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•' .. ,
Notes: , ,;. ..
,0
I o
• • The data provide'd in these charts may not reflect the latest information
which you may have. The following notes identify specific'changes which should
B * be made. If you have more recent data, or recognize any errors', please -notify
I' the Land Use Planning Branch. „
' ' • « •.
1.1. More recent air quality data for -the Metropolitan Philadelphis Region
' ' ' ' '- ,' 3
• "o -shows a second high value of 30 ppm (34 ing/m ) for carbon monoxide.
I • e 2. Louisiana's recently adopted hydrocarbon regulation wi'll provide
significant reductions from stationary sources. Transportation controls
• . will probably not be needed. Air quality data from Louisiana was used
t '
• • *
• • t. ' for'this entire Region. Recent data taken in the Texas portion shows
a second high value of .30 ppm for oxidants. This' is the value which
Texas will use to develop a plan for its portion of the Region.
• '3.' The'revised Texas emission inventory shows a significant change in the
mobile source contribution to total hydrocarbons. The ratio of mobile
I to total emissions is now .14. Transportation controls.will therefore
. • have less of an effect on total emission reductions. , The same type
™ • ratio for the Houston-Galveston Region also changed, and now is .16.
• • *
• 'Stationary source controls must obtain significant reductions in these
two Regions if the NAAQS are to be achieved by'May 31, 1972.
I ' 4. The^air quality data used for these calculations are second high values.
• However, the California Air Resources Board wi'll use the maximum values
.
of .46 ppm and .40 ppn for the Southeast Desert and San Diego Regions
I- - • - .
respectively in developing their plans-.
I . " • ' /
•
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North'Carolina 27711
"HjECT: Format for the Review and Evaluation of Transpor- DATE: March 28 1973
tation Control Plans • *
TO: Transportation Planning Representatives
Regions I-X
At the meeting of Air and Water Program directors and transpor-
tation planning representatives in Chicago on March 20, 1973, Dr.
Tom Wright of TR1-I Systems, Incorporated, handed out two documents
that pertained to TRW's Basic Ordering Agreement No. 68-02-0048,
Task Order No. 14.
One document was a 20-page set of tables that TRU plans to use
during their initial review of the SIPs to gather data concerning
items one and two of the Task Order. Item one primarily covers
the social and economic impacts of transportation controls while
item two summarizes the general and specific features of transpor-
tation control strategies selected by the States. The other document
furnishes some brief directions for the completion and use of the
tables.
It was explained at the meeting that these tables were going to
Obe used by TRU and could be used by the Regional offices if they found
them useful. It was' further requested that tne Regional otnces sena
comments in to the Land Use Planning Branch concerning the adequacy of
the tables so that these comments could oe forwaraed 10 "IK'W.
Dave Tamny, of the Land Use Planning Branch, has contacted the
transportation planning representatives by phone again asking for
comments. It was his understanding that if he did not receive
comments by March 23, 1973, it meant the Regional offices had no
comments regarding the forms/tables to be used by TRW for the review
and evaluation of the transportation control plans. • *
As of March 27, "1973, no significant comments have been received
regarding TRW's format for review and evaluation of transportation
control plans. Therefore it is assumed the Regional offices have no
additional comments and there is no need to issue revised tables.
Frederick Winkler
Land Use Planning Branch
EPA Foim 1320-6 (Rev. 6-72)
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',,,-
UNITED STATES ENViriONMEHTAL PROTECTION
.Office of Air Quality PI aim ing and Standards
Research Triangle Park, North Carolina 277,11
sbv/jV,CT: Transportation Control Meeting
(3/30/73 -.Chicago, Illinois)
,.c
DATE: March 28, 1973
FROM: •' SASD/I.UPB
TO:
O
See Addressees
I ,
A meeting was held in Chicago on March 20, 1973, to discuss
the status of transportation control plan development, and the
reccirinoided approach to HPA plan development. All EPA regional
offices, GAMP, OGC, OAQPS, MSAPC, MSF.D, FHUA and TRW were represented
at the meeting. An attendance list is enclosed.
Also enclosed are the minutes of this meeting. Questions
concerning the minutes should be directed to the Land Use Planning
Branch (Dob Clark: (919) 688-8291.) Follow-up on Action Items (see
enclosure) generated at the meeting is continuing. Questions
concerning these items should also be directed to the above.
Pvonald A. Venezia
Chief
Land Use Planning Branch
Enclosures (3)
Addressees:
T. Cortese
T. Dwyer
I. Mil nor
B. Burch
E. Enstrom
J. Crocker
D. Durst
J. Phil brook
R. Mueller
B.J. Steigerwald
J. Padgett
J. Horowitz
J. Me r-en da
D. Hanson
D. Grahani
H. Gompf ;
T. Wright i
EPA Coim 1320-6 (Rev. 6-7?)
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o
AGENDA
Transportation Control Meeting
Chicago', Illinois - March 20, 1973
O
10:00 Welcome from Region V
.
10:05 tOpening Remarks
10:15
Regional Status Reports
(Ten minutes each)
1:00
1:15
1:30
1:45
2:00
2:15
2: l\ 5
3:15
3:30
(B.J. Steiger^ald)
, (Region^ I-X)
Region IX will also discuss L.A. Hearings (Twenty minutes total)
12:00- Lunch
1:00
Review of SIP Task Schedule
•
Guidance for Writing Transportation Plans
(Venezia)
(Armstrong)
Hydrocarbon Emission Inventory and Controls 4 (Armstrong arid Horowitz)
EPA Proposed Strategies
o
Enforceability of Transportation Control
Strategies
Basis for Extensions
Transportation Regulations ~ Appendix N
•
Evaluation Reports
Discussion
(Venezia) . • «
(Graham)
•
(Trick)
(Armstrong and Mcrenda)
•
(Venezia) ,
5:OC . Adjourn
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Transportation Control N.oosures, tmcago i\\.
• . '• March 20, 1973 • • !
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Name. :
Wallace VJoo
Tony Cortese
Israel Milner
Chuck Miesse
Bill Burch
Lance Vins'on
'Ed Enstrom
Ed Muse .
Manuel Marks
Jack'Chicca
"Diana Dutton
. John Crocker
Dewayne Durst
Irwin L. Uickstein
'Charles W. Hurray Or.
John Phil brook
Ron Mueller
B.O. Steigerwald
0. Padgett
Ronald Venezia
•Donald Armstrong
David Tamnyt
Robert Clark
Ooel Horowitz
Joe Korenda
Dave Hanson
David B. Graham
Dick Kozlowskii
• i
Henry Gompf
Tom Uriqht
' Organization^ '
Region I - EPA
Region I - EPA
Region II - EPA
.Region III - EPA-
Region III - EPA
Region IV - EPA
Region V - FHUA
Region V - FHWA
•Region V - EPA
Region V - EPA
Region V.-EPA •
Region VI - EPA
Region VI - EPA .
Region VII - EPA.
'Region VIII - EPA
.Region VIII - EPA
Region VIII - EPA
[.Region IX--EPA
OAQPS, Durham
OAQPS, Durham
LUP.B, Durham
LUPB, Durham
. LUPB, Durham .
LUPB, Durham
DAMP
OAWP>
OAWP
USED
MSED
MSAPC
TRV!
Telephone
617-223-5609
617-223-5630
212-264-9800
215-597-9164
215-597-9303
404-526-3285
312-253-1471 '
312-353-6942
312-799-6300
312-799-6300
214-749-2142
214-749-1231
816-374-3791
513-837-3868
513-837,:4871.
305-837-4831
415-556-2332
919-688-8576
919-688-8204
919-688-8291
919-688-8291
919-688-8291
919-688-8291
202-755-0630
202-755-0650
202-755-0460
202-755-2598
202-755-2518
313-761-5230
703-893-2000
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MINUTES
Transportation Control Meeting
Chicago, 111. -'March 20, 1973
• • •
o" '
I. Ronion Office Summaries ' «
« —j . •
c
Region I: . %
• • * « « «
A. • Metropolitan Boston " "
1. New air quality data for this AQCR (.25 - .26ppm) in-
• . dlcatcs that a reduction in hydrocarbons of 86% will-be
, o required based on App. J of the Federal Register. Region
« , ,° I is considering letting the State use°a proportional
rollback for calculating the required reduction (about 70%).
'«
. « '2.. 'Region I expects the State to submit only a token plan.
• Therefore, EPA promulgation is likely.
B. Hartford - New Haven - Springfield
<•
1. Region I expects that the State will not submit a plan
for this AQCR until June. 6CA has been contracted by
Region I to-prepare an EPA plan.
. * - . «
Region II: . »
•,
A. New York - New Jersey -^Connecticut •• «
t
1. New York and New Jersey are using air quality data in
their respective portions of this AQCR for.plan development.
2. New York and New Jersey will be meeting to discuss reciprocal
transportation control strategies. Region II requested
advice on EPA's position on such strategies for interstate
regions'.
i
3. Region II expects a late submittal from New Jersey. Clari-
fication was requested on how this would be handled in
Federal Register notices.
«
4. No hearings for New Jersey's plan have been scheduled.
B. Metropolitan Philadelphia
. •
* 1. Pennsylvania and New Jersey are using air quality data from
their respective portions of this AQCR for plan development.
*--*"- * „•
2. Region II dxpects 3 late submittal -from New Jersey. Mo
• -'hearings have bo on :.>. u-jdulcd tor the plan.
