United States
Environmental Protection
Agency
Technology Transfer
&EPA Handbook
Industrial Guide
for Air Pollution
Control
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EPA-625/6-78-004
INDUSTRIAL GUIDE FOR
AIR POLLUTION CONTROL
U.S. ENVIRONMENTAL PROTECTION AGENCY
Technology Transfer
June 1978
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ACKNOWLEDGMENTS
This handbook was prepared for the Environmental Research Information Center by PEDCo
Environmental, Inc., under EPA Contract No. 68-01^147. Alsid, Snowden and Associates
and York Research Corporation were technical reviewers of the handbook. EPA reviewers
were Robert Walsh of the Office of Air Quality Planning and Standards, and Francis Biros,
Stationary Source Enforcement Division.
NOTICE
The mention of trade names of commercial products in this publication is for illustration
purposes and does not constitute endorsement or recommendation for use by the U.S.
Environmental Protection Agency. This manual is presented as a helpful guide to the user
and should in no way be construed as a regulatory document. For legislative or enforcement
assistance, the user should contact air pollution personnel in either EPA regional offices
or the appropriate state agency.
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CONTENTS
Chapter Page
ACKNOWLEDGMENTS ii
CONTENTS in
LIST OF FIGURES v
LIST OF TABLES viii
1 INTRODUCTION 1-1
2 COMPLIANCE PROGRAM PLANNING
2.1 Environmental Assessment and Planning 2-1
2.2 Implementing the Environmental Program 2-10
2.3 Related Responsibilities 2-14
2.4 Examples of Corporate Environmental Programs 2-15
2.5 References 2-19
3 PLANT EMISSION SURVEY 3-1
3.1 Introduction 3-1
3.2 Identifying and Cataloguing Emission Sources 3-1
3.3 Identifying and Quantifying Emissions 3-14
3.4 Preparing a Source Identification File 3-21
3.5 References 3-21
4 EMISSION REGULATIONS 4-1
4.1 Legal Requirements Under the Clean Air Act Relative to Testing 4-1
4.2 Inspection and Data Requirements Under the Clean Air Act 4-5
4.3 Confidentiality of Data — The Freedom of Information Act 4-6
4.4 State Implementation Plans 4-9
4.5 References 4-27
5 STACK EMISSION MEASUREMENTS 5-1
5.1 Introduction 5-1
5.2 Utilizing Consultants and Testing Service Organizations 5-3
m
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CONTENTS - Continued
Chapter Page
5-3 Planning and Conducting the Emission Test 5-7
5.4 Specified Methods for Measurement of Pollutants 5-23
5.5 References 5-45
6 AMBIENT AIR MONITORING/CONTINUOUS STACK MONITORING 6-1
6.1 Introduction 6-1
6.2 Selection of Sites for Ambient Air Monitoring 6-3
6.3 Equipment for Ambient Air Monitoring 6-7
6.4 Continuous Stack Monitoring 6-15
7 THE CONTINUING PROGRAM 7-1
7.1 Introduction 7-1
7.2 Control Equipment Maintenance 7-7
Appendix Page
A SAMPLE SAROAD AND NEDS FORMS A-l
B SAMPLING AND FACILITY OPERATION CHECKLISTS B-l
C DATA SHEETS (ELECTROSTATIC PRECIPITATOR, PARTICULATE
SCRUBBER, FABRIC FILTER, AND CENTRIFUGAL PURIFIER) C-l
D PROCEDURES FOR STARTUP AND SHUTDOWN OF ELECTRO-
STATIC PRECIPITATORS D-l
E PROCEDURES FOR TROUBLESHOOTING AND CORRECTION OF
BAGHOUSE MALFUNCTIONS E-l
F TYPICAL TROUBLESHOOTING CHART FOR AN ELECTRO-
STATIC PRECIPITATOR (EXAMPLE ONLY) F-l
IV
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LIST OF FIGURES
Figure No. page
1-1 A Three-Phase Compliance Program 1-3
2-1 Example Permit Application Form for Fuel Burning Equipment 2-4
2-2 Example Portion of Application Form for a Spray Booth 2-7
2-3 Small Oil-Fired Boiler 2-8
2-4 Spray Booth with Drier Duct in Background 2-9
2-5 Example Partial Organization Chart for Large Manufacturing Company 2-16
2-6 Alternative Partial Organization 2-17
2-7 Example Organization of a Large Utility 2-18
2-8 Example Partial Organization for a Small Company 2-19
3-1 Plant Personnel Verifying Emission Sources During Emission Survey 3-2
3-2 Example Process Flow Diagram 3-3
3-3 Roof of a Typical Chemical Plant With Numerous Emission Sources 3-4
3-4 Example Presurvey Data Sheet for Fossil-Fuel-Fired Steam Generators 3-5
3-5 Example Precipitator Survey Data Sheet 3-7
3-6 Example Fabric Filter Survey Data Sheet 3-8
3-7 Example Scrubber or Cyclone Survey Data Sheet 3-9
3-8 Technical Identifying Process Stack 3-10
3-9 Air Conditioning System and Duct to Root of Building 3-12
3-10 Obtaining Accurate Stack Information During the Plant Tour 3-13
3-11 Cyclone Outlet Requiring Modification by Most States Prior to
Performing Emission Test 3-14
3-12 Stack Data Requirements 3-15
3-13 Compliance Schedule Chart 3-17
3-14 Source Identification Form 3-22
3-15 Facility Cover Sheet 3-23
4-1 Pre-test Form Used by Ohio EPA 4-11
4-2 Process Information Form Used by Ohio EPA 4-13
4-3 Typical Permit System Flow Diagram 4-15
4-4 Typical Organization Chart for a Local Governmental Organization 4-17
4-5 Generalized Distribution of Functional Activities for Regulatory
Agencies Anticipated for 1974 4-18
4-6 Continuation of Permit System 4-20
4-7 Field Report Form, Dust and Fumes, Los Angeles County Air
Pollution Control District 4-21
4-8 Agency Inspection Complaint Form 4-22
4-9 Reporting of Violations 4-25
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FIGURES - Continued
Figure No. PaSe
4-10 Group Interactions for Violation Correction 4-26
4-11 Regulatory Agency Functions for Handling Violation 4-27
4-12 Typical Form for Compliance Schedule 4-28
5-1 Test Program Meeting Representatives 5-10
5-2 Test Program Agreement on Continuing Compliance Conditions 5-11
5-3 Test Program Agreement on Facility Operation 5-12
5-4 Minimum Number of Sample Points 5-15
5-5 Typical Sampling Provision 5-18
5-6 Monorail System 5-19
5-7 Stack Extension 5-20
5-8 Test Team and Equipment 5-21
5-9 Source Testing Report Format 5-24
5-10 Velocity Measurement System 5-25
5-11 Grab Sample Setup for Molecular Weight Determination 5-27
5-12 Integrated Sample Setup for Molecular Weight Determination 5-27
5-13 Moisture Sample Train 5-29
5-14 Approximate Moisture Sample Train 5-29
5-15 EPA Method 5 Particulate Sample Apparatus 5-30
5-16 EPA Method 6 Sulfur Dioxide Sample Train 5-34
5-17 EPA Method 7 Nitrogen Oxide Sample Train 5-36
5-18 Continuous Sample Train for CO 5-38
5-19 Integrated Sampling Train for CO 5-39
5-20 Sampling Apparatus for CO 5-39
5-21 Sampling Apparatus for Fluoride 5-42
5-22 Distillation Apparatus 5-42
6-1 Example of Annual Wind Rose 6-5
6-2 Coordinate System Showing Plume Dispersion 6-6
6-3 High-Volume Air Sampler 6-9
6-4 Field Sheet for High-Volume Air Sampler 6-10
6-5 Sulfation Plate and Holder 6-11
6-6 Dynamic Sampling Unit (Bubbler Train) 6-13
6-7 Systematic Approach to Continuous Stack Monitoring 6-18
6-8 Continuous Monitoring System 6-19
6-9 Technique for Visible Emission Detection 6-21
6-10 Stratification of Particles in Ducts 6-24
6-11 Schematic of Chemiluminescent Technique 6-30
6-12 Schematic for Nondispersive Infrared Detection 6-30
6-13 Schematic of Chromatograph 6-31
VI
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FIGURES - Continued
"Figure No. Page
7-1 Types of Variation in Process Operation 7-4
7-2 Upset/Breakdown Report Form 7-8
7-3 Required Startup Time to Achieve On-Line Load Demand for
Fossil-Fuel-Fired Steam Generators 7-10
7-4 Systematic Approach to Typical Air Pollution Control Equipment
Operation and Maintenance 7-12
7-5 Incinerator Used to Control Solvent Fumes 7-15
7-6 Baghouse Installation on an Asphalt Batch Plant 7-15
7-7 Wet Scrubber Installation on an Asphalt Batch Plant 7-25
7-8 Electrostatic Precipitator Installation on Power Boiler 7-25
7-9 ESP Maintenance Cycle 7-29
7-10 Test Data Relating Optical Density to Outlet Grain Loading 7-34
A-l SAROAD Site Identification Form A-l
A-2 National Emissions Data System (NEDS) Form A-3
A-3 SAROAD Hourly Data Form A-4
B-l Test Program Meeting Representatives Form B-l
B-2 Test Program Meeting Participants Form B-2
B-3 Form for Test Program Plant Requirements and Testing Methodology B-3
B-4 Form for Test Program Agreement on Facility Operation B-4
B-5 Form for Test Program Agreement on Continuing Compliance
Conditions B-5
B-6 Field Observation Checklist B-6
B-7 Sample Chain of Custody Form B-12
B-8 Sample Transport Particulate Checklist B-l3
B-9 Analytical Particulate Checklist B-14
B-10 Facility Operating Parameters During Test Period for a Power Plant B-18
B-l 1 Form for Process Data During Test B-22
B-12 Form for Fuel Input Data During Test B-23
C-l Data Sheet — Electrostatic Precipitator C-l
C-2 Data Sheet - Particulate Scrubber C-2
C-3 Data Sheet - Fabric Filter C-3
C-4 Data Sheet - Centrifugal Collector C-4
vn
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LIST OF TABLES
Table No. Page
2-1 Sample Corporate Objectives, Program Elements, and Results 2-2
4-1 Regulations Under The Clean Air Act 4-4
5-1 Time Requirements for Compliance Test Execution 5-8
6-1 Allowable Deterioration in Classes I and II 6-2
6-2 Absorption Sampling Devices 6-14
6-3 Recommended Sampling Methods 6-15
6-4 Industry-Monitoring Requirement Matrix 6-17
6-5 Performance Specifications for Opacity Monitors 6-22
6-6 Criteria for Continuous Monitors for Gases 6-25
6-7 Instrument Specifications 6-27
7-1 Effects on Emissions by Increasing Values of Selected Operating
Variables (Fuel Oil Consumption) 7-3
7-2 Incinerator Malfunctions That Affect Emission Rates 7-5
7-3 Effect of Shutdown Duration on Effluent S02 Concentrations
During Startup 7-6
7-4 Checklist for Routine Inspection of Baghouse 7-16
7-5 Baghouse Collection Maintenance 7-17
7-6 List of Replacement Parts for a Baghouse Filter 7-18
7-7 Cost of Base Replacement in Fabric Filters 7-19
7-8 Maintenance for Plugging and Scaling Venturi Scrubber 7-20
7-9 Scrubber Maintenance 7-21
7-10 Spare Parts Inventory for Venturi Scrubber 7-22
7-11 Type of Maintenance Required - Venturi Scrubber Systems 7-23
7-12 ESP Inspection Timetable 7-32
7-13 Maintenance of Typical Industrial ESP 7-33
B-l Allowable Operating Parameters for a Power Plant B-15
Vlll
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CHAPTER 1
INTRODUCTION
The information presented in this manual is intended for plant managers, engineers, and
other industrial personnel responsible for plant compliance with air pollution control
regulations. It is intended as a set of guidelines and is oriented to companies that are not
yet fully involved in a corporate program of environmental control. Some of the tasks
involved in achieving and maintaining compliance with regulations require expertise that
is beyond the usual range of skills and experience of industrial plant personnel; the
manual therefore presents criteria for evaluation of outside firms or consultants who offer
specialized environmental services.
The question may arise, "Why should we as an industry read and do what this guide
describes?" Certainly legislation and enforcement action by cognizant regulatory
authorities will force industry to comply with pollution regulations or face severe
penalties.
Perhaps another factor as important as the mandating aspect is the social awareness of
protecting the community from the harmful effects of air pollution. A well-conceived
pollution abatement program is important to those residing close to the plant. Industries
that maintain a good relationship with the surrounding community may recognize
benefits such as assistance in zoning changes and less vandalism.
Since this manual is designed for use in industry-at-large, much of the discussion is
general. The discussions are illustrated with examples that are industry-specific such as
flowsheets, survey forms, checklists, maintenance schedules, and similar materials
currently used in compliance programs of individual industrial plants. The example
illustrations typify the tools available to the corporate compliance planner.
The manual is designed to be used in different ways by personnel performing diverse
functions within the company structure. The plant executive will wish to know what this
document provides and how it can best be used by the responsible persons on his staff.
He may have no personal need for details of procedures for shutdown, maintenance, and
start-up of an electrostatic precipitator; he should, however, be aware of the degree of
technical knowledge and skill that is required to perform these tasks efficiently. In some
instances, sample detailed checklists are provided within the text with additional detailed
procedures included in the appendix. Not everyone will read or use all portions of this
manual. Some portions may be excerpted for distribution to the responsible staff.
1-1
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As closely as possible, the structure of the manual corresponds to the structure of an
industrial compliance program, consisting of three major phases:
1. Achieving compliance,
2. Demonstrating compliance, and
3. Maintaining compliance.
It is difficult to determine whether emission sources or emission regulations should be
discussed first. It was decided to place the Plant Emission Survey (Chapter 3) ahead of
Emission Regulations (Chapter 4). It is suggested that the reader refer to Chapter 4 prior
to conducting an emission survey in order to become familiar with the regulations that
apply to specific processes or operations.
The relationship of chapters in this manual to the three-phase, overall compliance
program is delineated in Figure 1-1 and is discussed below.
Achieving Compliance
Chapter 2: Compliance Program Planning — Intended primarily for industrial managers
with highest-level responsibility for'the compliance program, this chapter introduces the
basic steps involved in tailoring the program to the company's needs. It outlines
departmental functions, as exemplified in typical organizational options for large and
small industries.
Chapter 3: Plant Emission Survey - The emission survey identifies all sources of air
pollutant emissions within an industrial plant. This chapter, directed to the plant engineer
or process engineer, describes how to conduct the survey, quantify pollutant emissions,
and prepare a source identification file.
Chapter 4: Emission Regulations - Having determined the plant's specific pollution
problems, the industrial manager, possibly with consultation of the corporation's legal
counsel, can review in this chapter the requirements applicable to the company under
current and anticipated air pollution control regulations. The chapter outlines salient
provisions of the Clean Air Act of 1970; requirements for inspection, monitoring,
recordkeeping, and data reporting; legal considerations for confidentiality of proprietary
information;. and the major implications for industry of State Implementation Plans under
the Clean Air Act, including registration/permit programs.
Demonstrating Compliance
When the industrial plant manager has reviewed the available options for air pollution
1-2
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ACHIEVE COMPLIANCE
PLANNING THE
ENVIRONMENTAL PROGRAM
CHAPTER 2
CONDUCT PLANT
EMISSION SURVEY
CHAPTER 3
QUALIFY AND QUANTIFY
EMISSIONS-CHAPTER 5
DETERMINE APPLICABLE
REGULATIONS-CHAPTER 4]
SELECT AND INSTALL
PROPER CONTROL
EQUIPMENT - CHAPTER 3
DEMONSTRATE COMPLIANCE
FORMULATE COMPLIANCE
TESTING PROGRAM - CHAPTER 5
CONDUCT MANUAL COMPLIANCE
TEST -CHAPTER 5
INSTALL AND CERTIFY
CONTINUOUS MONITORS
CHAPTER 6
SET UP AMBIENT AIR
NETWORK -CHAPTER 6
MAINTAIN COMPLIANCE
'
ESTABLISH CONTINUED
COMPLIANCE PROGRAM
CHAPTER?
