
Arsenic
tral
< 5.93
< 9.15
< 16.15
< 0.01
0.00
< 0.02
Cadmium
Ira]
42.40
< 4.13
< 49.84
< 0.02
0.00
< 0.06
Chromium
(ral
87.40
< . 5.10
99.07
0.04
0.00
0.12
Lead
iPfl]
1480.00
< 18.42
1604.90
0.63
0.02
1.90
Th. vriuM A « B «r» uMd to comet for ttw Mquot tokm for HO »n*»*». A A B «• rwordod ki «w Md raoovwy torn
-------
Meter Volume [dscm] 2.34
Average Meter Temp [deg C] 37.00
A* 482.50
B* 431.90
Gas Emission Rate fdscm/min] 2.00
Front Haff
Back Half
Front Half + Back Half
Concentration [mg/dscm]
Concentration [mg/dscf]
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 1-Barre Sunoco
Arsenic
[ugl
< 5.93
< 9.15
< 16.85
< 0.01
0.00
< 0.01
Cadmium
big]
17.10
2.78
< 22.21
< 0.01
0.00
< 0.02
Chromium
lug]
16.10
< 2.74
21.05
0.01
0.00
0.02
Lead
lug]
9.63
< 18.42
31.34
0.01
0.00
0.03
The vttuM A t B m UMd to eemd tor «• MquM Man tor HO mlyifc. A A B tn recorded m «M **M i
iwwy term*.
-------
Meter Volume [dscm] 2.06
Average Meter Temp [deg C] 40.00
A* 734.30
B* 684.40
Gas Emission Rate rdscm/minl 2.00
Front Half
Back Half
Front Half + Back Half
Concentration [mg/dscm]
Concentration [mg/dscf]
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 2-Barre Sunoco
Arsenic
Ing]
7.28
< 9.15
< 17.63
< 0.01
0.00
< 0.02
Cadmium
b>g]
29.30
2.41
< 34.02
< 0.02
0.00
< 0.03
Chromium
Iral
17.80
< . 4.79
24.24
0.01
0.00
0.02
Lead
[Md
10.80
< 18.42
31.35
0.02
0.00
0.03
Th» vriuM A 4 B «r» uMd to eomet tor ttw MquM Wnn far Hd myth. A 4 B «ra raoordwl In ttw Md i
-------
Meter Volume [dscm] 1.66
Average Meter Temp [deg C] 17.00
A* 486.60
*' 436.00
Gas Emission Rate [dscm/min] 4.00
Front Half
Rack Half
Front Half + Rack Half
Concentration [mg/dscm]
Concentration [mg/dscf]
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 1-Rayview Cadillac
Arsenic
(pgl
8.77
< 9.15
< 20.01
< 0.01
0.00
< 0.05
Cadmium
IWJ]
23.90
< 1.18
< 28.00
< 0.02
0.00
< 0.07
Chromium
[PQ]
53.40
< 2.57
62.49
0.04
0.00
0.15
Lead
lug]
568.00
< 18.42
654.75
0.39
0.01
1.58
T)M wkiM A i B m M*d to eomet for «w •ftquot ttwn for HO •ralyd*. A t B m recorded In ttw **W i
-------
Meter Volume [dscm] 2.95
Average Meter Temp [deg C] 19.00
A* 404.00
B* 354.00
Gas Emission Rate fdscm/min] 4.00
Front Half
Back Half
Front Half + Back Half
Concentration [mg/dscm]
Concentration [mg/dscfl
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 2-Bayview Cadillac
Arsenic
IPO]
< 5.93
< 9.15
< 17.21
< 0.01
< 0.00
< 0.02
Cadmium
[Pfl]
46.70
< 1.08
< 54.53
< 0.02
< 0.00
< 0.07
Chromium
Ing]
71.50
< . 2.25
84.17
0.03
0.00
0.11
Lead
fog]
965.00
< 18.42
1122.32
0.36
0.01
1.52
Th« v»kM* A 4 B *ra UMdto oomet tor o» tttanot Man tor HO tnttytit. A t B tn raeontad In «w Md i
iryta
-------
Meter Volume [dscm] 2.46
Average Meter Temp [deg C] 33.00
A* 427.60
B* 401.50
Gas Emission Rate [dscm/min] 3.00
Front Half
Back Half
Front Half + Back Half
Concentration [mg/dscm]
Concentration [mg/dscfj
Emission Rate [mg/min]
VERMONT USED OIL STUDY
Run Number 1 - Cody Chevrolet
Arsenic?
[ugl
< 11.86
< 9.15
< 22.38
< 0.01
0.00
< 0.03
Cadmium
Ing]
142.00
< 2.93
< 154.35
< 0.06
0.00
< 0.19
Chromium
big]
251.00
< 4.02
271.60
0.11
0.00
0.33
Lead
fc>g]
2930.00
< 18.42
3140.09
1.28
0.04
3.83
A A B era uMd to comet fer *w alquet Man far Hd m**to. A t B w» neardrt to Vw Mtf i
-------
Meter Volume [dscm] 1.30
Average Meter Temp [deg C] 36.00
A* 376.60
B* 351.80
Gas Emission Rate fdscm/minl 1.00
Front Half
Back Half
Front Half* Back Half
Concentration [mg/dscm]
Concentration [mg/dscf]
Emission Rate fmg/min]
VERMONT USED OIL STUDY
Run Number 2 - Cody Chevrolet
Arsenic
Ing]
14.20
< 9.15
< 25.00
< 0.02
0.00
< 0.02
Cadmium
b>g]
74.00
< 3.40
< 82.86
< 0.06
0.00
< 0.06
Chromium
big]
108.00
< . 4.79
120.74
0.09
0.00
0.09
Lead
fug]
1590.00
< 18.42
1721.80
1.32
0.04
1.32
Th» V«|UM A ft B era und to correct tor ttw aliquot ttten fer HO «n«)y»*. A ft B era recorded ki th* fWd raoowry torm.
-------
TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
I. REPORT NO.
EPA-456/R-95-001
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
5. REPORT DATE
1995
Used Oil Analysis and Waste Oil
Furnace Emissions Study
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Slawomir Szydlo
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Midwest Research Institute
425 Volker Boulevard
Kansas City, MO 64110-2299
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
Contract No. 68-D2-0165
Work Assignment No. 1-28
12. SPONSORING AGENCY NAME AND ADDRESS
Control Technology Center
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
This project was co-sponsored by EPA and the Vermont Agency of Natural Resources.
EPA Project Lead: Robert J. Blaszczak (919) 541-5432; Vermont Project Manager (802) 241-3875.
16. ABSTRACT
This technical report characterizes waste oil and air emissions from waste oil furnaces in the State of
Vermont. The report is divided into two parts. Part One was prepared by the State of Vermont Agency
of Natural Resources, Department of Environmental Conservation, and includes information on used oil
sample collection and analysis, summary of stack emissions test results, and a comparison of the test
results to regulatory requirements in Vermont. Part Two summarizes the stack testing program funded
by EPA . Part Two includes descriptions of facility and sampling locations, tea results, information on
sampling and analytical procedures, and the quality assurance/quality control report.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
used oil, waste oil furnace, air emissions,
used oil combustion, waste oil combustion,
hazardous air pollutants, arsenic, barium,
beryllium, cadmium, chromium, lead, nickel,
zinc
Air Pollution
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
94
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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