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™ , Region III:
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O A. • National Capital/ • '
1. Results of the preliminary review of the plan for this
AQCR indicate that no EPA promulgation will be necessary.
However, minor changes to the plan have been requested
by Region III.
• 2. Based on new air quality data (.20 ppni), Virginia wi.ll
* • . submit a transportation'control plan for photochemical
oxidants. A special session of the State.legislature
° c must be called to approve the necessary legal authority.
o
* • • 3. ''Virginia is considering gas rationing as a back-up
strategy for its portion of this AQCR.
* • *
B. Metropolitan Baltimore
• 1. Region III anticipates an extension -request for this
AQCR. It is expected that such a request will be justified.
2. No promulgation is expected for this AQCR.
C. Metropolitan Philadelphia
c '
1 1. Region Ill-expects a justifiable extension request for
this AQCR. No EPA promulgation is anticipated.
D. Southwest Pennsylvania
1. . Region III expects a justifiable extension request-for this
AQCR. No EPA promulgation is anticipated.
Region IV:
* • .
A. Metropolitan Birmingham
» .
1. Region IV does not expect that transportation controls will
be required for this AQCR.
B. Mobile - Pensacola - Panama City
1
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C. Regions IV thinks that there may be carbon monoxide problems
in Atlanta and Miami. However, no steps have* been taken to call
for a revision to the plans for these AQCR's.
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Region V:
. A. ' Metropolitan Chicago
1. Public hearing dates have been announced for this
AQCR. The basis for the plan is a city -developed
/ Inspection/maintenance program. There may be conflict
with State authority/responsibility for the plan.
Region V does not think that the State has authority
to take over the program if the City, defaults.
.
2. Region V questions the method used to device emissions
• from heavy duty vehicles. If the method is not acceptable,
• -. <(a'larger reduction of carbon monoxide would be required.
•
' . e
B. Metropolitan Dayton c .
1. The State has revised the emissions inventory and will
use more recent air quality data for oxidants, Region V
expects the NAAQS to be met in this 'AQCR by 1975 without
transportation controls. However, an inspection/main-
tenance progrnm will probably be implemented by the State.
° • .
Q. Metropolitan Cincinnati
c
* I •*
* 1. * The emissions inventory has-been revised and mobile source
emissions recalculated. As a result, Region V expects
that stationary source controls in this AQCR will be
~~" sufficient to allow attainment of the NAAQS by 1975.
D. Metropolitan Toledo
1. As a result of emission inventory and mobile source emission
revisions, Region V expc-cts the NAAQS to be met by 1975
without transportation controls.
• .
E. Minneapolis - St. Paul i
*
1, As a result of new air quality data, Region V expects the
NAAQS to be met by 1975. GCA has been contracted by
Region V to rework the transportation data base for this AQCR.
*
•
• .
Region VI: '
1
A. Southern Louisiana - Southeast Texas '
•
•"* " i
1. Based on recently adopted stationary source controls by
the State, Louisiana is not expected to noed transportation
controls for its portion of this AQCR.
!
B. Texas will-not submit a plan containing transportation controls.
The Stale claims that 'the: N/'AOS can bo met in all applicable
AQCR'r, through more stringent'stationary source control:: v;!rich
have been adopted. Region VI does'not expect that stationary
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O source controls alone will bo sufficient. .Consequently,
•''Region VI con s.i do ring contractor assistance! for preparation
m . of a transportation conlroTplan for Texas.i
I ' , '
. . C.• Region VI expressed concern for a potential problem in the
,- • / El Paso - Las Cruces - Alamogardo AQCR. Emissions from Mexico
• , may prevent NAAQS from being met in this AQCR. * .
D., Texas will held public hearings-on April 4, 1973 to obtain
public reaction to transportation controls. No specific
c strategies will be recommended. The only purpose of this effort
is to get. public opinion if "transportation controls were
., implemented. '
* : ' • 6 * t *
Region 0VII: „ •
A. Metropolitan Kansas. City *
1.- Region VII expects that a 10% reduction in total carbon
'monoxide emissions will have'to be realized from trans-
' portation controls in this AQCR. Region VII thinks that
: 'a short extension (7 months) can be justified.
2. P£DCo has been contracted by Region VII to revise mobile
source emissions..
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Region VIII: • -. •
; " - . * •
A. Wasatch Front
• • '
1. Region VIII expects to have to promulgate a plan for this
AQCR.
2. New air quality data indicates a CO problem in Ogden similar
to the one in Salt Lake City.
B. Metropolitan Denver
1 Region VIII has doubts as to whether Denver's preliminary plan
P ' 1s sufficient for meeting NAAQS by 1975. The state has proposed
stationary source controls which will provide some help in getting
H the necessary hydrocarbon reductions.
. Region IX: ' • •
A, No hearing dates have been announced by. California. Region IX
>0 does not expect a plan submittal until June. -
B. California's current inspection/maintenance program is designed
to randomly select 15% of the L.A. vehicle population. The State
is considering a 50/' rejection.
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C. With the exception of Los Angeles, Region IX considers the
'San Diego and San Francisco AQCR's as most critical. The
Southeast Desert AQCR problem is considered a carry-over of
the Los Angeles problcml • •
• D. Phoenix - Tucson
. •
Region IX has discussed new emission inventory calculations
« with the State. Plan submittal is expected on April 15, 1973.
* fc ' « v
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E. ' Clark - .Mohave 9 • '
€ t
" Emission reductions .assumed for transportation controls in
•.Nevada's SIP are too high compared to that allowable'under .
« the proposed guidelines. In addition the State's committment
• < - to implement'the strategies set forth in the SIP is question-
able. Consequently, Region IX expects that a re-evaluation
,of the SIP would prove it to be inadequate for meeting the
• NAAQS by 1975.'
Region X: '
..Washington has the legal authority to implement an inspection/mainr
tenance program. However, lack of a vehicle safety inspection
x program would make it very difficult for such a strategy by 1975.
II. Plan Review Schedule • * '
* *
*
A. One of the main points of discussion was the importance of having
the FHWA participate in plan reviews and any EPA plan development;
Generally, FHWA and Region personnel have had only limited contact.
The Regions were urged to actively pursue participation by FHWA
both in plan review and development. FHWA representatives at the
meeting expressed a desire to participate and a willingness to
assist EPA.
B. The Regions were reminded that preliminary as well as final plans
were to be sent to all reviewers for comments. Comments should
be returned to the Regions as soon as possible.
C. The Regions are supposed to notify OGC (Bill Frick) immediately
on receipt of plans.
111.' Guidance for Writing Plans •
A. The recommended approach to preparing an EPA.plan was presented
• (See attachment I). During the ensuing discussion, the avail-
ability of various retrofit hardware and implementability of
•Inspection/maintenance programs were questioned. It was.generally
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agreed that the'VSAD and LIAF options would bo available
and implemcntablc by 1975. -There was disagrepment, however,
on the availability and'implementability of the EGR and
catalytic converter options. This disagreement led to the
question of whether a State's plan should be 'approved if one
or, both of these options were included as part of the overall
* ^trategy for NAAQS attainment by 1975. HSPCP pointed out • •
'„ 'that the proposed Appendix N required States to substantiate
the-availability of such retrofits and provide assurance that imple-
mentation could be achieved by the required deadline. If these
.requirements were satisfied,- then there would be no grounds for
« disapproval. "
1 •
. • • • * •
B. The" ability of States to have operational inspection/maintenance
• . ; programs by 1975 was questioned, especially- for those states
-: which do not now have safety inspection programs. MSPCP agreed
•• to provide information on the steps required to develop an
inspection/maintenance program and an estimate of the time
I needed for each phase of development. This information should
i be available early in the week of March 26.
IV. Enforceability of Strategies '
Dave Graham*(MSED) provided^a memorandum concerning this subject.
• \ ' ' . . .
V. Basis for Extensions -
•.
A. The following information on attainment date extensions.was
provided by OGC. . ,
1. Adequacy of extension justifications must be determined for
each specific case.
2. Although a maximum extension of two years may be granted, EPA
must ensure that States attain NAAQS as expeditiously as
, practicable.
I . • '
3. To be granted an extension (of any length) a State must have"
considered all available alternatives.
i *
! •
4; It would be very difficult for EPA to grant an extension reques
! which is based on social impact.
•*• *
B. i An interesting point was brought out during the discussion on plan
extensions. If EPA proposed a plan which included an extension,
* then this would essentially be a garranteed extension for the State
if the..State in turn submitted a late plan.
!•
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O
VI. Evaluation Reports
/ •
A checklist (prepared by TRW) for'plan review as part of •
TRW's impact analysis was'handed out to all reviewers.
Comments concerning this checklist should be returned to
, LUPB as soon as possible in order to make the list as
useful as possible for TRW. Reviewers may also use this
checklist as necessary in their review of SIPs.
VII. Transportation Regulations.- Appendix N" «
• .
A. All numbers of reflecting allowable reductions for the
, various control measures are to be used as a guide until
. . Appendix N has been officially approved.
«• •
•
B. MSPCP pointed out that failure rates for inspection/
' . maintenance programs are for individual pollutants.
° - For example, the worst 30% of hydrocarbon emitters
may not necessarily be the worth 30% of carbon monoxide
emitters. It is possible then, to have more than 3Q%
of the vehicle population fail if vehicles are tested for
hydrocarbons and carbon monoxide.
VII. Action Items
4 •«- .
A list of action items were identified as a result of the
various questions raised, points of disagreement, and
requests for guidance. This list, which includes the
responsible agency, is provided in Attachment 2.