PROCESS OPERATION
CHAPTER 7
CONTROL EQUIPMENT
OPERATION AND MAINTENANCE
CHAPTER 7
FIGURE 1-1
A THREE-PHASE COMPLIANCE PROG RAM
control and has conducted the modifications/installations that will bring the plant into
compliance with applicable regulations, compliance must be demonstrated to control
agency representatives by measurement of pollutant emissions in a series of compliance
tests during representative plant operations. Information on compliance testing and
monitoring, as well as continuing compliance efforts, includes approximate costs of
equipment, labor, and other expenditures; these estimates are based on 1977 costs.
Chapter 5: Stack Emission Measurements — This chapter presents the basic concepts of
emission testing, with detailed consideration of the planning, testing, and reporting phases
of an emission test program. It provides criteria for determining whether the tests should be
1-3
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performed by in-house technical staff or by contract for the services of a professional
emissions testing team. Section 5.3 briefly describes the sampling methods specified by
control agencies for each of the regulated pollutants.
Chapter 6: Ambient Air Monitoring/Continuous Stack Monitoring - In conjunction with
measurements of emissions in the stack, industrial plant operators may wish to conduct a
program of ambient air monitoring (i.e., measuring specific pollutants in the atmosphere
near the plant). Monitoring is done for a variety of reasons, often in conjunction with
planning of new plants or expansion of facilities. Continuous monitoring of plant
emissions for specified pollutants is required in certain industries under the U.S. EPA's
New Source Performance Standards. Chapter 6 describes the fundamentals of ambient air
monitoring and continuous stack monitoring, including selection of monitoring sites,
instrumentation, and data reporting.
Maintaining Compliance
Chapter 7: The Continuing Program - This chapter presents the elements of an industry's
continuing program to maintain compliance status when that status has been achieved.
It considers the effects of changes in raw materials and in-process operations, malfunctions
of process or control equipment, start-up and shutdown, maintenance and troubleshooting.
Three major particulate control system are considered in detail: the fabric filter, venturi
scrubber, and electrostatic precipitator. Each system is analyzed in terms of inspection/
maintenance/troubleshooting, spare parts inventory, and manpower requirements.
In presenting this manual for use by managerial and technical staff of diverse United
States industries, it is recognized that not all specific needs can be addressed. The
information presented here should, however, provide for industrial personnel an insight
into the probable scope of a company's compliance program and the methods by which
the plant can achieve and maintain compliance status.
1-4
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CHAPTER 2
COMPLIANCE PROGRAM PLANNING
2.1 Environmental Assessment and Planning
Environmental assessment and planning can be integrated into a company's corporate
structure in several ways. The company can manage and operate its own program with
in-house personnel, hire a consulting firm to outline and implement the environmental
program, or utilize some combination of in-house staff and consultants. The exact
mechanisms for carrying out these responsibilities will vary with each company,
depending on its size, staff, potential environmental problems, and its dedication to
solving these problems. This chapter discusses only the aspects of environmental planning
related to atmospheric emissions. A full-scale environmental program will also consider
water, solid wastes, and noise pollutants and will be coordinated with plant programs for
occupational safety, health, and energy conservation. In addition, other aspects of
environmental planning such as plant siting, assessment and impact studies, and
nondegradation should be considered but are beyond the scope of these guidelines.
2.1.1 Corporate Planning of the Environmental Program
Each company must define its objectives as they relate, for example, to legal
requirements, emission assessment, emission control plans, expansion plans, and corporate
responsibility. As these objectives are explored and defined, an awareness of the overall
environmental situation will develop and will provide a basis for planning. In determining
specific objectives and the tasks required to carry them out, the company must conduct a
preliminary assessment of process emissions at each operating location that could
constitute an emission source. This assessment will determine the number and complexity
of the subsequent steps required to fulfill the desired objectives.
Corporate objectives must be defined to develop a corporate environmental program.
Table 2-1 lists sample objectives as well as program elements and results which aid in
achieving those sample objectives. The extent and complexity of the program will depend
largely on specific objectives and on the number and type of processes involved.
2.1.2 Locate and Describe Atmospheric Emission Sources
A first step in any program is to determine what processes emit atmospheric pollutants
and are subject to a pollution control regulation, or could cause a public nuisance or an
adverse health effect. This inventory of sources provides the comprehensive basis for
many subsequent planning steps and thus should be as complete as possible.
2-1
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As described in Chapter 3, a comprehensive survey of each process should identify vents
and emission parameters. In an initial survey, only individual sources such as boilers,
incinerators, and manufacturing processes must be identified. In subsequent, more-
detailed surveys, all individual vents and stacks serving the processes should be identified.
2.1.3 Emission Assessment
Having determined what processes emit pollutants to the atmosphere and what regulatory
requirements apply to these processes, a preliminary assessment of their emissions is made
by applying emission factors, making material balances and measurements, and estimating
engineering requirements. Emission tests may be required for compliance with regulations
or when emission estimates are not adequate for inventory purposes.
2.1.4 Regulatory Requirements
Atmospheric emissions are regulated at local, state, and federal levels. All of these
regulations must be searched, with notation of sections applicable to the various plant
processes. The compliance status of each process must then be determined by comparing
actual emissions with allowable emissions.
Enforcement personel from state or local agencies will contact those industries which are
thought to be violating emission standards. The industry is then responsible for either
proving they are in compliance or implementing control systems to comply with
standards.
2.1.5 Permit Requirements
Since the early 1970's, and in many jurisdictions well before that, operating permits have
been required for various processes that are vented to the atmosphere. A thorough review
of regulations applicable to each plant site is required to determine precisely the
processes for which permits are required.* Copies of permit application forms can be
obtained from the appropriate agency. Example forms are shown in Figures 2-1 and 2-2
for an oil-fired boiler (Figure 2-3) and a spray booth (Figure 2-4). These forms should be
completed by persons with understanding of the regulations and of the process involved.
Air pollution control agencies will explain any ambiguous wording or interpretation
regarding processes requiring permits.
Permit applications provide the basis for a control agency's decision to grant or deny a
permit to operate. Most agencies require process flow diagrams, composition and feed
rates of raw materials, production rates, operating schedules, exhaust rates, and related
information characterizing the process. The information required on these forms is largely
*See Chapter 4.
2-3
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FUEL BURNING EQUIPMENT
(Boilers, Heaters, and Steam Generators)
1. Manufacturer.
Model No.
2, Your identification
Year installed
Max,
.Max.
3. Input capacities {106 BTU/hr): Rated
Output capacities (Ib—steam/hr): Rated
Note: Indicate units if different from above.
4. Percent used for: Space heat % Process %
5. Normal Operating schedule: hr/day, day/wk,
.Normal
.Normal
wk/yr
6. Type of fuel fired: D Coal
DWood
D Oil D Natural gas
D LPG D Other, specify.
7. Type of draft:
D Natural
D Induced D Forced
8. Combustion monitoring: D Fuel/air ratio
D Other, specify
DO.
D Smoke
COAL-FIRED UNITS
9. Type of firing: D Hand-fired D Underfeed stoker D Traveling grate
D Chain grate D Spreader stoker D Cyclones
D Pulverized, dry bottom D Vibrating grates
D Pulverized, wet bottom
D Other, specify _ •
10. Fly ash reinjection: D Yes D No
OIL-FIRED UNITS
11. Type of oil:
12. Atomization:
DNo. 2
DNo. 6
D Other, specify.
D Oil pressure D Steam pressure
D Rotary cup D Other, specify.
D Compressed air
13. Oil preheater: D Yes, temp.
a NO
FIGURE2-1
EXAMPLE PERMIT APPLICATION FORM FOR FUEL BURNING EQUIPMENT
2-4
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FUEL DATA
14. Complete the following tables for each type of fuel:
Type of Heat content
fuel (BTU/unit)
Coal BTU/lb
Oil BTU/gal
Gas BTU/cu ft
Wood BTU/lb
LPG BTU/gaf
Other
Percent
Ash
Sulfur
Quantity of fuel used
Per year
ton
gal
cu ft
ton
gal
Normal/hr
Ib
gal
cu ft
Ib
gal
Maximum/hr
Ib
gal
cu ft
Ib
gal
Type of
fuel
Coal
Oil
Gas
Wood
LPG
Other
Percent annual use
Winter
Spring
Summer
Fal!
1
*Obtain fuel analysis from vendor(s)
and report on an as-received basis.
Use weighted annual averages.
CONTROL EQUIPMENT
Control equipment code:
(A) Settling chamber
(B) Cyclone
{C) Multiple cyclone
(D) Electrostatic prectpitator
(E) Fabric collector {baghousej
15. Control equipment data:
(F)
(G)
(H)
(I)
(J)
Spray chamber
Cyclonic scrubber
Packed tower
Venturi
Other
Item
(a) Type (see above code)
(b) Manufacturer
(c) Model No.
(d) Year installed
(e) Your identification
{f} Pollutant controlled
(g) Controlled pollutant emission
rate (if known)
(h) Pressure drop
(i) Design efficiency
(j) Operating efficiency
Primary collector
Secondary collector
FIGURE 2-1 (Cent.)
EXAMPLE PERMIT APPLICATION FORM FOR FUEL BURNING EQUIPMENT
2-5
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EMISSION POINT DATA
16. Your emission point identification
17. Are other sources vented to this stack? D Yes D No
If yes, identify sources
18. Type: D Round, top inside diameter dimension
D Rectangular, top inside dimensions (L) x (W)
19. Height: Above roof ft, above ground ft
20. Exit gas: Temp °F, Volume acfm. Velocity ft/mm
21. Continuous monitoring equipment: D Yes d No
If yes, indicate type , Manufacturer
Make or model , Pollutant(s) monitored
22. Emission data: Emissions from this source have been determined and such data are
included with this appendix: D Yes D No
If yes, check method: C Emission test D Emission factor
Completed by , Date
FIGURE 2-1 (Cont.)
EXAMPLE PERMIT APPLICATION FORM FOR FUEL BURNING EQUIPMENT
2-6
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AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET, LOS ANGELES. CALIF. 90013. MADISON 9-4711
SPRAY BOOTH SUMMARY
IStt REVERSE SIIM I OH INSTRUCTIONS*
ONE COPY OF THIS FORM MIJST BE f (LLE 0 OUT COMPLE Tt LY FOR EACH BOOTH
AND MUST ACCOMPANY THE TRIPLICATt APPLICATION FOR PERMIT (FORK 400-Al.
I. BUSINESS LICENSE NAME OF CORPORATION, COMPANY, INDIVIDUAL OWEfi OR GOVERNMENTAL AGENCY UNDER
KW1CH APPLICATION (FORM 400-A) IS SUBMITTED:
2. BOOTH MANUFACTURER, MODEL NUMBER * SERIAL NUMBER: [SEE ITEM Z ON REVERSE SIOEt
3. BOOTH TYPE:
AUTOMOTIVE f~]
t. BOOTH DIMENSIONS' :
!. EXHAUST FAN DAIA:
NUMBER OF FANS:
MODEL NUMBER:
HORSEPOWER :
MANUFACTURER
FAN SPEED (HP-*)
VOLUME (CFM):
6. OPERATIONAL DATA -
USUAL OPERATING SCHEDULE:
HHS/OAV
T. EXHAUST CONTROL:
• ATERWASH CI] EXHAUST F I L TE R S O NONE[
IF *»T£B«ASH, GIVE PUVP CAPiCItY IN GALS./MlN.
IF FILTERED, GIVE NUUBtH 8 SIZE OF EXHAUST 'ILTER5
MOTOR HP..
8. NAME ALL TYPES OF COATINGS SPRAYED:
ENAMEL: GALS./OAY
LACQUER: _ GALS./DAY
OTHER: GALS./DAY
(DESCRiBE)
>DDEO THINNE R:
'ODED T HINNERI
THINNER:
GALS./DAY
GALS./DAY
GALS./OAT
THE AOOVE INFORMATION IS SUBMITTED TO f,E5CHin!r THE U St OF THE BOOTH FOR WHICH'
APPLICATION FOR PERMIT IS BEING WAf-F ON 111!" Af.f OMPANY INT, f ORM •100.A.
SIGNATURE 01 RESPONSIBLE
«E"BEB OF F I DM i ^^
TYPE OB PRINT NAME
AND Of f !CI »L Tl TLT
OF PEHSON SI &H IHT,
THIS OAT* f OOU.
NAME
TITLE
DO NOT WRITE HELO* THIS LINE
I. SOOTH CROSSDRAFT VELOCITY:
7. BOOTH FACE INDRAFT VELOCITY:
APPL. NO.
PROCESSED BY
CHECKED 9Y
3. SCRUBBING OR FILTERING RATIOt
1. AVC.. OAIIY SOIVI.NT LOSS TO AIMOSPHLRL:
COMMENTS:
16-50040
Form 400-C-I
FIGURE 2-2
EXAMPLE PORTION OF APPLICATION FORM FOR A SPRAY BOOTH
2-7
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FIGURE 2-3
SMALL OIL-FIRED BOILER
self-explanatory. Units of measurement must be carefully observed, e.g., an entry may be
in actual cubic feet per minute (acfm) or in standard cubic feet per minute (scfm,
corrected to 'a temperature and pressure specified in the regulations). Estimation of
emission rates is discussed in Chapter 3. If emission data are unknown, no value should
be inserted.
In some jurisdictions, the law requires that permits be obtained before a new source of
atmospheric emission is constructed or an existing source is modified. Permit forms for
2-8
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FIGURE 2-4
SPRAY BOOTH WITH DRIER DUCT IN BACKGROUND
these operations allow the control agency to evaluate the emission control equipment
that is planned and to assess potential compliance with applicable regulations. If the
agency judges that the source as planned will not operate in compliance with regulations,
agency officials may require changes in the design of the process or installation.
Only processes operating in compliance with the applicable regulations can receive
permits.
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2.1.6 Control Requirements and Compliance Programs
The preliminary emission assessment will indicate potential problems concerning regula-
tory violations, product loss, or public nuisance. For those sources that are shown to
require control, a compliance plan must be developed; this plan will be based on detailed
emission estimates and engineering feasibility studies. The compliance program must state
how processes will be brought into compliance with regulations and when compliance will
be achieved.
Corporate planning may require determination of detailed emission data such as gas
composition, particulate loading, particle size, and emission rates. This information may
be required for designing a new control device or process, or for obtaining bids from
vendors of control systems.
Product losses through process vents must be determined when material cannot be
accounted for in a materials balance (that is, a balance in quantities of input/output
materials). Product losses can occur in both gaseous and solid forms; depending on their
value, recovery of these losses could be economical.
A final step in the corporate plan is developing a system for maintaining compliance of all
emission sources. This system will include a program for updating the inventory of
existing and new sources and for obtaining the various construction and operating permits
that are required periodically. New regulations must be studied and the impacts
appraised.
New federal regulations are published in the Federal Register. Large utility and industrial
companies have adequate staff to review these regulations. Smaller companies that do not
have the time or manpower to scan the Federal Register must keep in touch with local
agencies or trade associations for the latest regulatory changes.
2.2 Implementing the Environmental Program
Structuring of the various program functions can be accomplished in a number of ways
depending on availability and expertise of the corporation's staff. Advantages and
disadvantages of several functional plans are described here.
2.2.1 Corporate Responsibility
One senior person or a small committee of senior corporate officials should have full
responsibility for implementing the corporate atmospheric emission compliance program.
This person or group will serve in a staff capacity and will be directly responsible to the
president of the corporation. When a program is implemented and operating, this person
or group can provide continuing internal review. In smaller companies, they may direct
2-10
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all environmental activities. This group can initially perform or take responsibility for
completing the objectives described in Table 2-1. If engineering personnel are available,
this work can be started internally. If knowledgeable staff personnel are not available, the
assistance of consulting engineers will be required.
2.2.2 Sources of Information and Assistance
Many publications are available concerning technical aspects of atmospheric emission
measurement and control. Sources of this information include the environmental
committees of various technical trade associations such as the following:
1. American Iron and Steel Institute,
2. American Petroleum Institute,
3. American Institute of Plant Engineers,
4. American Mining Congress,
5. Graphic Arts Technical Foundation, Inc.,
6. National Coal Association,
7. National Oil Fuel Institute,
8. National Asphalt Pavement Association
9. Technical Association for the Pulp and Paper Industry,
10. Portland Cement Association,
11. Manufacturing Chemists Association, and
12. Incinerator Institute of America.
Complete listings of organizations and their addresses are given in References 1 and 2.
Technical societies can also provide background information and guidance to a corporate
staff in assessing emissions; membership of one or two key employees should be
encouraged. These societies include:
1. Air Pollution Control Association,
2. American Society of Mechanical Engineers,
2-11
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3. American Institute of Chemical Engineers,
4. American Chemical Society, and
5. Source Evaluation Society.
A primary source of information on environmental subjects is the U.S. EPA and its
regional offices.
If in-house capability is not available, a consultant or engineering firm may be engaged to
assist in defining objectives and initial functions, to identify the required subsequent
functions, and to provide continuity in the corporate environmental program (see Section
5.2). The Air Pollution Control Association publishes annually a listing of consultants and
companies that specialize in air pollution control services.
Reports of governmental research and grant activities also provide a valuable source of
information on specific processes and control systems. Federal organizations active in
atmospheric emission control programs include:
1. Environmental Protection Agency — all sources of air and water emissions, solid
wastes management;
2. U.S. Bureau of Mines — combustion and metallurgical processing;
3. Energy Research and Development Administration — energy resources; and
4. Tennessee Valley Authority (TVA) — fertilizers and coal combustion.
2.2.3 Departmental Functions
After preliminary information has been assembled, various functions must be defined
more exactly, the format depending on size of the corporation and its manufacturing
processes. Some industries face significant potential emission problems. These include
most of the heavy industries such as ore refining and metallurgical processing, large
combustion sources, chemical manufacturing, pulp and paper manufacturing, and
processing of mineral products such as cement and asphaltic concrete. Companies engaged
in these types of industries and having more than two or three manufacturing locations
will, at least initially, require an internal staff to handle environmental planning. The size
of the staff can be minimized by use of consultants and outside engineering services.
Engineering — A corporation's engineering department usually handles all tasks pertaining
to plant and process construction and operation. Frequently, that department also
handles major maintenance projects. Because emissions result from process operations, the
2-12
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engineering department generally has initial prime responsibility for evaluating emissions,
completing permit application forms, and developing compliance plans.
The engineering department should thus be responsible for the following activities:
1. Process and Vent Inventories — As mentioned previously, an early step in any
environmental program is to inventory all processes that vent to the
atmosphere. Individual vents and their emission parameters should also be
inventoried as described in Chapter 3. This information will be useful from an
air pollution control standpoint and also in determinations of product loss, heat
loss, and building air balance.
In large firms this effort should be planned at the corporate level to ensure
completeness and uniformity, and should be carried out by the plant
engineering staff.
2. Emission Assessment — A critical and potentially time-consuming task is
determining the rate of emission from all process vents. These emissions can
sometimes be estimated from material balances, equipment design and operating
data, or published emission factors. The use of experienced consultants in this
phase of the work can save a great deal of time. Where the estimated emissions
approach or exceed emission regulations, the values should be confirmed by a
measurement program; if the source is obviously in violation, a compliance plan
may be based on experience with similar processes. Specific plans for
complying with applicable regulations should be developed by the engineering
department. Contact with engineering firms specializing in this type of work
and with control equipment suppliers is recommended. Smaller firms having
few if any environmental experts should hire a consulting firm rather than work-
ing initially with control equipment suppliers. Some control equipment suppliers
may tend to endorse their own hardware even if another control system is better
for a specific application. The engineering department should also develop equip-
ment operating and maintenance procedures.
3. Compliance Plans — The engineering department usually is responsible for
development of control plans and schedules or process modifications for
reducing emissions. The magnitude of this task depends on the number of
sources not in compliance and the modifications required.
4. Inspection and Maintenance of Process and Control Equipment — As part of a
continuing compliance program, the operation and maintenance of the process
and any pollution control equipment must be checked routinely. This effort
should be coordinated with the maintenance department. Key items to be
2-13
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observed include leaks in hoods and control device housings, operation of
instruments and records of values read, disposal of collected material, visible
plume from discharge vents, corrosion, and adherence to a maintenance
schedule.
Legal Activities — The legal staff should undertake a thorough review of federal, state, and
O o tj
local regulations pertaining to operating and planned processes. This review will enable
management to determine what sources are subject to the regulations, details of these
regulations, and what permits are required. The legal staff should also review tax laws
pertaining to pollution control equipment. They should also keep abreast of current
regulations pertaining to wastewaters, solid residues, noise pollution, industrial hygiene,
and energy resource management, since regulations applicable to one environmental
problem will frequently affect another. The company's legal staff can usually provide
contact with outside legal counsel knowledgeable in environmental matters.
O O
Budget Department (Comptroller's Office) - The corporation's budget group will
probably enter the environmental planning phase at the point of preliminary cost
estimates for control of processes that do not comply with regulations. Further studies of
control may not be warranted in marginal operations for which compliance would require
major expenditures.
Initial funding requirements for emission assessments, tests, and compliance plans could
be incorporated into routine operating or engineering budgets. A single member of the
accounting staff should be assigned to the budgeting and recording of environmental
program costs.
Research and Development — Initiation of new processes or process changes may affect
pollutant emissions. The research and development group should therefore be aware of
potential problems in manufacturing and also in product use and eventual disposal. R&D
departments frequently have a laboratory that can assist in making preliminary routine
measurements.
2.3 Related Responsibilities
In addition to the atmospheric emission aspects of environmental planning, a corporate
staff must-consider other environmental aspects of their manufacturing operations:
1. Liquid discharge,
2. Sludge or solid waste discharge,
3. Product use and eventual disposal,
2-14
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4. Accidental spills or emissions, and
5. Industrial hygiene.
Although some of these do not directly affect atmospheric emissions, many environ-
mental problems are interrelated. As examples, resolving an industrial hygiene problem by
ventilation of a workroom may create a new emission source, and installing a scrubber
system to remove atmospheric contaminants may introduce new problems of wastewater
discharge or sludge disposal. Potential atmospheric emissions from the use or eventual
disposal of a product (such as spray cans, reactive solvents, pesticides) must also be
considered.
Again, the nature of these related environmental responsibilities will vary widely for
specific companies and for specific products. Early consideration of potentially related
problems could save effort and expense in subsequent control plans.
2.4 Examples of Corporate Environmental Programs
Each company must decide how to integrate an environmental program into its corporate
structure. Examples are presented here to illustrate several practical arrangements.
2.4.1 Large Environmental Staff
Figure 2-5 illustrates how environmental control functions may be integrated into a fairly
large organization. This chart shows the environmental control group in a large company
with responsibility for control of air and water quality and for industrial hygiene
activities. The director of the environmental control group would report to the
vice president of operations and would have full responsibility for corporate activities in
environmental matters. This group will provide direction to plant managers in complying
with environmental requirements. A person or persons at the plant or division level
should also be responsible for handling day-to-day activities and carrying out the
corporate program. Figure 2-6 presents an alternative for a similar organization; here the
environmental functions are made part of the corporate engineering operations. This
organizational structure might be appropriate for a large company with relatively minor
environmental problems.
Figure 2-7 shows an example organizational chart for an electric utility company. Utilities
generally face significant potential environmental problems affecting air and water quality
and land use. Therefore a post at the senior level is generally established to direct
environmental efforts. Depending on the atmospheric emission problems, another assistant
could be assigned solely to this area. Utilities make extensive use of outside engineering
companies to assess and solve atmospheric emission problems.
2-15
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VICE
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DIRECTOR
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MANUFACTURING
DIRECTOR
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ENGINEERING
RESEARCH DESIGN
UTIL- ENVIRONMENTAL
ITIES CONTROL
PLANTS
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DIVISIONS
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PLANT
ENGINEERING
EQUIP. AND
BLDGS.
PROCESS
UTILITIES AND
ENVIRONMENTAL
CONTROL
FIGURE 2-6
ALTERNATIVE PARTIAL ORGANIZATION
2.4.2 Small to Medium Environmental Corporate Staff
A corporate ad hoc staff of one to about five persons could handle most of the
environmental planning functions of a multiplant corporation with relatively few emission
problems. After an initial peak workload, this staff could be reduced to one or two. The
degree of utilization of outside help will greatly affect the corporate staff requirements.
The environmental group is generally assigned to the engineering department. Individuals
at each plant location are then assigned tasks as required by the corporate staff. The
engineering department at each plant can exercise the option of requesting assistance
from consultants if the current workload is too great. A company may elect to request a
variance from the control agency which will enable them to have more time to evaluate
their environmental needs.
2-17
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Figure 2-8 shows integration of environmental tasks into the corporate structure of a
small company.
VICE
PRESIDENT
OPERATIONS
PLANT
MANAGER(S)
PRODUCTION
DEPT.
ENGINEERING
DEPT.
AD HOC
ENVIRONMENTAL
ADVISORY
STAFF
ENVIRONMENTAL
ENGINEER
FIGURE 2-8
EXAMPLE PARTIAL ORGANIZATION FOR A SMALL COMPANY
2.5 References
1. The Encyclopedia of Associations, published yearly by Gale Research, Detroit,
Michigan.
2. National Trade and Professional Associations, published yearly by Columbia
Books, Inc., Washington, D.C.
2-19
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CHAPTER 3
PLANT EMISSION SURVEY
3,1 Introduction
The initial step in a plant program for monitoring and controlling atmospheric emissions
is an emission survey. In this survey, all of the pollutant sources are identified and the
quantities of emissions from each source are determined, as shown in Figure 3-1. Results
of the survey will provide management personnel with a comprehensive overview and will
also provide enough detail from which to formulate plans for abatement and monitoring
programs. The eventual cost of a poorly executed survey will almost always exceed the
initially higher cost for a well-executed survey.
This section describes survey procedures, from planning through data reporting, and
provides examples of survey forms and checklists. Methods for conducting such surveys
efficiently have been developed over the years. In every case, three fundamental steps are
involved:
1. Identifying and cataloguing the emission sources,
2. Identifying and quantifying the emissions, and
3. Preparing a source identification file.
These procedures are described in the sections that follow.
3.2 Identifying and Cataloguing Emission Sources
Identification of pollutant sources within an industrial operation is accomplished in two
steps: analysis of process flow sheets and tour of plant facilities. The process flow sheets
serve essentially as a map, indicating points at which emissions are known to occur or are
possible. In the subsequent plant tour, the emission surveyor then verifies these sources
and possibly identifies others. In these efforts he will require assistance from process
supervisors and engineers and will also rely on his own observations.
3.2.1 Process Flow Sheets
A flow sheet of each process within the facility should be presented in sufficient detail to
indicate the flow of all raw materials, additives, end products, by-products, and wastes. A
simple process flow sheet is shown in Figure 3-2. The flow sheet should identify all
3-1
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FIGURE 3-1
PLANT PERSONNEL VERIFYING EMISSION SOURCES
DURING EMISSION SURVEY
points of feed input and all points at which atmospheric, liquid, and solid wastes are
discharged. The engineer or foreman responsible for each process should verify that the
flow sheets identify all sources. Many plants, as shown in Figure 3-3, have numerous sources
that must be identified correctly for identification purposes.
Analysis of process flow sheets ean be further verified by review of permit applications,
process blueprints, photographs, and inspection manuals. With the aid of these and any
other resources available, the emissions surveyor can then develop checklists in the form
of survey data sheets that will be used in the plant tour to ensure complete and efficient
gathering of pertinent data. These survey data sheets will pertain chiefly to two
categories: (1) process and feed data, and (2) control equipment and emissions data An
3-2
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3-3
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FIGURE 3-3
ROOF OF A TYPICAL CHEMICAL PLANT WITH
NUMEROUS EMISSION SOURCES
example process survey data sheet is shown in Figure 3-4, representing presurvey
evaluation of a fuel-fired combustion source. These examples can be modified to apply to
most types of control equipment now in operation.
The process survey data sheet should include the following:
1. Detailed information on operating conditions for the process as designed;
2. Identification of normal operation as continuous, batch, or intermittent, with
frequency of emission discharges for each operation;
3. Description of raw materials, products, and wastes; and
4. Values for normal operating temperature, equipment performance ratings,
flows, pressures, and similar data that are routinely monitored and/or recorded.
A blueprint of the exit stack should be obtained for use on the plant tour. If a blueprint
is not available, a sketch of the exit stack, with accurate measurements, can be made
during the tour. Examples of stack survey data sheets are presented for electrostatic
precipitators, baghouses, and scrubbers in Figures 3-5, 3-6, and 3-7.
3-4
-------
POWER PLANT SURVEY FORM
TYPE OF HEAT EXCHANGER
RATED INPUT CAPACITY.
MAXIMUM OPERATING RATE
RATED STEAM OUTPUT
MAXIMUM STEAM OUTPUT.
FURNACE VOLUME width
OPERATING SCHEDULE
COAL FIRING
TYPE OF FIRING
FLY ASH REINJECTION
SOOT BLOWING
D Continuous
D Intermittent
Coal-fired
Oil-fired
Gas-fired
PRIMARY
n
n
n
STANDBY
n
a
a
If multiple-fired, check appropriate boxes
BTU/hr
, BTU/hr
Ib/hr (a)
Ib/hr (a)
-ft x depth
_ hr/day .
BTU/lb steam
BTU/lb steam
. ft x height ft = ft3
day/wk
wk/yr
D Grate Type
D Spreader stoker
D Pulverized coal D Dry bottom D Wet bottom
D Cyclone
D YES
D NO
TIME INTERVAL BETWEEN BLOWING
DURATION
minutes
OUTSIDE COAL STORAGE
MAXIMUM AMOUNT STORED OUTSIDE
minutes
DYES
D NO
.tons
FIGURE 3-4
EXAMPLE PRESURVEY DATA SHEET FOR FOSSIL-
FUEL-FIRED STEAM GENERATORS
3-5
-------
POWER PLANT SURVEY FORM
ISOUTSIDE STORAGE SPRAYED D YES O NO
COAL COMPOSITION Range Average
Ash % to % %
Sulfur % to % %
BTU/lb as fired to
ARE FUEL CONSUMPTION RECORDS KEPT D YES D NO
FOR STOKER SYSTEM,
Coal size
FOR PULVERIZED GOAL AND CYCLONE SYSTEM
FIRING METHOD D Frontwall
D, Front wall - rear wall
D All wall
D Tangential
D Other Type
OIL FIRING
FIRING METHOD D Frontwall
D Front wall — rear wall
D All wall
D Tangential
D Cyclone
D Other Type,
TYPE OF FUEL D No. 1
Q No. 2
D No. 4
D No. 5
D No. 6
a Other Type
FIGURE 3-4 (Cont.)
EXAMPLE PRESURVEY DATASHEET FOR FOSSIL-
FUEL-FIRED STEAM GENERATORS
3-6
-------
ELECTROSTATIC PRECIPITATOR
Manufacturer's name
Date of start up
, Model No.
Design efficiency
Number of electrical fields in direction of flow,
Total plate area ^^__^_^_^_^_^_
Methods for cleaning plates
Normal rapping sequence. Plates
Preconditioning or dilution air
Gas conditions Design
volume, acfm ^__
Wires
Normal
temperature, °F
fan motor amperes
Rectifier
No.
1
2
3
4
5
6
Operating
condition
design
normal
design
normal
design
normal
design
normal
design
normal
design
normal
Rectifier power output
Voltage
kilovolts
Current
milliamps
Sparking rate
sparks/min
FIGURE 3-5
EXAMPLE PRECIPITATOR SURVEY DATA SHEET
3-7
-------
FABRIC FILTER COLLECTOR
Manufacturer's name
Make or model number
Date of start up
Design efficiency %
Number of compartments
Number and size of bags
Type of filter material
Average bag life
Pressure drop across collector, inches of water Design Normal
just prior to bag cleaning
just after bag cleaning
Gas Conditions
volume, acfm
temperature, °F .....
dew point
fan motor amperes .