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I
I
II GUIDELINES FOR WAIVERS OF EMISSION
J TESTING IN FACILITIES INVOLVING
J BERYLLIUM
I
, I. Introduction
* < These guidelines cover requirements necessary to qualify
— ' i
• for a waiver of emission testing for beryllium extraction
' plants, machine shops, ceramic plants, foundries, and
I • others processing beryllium-containing materials.
I
1. Beryllium Emission Limit
I According to Section 61.32, Suupart C, of the National
!
j Emission Standards for Hazardous A1r Pollutants, total
mt •• effluents emitted to the atmosphere from a source must be
m controlled so as to limit beryllium emissions to a maximum
™ of 10 grams in a 24-hour period,
• 2. Waiver of Emission Tests
Emission tests - initial, periodic or both - may be
1 waived upon written application to the Administrator, if in
I his judgement the source is meeting the applicable emission
i . limits or 1f the source 1s operating under a waiver of
• , compliance or has requested a waiver of compliance.
| ! Sources not meeting the requirements of II(a) below may
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apply for waiver of emission testing. The decision on
the application will be based on the amount of material
processed, the type of operation, the type of control
system Installed and special factors pertinent to that
source.
II. General Waiver Qualifications
The following requirements are necessary to qualify for
a waiver of emission testing and recordkeeplng required
by the National Emission Standards for Hazardous A1r
Pollutants, Section 61.13.
a* Sources which certify that less than 10 pounds per
month of beryllium 1s processed will automatically
be granted a waiver of both Initial and periodic
emission testing.
b. The source must be controlled so that the total
effluents emitted to the atmosphere do not contain
more than 10 grams of beryllium 1n a 24 hour period.
c. Control equipment and operation thereof must be
correctly represented 1n the waiver request application
and must continue to exist and be operated as was
represented. If source test results were submitted
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I
I
with the waiver application, collection efficiencies
M shall continue to equal or exceed those claimed 1n
• the application.
I III. Required Information for Waiver of Emission Testing
I
The following specific Information concerning the beryllium
control systems with which the facility is attempting to
m qualify for a waiver must be supplied with the waiver
application.
• 1. Process Information
™ i
a. Complete flow diagrams of all operations contributing
I
to emissions. Include material balances.
b. Estimated flow rate, composition, temperature, and
^ other pertinent Information on atmospheric emissions.
c. Location and number of emission points.
I
d. Operations considered to be the major sources of
emissions.
I e. Process calculations having any bearing on emissions
and emission rates.
f. Effects of startup, shutdown and abnormal operation
1
I
on emission rates. Description of process instrumentation
which can correct overloads or failures (such as alarm
-1
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for ruptured prefliter or an override on a recording
flow control to a baghouse).
2» Control Equipment Information
a. Engineering design calculations, including assumptions,
operation principle, and operating variables affecting
performance and efficiency,
b« Manufacturer and ntudel number.
c. Equipment specifications including: design capacity,
guaranteed efficiency, performance, operating instructions.
Include,, where applicable, information such as:
allowable pressure d,- . , gas velocity, filter ratio,
temperature, partlculate gas loading, etc.
d. Equipment drawings*.
e, Engineering drawings of control equipment as
Installed; wHh ductst hoods, fans, piping and other <
auxl S ic»f>., *.
\
f,, Spare pa^ts wn'.ch a^e proposed.
g, Scheduled maintefsance procedures,
3, Source Tests for Emission
If requested, the results of an emission test performed
according to EPA-approveo sampling and analytical techniques
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I
published with the standard must be Included 1n the waiver
• application. All reports should Include the name and
, telephone number of a company representative who can be
I
•
I
contacted to clarify any Information submitted.
IV. Suggested Procedures for Applicants for Waiver of
Emission Testing
_
The following maintenance and Inspection procedures,
• where applicable, are suggested for those sources applying
• or qualifying for a waiver of emission testing.
- 1. Fabric Filters
The following maintenance and operating procedures
«hall be adhered to wherever fabric filters (baghouses)
are utilized to control emissions regardless of their
position 1n any specific control arrangement.
Dally Inspections
1. The clean side of all baghouses must be Inspected
for leaky, torn, or poorly sealed bags. In cases where
• sufficient light 1s not available to properly Inspect
all bags, a portable light source shall be used.
2. All dust tubes shall be Inspected for abrasion
ft . or wear.
3. The clean side of the cell plant floor shall be
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Inspected for any dust accumulation. Dust build-up 1n this
area 1s evidence of leaky fabric filters or cell plate joints.
Weekly Inspections
1, The baghouse housing shall be Inspected for air
leaks and all Interior sections checked for excessive
abrasion or wear.
2. The shaker mechanism shall be Inspected for
proper condition.
3. All fans, drivers, and power equipment shall be
Inspected for wear, damaged parts and leaks.
General Maintenance
1. All maintenance and Inspection requirements
cited by the manufacturer of the subject control equipment
shall be strictly adhered to with the exception of those
that require fewer Inspections to be performed than cited
In this document.
2. Periodic Inspection of the dust collector housing
and structural components 1s required. All bolts shall be
Inspected and tightened and Inspection door seals checked
for leaks.
3. Upon determination of any unsatisfactory conditions
of control equipment. Immediate correction action shall be
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taken. In order to avoid excessive emissions and/or loss
of operating time, a supply of spare parts shall be
maintained. Control equipment manufacturers should
provide recommendations as to which parts should be kept
I on hand. In all cases, enough wearable parts and fabric
m filters should be stocked to equip one baghouse or one
compartment of a baghouse.
•»
Fabric Filter Material and Construction
*
In the event filter material, filter construction, or any
control or process variable that may adversely affect
m
I collection efficiency or increase total emissions 1s
• changed after a source test waiver has been granted, the
waiver 1s cancelled until these changes have been approved
m by the Administrator.
| 2. HEPA Filters
_ The following maintenance and operating procedures
* shall be adhered to wherever HEPA (High Efficiency Partlculate
• A1r) filters are utilized as the final emission control
device 1n any control arrangement.
Maintenance
• 1, Filters and mounting frames shall be visually
Inspected on a dally basis for damage or defects. Special
• j attention shall be paid to the assurance of a proper
i '
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filter seal to the frame, condition of frame clamps, and
any obvious damage to both frame and filters.
2, Pre-fliter banks shall be visually Inspected
on a weekly basis for damage or defects. Special attention
shall be paid to the clean side of pre-fliter banks where
any leaks may be Indicated by the presence of soiled or
discolored areas.
3. The filter housing shall be Inspected for air
leaks and damaged or corroded areas that may result 1n
filter damage and the reduction of both filter efficiency
and life.
4. Prior to Installation of HEPA filter, the following
Inspections shall be performed. A record shall be retained
verifying performance of such Inspection for the period
1n which the filter is 1n service.
a* Exposed filter areas shall be visually Inspected
with the aid of a strong light source for cracks,
plnholes, and breaks. Special attention shall be
paid to the presence of cracks or breaks on the edge
of the filter pleats and the adhesive seal around
the filter unit face.
b. The filter case gasket shall be Inspected for non-
uniformity of thickness, Improperly formed comers,
8
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•Incomplete bond to the filter housing, degraded
normal plant operations.
I
m , 6. Upon determination of any unsatisfactory conditions
I!
of control equipment, Immediate corrective action shall
j be taken. Exhaust gases normally passed through HEPA
I;
filters prior to entering the atmosphere shall not be
f emitted 1n the event the HEPA filter control arrangement
Is defective or damaged 1n any way that may affect filter
• efficiency. Such conditions Include, but are not limited
to, those cited 1n this document with respect to the
I HEPA filter and/or the HEPA filter bank.
I
_
I
HEPA Filter Material and Construction
Ij In the event filter material, construction, specifications,
|
I or any control or process variable that may adversely
I * affect collection efficiency or Increase total emissions
1s changed after a source test waiver has been granted,
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Mf
the waiver 1s cancelled until these changes have been
approved by the Administrator.
V. Evaluation of Information Submitted with Testing
Waiver Application
The application examiner can automatically grant a waiver
for cases covered by II(a) above. In other cases, he
must be convinced that beryllium emissions have been or
will be kept within the limits shown 1n II(b). The safest
course 1s to act upon the evidence of actual source tests
submitted with the waiver application. Here, the examiner
must convince himself that the data are truly representative
and not accidentally low.
In the absence of source tests, the safest course 1s
to realize that control equipment will probably operate
satisfactorily 1f 1t has a history of good operation
1n similar duties elsewhere. Accordingly, we hereby
present Figures 1 through 8. These figures show
the controls used 1n several beryllium machine shops and
a foundry and ceramic plant. All of these sources were
tested by EPA and were found to be well-controlled. These
figures are given for perspective, however, and should not
be used to judge waiver applications.
The Information received with an emission testing waiver
application should be evaluated by an experienced engineer.
10
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1
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1* • <
1
1
1
•
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1
FIGURE 1
i
SOURCES AND CONTROLS \
1. Beryllium Machine Shops
Emission Point A2
.
unip ^01 lecLiun
MarhinP1; 9 lathes i ; ...
in Material - ' — __ r~~"j
Operation Be j~~~[
__ r~-i
i 1
<— .I
i i
ST3 — ' /~^» •
r f
Baghouse
"1
jl I
Test! Point <
i
rV
1 •
I i
s
y
i 1
Number of bags 45 45
1
1
1
1
M
1
1
1 '
I
61 61
Total cloth area 188 188 383 383
(ft2)
Avg. air to cloth
ratio ft
Avg. total
(min)
flow
rate (cfm)
4.3
4800
Fabric specifications:
Material
- silicon treated cotton
weave - 12
Thread count - 78 x 70
Permeability - 4-4.5 cfm/ft2
Max. temp. - 180°F
1
j
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Test Point
FIGURE 2
Emission Point Al
Machines in Operation
t
9 mills
Material - Be
Chip Collection
i — -H i
4
Number of bags > 61
Total cloth area (ft2) 383
Jaghouse
^"
6'
3*
L
13
\^^
Avg. air to cloth 2.8
ra tio'( ft/mi n)
Total flow rate (cfm) 1600
Fabric Specifications: same as A2
12
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FIGURE 3
Emission Point A3
A-3
-------
Emission Point Bl
Machines in
operation
15 Lathes
13 Dry
2 Wet
Material Be
Emission Point 82
FIGURE 4
Avg. flow rate (cfm) 2960
Test
Point
CP
Baghouse
•e-
Machines in
operation
2 Grinder,
wet
Material BeO
Avg. flow rate (cfm) 920
14
Test
Point
Baghbuse
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FIGURE 5
-:-:-,i.-.. r'o!:tt 3-3
Operations
3 mills-wet
2 ultra sonic-wet
1 lathe dry
1 Grinder-wet
material BeO.Be
Test
Point
Baghouse
Avg. flow rate (cfm) 1875
15
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FIGURE 6
2. Beryllium-Copper Foundry
Test Point C]
Emission Point
cooling
Test
Point
V
Cyclone
Test
Point
Bag-
House
Avg. flow rate (cfm) 20,435
Permeability ft/min 15-25
Material Dacron
Total filter area (ft2) 7,986
Fabric count 78 x 74
Air to cloth ratio (ft/min) 2.5
16
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FIGURE 7
3. Beryllium Oxide Ceramic Plant
Emission Point D-l
Operations
Machining
Grinding
Formi ng
Weighing
etc.
Mt. BeO
nrs/uay
\r
i
(T
L
_
1
0— i
t—
n
l_;
i
i
<=
r
r
c.
n i Te!
) Pnii
I
1
1
i
<
5t
->4-
It
(
\
Pre-Filters
HEPA Filter
Dimensions (ft) 4'x4'xT
Avg. Flow Rate (cfm) 18,900
17
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Emission Point D-2
FIGURE 8
Spray
Drier
40 Ibs
BeO/hr.
r
C
I
\>
I
Baghouse
Reverse
Jet
Test ^
Point v>
HEPA
Filter
Bag Material - Dacron, Silicon treated
Avg. flow rate (cfm) - 1,857
Cleaning Cyclo - 2 ea., 5 sec. pulses per min.
Emission Point 0-3
Calciner
250-660°C
Zone Heating
I
Test
Point
Pre
Filter
HEPA
Filter
18
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This can be performed 1n as much detail as manpower
8 I will allow, consistent with the number and complexity of
emission points and control devices. As a minimum, the
evaluator must match gas flows from the material
balance to the available area of the various filtering
devices proposed and given in the vendors specifications.
Beryllium extraction plants have all been designed to
limit ambient concentrations of beryllium to 0.01
micrograms/cu meter and have demonstrated the capability for
operation within this limit. They have a great variety
of potential beryllium emission sources. Appropriate
practices for control o* fmissions include:
1. Ventilation hoods of very careful design.
2. Removal of larger partlculates by prefilter,
followed by HEPA filter for fines.
3. High energy wet collectors.
The following general comments may act as a guide to
the waiver evaluator.
1. Wet Collectors
In general, wet collectors are applied in beryllium
handling to remove hot, wet, sticky, agglomerating, hygroscopic,
or inflammable materials from a gas stream. Efficiency is
not high enough to remove submicron particles satisfactorily.
19 .
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2. Fabric Filters
These devices have over 99 percent efficiency for
ore handling operations of crushing and milling, and for
handling dry beryllium hydroxide. They are used to
control emissions from conversion of beryllium metal
billets to metal forms; and of beryllium hydroxide to
alloys, oxide powder, and ceramics. They depend upon
use of filter aids and buildup of a cake, for their
highest efficiency* Oaoron, Orion and nylon are used
for fine partlculates because cotton sateen bags are more
easily blinded by fine dusts. The usual filter ratios are
1:1 to 1:3 cfm/sq ft cloth area, and operating pressure
drop range 1s about 2" - 8" H-O.
The choice of an effective filter can be made with
confidence only on the basis of previous successful
operating experience with a similar system. Otherwise,
the determination of a satisfactory combination of filter
fabric and bag cleaning system should be considered as
a development program, rather than as an engineering task.
20
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3. Prefliters
These filters are frequently utilized to protect
HEPA filters from high partlculate concentrations. They
can be designed to collect high concentrations of the
larger particulates; this statement applies particularly
I
to the viscuous impingement panel type. There are
two other, extended medium, dry type prefliters which
operate at higher pressure drops and have higher dust
collection efficiencies. Some idea of the nominal
values of air handling capacity, pressure loss and dust
holding capacity of prefilters is given by Table 1.
The cited dust holding capacities are those for Cottrell
precipHator dust as determined by NBS test method. The
properties of a beryllium dust might produce a considerably
different dust holding capacity.
21
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CO
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o u u u
X Id «0,
I D.O O|
+>
ou.
o «
r- «r- CT4J
U. U M
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«^-
u
£
UI
o
o
CO
in in
in
o
in
•
o
CM
in
»
o
to
•
o
in
*
o
CM
10
O
in
o
in
CM
o
in
s
CM
a
£
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4. HEPA (High Efficiency Participate A1r) Filters
This 1s a filter with very extended surface. The
filtering medium (a special fibre glass or paper sheet) 1s
wrapped 1n an S pattern across corrugated metal or ceramic
spacers which support the fragile filter sheet and
maintain the appropriate spacing between adjacent faces of
the filter medium. The dusty gas enters the filter
at the covered edges of the paper supports, flows Inward
parallel to the paper, and then passes at right angles
thru the numerous layers of filter sheet.
The HEPA filter 1s defined by the following specifications:
a. It 1s an extended-medium, dry, throw-away type.
b. Collection efficiency 1s at least 99.97 percent
for partlculates of 0.3 micron diameter.
c. Clean flow resistance at rated air flow capacity
Is no larger than 1.0 Inch w.g.
d. A rigid housing extends the entire length of the
filter medium.
The waiver evaluator should compare the proposed air flow
to the filter with that 1n the vendors recommendations.
23
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Overpressurlzatlon of HEPA filters for even short periods
of time can rupture the filter medium, or even cause
complete blowout of the filter core. Instrumentation
should exist to prevent excessive airflows leading to
filter damage. The shock overpressure resistance, which
1s the maximum short-duration overpressure that a filter
can sustain with no visible damage and no decrease 1n
collection efficiency, 1s shown 1n Table 2.
Table 2. SHOCK OVERPRESSURE RESISTANCE OF OPEN-FACE HEPA FILTERS
Overpressure (pslg)
Filter
Dimensions. (In
Face
8 by 8
8 by 8
12 by 12
24 by 24
24 by 24
A
Tepth
3 1/16
5 7/8
5 7/8
5 7/8
11 1/2
Test
Vilua*
3.6
4.5
3.6
2.2
3.2
Recommended .
Design L1m1tD
With Face
Guards
3.1
3.8
3.1
1.9
2.7
Without Face
Guards
2.0
2.5
2.0
1.2
1.8
"dean filter with 4 by 4 mesh face guards on both faces.
bD1rty filters.
24
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• ^ The nominal dust-holding capacity of HEPA filters varies
with the type of particulates, but 1s approximately 4
| pounds per 1000 cfm of rated gas flow capacity. Prefliters
B are definitely recommended 1f the particulate loading
™ 1s greater than 50 nrfcrograms per cubic meter.
• Particles having a fibre or flake form are capable of
• * Inducing rapid clogging of a HEPA filter.
_ ] 5. Beryllium Machine Shops
j Figures 1 through 5 Illustrate some of the
• 1 emission controls.
i
!
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; Finish cutting and grinding operations produce more and
« finer particulates than rough cutting. Open face hood
velocities usually range from 150 to 300 fpm. Dust
• j and chip capture velocities range from 500 to 3000 fpm.
Transport velocities are usually 3000 to 4000 fpm.
6. Foundries
* ' Gas fired lancing forms excessive fumes. One
• i foundry control 1s shown 1n Figure 6.
\
• i The evaluator should check emission controls for finishing
operations, which are dusty, and Involve cutting, grinding
i i
and buffing. Fabric filter installations have bags with
I
25
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air flow permeabilities 1n the range of 15 to 25 cfm/sq ft
and have been successfully operated at filter face
velocities of about 2 ft/m1n 1n beryllium - copper foundries.
The filter vendor's recommendations should be noted.
7. Beryllium Oxide Ceramics
Controls useful 1n ceramic plants are shown in
Figure 7 and 8. Such plants generate considerable submicron
partlculates.
26
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!