Air to cloth ratio
Type of cleaning
D shaking — number of compartments
D reverse air flow — number of compartments
D repressing — number of compartments
D pulse jet (cleaned while on stream)
D other
Normal cleaning cycle
Normal particulate removal sequence,
Preconditioning of dilution air
FIGURE 3-6
EXAMPLE FABRIC FILTER SURVEY DATA SHEET
3-8
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SCRUBBER OR CYCLONE
Manufacturer's name
Make or model number
Date of start up
Design efficiency
Type of collector
D cyclone
D venturi scrubber
O turbulent bed
D other
D raulticyclone
D variable throat
D plate
Operating conditions
pressure drop across col lector, in. H20
gas volume out of collector, acfm
gas temperature to collector, °F
gas temperature out of collector, °F
fan motor, amperes
liquid flow rate to scrubber, gpm
recirculation of scrubbing liquid, %
Type of liquid used in scrubbing
Liquid and/or particulate removal sequence
Preconditioning of dilution air
D fixed throat
D spray
Design
Normal
FIGURES-?
EXAMPLE SCRUBBER OR CYCLONE SURVEY DATA SHEET
3-9
-------
In further preparation for the plant tour, a tentative filing or catalog system will be
helpful. For ease of data handling, each process can be assigned a unique name or letter,
and emission points for each process can be numbered as shown in Figure 3-8. If the tour
discloses an additional process or emission point, it can be easily logged into the system.
FIGURE 3-8
TECHNICIAN IDENTIFYING PROCESS STACK
3.2.2 Plant Tour
A tour of the plant facilities, including discussions with the person responsible for each
process, is the most productive means of identifying all sources and verifying the process
flow sheets. Enough data should be gathered from the files and by on-site inspection to
allow calculation of a material balance as a basis for qualifying and quantifying each
emission source.
3-10
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The plant tour starts at the files. There the surveyor will gather design specifications for
each process and control device. Correspondence may also yield pertinent information
relating to operation and maintenance of process and control equipment, current status
of compliance, comments of control agencies, public complaints, and the like. This kind
of background information can enhance the understanding needed for a meaningful
onsite inspection of each process and control device.
Each air contaminant source has a duct that vents from the process to an outside
chimney or stack. The exhaust gas is moved by a fan, or in some instances where heat is
applied, by natural draft. For each operation, the ducting should be followed from the
process to the point of entry to the atmosphere. In some instances, the exhaust gas
stream is difficult to follow. Introduction of make-up air, split gas streams, and ducting
of several operations to a common stack complicate the overall exhaust system and
require careful tracing to ensure that exhaust gas paths are properly defined. Placement
of fans and control devices must be noted. Air conditioning, heating, and make-up vents,
as shown in Figure 3-9, must not be mistaken for process stacks.
After defining all process systems, the surveyor should check the roof to identify any
emission points that are "left over." The check ensures that all egress points are
accounted for.
Equipment requirements for an onsite survey depend largely on the processes surveyed.
Following is a partial list of basic equipment:
1. 50° to 1200°F dial thermometer (12-inch stem),
2. Velocity measuring device (Velometer),
3. 50-foot tape measure,
4. Set of basic shop tools,
5. Camera,
6. Detector tube samplers (for measuring gas concentrations),
7. Survey data forms, and
8. Safety equipment (hard hat, safety shoes, goggles).
Obtaining accurate stack information during the tour, as shown in Figure 3-10, is a
prerequisite to effective stack sampling, since the configuration of sampling sites and the
characteristics of the exhaust gases will affect the quality of samples that may be
3-11
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FIGURE 3-9
AIR CONDITIONING SYSTEM AND DUCT TO ROOF OF BUILDING
extracted. In addition to flow considerations, the factors of accessibility and safety are
important to emission testing. Clearance for probes and sampling apparatus, availability of
electricity, potential for exposure of personnel and equipment to weather or excessive
heat, presence of toxic or explosive gases, and other safety factors should be noted and
recorded during the plant tour. Outlet ducts must be examined to ensure proper
3-12
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FIGURE 3-10
OBTAINING ACCURATE STACK INFORMATION DURING THE PLANT TOUR
sampling. In most states, a stack as shown in Figure 3-11 requires an extension to meet
emission testing requirements. However, some states have adopted a procedure for
sampling cyclone outlet elbows with a Hi-Yol Sampler. Stack data should be recorded
on a form as shown in Figure 3-12.
3-J3
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FIGURE 3-11
CYCLONE OUTLET REQUIRING MODIFICATION BY MOST STATES
PRIOR TO PERFORMING EMISSION TEST
3.3 Identifying and Quantifying Emissions
All of the data obtained thus far from the process flow sheets, process survey forms,
control equipment survey forms, stack survey form, photographs, correspondence,
discussions, and the plant tour can now be organized for development of an emission
survey plan. This plan will indicate the quantity of emissions to be expected from each
source, with possible variations due to season, time of day, feed materials, and similar
3-14
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Sampling location parameters
Process vented
Platform height, ft
Platform width, ft
Platform length, ft
Inside diameter, in. at port
Wai! thickness, in. at port
Material of construction
Ports: a. Existing
b. Size opening
c. Distance from platform
Straight distance before ports, ft
Type of restriction before ports
Straight distance after ports, ft
Type of restriction after ports
Environment at sampling site
Work space area
Ambient temperature, °F
Average pitot reading, in. H20
Stack gas velocity, ft/min
Stack gas flow, acfm
Moisture, % by volume
Stack gas temperature, °F
Particulate loading, gr/scf
Particle size
Gases present
Stack pressure, in. H20
Water sprays prior to site
Dilution air prior to site
Elevator to site?
Available electricity and distance
Stack or vent number
FIGURE 3-12
STACK DATA REQUIREMENTS
3-15
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variables. The emissions characterization should identify all important parameters
affecting control of the pollutants and possible sampling techniques. These data will be
used to establish a compliance program for each source. These programs will describe the
plans that will be implemented by the company to achieve compliance and should
contain the following increments of progress or milestones (1):
1. Date of submittal of the final control plan to the appropriate air pollution control
agency;
2. Date by which contracts for emission control systems or process modifications
will be awarded; or date by which orders will be issued for purchase of
component parts to accomplish emission control or process modification;
3. Date of initiation of onsite construction or installation of emission control
equipment or process change;
4. Date by which onsite construction or installation of emission control equipment
or process modification is to be completed; and
5. Date by which final compliance is to be achieved.
Figure 3-13 presents an example of the activities that must be completed before compliance
can be achieved. Depending on the nature of the emission source and the complexity
and size of the modifications required, the time requirements for compliance can range
from a few months to several years (2).
3.3.1 Data Usage
Emissions from each source will be identified and quantified as part of the compliance
program throughout each of the major phases: achieving, demonstrating, and maintaining
the company's compliance status. The compliance status of each source determines the
type of data that must be collected.
Achieving Compliance - The first step in the compliance program is to bring all emissions
within the allowable limits established by the control agency. This phase of the
compliance program usually involves the purchasing of control equipment. Because of the
high initial costs of current control equipment, as well as operating and maintenance
costs, the gathering of process data for equipment selection is of utmost importance.
Most vendors of control equipment base their guarantee on process data presented to
them before the equipment is installed. If the installed control equipment does not
enable the plant to comply with the allowable emission rate and the process parameters
are different from those specified to the control vendor, then the plant must alter the
process or provide additional control equipment at its own expense.
3-16
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Detailed procedures for selecting the proper type and size of control equipment are
beyond the scope of this manual. The basis for selection changes continually with
changes in cost of materials and with development of new technology. When a company
is uninformed regarding control equipment, the best method of selection is usually
through an evironmental consulting group that is not affiliated with a control equipment
vendor.
The most important process parameters that must be collected for selection of control
equipment are the following:
Flue gas characteristics (from emission test)
1. Total flue gas flow rate,
2. Flue gas temperature,
3. Control efficiency required,
4. Particle size distribution,
5. Particle resistivity,
6. Composition of emissions,
7. Corrosiveness of flue gas over operating range,
8. Moisture content, and
9. Stack pressure.
Process or site characteristics (field survey)
1. Reuse/recycling of collected emissions,
2. Availability of space,
3. Availability of additional electrical power,
4. Availability of water,
5. Availability of wastewater treatment facilities,
6. Frequency of startup and shutdown,
3-18
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7. Environmental conditions (e.g., extremely low ambient temperatures),
8. Anticipated changes in control regulations,
9. Anticipated changes in raw materials, and
10. Plant type (stationary or mobile).
Demonstrating Compliance — The second phase of the compliance program is providing
proof that ail emissions are within the specified limits. This involves a compliance test
using a specified or reference test method. The test is usually witnessed by control
agency officials. During the compliance test, enough process and emission data must be
recorded to satisfy the control agency's requirements and to confirm the control
equipment vendor's guarantee. If the process data indicate operation within the design
range specified by the plant to the vendor but compliance is still not achieved,
documentation of process and emission parameters will demonstrate failure of the
vendors to meet their guarantee. If the process data recorded during the test are different
from or are not within the range earlier specified by the facility, failure to achieve
compliance cannot be attributed to the control equipment vendor.
Control agency requirements for process parameters that must be collected during a
compliance test are variable. If any of the requirements concern process data that are
considered confidential, operators of the facility should so inform the agency by
registered mail. Most control agencies follow specific guidelines regarding confidentiality.
These matters and other aspects of compliance testing are discussed more fully in Chapter
5.
Continuing Compliance - After compliance of each source has been demonstrated,
compliance status must be maintained. Chapter 7 describes in detail the procedures that
will provide a continuing compliance program.
3.3.2 Quantification Techniques
The emission survey can be developed by applying a combination of techniques:
calculation of mass balance, application of emission factors, review of permit applications,
analysis of fuels, and source emission tests. These techniques are described in more detail
below.
Mass Balance - When the throughputs and composition of raw materials are known, a
mass balance usually can be established around each process. The materials balance will
indicate the extent of solid, liquid, and gaseous wastes. A materials balance for the entire
facility will also indicate the amounts of wastes generated, a value obtained by
3-19
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subtracting the amounts of material shipped from the amounts purchased. Much of the
waste generated is, of course, not airborne.
A search of applicable air pollution control regulations will provide the basis for the mass
balance. The control regulations state what pollutants are regulated and define each
pollutant. The definition of each pollutant determines the conditions under which the
pollutant is sampled and its chemical or physical makeup. For instance, because water
vapor is not considered an air pollutant, it need not be accurately accounted for in the
mass balance. Emissions of sulfur dioxide or organic substances are usually regulated and
must be estimated in the materials balance.
A materials balance for gaseous pollutants can be determined by analysis of raw
materials, fuels, and products to give the gaseous pollutant potential of many of the
compounds liberated during a combustion or chemical process.
Fuel Analysis — Knowledge of fuel composition is especially useful in estimating
emissions, since many gaseous compounds in the fuel become airborne after combustion
(e.g., sulfur in fuel oil exhausts as sulfur dioxide). Other constituents, such as ash and
volatile matter, directly affect the quantity of particulate emissions.
Permit Applications — A completed copy of the facility's current permit application
should provide information on equipment, input materials, and potential emissions.
Permit applications that are no longer current can be used for background information
and reference.
Visible Emissions — State regulations emphasize visible emissions except for water vapor.
Training and certification are required for a compliance determination of visible emissions.
Although an untrained observer cannot make an official determination, he can attempt to
estimate the percent obscuration of an object viewed through the stack discharge plume.
If no emissions are visible, emissions would be judged to be in compliance with visible
emission regulations. The percent of \isible opacity is not an accurate indication of total
mass emissions but can indicate trouble areas.
Emission Factors — Publications listing emission factors (3) provide a range of emissions to
be expected from specific processes. These values, which are based on uncontrolled
process operations, can be factored with the expected collection efficiency of the
facility's air pollution control equipment to yield an estimated pollutant emission rate.
For example, where the emission factor for a process is 10 pounds of particulate per ton
of product and the process is equipped with a particulate control device that is 90
percent efficient, the emissions would be:
10 ib/ton x f Q ) = 1.0 Ib/ton
3-20
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Emission Testing - Emission testing is usually the most accurate method of determining
emissions. Specific emission testing procedures are usually prescribed for each pollutant
from each process. Emission testing by these prescribed methods, however, is also the
most expensive technique of emissions survey. An emission testing program may include
ambient sampling, a series of stack tests over a period of several hours, continuous
monitoring, or a combination of these, as described more fully in Chapters 5 and 6.
Detailed sampling procedures have been published for various pollutant
compounds (4), (5).
Even if it is determined that emission testing of all sources is required for a
comprehensive emission survey, data gathering by the methods described earlier will
establish the normal operating conditions for processes and control equipment and will
provide a check on values obtained in emission tests. Data from earlier emission tests of
a process or a similar process are also helpful.
Testing methods other than those prescribed (such as use of a velometer or vane
anometer to determine stack gas velocity and of detector tube concentrations for gaseous
pollutants) can provide approximate engineering data in a rapid and relatively inexpensive
manner.
3.4 Preparing a Source Identification File
A source identification file provides a means of standardizing data for the emission
survey. For each pollutant source, a standard identification form gives a description of
the process, a summary of emission data, the current compliance status, and proposed
actions, if any are intended. A basic source identification form is shown in Figure 3-14.
Some sources involve several emission points with more than one pollutant at each point.
The source identification file should be indexed to provide easy access by any concerned
party. The index should list all sources and identify each emission point for each source.
Assignment of a number for each emission point, as discussed earlier, will facilitate an
alphanumeric search for emission points in the source identification file. A facility cover
sheet, as shown in Figure 3-15, should precede the index. As an aid to management
personnel in tracking and holding large numbers of sources, a corporate environmental
management information system has been developed (6).
The source identification file should provide sufficient information to enable control
agency staff to complete an appropriate form for entry of data into the National
Environmental Data Systems (NEDS). Appendix A contains an appropriate form.
3.5 References
1. Code of Federal Regulations, Vol. 40, Part 51, August 14, 1971.
3-21
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Emission point no.
Emission point name,
Date of record
Source name
Description of source
Type of permit
Date of permit.
Applicable regulation(s).
Particulate emissions . units
Allowable emissions. . .units
Method of determination
Gaseous emissions
type
Compliance status
Date contact awarded
Date construction began
Monitoring.
ambient
stack —
units,
Allowable emissions units
Method of determination
FIGURE 3-14
SOURCE IDENTIFICATION FORM
3-22
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Plant name
Address
City, state
County
AQCR
Telephone number
Environmental project director
Official local control agency
Name
Address
City
Telephone number,
State control agency
Name
Address
City —
Telephone number.
Corporate office
Name _
Address
City, state
Telephone number
Environmental director
FIGURE 3-15
FACILITY COVER SHEET
3-23
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2. Technical Guide for Review and Evaluation of Compliance Schedules, U.S. Envi-
ronmental Protection Agency, EPA-340/l-73-001a, Washington, D.C., July 1973.
3. Compilation of Air Pollutant Emission Factors, U.S. Environmental Protection
Agency, EPA AP-42, Research Triangle Park, North Carolina, April 1973.
4. Federal Register, Vol. 36, No. 247, December 23,1971.
5. Federal Register, Vol. 39, No. 47, March 8,1974.
6. Corporate Environmental Management Information Systems Users Guide, PEDCo.
Environmental Specialists, Cincinnati, Ohio, 1972.
3-24
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CHAPTER 4
EMISSION REGULATIONS
4.1 Legal Requirements Under the Clean Air Act Relative to Testing
4.1.1 The Clean Air Act - General
The Clean Air Act of 1970 was structured by Congress to channel regulatory action in a
well-planned manner. Basically, two types of pollutant sources are regulated: stationary and
mobile. This industrial guide pertains only to stationary source pollutants. Congress meant
to control both new and existing stationary sources as follows:
1. The regulatory agency (now the U.S. EPA) is charged with the task of setting
National Ambient Air Quality Standards for nonhazardous pollutants. Once a
standard is set, each state must develop a plan for achieving and maintaining the
prescribed ambient air quality. Pollutants so controlled are known as criteria
pollutants.
2. New or modified sources of air pollutants are to be regulated to a greater degree.
The rationale here is that newer technology can be utilized and pollutants better
controlled for a new source where the control is part of the original process
design.
3. Certain air pollutants may directly or indirectly cause an increase in mortality,
illness, or discomfort. These are termed hazardous pollutants. These pollutants
are first identified by U.S. EPA, whereupon a standard is proposed within 180
days for that hazardous pollutant. Test procedures are defined for the pollutants
and published in the Federal Register.