GUIDELINES FOR WAIVERS OF EMISSION
TESTING IN FACILITIES INVOLVING
MERCURY
I. Introduction
These guidelines cover requirements necessary to qualify for
a waiver of emission testing for mercury extraction facilities
•
and facilities using mercury chlor-alkali cells to produce
chlorine gas and alkali metal hydroxide,
A. Mercury Emission Limit
According to Section 61.52,, Subpart E, of the National
Emission Standards tor Hdiardoub Air FulluiauLA, i,ul«u merCur v
emissions to the atmosphere from a source must be limited to a
maximum of 2300 grams in a 24-hour period. This limitation applies
to the stack gas emissions from mercury extraction facilities
and the combined hydrogen stream, end-box ventilation stream,
and cell-room emissions from chlor-alkali facilities using mercury
cells. Sources subject to the mercury standard must ver'f? their
compliance by conducting periodic emission tests, Section 61 ..53
of the National Emission Standard for Hazardous Air Pollutants
includes provisions for the initial and periodic testing of
both types of affected facilities.
B. Waiver of Emission Tests
Emission tests - initial, periodic or both - may be
waived upon written application to the Administrator, if in his
1
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Judgement the source 1s meeting the applicable emission limit
or 1f the source 1s operating under a waiver of compliance.
Sources not meeting the requirements of II(a) may apply for a
waiver of emission testing. The decision on whether or not to
grant the waiver will be based on the amount of material processed,
the type of operation, the type of control system Installed,
and special factors pertinent to that source.
II. General Waiver Qualifications
The following requirements are necessary to qualify for a
waiver of emission testing under Section 61.13 of the National
Emission Standard for Hazardous Air Pollutants.
A. Mercury extraction facilities which are either retort
operations producing 2 .^sks of mercury per day or less
or directly heated operations with capacities of 20 tons
of mercury ore per day or less will automatically be granted
a waiver of both initial and periodic emission testing.
B. Sources not qualifying for an automatic waiver of
testing under II(A) must be controlled so that the total
effluents emitted to the atmosphere do not contain more
than 23QO grams of mercury per 24-hour period.
C. Control equipment and operation thereof must be correctly
represented in the waiver request application and must continue
to exist and be operated as was represented. If source
test results were submitted with the waiver application,
collection efficiencies should equal or exceed those claimed
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|1n the application.
, , .. -
_ D'. Owners or operators 'of facilities employing mercury
chlor-alkall cells may demonstrate compliance with the
8 cell room ventilation portion of the allowable emissions
by applying the following design, maintenance, and house-
I keeping practices specified by the Administrator. Initial
•* and periodic source test requirements applying to the cell
room will then be waived. A- value of 1300 grams of mercury
I per day will be assigned to the cell-room emissions.
• (a) Chlorine cells and end-box covers should be
Installed, operated, and maintained in a manner to
•' minimize leakagt of mercury and mercury-contaminated
materials.
(b) Daily inspection should be made by operating
| personnel to detect leaks, and Immediate steps to
_ stop the leaks should be taken.
(c) High housekeeping standards should be enforced
• and any spills of mercury should be prompt!: cleaned
• up either mechanically or chemically, or by other
appropriate means. Each cell room facility should
• have available and should employ a well -defined
procedure for handling these situations.
(d) Floor seams should be smoothed over to minimize
«
depressions and to facilitate washing down of the
floors.
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(e) All floors should be maintained in good condition,
free of cracking and spall ing, and should be»regularly
Inspected, cleaned, and to the extent practical, chemically
•
decontaminated.
•
(f) Gaskets on denuders and hydrogen piping should be
maintained 1n good condition. Daily inspection should
be made to detect hydrogen leaks and prompt Corrective
action taken. Covers on decomposers, end-boxes, and
mercury pump tanks should be well maintained and kept
closed at all times except when operation requires
opening.
(g) Precautions should le taken to avoid all mercury
spills when changing graphite grids or balls in horizontal
decomposers or graphite packinq in vertical decomposers.
Mercury-contaminated graphite should be stored in closed
containers or under water or chemically treated solutions
until it is processed for reuse or disposal.
(h) Where submerged pumps are used for recycling
mercury from the decomposer to the inlet of the chlorine
cell, the mercury should be covered with an aqueous
layer maintained at a temperature below Its boiling point.
(i) Each submerged pump should have a vapor outlet with
a connection to the end-box ventilation system. The
connection should be under a slight negative pressure
so that all vapors flow into the end-box ventilation system.
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(j) Unless' vapor tfght covers are provided, end-boxes
• » • •
of both Inlet and outlet ends of chlorine cells should
* i •
be maintained under an aqueous layer maintained at a
temperature below Us boiling point.
(k*) End boxes df cells should either be maintained under
a negative pressure by a ventilation system or should be
equipped with fixed covers which are leak tight. The
ventilation system or end box covers should be maintained
1n good condition.
(1) Any drips from hydrogen seal pots and compressor
seals should be collected and confined for processing
•
to remove mercurv, and these drips should not be allowed
to run on the floor or in open trenches.
(m) Solids and liquids collected from back-flushing
the filter used for alkali metal hydroxide should be
collected in an enclosed system.
(n) Impure amalgam removed from cells and mercury
recovered from process systems should be stored r> an
enclosed system.
(o) Brine should not be purged to the cell room floor.
Headers or trenches should be provided when it Is
necessary to purge brine from the process. Purged brine
should be returned to the system or sent to a treating
system to remove Its mercury content.
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(p) A portable tank should be used to collect any
mercury spills during maintenance procedures.
(q) Good maintenance practice should be followed
when cleaning chlorine cells. All cells when cleaned
should have any mercury surface covered continuously
with an aqueous medium. When the cells are
disassembled for overhaul maintenance, the bed plate
should be either decontaminated chemically or thoroughly
flushed with water.
(r) Brine, alkali metal hydroxide, and water-wash
process lines and pumps should be maintained in good
condition, and leaks should be minimized. Lea!;:;
should be collected n -u1table containers rather than
allowed to spill on floor areas.
III. Required Information for Waiver of Emission Testing
The following process data and Information concerning the
mercury control systems with which the facility is attempting to
qualify for a waiver must be supplied with the waiver application.
A. Process Information
1. Complete flow diagrams of all operations contributing
to emissions. Include mpteHal balances.
2. Estimated flow rate, composition, temperature,
and other pertinent information on atmospheric emissions.
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I
I
3. Location and number of emission points.
4. Operations considered to be the major soyrces
of emissions.
•
5. Process calculations having any bearing on emissions
and emission rates.
6. Effects of startup, shutdown, and abnormal operation
on emission rates. Description of process instrumentation
designed to correct overloads or failures.
B. Control Equipment Information
1. Engineering design calculations, Including
assumptions, operation principle, and operating variables
affecting performance and efficiency.
2. Manufacturer and model number.
3. Equipment specifications, include: design capacity,
guaranteed efficiency, performance data, and operating
Instructions. Include, where applicable, Info-nation
such as: allowable pressure drop, gas velocity, temperature,
particulate loading, etc.
4. Equipment drawings.
5. Engineering drawings of control equipment as installed;
with ducts, hoods, fans, piping and other auxiliaries.
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6. Spare parts required.
7. Scheduled maintenance procedures.
C. Source Test for Emissions
If requested, the results of an emission test performed
according to EPA - approved sampling and analytical techniques
published with the standard must be included 1n the waiver
application. All reports should Include the name and telephone
number of a company representative who can be contacted to
clarify any information submitted.
IV. General Maintenance and Inspection Procedure
The following general maintenance and inspection procedures
are suggested for those sources applying or qualifying for a
waiver of emission testing.
A. All maintenance and Inspection requirements cited by
the manufacturer of the subject control equipment should be
strictly adhered to with the exception of those that require
fewer inspections to be performed than cited 1n this document,
B. If the good housekeeping option is used to demonstrate
compliance with the cell room ventilation portion of the
allowable emissions from a chlor-alkali facility, the maintenance
and inspection procedure discussed on pages 3-6 must be followed.
C. Upon determination of any unsatisfactory conditions,
corrective action should be taken. In order to avoid excessive
8
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emissions and/or loss of operating time, a supply
of spare parts should be maintained. Control equipment
t
manufacturers can provide recommendations as to which
•
parts should be kept on hand.
V. Evaluation of Information Submitted with Testing Waiver
Application
•
The sources meeting the requirements of II(A) or II(D) should be
automatically granted a waiver of emission testing. When evaluating
the application of sources not qualifying for an automatic waiver,
the examiner must be convinced that mercury emissions have been
or will be kept within the allowable Urit (2300 grams per ^-nour
period). The safest course is to base any decision upon actual
source test results submitted with the waiver application. In
this case, the examiner must convince himself that the data are
truly representative and not accidentally low.
The Information received with an emission testing waiver application
should be evaluated by an experienced engineer. This can t,<
performed in as much detail as manpower will allow, consistent
with the number and complexity of emission points and control
devices. As a minimum, the examiner should compare the gas flow
rates, temperatures, and mercury concentrations with the values
listed in the vendors specifications and use the estimated collection
efficiencies of the control equipment to calculate an approximate
emission rate.
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The condenser gas stream is the major source of emissions
from a mercury extraction facility. Appropriate control techniques
Include cooling and mist elimination, wet scrubbing, er absorption
beds. Major emissions of mercury from chlor-alkali- plants using
mercury cells are from the hydrogen gas stream, the end-box
ventilation stream, and the cell room ventilation air. Emissions
from the hydrogen gas and the end-box ventilation air streams
can be controlled by cooling and mist elimination, chemical
scrubbing, or adsorption beds. No techniques are presently
available to control the cell room ventilation air. The control
of emissions from this source is dependent upon the application
of the good housekeeping practices presented in Section II of this
document.