The Clean Air Act Amendments of 1977 (Public Law 95-95) made significant changes in
the Clean Air Act of 1970. A summary of major provisions related to industrial sources
follows:
1. A new short-term nitrogen dioxide standard will be promulgated unless there is
evidence that the standard is not necessary to protect public health.
2. A new system is implemented to prevent significant deterioration of ambient
air quality. The country will be divided into three classes, each allowing a dif-
ferent amount of industrial activity.
4-1
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3. The new act now allows the agency to assess non-compliance sources with a
penalty equal to the cost of complying with regulations, rather than a maximum
fine.
4. Procedures are outlined for new industries that desire to locate in "non-attain-
ment" areas, i.e., areas where national health standards are exceeded.
All stationary source regulations are addressed in Title I, Sections 101 through 119 of the
Act. A very brief outline of these sections follows:
Sections 101 through 106 — Defines purpose of the law; establishes research and
training means; provides for planning and control program grants.
Section 107 — Mechanism for naming Air Quality Control Regions; assigns
environmental responsibility to state governments.
Section 108 — Provides for background studies to establish air quality standards; basic
data to include control technology costs, energy requirements, emission reduction
benefits, and environmental impacts.
Section 109 — Mandates the EPA Administrator to promulgate national ambient air
quality standards (AQS) based on the information gathered pursuant to Section 108.
Section 110 — Directs each state to develop a plan (State Implementation Han, or
SIP) to achieve and maintain the AQS set pursuant to Section 109.
Section 111 — Establishes new source performance standards (NSPS). Authority may
be delegated to states to implement and enforce standards.
Section 112 — Establishes national standards for hazardous air pollutants; applies to
both new and existing sources.
Section 113 — Outlines mechanisms for federal enforcement; authorizes federal
endorcement of standards.
Section 114 — Authorizes U.S. EPA to require record-keeping and monitoring;
authorizes inspections and test requirements.
Sections 115 through 119 — Provides for administrative means of abatement; certain
state authority is specifically retained; establishes a Presidential Advisory Board;
mandates federal facilities to comply with air pollutant regulations; defines procedures
4-2
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pertaining to fossil-fuel-fired units during periods of fuel switching, fuel unavailability,
and fuel stipulations as defined by the Energy Supply and Environmental Coordination
Act.
Table 4-1 lists the entities affected by the three different types of regulatory schemes and
the citations wherein the various emission limitations and test procedures are given.
4.1.2 Criteria Pollutants
Criteria pollutants are promulgated pursuant to Sections 108 and 109. Particulate matter,
sulfur oxides, nitrogen oxides, hydrocarbons, and carbon monoxide were defined as criteria
pollutants when the 1970 CAA was promulgated. On March 31,1976, lead was added to the
list of criteria pollutants.* Each state has promulgated regulations to control these pollu-
tants such that the national ambient air quality standards (AQS) are achieved. These regula-
tions, part of each SIP, may vary from state to state. The regulations cover both existing
and new sources and may be thought of as basic regulations. Determining whether sources
meet these regulations may require source tests. Although the U.S. EPA has promulgated
test procedures, tests prescribed by state regulatory agencies for criteria pollutants vary.
For example, one state may measure the amount of condensible pollutants whereas another
state may count only the "front end" of the sampling train (filterable particulate matter).
Not only may the test method vary, but process monitoring can affect the emission
regulation. Whether a regulation limits a pollutant in terms of parts per million (ppm) or
pounds per ton of raw material throughput determines the process monitoring requirements.
4.1.3 New Source Performance Standards
It is recognized that some processes emit greater quantities of pollutants than others.
Section 111 of the Act requires U.S. EPA to single out certain processes for new source
performance standards (NSPS). Generally, such standards are more stringent than those
applicable to existing sources that emit criteria pollutants. Congress intended for such new
sources to employ the best technology in controlling pollutants. Should an NSPS apply to a
criteria pollutant, a newly built facility must comply with the NSPS limitation for that
pollutant or with the SIP regulation, whichever is more stringent.
Since these standards are national in scope, the test methods do not vary by state. Specific
test methods are promulgated with the NSPS. Although in general the NSPS do not apply to
existing facilities that emit pollutants, there are two exceptions. The first exception relates
to emitters of noncriteria pollutants. Such existing facilities must meet a state-promulgated
standard, which the states are required to adopt under Section lll(d). These
*EPA has proposed an ambient air quality standard for lead of 1.5 micrograms per cubic meter, figured
on a monthly average. Issuance of a final standard by EPA is scheduled for June, 1978.
4-3
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state-promulgated standards may be less stringent than the NSPS. The other exception
concerns modification of existing sources. Should an existing source be modified or
reconstructed to the degree that it may be deemed a new source, it is subject to the NSPS.
4.1.4 Hazardous Pollutants
The Clean Air Act differentiates nonhazardous and hazardous pollutants. The U.S. EPA
Administrator is charged with promulgation of standards for hazardous pollutants regardless
of whether they emanate from new or existing sources. At the state's option,
implementation plans may be submitted to U.S. EPA. Upon U.S. EPA approval, the states
are authorized to enforce the hazardous pollutant standards within their jurisdiction. Should
the state fail to implement such a plan, however, U.S. EPA will enforce standards for
hazardous pollutants against both existing and new sources.
Source test methods are promulgated with the hazardous pollutant standards. These test
methods are the only approved means by which compliance may be determined.
4.2 Inspection and Data Requirements Under the Clean Air Act
Section 114 of the Act gives the U.S. EPA Administrator broad powers to inspect, monitor,
and test pollutant-emitting facilities and to require record-keeping, monitoring, and testing
by the regulated source. The 1977 Clean Air Act Amendments have significantly changed
permit requirements. It is recommended that the reader contact an EPA Region office or a
state agency to obtain requirements on permits. Section 4.4.3 of this publication will be
revised at a later date,
4.2.1 Sources of Criteria Pollutants
In general, reporting requirements for sources of criteria pollutants are minimal. These
requirements are set forth in the applicable SIP. Most of the reporting is in the form of use
permit applications, which provide information, on process throughput, control facilities,
stack gas temperatures, and the like. This information is very useful to state and local air
pollution control agencies because it allows them to inventory total pollutants over large
areas and thereby to formulate large-scale control strategies.
On occasion, the source must verify its claim of compliance with applicable emission
limitations by providing source test data. Most monitoring and reporting requirements for
existing large sources are formulated for the individual source as a result of compliance
negotiations. For small sources, such as small incinerators used by grocery stores and
grain-conveying cyclones used by small feed and grain stores, the reporting or monitoring
requirements usually are not extensive.
4-5
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4.2.2 Sources Subject to New Source Performance Standards
Requirements for testing and reporting under an NSPS are usually extensive. Within 6
months of startup, performance tests must be conducted in accordance with
EPA-promulgated methodology. All new sources subject to an NSPS must provide test ports
and facilities adequate for performing source tests as required by the regulations. This is a
national regulation, and variations from the test requirements are not permitted. Prior to
performance testing, the source must notify the U.S. EPA. Generally, observers from EPA
or from the state or local agency are present to ensure that proper test methods are used. All
new sources subject to an NSPS are required to have performance tests.
The individual NSPS regulations specify monitoring and reporting requirements. Logs
showing startup, shutdown, and malfunctions must be kept for 2 years. Quarterly reports of
excess emissions must be submitted to the Administrator.
4.2.3 Sources of Hazardous Pollutants
Hazardous pollutant regulations apply to both new and existing sources. The regulations
specify reporting requirements for the source. Not, only must operational data be
maintained, but application must also be made to EPA prior to any modification of existing
sources. This application may be denied. No new or modified source of a hazardous
pollutant may start operation without prior notification of EPA.
Source testing facilities are required for both new and existing sources. Testing, monitoring,
and reporting requirements for sources of hazardous. pollutants are set forth m the
individual regulations for each pollutant.
4.3 Confidentiality of Data - The Freedom of Information Act
4.3.1 General Business Information
It is the general policy of U.S. EPA to make the fullest possible disclosure of information to
the public. In carrying out this policy, the U.S. EPA has devised a procedure intended to
protect both the interests of businesses that furnish information to the U.S. EPA and the
interests of the public. This procedure is designed to afford business a fair opportunity to
assert a confidentiality claim and to substantiate the claim prior to any U.S. EPA ruling on
the claim.
Certain types of business information gained by the U.S. EPA are entitled to be treated as
confidential and are protected from disclosure to the public. Generally this includes any
information concerning which a business has a legal right to limit disclosure to others. For
4-6
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example, proprietary information and commercial or financial information that is privileged
or confidential are specifically exempted from the mandatory disclosure requirements of the
Freedom of Information Act.
Information supplied to the U.S. EPA is entitled to confidential treatment if:
1. The business has asserted a business confidentiality claim,
2. The business has taken reasonable measures to protect the confidentiality of the
information,
3. The information has not been reasonably obtainable by others without consent of
the business,
4. No statute requires disclosure of the information, and
5. Either
a. Disclosure of the information is likely to cause substantial harm to the firm's
competitive position, or
b. The information was voluntarily submitted, but its disclosure would impair
the Government's ability to obtain necessary information in the future.
4.3.2 Special Rules Governing the Clean Air Act
Generally, the procedures and substantive rules for maintaining and claiming the
confidentiality of business information also apply to data provided to the U.S. EPA under
Section 114 of the Clean Air Act. Information is eligible for confidential treatment in these
circumstances:
1. It was provided in response to a request by the U.S. EPA made for any of the
purposes stated in Section 114; or
2. It could have been required under Section 114.
Emission data, however, are not eligible for confidential treatment. Ineligible information
includes:
1. Information necessary to determine the characteristics of an emission by a source,
and
4-7
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2. General descriptions of the location and/or nature of a source to the extent
necessary to identify the source and to distinguish it from other sources.
Under certain circumstances, this category may also include data relating to:
1. The manner and rate of operation of a source, and
2. The device, installation, or operation constituting a source.
As a result of this broad exclusion, much of the information gathered in inspections and
source tests of facilities under Section 114 of the Act is available to the public. This
information may include such items as process throughput, stack gas temperatures, and the
like.
Certain limitations, however, are applied to disclosure of information relating to research
and commercial facilities. The following information is considered emission data:
1. That concerning research on any project, method, device, or installation that was
produced, developed, installed, or used only for research, and
2. That concerning any product, method, device, or installation designed and in-
tended to be marketed or used commercially but not yet so marketed or used.
Such emission data are therefore available to the public only insofar as it is necessary to
disclose whether a source is in compliance with an applicable standard and to demonstrate
the feasibility, practicability, or attainability of an existing or proposed standard.
4.3,3 Asserting a Confidentiality Claim
A business that submits information to U.S. EPA may initially assert that the information is
entitled to confidential treatment by attaching a notice or legend to the information at the
time it is submitted, employing language such as "trade secret," "proprietary," or "com-
pany confidential." Although confidentiality of information previously submitted may be
claimed, the U.S. EPA is obligated only to use such efforts as are practicable to associate the
claim with the previously submitted information; consequently, such efforts may be
ineffective. If a business fails to assert a confidentiality claim, the information will not be
entitled to confidential treatment.
If U.S. EPA determines that information may be entitled to confidential treatment, each
business asserting such a claim is asked to comment. In other words, the burden of proof of
confidentiality is on the claimant. These comments must address the following matters:
1. The portions of the information entitled to confidential treatment,
4-8
-------
2. The period of time for which confidential treatment is desired,
3. The purpose for which information was furnished to the U.S. EPA,
4. Whether business confidentiality claim accompanied the information,
5. Measures taken to prevent undesired disclosure,
6. Extent to which the information has been disclosed to others,
7. Pertinent confidentiality determinations,
8. Whether disclosure would likely result in substantial harm to the company's
competitive position, and
9. Whether information was voluntarily submitted.
The legal office of U.S. EPA is responsible for making the final determination whether
business information is entitled to confidential treatment. If a business fails to submit its
comments in the time permitted, the confidentiality claim is waived and the information is
not entitled to confidential treatment. In all other cases, the legal office will evaluate the
claim and comments and determine whether the information is in fact entitled to
confidential treatment.
A notice of denial is provided to a business whenever U.S. EPA determines that the
information is not entitled to confidential treatment. Public disclosure of the information is
then automatic unless the business commences action in a federal court to obtain judicial
review of the determination and to obtain a preliminary injunction prior to such disclosure.
4.4 State Implementation Plans
4.4.1 Emissions Regulations
Each state is required to develop and implement a plan whereby it will achieve the federal
ambient air quality standards set for criteria pollutants (Sections 109 and 110 of the Act).
This plan is known as the SIP. The cardinal part of an SIP is the emission regulation scheme.
*• o
For a given pollutant, a state may adopt many regulations. This is true of particulate matter,
for example, where it is not uncommon for an SIP to include separate particulate emission
regulations for indirect-fired heat exchangers, incinerators, cement kilns, asphalt batching
plants, and catalytic cracking units, with a general regulation for all other sources of
particulate emissions. Further, the units of various emission regulations may be different,
taking the following forms:
4-9
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1. Pounds of particulate per hour per pound of process throughput,
2. Grains per standard cubic foot of exhaust gas,
3. Pounds of paniculate per million BTU heat input, and
4. Pounds of particulate per ton of refuse burned.
Persons monitoring a process during performance of a source test must be cognizant of these
units, since they directly affect the monitoring requirements. For example, much more
detailed process monitoring and recording are needed to determine compliance with a
standard expressed in pounds of particulate per ton of throughput than with a standard
expressed in grains per standard cubic foot.
4.4.2 Source Test Regulations
Each SIP provides a regulatory scheme for source testing. Some of these schemes require
continuous monitoring in addition to periodic testing. It is stressed that each state may have
different requirements; no industry should assume that requirements of any specific state
are similar to those of its neighboring states or of the federal government. Almost all states
specify the test method to be used. All but four states, however, further provide that the
source may utilize a nonspecified test method if prior approval is obtained. Most of the
SIP's require the use of EPA's Test Method 5 for particulate source tests. A substantial
number specify the ASME-PTC27 method, and two jurisdictions (Connecticut and the
District of Columbia) also require use of the ASME-PTC21 method for certain sources.
Since source tests are expensive, it is important that approval of any proposed test
method be obtained from appropriate authorities in advance. Additionally, the test must be
performed in such a way as to determine compliance. Not only must the facility be
operating normally during the test, but a knowledgeable and reliable person must monitor
and record the production operations to assure that the extracted sample can be gauged in
terms of the emission standard.
With regard to obtaining prior approval of a proposed test method, at least 13 states require
prenotification of a proposed source test. Failure to comply with this regulation in a timely
manner may negate any test data obtained. Since costs of many compliance tests exceed
$5,000, this could be an expensive mistake.
As the results of source tests are being used more and more as proof of compliance, the
requirements for pretest preparation and post-test reporting are becoming more
sophisticated. Figures 4-1 and 4-2 show the "Intent to Test Notification" form and
"Statement of Process Rate" form used by the Ohio EPA. In addition, that agency requires
that the following guidelines be observed in preparation of test reports:
4-10
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4-11
-------
Page 2 of 2
THE FOLLOWING ADDITIONAL INFORMATION SHALL BE SUBMITTED AS
ATTACHMENTS:
V. DATE OF LAST CALIBRATION
1. Velocity measuring equipment ,
2. Gas volume metering equipment..
3. Gas flow rate metering equipment
4. Gas temperature measuring equipment _ —
VI. SAMPLING TRAIN INFORMATION
1. A schematic diagram of each sampling train. The name, model number, and date
of purchase of commercially manufactured trains should be included with the
diagram.
2. The type or types of capture media to be used to collect each gas stream pollutant.
3. Sample tube type, i.e., glass, teflon, stainless steel, etc.
4. Probe cleaning method and solvent to be used, if applicable.
VII. LABORATORY ANALYSIS
A description of the laboratory analysis methods to be used to determine the con-
centration of each pollutant.
VIM. DATASHEETS
A sample of all field data sheets to be used in the-test or tests.
IX. DESCRIPTION OF OPERATIONS
A description of any operation, process, or activity that could vent exhaust gases to
the test stack. This shall include the description and feed rate of all materials capable
of producing pollutant emissions used in each separate operation.
Note: All testing shall be performed at maximum rate capacity as specified by the
equipment manufacturer or at the maximum rate actually used in the source
operation, whichever is greater.