The following general comments "^xr-ning control techniques
may act as a guide to the waiver evaluator.
A. Cooling and Condensing
The cooling of a gas stream containing mercury vapo** below
Its mercury saturation temperature will cause the vapor to
condense, thereby reducing the mercury content of the gas.
Cooling can be accomplished by the use of either direct or
Indirect cooling techniques. Because of the large particulate
loading of several of the process gas streams, direct cooling
methods may possess an advantage over indirect methods since
direct cooling would aid 1n mist and particulate removal. The
use of direct cooling, however, would also introduce the
10
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I
necessity of water treatment facilities and create the possibility
of a water pollution problem.
In order to be effective as a control technique, cooling should
be followed by some type of mist elimination device.
B. Mist Elimination
There are two basic types of mist eliminators commercially
available to remove mercury mist from process gas streams. One
of these consists of a fiber bed, equipped with water sprays,
that removes the entrained mist by the mechanisms of impaction,
Interception, and Brownian movement. A high particulate loading
(of contaminants other than mercury) may cause the efficiency of
this device tc be Icv/cr 1 ^n normal. L'3c of additional flushing
water within the mist eliminator or installation of air precleaning
equipment prior to the mist eliminator may effectively solve the
problem. The particulate mercury removal efficiency of this
type of mist elimination device has been estimated at 86 percent.
Another type of mist eliminator utilizes a coverglng - diverging
nozzle arranged so that the gases being cleaned follow o ,<'rved
path and are acted upon by high centrifugal forces in the
throat area. These forces are reported to cause the coalescence
of mercury mist and entrapment of sub-micron mercury particulate
upon the upper wall of the divergent section. This mist eliminator
1s reported to have an efficiency comparable to that of the fiber
pad type mist eliminator.
11
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C, Wet Scrubbing • •
Wet scrubbing devices employ a variety of mechanisms
to collect particulate matter. Interception of partlculate
matter by liquid dro'plets resulting In a heavier dust-liquid
•
agglomerate Is the most important of these mechanisms. Particulate
matter collected on a liquid droplet in this manner can be
efficiently removed from the gas stream by a centrifugal collector.
The particulate collection efficiencies of wet scrubbers vary
with energy input and can extend over a wide range depending on
the design.
The venturi scrubber is a high-energy, high efficiency scrubber
•
that has been used to remove particulate matter from gas streams
•
similar to the stack gas streams of mercury extraction facilities.
The water necessary to scrub a ,oOO SCFM gas stream is estimated
to be between 5 and 9 CPM, depending on the gas loading and
size distribution of the partlculate matter. It is expected
that a particulate collection efficiency of 95 percent cc-jld be
achieved with a pressure drop of 20 to 30 inches of water through
the venturi and cyclone.
D. Chemical Scrubbing
1. Depleted Brine Scrubbing
The depleted brine scrubbing technique uses the brine
discharged from the chlorine cell as the scrubbing
liquor. This depleted brine contains about 250 grams
per liter of sodium chloride and 0.6 to 0.9 grams per
12
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I
I
• lit'er of available chlorine; it has a pH of from 2
to 4. The solution is used as the scrubbing medium
in a sieve plate tower or in a packed bed scrubber.
M Upon contact with the brine scrubbing solution, the
mercury vapor and mist form soluble mercury complexes.
Mercury can be recovered by electrolysis when the
scrubbing medium is recycled to the cell. The exit
mercury concentration of a hydrogen stream treated by
H this system has been reported to be approximately 85
micrograms per cubic meter.
• 2. Hypochlorite Scrubbing
• This system employs a dilute solution of sodium hypochlorite
with a large excess of sodium chloride over the
• stoichiometric quantity. The mercury removal efficiency
of this system is maintained over a wide enough pH range
• to make control possible. A mercury collection efficiency
of 95 to 99 percent has been reported.
E. Adsorption Beds
1. Treated Activated Carbon
Control systems containing either sulfur or iodine-
impregnated activated carbon are being utilized by several
chlor-alkali facilities for reduction of the mercury
concentration in the hydrogen stream. In these systems,
the mercury vapor is adsorbed by the carbon and chemically
13
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reacts with 'the iulfur of Iodine to form mercury
* * *
compounds. Some problems could arise 1f substantial
amounts of particulate mercury are present In the gas
stream; however, this situation could be corrected by
•
• t
either preheating the gas stream or by using a mist
elimination device prior to the carbon bed.
In order for treated activated carbon to perform
efficiently, the gas stream velocity through the bed
should be In the range of 20 to 40 feet per minute.
This low gas velocity is required to allow sufficient
contact^time between the mercury and the treated carbon.
A mercury vapor collection efficiency of approximately
90 percent is expected. Destructive distillation of
the spent carbon appears practical for recovering the
adsorbed mercury.
2. Molecular Sieve
The molecular sieve control technique utilizes a sieve-
adsorbent blend to adsorb the mercury contained in the
gas stream. A molecular sieve system currently available
for the treatment of both the hydrogen gas and the end-box
ventilation streams of chlor-alkali plants is the
PuraSiv - Hg System. The designer of this system
guarantees a reduction of the mercury concentration to
0.50 milligrams per cubic meter.
14
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I ..
i ••;•'.-
i
I GUIDELINES FOR' WAIVERS OF
•COMPLIANCE WITH EMISSION STANDARDS
_ FOR BERYLLIUM
_ I. Introduction
• 1. Legal Basis for Waivers of Compliance.
• According to Section 61.10 of Subpart A of the National
| Emission Standards for Hazardous Pollutants, the operator of
| an existing stationary source unable to operate 1n compliance
_ with the standard prescribed under Subpart C may request a waiver
™ of compliance with such standard. Therefore, a plant that is
• operating (including plants that are starting up) at the time the
NESHAP 1s promulgated and that is a source category covered by the
£ «t»»tri;irri should be eliaible for a waiver of compliance. Plants
f not 1n operation on the date of promulgation should not be
•• granted waivers of compliance. An eligible plant may apply to EPA
1M for a compliance waiver by presenting the information required by
Section 61.10 of NESHAP. Presentation of complete and necessary
I Information is the operator's responsibility and should be done
.
_ with his first transmittal of Information, drawings, and data.
™ It 1s particularly important for him to be concise on his ^ onosal
fl for emission controls and on the timetable for their accomplishment,
^
m II. Guidelines to Length of Waivers
According to Section 61.11 of NESHAP, the Administrator may
• grant a waiver of compliance with the beryllium emission standard
for a period not exceeding tv/o years.
I
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The request for a waiver of compliance should Include the
>
listing of certain milestone dates 1n a plant's effort to achieve
compliance. The persons 1r EPA evaluating a waiver request should
use the information presented 1n Section III as a guideline to
determine the length of the waiver. It is suggested that the
milestone guidelines be used as follows:
A) If the owner's or operator's requested lead time is .
less than the EPA guideline time, allow a waiver time equal to
•
the operator's requested lead time.
B) If the owner's or operator's requested lead time exceeds
the EPA guideline time by up to 20 percent, allow a waiver time
equal to the operator's requested lead time.
C) If the owner's or operator's requested time exceeds the
EPA guideline value over 20 percent., justification must be
supplied for this longer milestone time or the EPA milestone
lead tire? will be granted.
III. Derivation of Allowable Waiver Lengths
1. Operations Involved in Emission Control.
Table I shows a typical sequence of ooerations Involved in
the design and construction of any sizable emission control equip-
ment. Major activities are Included; many minor ones are omitted.
If a simple item like a small cyclone were the only one installed,
many of the 23 listed operations would not be involved. The most
complex case would involve large baghouses with new fans and
ductwork.
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, i
4
i
TABLE I. SEQUENCE OF OPERATIONS IN
DESIGN AND CONSTRUCTION OF BERYLLIUM EMISSION
CONTROL EQUIPMENT.
1. Process design and flow diagram. • ^
2. Engineering flow diagram and preliminary plot plans.
3. Specification and procurement of major items such as fans
and baghouse.
4. Specification of minor items, obtainable without complete
i
drawings.
5. Design of electrical starters, switch-gear and distribution system,
6. Duct and piping arrangements and specifications.
7. Foundation design.
8. Structural steel design.
9. Receipt of certified dimension drawings of fans, baghouse, etc.
10. Release of foundation and structural steel drawings.
11. Start construction.
12. Complete pipe and ductwork takeoffs, and drawings for field support
13. Release drawings and material listings for construction.
14. Complete underground installations.
15. Complete foundations.
16. Delivery of structural steel and major items of equipment.
17. Erect major items.
18. Install ductwork and piping.
19. Install electrical.
20. Install instrumentation.
21. Startup
22. Source testing and analytical.
23. Final report.
3
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Table I shows that, 1n general, design continues Into
procurement and Into the early part of construction. Nor can
>
design be complete until receipt of certified drawings; which
presupposes that equipment purchase orders have been'placed
sometime before. In short, many operations necessarily overlap.
Thus, the waiver evaluator should be an experienced engineer
who can deal with the real complexities of plant design and
scheduling; and - if at all possible - each waiver application
should be dealt with on a case by case basis. Only for a simple
retrofit is it possible to generalize on project timing with
very much confidence.
2. Time Requirements for Construction and Startup.
Table 2 gives the approximate lead times required for
fabrication, installation and startup of the equipment and
accessories likely to be Involved 1n retrofitting a plant
handling beryllium.