X. STACK AND VENT DESCRIPTION
A dimensional sketch or sketches showing the plan and elevation view of the entire
ducting and stack arrangement. The sketch should include the relative position of all
processes or operations venting to the stack or vent to be tested. It should also in-
clude the position of the sampling ports relative to the nearest upstream and down-
stream gas flow directional or duct dimensional change. The sketches should include
the relative position, type, and manufacturer's claimed efficiency of all gas cleaning
equipment.
A cross sectional dimensional sketch of the stack or duct at the sampling ports, show-
ing position of sampling points. In the case of a rectangular duct, show division of
duct into equal areas.
XI. SAFETY
Describe all possible safety hazards including such items as weak roofs, low railings,
toxic fumes, hot items, electrical power lines, nearby by-pass vents, unguarded
ladders, etc.
List all safety warning signals such as fire alarms, sirens, etc.
Note: Conditions considered unsafe at the time of the test will cause postponement.
FIGURE 4-1 (Cont.)
PRE-TEST FORM USED BY OHIO EPA
4-12
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STATEMENT OF PROCESS RATE
TEST NUMBER.
FIRM NAME __
ADDRESS
DATE
DATA ON OPERATING CYCLE TIME
START OF OPERATION, TIME
END OF OPERATION, TIME __
ELAPSED TIME, MINUTES
IDLE TIME DURING
CYCLE, MINUTES _
NET TIME OF
CYCLE, MINUTES
DATA ON MATERIAL CHARGED TO PROCESS DURING OPERATING CYCLE:
FOR FUEL BURNING OPERATION ONLY:
Weight Attach analysis Maximum design BTU input
% Excess air _ Actual BTU input for test
Gas flow
.ACFM
Total BTU input for all fuel burning equipment on a plant or premises which are
united physically or operationally (based on permit submissions) -
Note: Include stream flow chart with proper identification of scale, etc.
II. FOR INCINERATOR ONLY:
Total weight charged during test -Weight per charge .
Number of charges ^__ Type waste
OTHER SOURCE OPERATIONS:
Material
Material
Material .
Material
Material
.Weight
.Weight
.Weight
.Weight
.Weight
Note: Include any pertinent charts or other operational data.
I certify that the above statement is true to the best of my knowledge and belief:
SIGNATURE. __
TITLE
FIGURE 4-2
PROCESS INFORMATION FORM USED BY OHIO EPA
4-13
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1. Display test results in tabular form (the units of measurement shall be consistent
with units in the applicable regulations),
2. Include a copy of all field data sheets completed during testing,
3. Include information required by Item IX of the "Intent to Test Notification,"
4. Include a completed "Statement of Process Rate" form for each test, and
5. Include a sample of all formulas used in calculating results.
Many states that do not require a formal notification of an intent to test do require that a
state representative be present during the test. Again, faUure to notify may invalidate the
test results.
In addition to requiring the source to provide test data, many state agencies are empowered
to perform source tests. Although most states do not maintain an extensive test program
because of the great expense, the authority to test is a powerful tool for enforcement of
state regulations. As is the case with industry, the state agency can hurt its case through use
of improper testing methods. Full cooperation must be given with regard to unit operations
during an agency-conducted test.
4.4.3 Permit System Review Requirements
Permit systems of most air pollution control programs at the state and local level require the
following:
1. Source registration data (identify type and location of source),
2. Information on the process employed and control devices installed, and
3. Emission inventory data (emission information for comparison with regulations
and as input for air impact analysis through modeling).
Construction and Operating Permits - The permit system is the main mechanism by which
industrial emissions are controlled.
Before a facility can be constructed, a permit to construct must be issued by the state
and/or local regulatory agency. As illustrated in Figure 4-3, a permit application may
include the following:
1. Application forms, including process description,
444
-------
INDUSTRY
CONSULTANT
REGULATORY AGENCY
(STATE OR LOCAL)
SUBMITTAL
PREPARATION
INITIAL SUBMISSION
COMMENTS
APPLICATION
REVIEW
ISSUE
PERMIT
M- OPERATION
H
Z
1
APPLICATION
1
*
^^
INI
SUBMITTAL
PREPARATION
TIAL SUBMISSION
COMMENTS
ST/
TE
1
APPLICATION
REVIEW
I
i
VCK
ST
TEST
REPORT
-
OBSERVE
TESTS
INSPECT
FACILITY
—
ISSUE
PERMIT
FIGURE 4-3
TYPICAL PERMIT SYSTEM FLOW DIAGRAM
4-15
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2. Area map showing surrounding structures,
3. Site plan showing building/process, and
4. Equipment specifications.
Larger industries having an environmental engineering staff prepare these documents
in-house whereas smaller industries usually retain consultants to help with this activity. In
some states, applications must be signed and sealed by a registered professional engineer.
The regulatory agency reviews the application package and after any questions are resolved,
issues a permit to construct a facility and/or control device. After the facility is constructed,
the industry or consultant submits as-built plans to the regulatory agency indicating any
changes from the original plans.
Once the facility has been placed in operation, it is usual for the agency to inspect the
facility to determine whether the plant is built in accordance with approved plans and to
perform stack and/or visible emissions tests at all emission sources. An operations permit is
applied for after the shakedown period; if the inspection(s) and tests indicate compliance
with applicable regulations and standards, an operations permit is issued. The permit usually
incorporates (1) limitations on production rate, and (2) monitoring requirements such as
type of monitoring (continuous or manual), frequency of sampling, and reporting
frequency.
If the facility comes under the New Source Performance Standards, it must comply with
federal as well as state and local requirements.
Testing of new or modified sources must be performed no later than 60 days after achieving
maximum production rate, but no longer than 180 days after initial startup. The tests must
be conducted during representative performance, with fuels and raw materials representative
of those used during normal operation.
The owner or operator has the following responsibilities:
1. To give a minimum of 30 days notification of scheduled tests.
2. To give a minimum of 30 days notice of anticipated startup. U.S. EPA must be
notified of actual startup within 15 days after startup.
3. To provide adequate sampling ports, safe sampling platforms, safe access to the
platforms, and utilities for sampling and testing equipment.
4. To perform emission tests and furnish a written report of test results to the
Administrator.
4-16
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Testing methods are specified in 40 CFR 60.
Permit Renewal — The permit system within a state or local program is operated under the
combined direction of the engineering services and field enforcement services departments.
A typical organizational chart for a local governmental air pollution agency is shown in
Figure 44..
MAYOR, MANAGER,
COMMISSION, BOARD OR
MUNICIPAL DEPARTMENT
HEARING OR APPEALS
BOARD
AIR POLLUTION
CONTROL OFFICER
ADMINISTRATION
(BUSINESS
MANAGEMENT)
TECHNICAL
SERVICES DIVISION
AIR QUALITY MEASUREMENT
LABORATORY ANALYSES
DATA PROCESSING
METEOROLOGY
EFFECTS STUDIES
TECHNICAL ADVISORY
COMMITTEES
PUBLIC INFORMATION
AND EDUCATION
FIELD SERVICES
DIVISION
FIELD PATROL
SOURCE INSPECTION
COMPLAINTS
COURT TESTIMONY AND
CASE PREPARATION
PLUME EVALUATION
TRAINING
EMERGENCY OPE RATIONS
ENGINEERING
DIVISION
CONSTRUCTION PERMITS
SOURCE TESTING
INDUSTRIALSURVEYS
REGULATION DEVELOPMENT
EMISSION INVENTORY
CERTIFICATE TO OPERATE
FIGURE 4-4
TYPICAL ORGANIZATIONAL CHART FOR A LOCAL GOVERNMENTAL
AIR POLLUTION AGENCY
4-17
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A large part of the activity of a state or local air pollution control agency is permit-related.
Figure 4-5 shows that of the 23 percent (23.3) of time spent in engineering services, 15
•percent (14.8) is spent in operation of the permit system. Field enforcement services
consume up to 8 percent (7.9) of the agency's time. Almost 13 percent (12.9) of the field
services consist of scheduled inspections for permit renewals.
TECHNICAL
SERVICES
FIELD
ENFORCEMENT
SERVICES
D FIELD
PATROL AND
COMPLAINTS
MANAGEMENT
SERVICES
ENGINEERING
SERVICES
FIGURE 4-5
GENERALIZED DISTRIBUTION OF FUNCTIONAL ACTIVITIES
FOR REGULATORY AGENCIES ANTICIPATED FOR 1974
4-18
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The reinspection procedure for permit renewals entails a number of functions:
1. Processing data for determining whether to issue or deny a certificate to operate,
2. Processing data for determining the need for source testing,
3. Verifying data for source registration,
4. Verifying data for emission inventory,
5. Procuring data for court or appeals board action,
6. Procuring data for evaluation of operating procedures relative to compliance with
current standards,
7. Procuring data for evaluation of possible nuisance problems, and
8. Verifying operating schedules of equipment.
Reinspections are done primarily in connection with permit renewal but may also be done
in response to citizen complaints (which require about 6 percent (6.3) of an agency's time)
or in connection with a periodic (usually annual) compliance test and/or inspection. A
continuing permit system operation is illustrated in Figure 4-6.
Typical of the forms used by inspectors in these surveillance activities are those of the Los
Angeles County Air Pollution Control District for field inspection reporting (Figures 4-7 and
4-8).
4.4.4 Reporting Requirements During Violations
Industrial plants are normally considered in violation of regulations when a process or
control device emits pollutants in excess of the rate cited in the applicable regulation or
standard. Excessive emissions could occur because of poor operation and maintenance or a
malfunction in the process.
The Federal Register defines malfunctions as follows:
"Malfunctions are sudden and unavoidable failures of control or process equipment, or
processes that do not operate in a normal or usual manner. Failures that are caused
entirely or in part by poor maintenance, careless operation, or any other preventable
condition shall not be considered malfunctions." (2)
4-19
-------
INDUSTRY
CONSULTANT
REGULATORY AGENCY
1-
H
MPLIANCE TESTS
INSPECTION COMPLA
z
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PROCESS
ADJUSTMENTS
1 t_
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V
NOTIFICAT
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ANN UAL TEST
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* FOR CORRECTIVE
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ION OF CORRECTION
STACK OR
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J NOTIFICATION OF COMPLIANCE
i At
SUBMITTAL
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INITIAL SUBMISSION
COMMENTS
(STATE OR LOCAL)
FIELD PATROL
AND COMPLAINTS
ENFORCEMENT
OFFICE
RE VIEW TESTS
FOR CONTINUED
COMPLIANCE
t
APPLICATION
REVIEW
_J 1
I
FACILITY
INSPECTION
1 ,
REISSUE
PERMIT
FIGURE 4-6
CONTINUATION OF PERMIT SYSTEM
4-20
-------
ENGINEERING DIVISION—FIELD REPORT
DATt 01 INSPECTION1
«*1L(MG A.OORC.SS
PENUlT APPL. NO.
IOU1?*£NT LOCATION UOOBESi)
A.P.C.O. IONE NO.
ASON PCKMIT
IS »EOUl"[0:
NCw CON-
STRUCTION
CHANCE or
OWNERSHIP
CHANGE OF
LOCATION.
EOUIPMtNT
DATE COKSTRUC-
TION AUTHOR I if D :
TIME SPENT
"AKIHC INSPECTION:
USUAL OPERATINC SCHEDULE
I THIS tOUIPutNT:
E*TIM*rtD
COST:
ES 6 intvs OF
CCSTACTto »v EHCIN
FOR DUST *
PROeLE'.'S C-iLY:
• f PCHT Is)
/KH.
/H*.
ESTIMATED
LOSSES:
rflCIAL £&ulP«tsT DESCBIfTlON. "CALCULATION Of PROCESS, Hi I «MT I S ( 7 > IIOC^ESS OESCR 1 PT I OfT AND FIND1NCS
LI*.
/MK.
'"•"" ( )
•ITION: PERMIT.
TO CONDITiCNS LISTED B(
HOLD. SEE EX.
PLANATION BELOW.
I ) 1 CONCUR WITM RCCOMUEHDATteNS
( ) I 00 NOT CONCUR olTH KECOUHCNDATIOut
t 1 SEE COUMOTS ON ATTACHED PACE
1 or.
FIGURE 4-7
FIELD REPORT FORM, DUST AND FUMES, LOS ANGELES
COUNTY AIR POLLUTION CONTROL DISTRICT (1)
4-21
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AIR POLLUTION CONTROL DISTRICT COUNTY OF LOS ANGELES
434 South Sin Pedro Strtet, Lot Angeles, C»liforni» 90013
COMPLAINT FORM
(plus* print or type)
Statement of Mr. I 1 Mrs] IMS.! 1
ICn«ck On* Qni
Home Address
IStr««t Number t (City) (Z.pCoaei
Mailing Address Tel. No.
(H S«me At Home Enter "Same")
Business Address
II* None Erne' "None") ICity)
Business Telephone No. Extension
1. NAME OF COMPANY OR SOURCE:
(It NOT Known Lmr* Blank I
2 Nature of emission complained of: (Checkbox) Smoke | |
Dust I I Soot I 1 Odors O Other Q
Describe odor or emission
(Eg P^nt.Sfcunk flonen Egg. Etc.!
3 Date and time emissions observed
ISrwcify Es From To am/pm and Include Date)
4. If possible, designate specific source ,__
{Eg. Stick, Tink. Eic.l
5 Have you or any member of your household become ill because of these emissions?
Yes d No Q
6. Describe nature of illness
7 State any damage done to your property, home, furniture, automobile, clothing, etc..
8. Will yOU testify in COUrt? YeS \__\ No Q <" no.wm«*tld»el»r«iononrW»r»i,del
I declare under penalty of perjury that the above information is true and correct.
Executed on 19 at _^ . . , California
lSign»iure!
40D261:Rev.
1U20/73
FIGURE 4-8
AGENCY INSPECTION COMPLAINT FORM (1)
4-22
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Declaration of
Address
COUNTY OF LOS ANGELES
AIR POLLUTION CONTROL DISTRICT
(Full Mantel
(Ncmcl
(C-tv)
.declare that:
(Zip Code)
I have read the foregoing declaration and I declare under penalty of perjury that the information is to the
best of my knowledge true and correct.
Executed on - -. , ia t «t _
(City o* Community)
California.
APCD USE ONLY
Complaint and/or declaration received by
on 19
(Dm)
Verified source
No.
(FA or Complain H
HmpKtort MM* • Print!
inwocton Signttura)
Address
H»etorl
FIGURE 4-8 (Cont.)
AGENCY INSPECTION COMPLAINT FORM (1)
4-23
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Therefore, a violation can occur in a plant whether the problem results from poor
operation/maintenance or from a malfunction. Technically, a malfunction is considered
legitimate, whereas a violation caused by an operation/ maintenance problem could result in
prosecution.
Most agencies require the reporting of violations in accordance with the SIP. Some agencies
request notification by phone, and others use a more formal reporting system.
Because companies often do not call the regulatory agencies when violations occur, com-
plaints by affected citizens provide a method for detection of violation. Some plants subject
to NSPS must operate continuous monitors; for such plants, an inspector can readily check
the records on the stack monitors to document a violation. For compliance with the NSPS,
the owner or operator of a plant is required to record any emissions resulting from mal-
functions of startups that are measured or estimated to be greater than those allowed by
NSPS. A report of such emissions must be submitted to the Administrator on the 15th day
following the end of each calender quarter. Figure 4-9 illustrates the violation notification
process.
Violation Notices - Although procedures for notification and correction of violations vary
among state and local agencies, many of them simulate U.S. EPA procedures. The proce-
dures discussed in this section are typical; however, each industry should check with the
appropriate regulatory agency to determine specifics and deviations.
The following groups are usually involved in a violation notice:
1. Regulatory agency personnel,
2. Industry consultant,
3. Industry attorney, and
4. Industry management.
Figure 4-10 illustrates interaction of these groups during the procedure for violation cor-
o
rection. The individual agency functions are shown in Figure 4-11.
The regulatory agency determines a violation and issues a violation notice. The industry
must respond to the notice within a specific period of time. The regulatory agency and the
industry confer to discuss the problem, the intent of the industry to correct the problem,
and the corrective alternatives that are available.
4-24
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STATE OR LOCAL
AGENCIES
EPA
INDUSTRY
QC
O
Q.