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Fabrication lead times are Influenced by many things, Including
size of equipment, materials of construction, general and specific
»
level of construction activity, condition of war or peace, foreign
and domestic labor trouble, government policies, and so on. This
1s largely because of the effects of the above upon materials
and labor availability. For Instance, foreign expropriation of
U. S, - owned copper mines can cause delays 1n delivery of
electrical equipment. A condition of war tends to Increase
delivery time for all non-military Items. The waiver evaluator
should make his own check on Table 2 lead times, especially 1f any
of the Items are large and costly, or 1f strategic iretals like
copper, nickel or chromium are Involved.
3. Events Required for Meeting Emission Standards.
A waiver request can be granted for up to 2 years, but the
actual waiver time allowance should only be that required to
design, install, startup, test and prove the performance of
suitable control equipment. For this overall objective, a
number of events must take place, or a number of milestones have
to be met. Table 3 Illustrates these events or milestones of
emission control progress. The reader should note the range
of time requirements. Table 3 fits no actual case. If one
package control item only were involved, events could tend to
be consecutive: thus, ordering could follow grant of waiver,
Installation would follow procurement, startup follow installation,
etc. In the more general case of more than one control, with
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each control requiring fabrication, no simple sequence of
consecutive events 1s possible. Instead, the events overlap
1n a manner which requires case - by - case study. Thus, the
wise operator will begin engineering design before he submits
t
his waiver application; and some design work must continue
during equipment fabrication and sometimes even continue Into
the Installation period. Fabrication starts as early as possible
on Items needed early; they may be installed while other items
are still being fabricated.
It 1s clear that the total time requirements suggested by
Table 3 apply to only a complex case, such as 1f a beryllium
extraction facility were suddenly to require emission controls
throughout (a hypothetical case). Early initiation of an activity
tends to be controlling (such as a quick start on bids and
fabrication). The lengthening of an activity (like engineering
design) is only important to the degree that 1t can lengthen the
overall time schedule. Startup, of course, must follow installation
without overlap. However, report writing can be partly done
before completion of source testing.
Line lengths on Table 3 indicate 5 month ranges for fabrication
and installation. But two 5 - month Items could require a
longer total fabrication time if not started simultaneously.
In other words, the total times for fabrication or installation of
all Items could be considerably more than 5 months, depending
upon proper project management.
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I
I
• 4. Compliance Wa(1ver,T1mq Requirements.
• The derivation of allowable waiver time 1s best represented
1 by specific examples. Consider an operation currently having
P bag filters. To Insure that beryllium emissions will be
^ maintained below the lega> fimits, a HEPA filter will be added.
* Its operating pressure drop will be low enouqh to require no
ft additional fan capacity, and additional ductwork will be minimal.
] This, then, 1s a simple case of addition of one equipment piece
0 without significant auxiliaries. The derivation of allowable
— waiver tiire is given in Table 4 and the total waiver time 1s
* the sum of Items in the last column of that table. The total
ft allowable waiver, time is therefore 302 days after grant of
v/aiver, assuming ordering activity started at time of waiver
ft grant.
I In Table 4, filter ordering includes writing specifications,
getting and comparing bids, and placing an order. Filter delivery
P Includes fabrication and assembly, shipping and delivery to
• jobs He.
M Note that the waiver evaluator must feel that the HEPA
^ filter addition will be an Improvement and will do the job;
i
ft otherwise he would refuse the waiver.
to Waiver evaluations for more complex situations can be treated
by a similar method, with exceptions as pointed out below. Consider
I a beryllium oxide ceramic plant which must add control equipment
to a certain operation. The flow 1s 10,000 cfm and a baghouse
I
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must be added. This baghouse must be proceeded by a cyclone
separator. Also, because of a wide particle size distribution,
a HEPA 1s advisable to remove part of the fines that escape the
baghouse.
Referring to Table 2, this case clearly involves design
and Installation of all of the equipment shown in the table,
including fan and extensive ductwork. One could therefore make
five tables (like table 4) to cover the five major items of
work. If we assume that design, procurement, and Installation
could proceed independently for each item/1.e. for baghouse,
fan, etc) the time to startup would just be the latest time shovm
among the five items.
For Instance, from table 2, the time for fabrication and
deliveries to the job site are:
cyclones 164 days
Im baghouse 164 days
, HEPA filter 164 days
jl fan 98 days
! ductwork 74 days
!• and this part of the job would consume 164 days if all orders
i
• were placed simultaneously. This can seldom happen, due to
manpower limitations and it 1s less likely to happen as the
I number of items increases.
• The waiver evaluation for addition of controls to the ceramic
plant is shown in Table 5. Time starts at arant of waiver.
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Procurement work was started first on the baahouse. It Is
assumed that the staff 1s not large enouqh to start on all
Items simultaneously, but that some work can be done on the
HEPA after 20 days, on the cyclone after 30 and on the fan after
40. The ductwork can be done right along, due to previous work
on engineering and to the simple specifications.
Other appropriate time requirements are added to Table 5
from Table 2. The on-site time for the various Items is
shown. Ductwork is available when other Items arrive. Some
of it can be installed after the fan arrives, most of it when
the baghouse is set up, and all of it wnen the HEPA is in place.
In other v/ords, all ductwork can be installed within about 150
days of 244 + 30 days (Hi.A column, table 5). However, we will
start installation when the fan is positioned, after say, 197
days. Our time schedule will be as shown in table 6 and will
be the total waiver time. Table 6 corresponds to column 3 in
table 4 for the simple case. The other missing columns may
readily be derived for the ceramic plant, to make a table like
table 4.
13
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TABLE 6 TOTAL WAIVER TIME FOR CERAMIC PLANT
»
Procurement 85 days ' .•
Delivery 98_
on site time 183
Installation, fan 14
Installation, ductwork 150
•
Startup 14
Source sampling & analysis 40
Final report 30
Total waiver time 431 days
Table 5 assumes one source sampling team, starting on the
HEPA exit and then moving to the baghouse. A less conservative
waiver time would assume ductwork Installation time to
commence upon positioning of the baghouse (I.e. 224 + 30 •»• 150
etc. days) for a total waiver time of 508 days.
A second method of estimating total waiver time for the
above beryllium ceramic plant v/ould Involve the use of critical
path techniques. To do this, one needs to 11st all of the tasks
Involved, from grant of waiver to final report. The time required
to perform each task Is then carefully determined and listed.
Secondly, the necessary and sufficient predecessor of each task
1s determined. In general, this will lead to two or more parallel
lines of tasks, or chains of milestones or events. In general, also,
14
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the time required to perform'each of these lines of tasks will
differ. The longest time path will be the allowable waiver time,
to be modified as shov/n in table 4. This critical path technique 1s
well known and 1s explained in numerous reference v/orks.
15
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•T
I
I
I
GUIDELINES FOR WAIVERS OF
COMPLIANCE WITH EMISSION STANDARDS
FOR MERCURY
I. Introduction
1, Legal Basis for Waivers of Compliance.
According to Section 61.10 of Subpart A of the National
Emission Standards for Hazardous Pollutants, the operator of
an existing stationary source unable to operate in compliance
with the standard prescribed under Subpart C may request a waiver
of compliance with such standard. Therefore, a plant that is
operating (including plants trvc are starting up) at the time the
NESHAP is promulgated and that is a source category covered bv the
standard shou'M be eligible *'-.r a waiver of compliance. Plants
not in or>frai (.. > thr ' ,•* 'MS!Cation should not be
grant's; •. - , e plant may apply to EPA
frr a -ro", i -. -. i-:f f'V ,- • '"e ^formation requ*"rnd hv
Section 61,;. ' -{ SHAIJ, Prt-- :.L:,i- ./f complete and nec'lssarv
information i': t'-- operator'j r-\^- n•-• ^H ny and should be dr ie
v/ith his ?ir-i' ,.<• I'ssmittal of infom-.f>on, drawings, a°d data.
It is part:, .• < > important ^or film to tie concise oo his proposal
for en• ••.,.••'^ f-n.if;>is and on the timetable for their ac^. ishment.
II. Guidelines to Length of fivers
According to Section 61.11 of NESHAP, the Administrator may
grant a waiver of compliance with the mercury emission standard
for a period not exceeding two vt^r^.
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The request for a waiver of compliance should Include the
listing of certain milestone dates in a plant's effort to achiove
compliance. The persons in EPA evaluating a v/aiver request should
use the information presented in Section III as a guideline to
determine the length of the waiver. It is suggested that the
milestone guidelines he used as follows:
A) If the owner's or operator's requested lead time is
less than the EPA guideline time, allow a waiver time equal to
the operator's requested lead time.
B) If the owner's or operator's requested lead time exceeds
the EPA guideline time by up to 20 percent, allow a waiver time
equal to the operator's requested lead time.
C) If the ov/ner's or operator's requested time exceeds the
EPA guideline value over 20 percent, justification must be
supplied for this longer mllesx^ie time or the EPA milestone
leau ti>e v, 11 be granted.
Ill, Derivation of Allowable Waiver Lengths
1. Operations Involved in Emission Control.
Table I shows a typical sequence of operations involved in
the design and construction of any sizable emission control equip-
ment. Major activities are included; many minor ones are omitt; >.
If a simple item like a mist eliminator were the only one installed,
many of the 23 listed operations would not be involved. The more
complex cases would involve such items as chemical scrubbers, or
cell room modifications.