LU
CC
QC
O
DATA STORED
PRESENTED UPON
REQUEST
'
MONTHLY,
QUARTERLY OR
ANNUALLY AS
REQUIRED
11
INDUSTRIAL
PROCESS
H
QC
O
a.
LU
CC
LU
Q
O
w
a.
LU
cc
O
O
PHONE CALL
AND/OR
REPORT
i
EMISSIONS
GREATER THAN
NSPS STANDARD
J
15 DAYS FOLLOWING
END OF QUARTER
FIGURE 4-9
REPORTING OF VIOLATIONS
4-25
-------
INDUSTRY REPRESENTATIVES
REGULATORY
AGENCY ENGINEER ATTORNEY MANAGEMENT
NOTICE OF
VIOLATION
*
CONFE
RESPONSE BY
* LETTER
RENCE f 4
OPTIONAL OPTIONAL
PERMIT ' ~-
APPLICATION
,
COMPL
SCHE
DULE
*
CONSENT
r^BPFR „ L
1
J' STACK
- TfcST
* . * ..,
COMPLIANCE COMPLIANCE
1 I
ISSUE
PERMIT
FIGURE 4-10
GROUP INTERACTIONS FOR VIOLATION CORRECTION
A permit application is generally filed by a registered engineer. The control agency deter-
mines the compliance status of the process or operation for which the application has been
filed. If the operation is not in compliance, then a compliance schedule is filed, which is the
basis for a consent order. The compliance schedule is a timetable or milestone chart indi-
cating when certain increments of progress toward correction of the violation will be com-
pleted. The consent order is a formal agreement to complete the engineering indicated in the
permit application according to the compliance schedule. When changes have been made to
correct the violation, a stack test is performed to indicate whether the plant is in compliance
or in violation. If the plant is in compliance, the regulatory agency issues a permit.
If compliance is not reached in the first attempt, the process is repeated with a new consent
order.
4-26
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REGULATORY AGENCY FUNCTION
ACTIVITY
PLANT IN
VIOLATION
.
I
ENFORCEMENT
ACTION
i
PERMIT
SECTION
i
COMPLIANCE
SCHEDULE
1
CONSENT
ORDER
, i
NOT IN
^ COMPLIANCE COIV
IN
PLIANCE
EXPIRED
PERMIT
PERMIT
VIOLATION
NO
PERMIT
TEST INDICATES
NOT IN COMPLIANCE
ISSUES ENFORCEMENT
NOTICE
INDUSTRY SUBMITS
APPLICATION
MAINTENANCE
PROGRAM
NEW
CONSTRUCTION
PROCESS
MODIFICATION
CONTINUE
TO OPE RATE
PLANT
COMMENTS
FROM RECORDS
REVIEW
> FROM TESTING OR
COMPLAINTS
• OBSERVATIONS BY
SURVEILLANCE TEAM
• STACK TEST
'VISIBLE EMISSION
OBSERVATION
• INDICATES CHANGES TO
BRING PLANT INTO
COMPLIANCE
• INCLUDES
TIME TABLE
'DETAILS OF
CORRECTION
TECHNIQUES
FIGURE 4-11
REGULATORY AGENCY FUNCTIONS FOR HANDLING VIOLATION
Compliance Schedules — When a plant is in violation, an enforcement notice is issued that
leads to the formation of a compliance schedule and eventual correction of the problem.
Figure 4-12 illustrates the steps involved in the establishment of a compliance schedule.
The compliance schedule is a timetable under which certain corrective measures will be
accomplished. Figure 4-12 is a typical form used as the basis of a compliance schedule. Note
that the compliance schedule conditions are made a part of the permit that, in this case, the
State of Florida would issue.
4.5 References
1. Guide to Engineering Permit Processing, U.S. Environmental Protection Agency,
EPA APTD-1164, July 1972.
2. Federal Register, Vol. 38, No. 84.
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STATE OF FLORIDA
DEPARTMENT OF POLLUTION CONTROL
OPERATION PERMIT CONDITIONS
FOR AIR POLLUTION SOURCES
{An "X" indicates applicable conditions)
DATE: PERMIT NO.-
( ) 1. Test the emissions for the following pollutant(s) at
intervals of from the date of this permit and submit
two copies of test data to the regional engineer of
this agency within fifteen days of such testing. Chapter
17-2.07(1).
( } Particulates ( ) Sulfur Oxides
[ ) Fluorides ( ) Nitrogen Oxides
( ) Plume Density ( ) Hydrocarbons
( ) 2. According to revised Chapter 17-2, (revised 1/18/72), this
facility must be modified, up graded, or eliminated in order
to comply with applicable emission limitations. *To insure
compliance pursuant to the time limitation specified in Sec-
tion 17-2.03(2), Chapter 17-2, Florida Administrative Code,
the following steps toward compliance are made a condition
of this permit,
(A) Submit on or before a final control plan
for complying with Chapter"17-2, Florida Administrative
Code. This plan is subject to approval by the regional
office.
(B) Submit on or before a copy of contract (s)
for modification/control equipment and/or fuels necessary
to comply with Chapter 17-2.
(C) On or before , construction and/or modification
must be initia"ted7 SuEmTt 60 days prior to this date con-
struction permit applications and necessary information.
(D) Construction and/or modifications toward compliance must
be completed by Submit no later than
confirmation of this condition.
(E) Submit on or before proof of Compliance. This
must include any changes irTthe construction permit appli-
cation as submitted, and a final engineering report and
_ to prove compliance. (test results
and/or calculations!
* Th« applicable emission limitation for this facility is:
Section Chapter 17-2,
Florida Administrative Code.
( ) 3. Submit for this facility, each calendar year, on or before
March 1, an emission report for the preceding calendar year con-
taining the following information:
(A) Annual amount of materials and/or fuels utilized.
(B) Annual emissions.
(C) Any changes in the information contained in the permit
application.
FS19
1-74
FIGURE 4-12
TYPICAL FORM FOR COMPLIANCE SCHEDULE
4-28
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CHAPTER 5
STACK EMISSION MEASUREMENTS
5.1 Introduction
Measurement of pollutant emissions in the stack of an industrial process, often called "staek
testing, source sampling," or "emissions testing," provides for industry management the
data required for several determinations:
1. Losses of product through the stack,
2. Efficiency of control equipment, and
3.
Compliance/noncompliance with emission regulations.
Methods for manual measurement of emissions from point sources are becoming
increasingly sophisticated, although such practices still remain an art rather than a science
Requirements for emissions testing are becoming more stringent, and quality assurance
programs are being initiated at all levels of government to ensure control of testing
procedures, transport of samples, and laboratory analysis.
This chapter provides background information on the concepts, techniques, and quality
control requirements involved in an industrial emissions sampling program. Although no
attempt is made m this guide to provide a training manual on emissions testing, these
discussions should provide the knowledge that is needed to formulate an industrial testing
program secure the services of a professional test team when one is required, and obtain the
data needed to determine a plant's compliance status.
Each industry produces an identifiable "fingerprint" in the air pollutant spectrum, emitting
particulates, gases, or both in characteristic combinations. The experienced observer is
aware, for example, that an asphalt plant emits particulates of a certain type, and that a
paint spray booth emits hydrocarbons in the form of solvent vapors. He also recognizes that
certain sources may produce major emissions of specific pollutants and only minor
emissions of others. The principal emissions from a phosphate chemical processing plant for
example, are particulates, sulfur dioxide, and fluorides; minor emissions from the same plant
will include ammonia and sulfuric acid mist, which are of secondary concern.
In formulating an emissions testing program and determining what emissions should be
measured, the industrial planner must consider these factors:
1. The plant's major emissions sources,
2. Sources having an impact on sensitive receptors,
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3. Local, state, and federal regulations, and
4. Community environmental concerns.
A basic concept of manual emissions testing is that a representative portion
faken from a pollutant-laden gas stream being exhausted from a stack or other duct to the
atmosphTe L purpose is to determine the total mass emission rate or concentrate of a
poZant I a form dictated by the applicable emission regulations. Rep Rations limiting
em" to a specified value in parts per million (ppm) or grains per standard cubic foot
gT^uire that the concentration of the poUutant be determined. ReguUtio^hmmn,
emissions to a specified value in pounds per hour or total mass emiss1Ons requn-e that the
concentration and the total flue gas volumetric flow rate be determined.
In obtaining the sample, a sampling tube or probe is placed in the stack and the sample is
"t a*Td! Ihis sampfe is then s'ubjLed to analysis usually in a laboratory Anjys, «f *
sample gives the concentration of the pollutant in the gas stream. Cdf-^™
emission^ rate requires measurement of the volumetnc flow rate, winch can be ex
pmr
= C x
where:
pmr = the total pollutant mass emission rate
Cs = concentration of the pollutant in the gas stream
Qs = volumetric flow rate of the entire gas stream out of the stack to the atmosphere.
A sampling apparatus is designed for a specific sampling method to provide data that display
the test results in the desired form.
Throughout the discussion of emissions testing, the concept of representativeness .is
Impha^ed repeatedly. For an emissions test to be representative, the following cntena
must be met:
1. Process and control equipment must be operated in such a manner as to produce
representative emissions. Many regulatory agenc.es requ.re that the process be run
at the "maximum normal production rate" during the emission tests.
2. Locations of the sampling site and sampling points must provide samples
representative of the emissions.
3. The sample collected in the sampling apparatus must be representative of the
sampling points.
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4. The sample recovered and analyzed must be representative of the sample collected
in the sampling apparatus.
5. The reported results must be representative of the sample recovered and analyzed.
A sample obtained in an emissions test represents a very small fraction of the total gas
stream exhausted to the atmosphere; sample volumes may be as small as 0.002 cubic meter.
Since only a very small portion of the total pollutant is collected during a test, a high degree
of skill and knowledge is required to obtain a representative sample. Complex sampling and
analytical procedures also require competent and experienced personnel, since any error in
the sample is multiplied many times when related to the total exhaust flow. Recognizing the
need for skills and experience in an emissions test team, the industry planner is faced with
an important decision: whether the test should be conducted by in-house personnel or by a
consultant testing group. Following are some considerations affecting this decision.
5.2 Utilizing Consultants and Testing Service Organizations
Many companies engage consultants or service organizations to supplement their own staff
m such specialized areas as law, advertising, and accounting. Consultant groups are also
available to assist in an environmental program by performing emission tests, evaluating
emission control systems, determining environmental impacts, and related services.
Depending on their -experience and capabilities, such firms can provide a variety of services
on an intermittent or continuing basis (1). A service that should be strongly considered for
contracting to an outside firm is emission testing, especially for initial or intermittent test
work.
5.2.1 Contract or In-House Testing Considerations
In considering the use of an outside testing service, a company must evaluate the following
factors:
1. Availability and experience of in-house staff,
2. Availability of test and analytical equipment and work area in-house,
3. Utilization of test data,
4. Estimated cost of in-house versus outside service,
5. Estimated total amount of testing (number of sources and repetitions),
6. Restrictions imposed by labor unions,
7. Safety and employee insurance,
5-3
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8. Proprietary nature of processes to be tested, and
9. Plant security.
Any one of these factors (and possibly others) could be decisive in the choice of in-house
versus outside services; a combination of factors usually affects the final decision.
Availability and experience of in-house staff are two primary factors. Personnel with
chemistry or engineering backgrounds could be trained in a 4-day introductory course, for a
fee of approximately $500 (plus salary of personnel), together with participation in
preliminary or practice runs to gain experience. In-house staff could also gain experience by-
working closely with a service company for a few initial test series. "Hands-on" testing
should be supported by a thorough understanding of the principles involved in obtaining a
representative sample. An alternative to training staff personnel is to hire personnel
experienced in emission testing, however, such personnel are not easily found.
Availability of testing and analytical equipment also takes high priority in the decision to
stay in-house or go outside for emission testing. The cost of particulate and gaseous
sampling trains, calibration devices, and analytical equipment is approximately $12,000. If
an in-house laboratory already is equipped with basic analytical tools, such as a balance,
dessicator, and colorimeter, and with a suitable work area, the cost of sampling equipment
would be about $7,000. The availability of staff members with skills and experience in
sample analysis must also be considered.
Utilization of test data is sometimes ignored in the planning of emission tests. For
approximate data-gathering functions with a flexible schedule, a relatively inexperienced
staff may be adequate. Only an experienced test team can provide precise engineering data
or perform compliance testing. Testing by a third-party team often satisfies the needs of
both the plant owner and the control agency for impartial, accurate emission test data.
The cost of emission testing is always an important consideration. Unfortunately, a direct
cost comparison of in-house and outside testing is difficult. Many costs, such as those for
equipment, space, and fringe benefits, must be added to direct salaries to arrive at estimated
testing costs. Also, costs per test vary widely with the number and type of tests and with
accessibility of the test site. A 1973 article summarizing costs for emission testing services
states the following conclusions (2):
1. A firm doing more than $60,000/yr of testing per location with an environmental
testing firm should consider performing most of the tests in-house and using the
test consultant as an auditor.
2. A firm doing $20,000 to $60,000/yr of testing work should investigate in-house
testing, particularly if it has idle or under-used man-hours.
3. A firm doing less than $20,000/yr of testing will find that the use of testing
services is almost invariably more economical than in-house testing.
5-4
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A key factor in assessing cost is the number of tests to be performed over a given time
period. For a long-term program that involves frequent testing, the use of in-house personnel
is usually more cost-effective.
Employee job functions or descriptions and applicable labor union rules also affect decisions
regarding test work. Emission testing is not usually covered in descriptions of routine job or
trade functions. Although job iunctions are negotiable, such negotiations can be
time-consuming and, for a brief test series, not worth the potential problems. Employee
safety and possible insurance problems must also be considered. Personnel performing
emission testing are required to use safety gear; they also must carry heavy equipment and
often must work from platforms above ground or at roof level. Exposure to toxic fumes,
electrical wires, and inclement weather may add to the hazards of testing. Special safety
precautions and great care are required to prevent serious injury (3).
Testing of highly proprietary processes may necessitate the use of in-plant personnel to
maintain confidentiality of the process or the emission data. Although this problem may be
overcome by requiring secrecy agreements with outside testing personnel, some risk is still
incurred. Plant security procedures that restrict the admittance of outside personnel could
present a problem in gaining entrance for contractor personnel into some areas of a plant,
especially where classified governmental work is performed.
Some less tangible considerations are also involved in deciding whether to engage an outside
test consultant:
1.
2.
3.
A consultant organization might act as a third party in negotiations with a state,
local, or federal air pollution control agency.
Where the company has poor rapport with control agency personnel, an outside
test firm could be used to advantage.
A consultant firm would provide assistance in related environmental matters
concerning, for example, potential regulatory actions, evaluation of control
systems, occupational safety and hygiene problems, and water pollution aspects
of emission controls.
5.2.2 Selecting Consultants and Testing Services
Selection of a consulting firm requires that the industry specify exactly what is to be done
and determine what specific applicable experience is offered by various consulting firms.
The effort expended in selection of a consultant varies with the amount and nature of the
work to be performed. For short-term, relatively simple tasks, selection may be based upon
phone contact and a review of capabilities. For more extensive and complex tasks, a
carefully prepared bid solicitation is desirable.
Recommendations of business associates, trade and technical associations, and past clients
of a consulting firm can influence the selection. A firm's promotional literature usually
5-5
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describes facilities, capabilities, and experience. Written responses from prospective
consultants should include:
1. A statement of the objective of the study or task,
2. The procedures to be followed,
3. A schedule for completing these procedures,
4. An estimate of effort and costs, and
5. Specific capabilities or staff experience.
The hiring firm can require that all test methods, equipment, and test reports be acceptable
to and approved by the responsible air pollution control agency. Such requirements would
cover equipment calibration, use of the test methods required by the agency, test program
preparation, quality control, chain of custody of samples, calculation procedures, and report
format and content. Ideally, a prospective contractor will provide for review an earlier test
report prepared by the firm. Control agency personnel usually can assist in procuring an
emission testing service by listing a number of capable companies in the local area. It is
advisable to visit the prospective test company to inspect the equipment calibration area and
laboratory.
Suppliers of pollution control and related equipment sometimes offer consulting and testing
services. Although these companies may offer extensive experience, they may not be
completely objective in recommending a method of control or in evaluating an existing
device. In addition, if confidentiality is involved, it may not be prudent to divulge process
information to a company that also deals with competitors.