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TABLE I. SEQUENCE OF OPERATIONS IN
DESIGN AND CONSTRUCTION OF M
CONTROL EQUIPMENT,
1. Process design and flow ••; --i!i»
2. Engineer ;.'(=., !•;..* diagram *•..'< rn i •• inary plot plans,
3. SpecifH;atiu!\ and procurnM->.> c,' rvjor Items such as molecular
'if , 'i» t-innablf1 without complete
5,
siribution system.
/, f< •;:' 1ft! '•• : ...-
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1 ! ' . ' ,
12 •''• • I. .- ,
- ; , t J .. •'
"4, < :•', i l-r>
i«- n equipment.
' ;" ;i.'' ' '-;" .
^or field supnnrt
22
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Table I shows that, in qcneral, de/nn conn rues Into
procurement and Into the eurly part :. ' , .,, , [on, Nor can
design be complete until rerc^pt <">; v ; ' . .-'V.incs., which
presupposes that equipment purchase :-\ <•••.-,—, • %-c- been placed
some time before. In short, many operations necessarily overlap.
Thus, the waiver evaU'a*^'" should b.? ;>n exr^r- -:nrecl engineer
who can deal with *• ' <• ;': r ::plexit <; • "•'; • * .-ipv;..- ^r»H
schedul inri; ••• ••.,'-,:, , A-^ * •_•••••
should be k ,-.;•'.;• . , -, . , . , < ^ -^inple
retrofit is u po-.^ -> - ! • ,-• • M .- '.lining with very
much confidence,
2"| - r . > *~s t , *. - - s ,
t I ' E c, \ u « ,-
Table ." -;' - -r: ; - \ • • • . 1 'or
fabricatic . :•.• . • . •.••, ^'i
ce '< . \ fM- j o«"ii,i;irv . ,, » riro^i , :.••'_. It;;'t, 15
17 in1- o-vt process chap ...;ic,- cov. -• x •• - • ..-^ ,,
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• Fabrication lead times are Influenced by many things, Including
• size of equipment, materials of construction, general and specific
level of construction activity, r (•••-> <.i if ion of war or peace, foreign
| and domestic labor trouble, - ^enr policies, and so on. This
— is largely b-f,. . ,,, tiiL !•-'• •,-. -..: •• dbove t-p'^n materials
™
and lafior ,-\\-.\ •;• "?•; Kn , •:•••(•, rire <<'r-. -• > ;>r(V:riation of
• U, S. <'M,vJ • p; • r 'tis.-'S t.u. , :.,••.' ;i,'"i', " . ,s • ". ' ii"da"ds.
A v/aiv'-" - •• r -- t,r'» : ^r.-M'.eci f,; jp tr; ? years, but the
• actua" wa-V'.-; *•.:<• ! ••'•'., ,;,-s on)v ;>t' <.f-af f'Vouired to
•ic: ; v '••••• ' - -v • • ; -. ' .- ;.«r -run ,re of
• -' ' - •• 7 >ft
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tO be li ."I , ' • . •• i--', ^.iriijS
• emission coritrr • i'-ess, • -•.'•;.'?-> nns'Uf note the *anqe
of time tt ; ,-, r- ' *., fable '; f^r, no '*rtu-"«'! c.'.sA, If one
m pack?[-,- •• =- • -. >>;'v i- r '.- ,'•. •'/*-•.;, rvent-s >;o,.nd if ,
•j oe ee>r>-.'''. . . - . a-' •••, • ;u- i i- '.'., i " o» waiver,
• etc, ;« -oir. i^' c; . • - • tfi,
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each control ren.^rii>n fabric.iri'in, no :>4t-,ple scM(uencr» of
consecutive ; :•< • \ \'- j<'.;ss1!'
in a manne-r •,'••'••
wise oper-s* • • ' . •••' ii •*;-••
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^nies ever, continue into
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• • t-il ioci .."i c*-- f:;> - Hems
It is clear that tne tot, "^' t
Table 3 apply to '-hlv a comp-e«, •>. t-,
mercur, ex^'ar 1 \ --rs < ^' > ,
cul rrinonts suggested by
v »i -'^ it" a large primary
, : *rnt, , i- emission
',;<", ir. ': ' ,-^tHin of an
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, ' :' -• engineer inq
, • -' ' ' L -1 lotion
{irtore t •*'••, ,•'
raoncii v «
items could f
simul tdr,eA.-s 1
lon.;«r tot.,) r ar,r' c.at TO- r line it not started
non'
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4. Compliance Waiver Time R<*;<-. • '?ents,
The derivation of dUowablp .? s i no is best represented
by specific exar-'ip-v, . certain ,, « r,-• urv extraction
facility has o>-3l^ed a new supplv t.t cola 'nountain v/ater v/hich
novi changes their mercury condenser ccoMnc water temperature
from 78°F to a new temperature of ro°(-. This results in increased
particulate me re urv emission and they ""H>e$t a v/aiver during
installation of ^ T,err...> ^ist el in incite-, 'Ms is a simnle case
of additi'-r. o"" ' -ir . -\,
The derivation of a'• h
the total v.Mv--r u-:.-j
that table, T» e • '
after gram at wa i ver
of waiver - - •'. .
', a i vf-r
.mfirant auxiliaries.
•""- *!ri "fable 4 and
.••!=• ir-st column of
! •; tnr-refore 271 days
• ly star.ed at time
12
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In Table 4, mist eliminator or<•"•'' :>
treated by a similar net hod, with e< -
below. Consider the folio M: ; •• mv»? >t
a chlor-alkali pl:»' -•> • ,:,jl(, • >
plant will ,,,e i >J;-;inicd! •••-•' r,
box vet'.t", ''^ -~>r. •• • 'i- ' - fi/fif. ,-<•'•,
can be
- -~ pointed out
,^,": -pceived from
i:\a ;.i.indard., This
.. ,- ;in jioth the end
v. - ' *• »r, to achieve
lov-e-/ ,r, t-,t, pla-it . - ;,5-. ; •
their end boxes and t*H- e vn 1 ] be cor, itr..;
and design work sill '• ie in-hou-.r
All the engineering
Referrinr t-.-. 'lat-i- , , this cas-; clearly involves design
and co- v.t >":>•• - '-> • " i:~., t ^ -• , ,a! tank, scruhbor,
mist eliminator,. . •. t ;-^ ,,-v. ?•-,„ _,>,. '>.-/:•. ,j',j Herhc.p> fan. However,
it will be assumed trial (-.-• addit'."'.--'! ''>**•• ". '"^lui^ed for
this job di.n auv n-^tde.: ; • ',. •-, ; 1 1 -e ' ••"• • ' ••! \/1th the scrubber.
One could there"(,M, HWK^ f^vt- t-. i • ' < ,• .. . 1; ti> cove,1
the five me • • ':..•„ t, - ^tsign, procurement
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I
_ and Installation could proceed independently for each item
' (I.e. for seal tank, scrubber, etc) the time to startup would just
I be the latest time shown among tK< five items.
• For instance, from tabie \'., tne tme for fabrication and
deliveries to the job site are-,
• scrubber 1^4 days
mist eliminator 140 days
• end t\jx covers 74 days
• and this part of the job would consume 194 days if all orders
were placed simultaneously, This can seldom hanpen, due to
• manpower limitanoris arid it is l- ss likely to happen as the
number of items increases,
The waive' * valuation f -: addition of controls to the
| chlor-aikalie plant is sf• rable 5, Time starts at grant
_ ,>f wav-->! « 'fun-'o : , Hrct on the chr--ri_,'i scrubber which
• • -•• -••• !,: 41- .M.^tiC'^i '" ",="" dm*="" proc'-irnmenl="" mt="" at="" this="" s3--i'="" ;.•="" -="" ..="" ^..u-,="" ;-•:="" f-="" ".i="" !;="" „="" sore="" cf="" t'iis="" f-'ork="" may="" be="" done="" «_•-•="">. •
™ The r>(5,.'• t-si-- is a ?.im> i-.- - ie.fi wMc1- : *.f- i-o >tarted at any
• reasonable time, If time permits, the end bc,\ covers should be
started eariy, because of thnir relation to connections,,
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Other appropriate time requirements are added to table 5
from table 2, The on-site time for the various Items is shown.
All ductwork and piping is avaiKl-le shortly before scrubber
arrival and sonic :" t'vis v/oulc , JDUUV ; .;• on rite and installed
even e^ ' ;
exst of n
ThUS, O'u: « ?c.
wil! br th-' f
in tabi column 3
'; • •<.-!• sin<; columns
;,<• the chlor-alkalie
• >us to table 4.
1 ••*, ;~ "-pducpd somevhat,
• • • i.hc conservative
otal waiver" time for lt;f
• '.'^: :is-.- o* cr Hlcal
•-• ,-•> ! *i ,* ! of the
•"•.,'ui • •.'r.-.r'f, The time
• -j^Hient preaecessor of
I
17
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TABLE 6. TOTAL WAIVER TIME FOR CHLOR-AlML IF PLANT
Procurement 145 days
Delivery JB£
On site tine ~-'1r-
Install at ion
Startup
Source sampling and analysis
Final report
Total v/aiver t i;\e
18
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each task is determined. In general, this will lead to two
or more parallel lines of tasks, or chains of milestones or events,
In general, also, the time required to perform each of these
lines of tasks will differ. The longest time path will be the
allowable waiver time, to be modified as shown in table 4. This
critical path technique is well known and is explained in
numerous reference works.
ravi..'or.m T.r,:.I Protection Agency
R-" ] -. V,_ Jr.brery
rc> i >... .-h r>.;sr-bo'rn Street
Cl—„, i/>D Illinois 6060«f
19
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