5.2.3 Obtaining Emission Testing Services
Written requests for emission testing services should be submitted to candidate companies.
These written requests should specify:
1. What is to be tested, i.e., boiler, process, or other;
2. Plant location;
3. Purpose of test;
4. Compounds to be measured (if known);
5 Details of the test site, such as height of test ports, stack diameter, platform
dimensions, approximate gas temperature, and other details of the work area; and
6. Desired test and report dates.
5-6
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On the basis of specifications, the testing firms will submit proposals and specific
qualifications.
Purchase of emission testing services can be accomplished on a fixed-cost basis for a
well-defined task, or on a man-hour basis for a task whose scope is not yet defined.
Estimated total costs or average hourly rates will allow comparison of bids from various
respondents. Cost estimates for a given task do not usually vary widely among competent
testing consultants, since the same amount of work is required by persons with similar
salaries.
To ensure that estimated costs are not exceeded, the plant officials must assume certain
responsibilities:
1. Maintenance of constant process operation for the duration of each test.
2. Provision of unobstructed sampling ports for access to the gas ducts. A minimum
3-inch opening is required at the locations requested by the test engineer.
3. Provision of 110-volt, 25-ampere electrical supply at the sampling site.
4. Provision for access to the sampling site and safe working conditions.
5. Prompt clearance of personnel, vehicles, and equipment through plant security.
5.3 Planning and Conducting the Emission Test
5.3.1 Sequence of Events in an Emissions Test
Three groups are involved in the planning and execution of a compliance test:
representatives of the plant whose emissions are being tested, the testing team (consultant or
in-house), and the responsible control agency. Each of these groups has specific
responsibilities in performance of the test. The plant representative is responsible for
monitoring and recording facility operations and for collecting process samples, such as
samples of feed materials used during the test. The test team sets up the sampling
equipment, performs preliminary measurements, conducts the sampling runs, recovers
collected samples, and disassembles the equipment. The test group is also responsible for
analysis of samples and reporting of results. The control agency representative is responsible
for guidance before and during the test, for evaluation of sampling procedures, and for
taking readings of visible emissions during the test. The usual sequence of events is described
briefly in the remainder of this section.
Before the compliance test, representatives of each group conduct a pretest meeting to
develop testing procedures, establish conditions of facility operation, determine data
requirements, and formulate a test schedule. All responsibilities for specific tasks are
determined in detail at this meeting. A test program detailing the elements discussed at the
meeting should be prepared by the test group.
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A compliance test consists of three sampling runs, preceded by preliminary measurements to
check the test equipment. The normal time requirements for each phase of the test are
shown in Table 5-1. A usual sequence of events would be completion of tasks 1, 2, 3, and
4A or 4B for the first run; task 2 (optional), 3, and 4A or 4B for the second run; and task 2
(optional), 3, 4A or 4B, and 5 for the third run. If the test team is well-equipped, it will not
be necessary to recover the collected samples until all runs are completed.
TABLE 5-1
TIME REQUIREMENTS FOR COMPLIANCE
TEST EXECUTION
Task
No.
1
2
3
4A
4B
5
Task
Set up equipment
Make preliminary measurements
Conduct one sample run
Recover sample and set up for next run
Set up for next run without sample recovery
Disassemble and pack equipment
Time required
2-4 hr
Ihr
1-4 hr
1-3 hr
1-2 hr
1-2 hr
Under ideal conditions, it is possible to set up the equipment and make all three runs in one
day. A more usual sequence, however, is to set up the equipment on the morning of the first
day and perform one sample run in the afternoon. The test team then can review the data
from the first run that night to determine whether the tests are yielding valid data. The
second run is then made on the morning of the second day, and the last run in the
afternoon.
When all testing is completed, the sampling equipment is disassembled and removed from
the site. The equipment is carefully repacked to ensure safe transport. Transport is
especially critical if the collected samples are not recovered on site. A professional testing
firm will usually provide preliminary test results in about 1 week and a final report in 2 to 3
weeks.
The emission test procedures are described in detail in the following sections.
5.3.2 Developing the Test Program
At the outset, all of the groups involved in emission testing should understand the potential
legal implications of the compliance test. Because of the possibility that test results or the
control agency's decision might be challenged, full understanding among the concerned
parties should be achieved and documented before the test is performed.
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Upon notice from the plant representative that a compliance test is intended, the control
agency will prepare written guidelines that clearly delineate the acceptable sampling
procedures. These guidelines will inform the test team and the plant representative of all
baseline or minimum conditions to be met in the test and will indicate procedures for
calculation and reporting of test data. The requirements may be part of an overall regional
compliance schedule or they may be stipulated in a Federal Standard for New Source
Performance (NSPS).
On the basis of specified requirements, the plant representative and test consultant will
develop a proposed compliance test program, which will be discussed with an agency official
in one or more pretest meetings. One of the most significant items to be determined is what
constitutes representative facility operation.
Determining Representative Facility Operation - Representative facility operation must be
specified in detail before the test, for the protection of both the facility and the control
agency. Facility operations are defined to include the key process operating parameters and
the operation of air pollution control equipment. An emissions test can be set up both to
determine the plant's compliance status and to verify the efficiency of control equipment in
fulfillment of the vendor's guarantee. If the latter is part of the test program, samples
sometimes must be taken both before and after the control equipment. In any case, the test
team must be apprised of all criteria to which the test data will be applied.
Where the facility is new or is a modified older facility, the plant operators must provide for
the control agency the anticipated facility operating conditions in order to obtain a permit
to construct and/or operate. The specified facility operations will then be monitored and
recorded during the compliance test and later will be routinely monitored as part of the
continuing compliance program.
Most control agencies have developed standard facility checklists for each of the major
industrial processes and pollution control systems. Figure 5-1 is a standard cover sheet
identifying the persons who will represent the plant, the test team, and the control agency.
It also identifies the persons in each group who have senior responsibility and authority in
matters pertaining to the compliance test. Most communications regarding the test will be
among the representatives; higher authority is usually sought only in the event of
disagreement regarding validity of the test or in other special circumstances.
Figure 5-2 is a general "Test Program Agreement on Continuing Compliance Conditions"
form, setting forth the operating conditions that must be met in the future for the plant to
maintain compliance. This information provides the basis on which to establish the
representative facility operations for the test, as shown in Figure 5-3, "Test Program
Agreement on Facility Operation". A specialized checklist series for coal-fired boilers is
presented in Appendix B.
In determining representative facility operation, the plant representative has several
important responsibilities. He should know all aspects of plant operation well enough to
5-9
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TEST PROGRAM MEETING REPRESENTATIVES
Plant Name.
Plant Address.
Source to be Tested,
Plant Representative.
Plant Manager
Test Team Company Name.
Team Representative
Responsible Person.
Members of
Test Team .
Agency(s).
Agency Representative.
Responsible Person
Agency
Observers.
Title
Date
.Phone.
.Phone.
.Phone,
Phone.
.Phone.
.Phone.
Affiliation
and Tasks
FIGURE 5-1
TEST PROGRAM MEETING REPRESENTATIVES
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TEST PROGRAM AGREEMENT ON CONTINUING COMPLIANCE CONDITIONS
Process
1) Process parameters that must be recorded and submitted to agency or kept on file
for later inspection
2) Percentage by which each process parameter can exceed the tested rate and on
what time-weighted average
3) Future operating procedures
Control Equipment
4) Control equipment parameters that must be recorded and submitted to the agency
or kept on file for later inspections
5) Normal operating procedures
6} Normal maintenance schedule
7) Frequency of scheduled inspections by agency
Reviewed and approved by;
Agency. Facility Tester.
FIGURE 5-2
TEST PROGRAM AGREEMENT ON CONTINUING COMPLIANCE CONDITIONS
anticipate any potential problems. He should make sure that all values specified for
operations that could cause upset conditions are outside the acceptable values. If these
operations then should cause upset conditions during the test, the test data cannot be used
against the plant in any future litigation. Documentation of upset conditions during testing
is important, since a control agency's compliance test report can be used as evidence by any
public or private group or individual at a later date.
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TEST PROGRAM AGREEMENT ON FACILITY OPERATION
Process
1) Method of process weight or rate determination
2) Process parameters to be monitored and recorded, and their acceptable limits to
document process operation
3) Raw material feed and/or fuel acceptable analyzed values
4} Normal operating cycle or procedures
5} Portions of the operating cycle or procedure that will be represented by each run
Control Equipment
6) Control equipment and effluent parameters to be monitored and recorded, and
their acceptable limits to document control equipment operations
7) Normal operating cycle (cleaning, dust removal, etc.)
8} Normal maintenance schedule
9) Manner in which the control equipment will be operated during test
FIGURE 5-3
TEST PROGRAM AGREEMENT ON FACILITY OPERATION
Although some control agencies have the authority to establish unilaterally the operating
conditions for a compliance test, the agency representative usually seeks input and
agreement from the plant representative. If the agency does not, and the plant
representative believes that the stipulated operating conditions are unjust, then the company
should notify the agency of its objection by registered letter. Although the test may be
conducted under the disputed conditions notwithstanding the objection, the plant would
then have the right to contest the results in court if the agency has been notified prior to
testing.
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Another point of significance to the industry being tested is that the agency should not
require the monitoring and recording of any parameter of process operation unless that
parameter has a direct bearing on process rate or on atmospheric emissions. If the agency
representative proposes the monitoring of parameters that seem not directly related to
process rate or emissions, it is appropriate to ask how the resulting data will be used and
what values would be considered unacceptable.
Future Facility Operations - Future operations of the plant must be factored into the
determination of representative conditions. If the plant has been operating for some time
and significant changes are anticipated, the compliance test should be geared to future
operations. For example, a plant that has been firing high-sulfur coal may plan to switch to
using low-sulfur coal as part of a compliance program. The agency will allow firing of the
low-sulfur coal during the compliance test if assurance is provided that this coal will be
representative of the plant's future operations. Similarly, use of a new type of solvent could
be introduced into plant operations to reduce hydrocarbon emissions. Use of the new
solvent in the compliance test would be allowed if the plant then continued its use in regular
operations. A statement of future operations is included in the "Test Program Agreement on
Continuity Compliance" form (Figure 5-2). Failure of the plant officials to consider such
potential changes m operation could lead to significant expenditures of time, money, and
effort in the event that retesting is required because of such a change
D "
At the conclusion of the final test program meeting, all of the parties involved should clearly
understand how the test will be conducted, the sampling procedures to be used the
operating parameters to be monitored and recorded, the raw materials to be fed to the
process, and any conditions that would invalidate the test. With the testing program agreed
upon and defined in detail, the compliance test should proceed smoothly and should yield
valid results.
Measurement Errors - In further preparation for the compliance test, the plant
representative should understand the significance of measurement errors that might occur
Although such errors can be minimized by selection of an experienced testing firm they
rarely can be eliminated entirely. Determining pollutant emission rates by stack sampling
involves measurement of a number of parameters. Errors of measurement associated with
each parameter combine to produce an error in the calculated emission rate. Measurement
errors are of three types: bias, blunders, and random errors.
Bias errors, usually resulting from poor technique, cause the measured value to differ from
the true value in one direction. This operator error often can be minimized by proper
calibration of instruments and by adequate training in instrument operation. Most bias
errors can be eliminated if the testing supervisor provides documentation of the calibration
of equipment at the pretest meeting. A one-point field check of calibration is sometimes
warranted.
Most blunder errors occur during collection, recovery, or transportation of the sample or
dunng analysis. Unfortunately, such errors are difficult to observe, and the total effect
5-13
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cannot be calculated. Elimination of blunders should be a main concern of the testing
supervisor. The plant representative also should be alert to possible blunders.
Random errors, which result from a variety of factors, cause a measured value to be,either
higher or lower than the true value. Such errors are caused by inabihty of sampling
personnel to read scales precisely, poor performance of equipment motors, and lack of
sensitivity in measurement devices. The usual assumption is that random errors are normally
dlTributld about a mean or true value and can be represented statically m terms o
probabilities. Determining the maximum expected error, however, does not require a strict
statistical approach. Total maximum error can be estimated by summing the maximum
expected errors for each factor.
The impacts of measurement errors on test remits can vary greatly. With some parameters
such /static pressure of the stack gas, the error may be ±100 percent and s*no^fa*
the result, appreciably. Conversely, a blunder error that might seem insignificant, such as
bumping theTampling apparatus against the inner stack wall, eould produce emission values
that are 10 times higher than the true emissions.
In an effort to minimize errors, the sampling procedures prepared by control agencies
include quality control, Most of these quality controls, however, are designed to ehmuiate
only the errors that produce a value lower than the true one, giving a low bias. It is the
responsibility of the testing team to eliminate errors or procedures that produce results
higher than the true value, giving a high bias.
5.3.3 Sample Site Requirements
The sampling site designated for an emissions test can affect the quality of the sample
exited Ite selection should be simple at new installations, since most states require
installation of an acceptable sampling site as a condition for obtaining a construction
permit. Acceptability is generally determined with reference to the distance from the
nearest upstream and downstream disturbance to gas flow by an obstruction or change in
direction. More sampling points are required for each test the closer it is to a disturbance, as
shown in Figure 5-4.
In addition to flow considerations, accessibility and safety are important. Clearance for the
probe and sampling apparatus, availability of electricity, exposure of personnel and
eouLent to weather or excessive heat, presence of toxic or explosive gases, and other
safety factors must be considered. The following guidelines constitute minimum require-
ments for safe and accessible stack sampling facilities:
Sampling Ports -
1 Port location - Ports should be located at least eight stack diameters downstream
of any bends, inlets, constrictions, abatement equipment or f^/^.^*^*^
least two stack diameters upstream of the stack exit or other flow disturbances. Where these
5-14
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FIGURE 5-4
MINIMUM NUMBER OF SAMPLE POINTS
5-15
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criteria are not met, a stack extension may be required unless the plant representative can
demonstrate that this remedy is not feasible. In such a case, an alternative port location
must be approved by the control agency.
2. Port type - A sampling port should be a standard industrial flanged pipe of 3-inch
inside diameter (ID) with a 6-inch bolt circle diameter. An easily removable blind flange
should be provided to close the port when not in use. Ports larger than 3-inches ID are
permissible and even desirable on large-diameter, double-walled stacks, which necessitate
use of longer probes. These ports also should be equipped with a standard industrial flange
of the same ID as the port. Gate valves should be installed only when unusual stack condi-
tions or the presence of hazardous materials require such devices to ensure safety.
3. Port installation - Ports should be installed flush with the interior stack wall. Ports
should extend outward from the exterior stack wall no less than 2 inches nor more than
8 inches, unless additional length is required for gate valve installation. Ports should be
installed no less than 2 feet nor more than 6 feet above the floor of the platform. Ports
should be installed with respect to the limitations of the clearance zone, described later.
4. Number of ports required - If the sum of the stack ID plus one port length (stack
inside wall to end of port extension) is less than 10 feet, two ports should be installed on
diameters 90 degrees apart. Proposed U.S. EPA guidelines for continuous monitoring of
certain categories of sources may necessitate the installation of four ports on diameters 90
degrees apart for stacks in this size range. If the sum of the stack ID plus one port length
(stack inside wall to end of port extension) is equal to or greater than 10 feet, four ports
should be installed on diameters 90 degrees apart.
5- Port loading - The port installations should be capable of supporting the following
loads:
a. Vertical shear of 200 pounds,
b. Horizontal shear of 50 pounds, and
c. Radial tension of 50 pounds (along stack diameter).
Work Platform -
1. Size and extent of platform - If two ports are required at 90 degrees, the work
platform should serve that quarter of the stack circumference between the ports and
extend at least 3 feet bejond each port. Minimum platform width is 3 feet. If four ports
are required at 90 degrees, the work platform should serve the entire circumference of
the stack. Minimum platform width is 4 feet unless the sum of the stack ID plus one port
length (stack inside wall to end of port extension) is less than 10 feet, in which case the
minimum platform width is 3 feet.
5-16
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2. Platform access — Safe and easy access to the work platform should be provided via
caged ladder, stairway, or other suitable means.
3. Guardrails, latterwells, and stairwells — A safe guardrail should be provided on
the platform. Angular rather than round rail members should be used if possible. No ladder-
well, stairwell, or other such opening should be located within 3 feet of any port. Ladder-
wells should be covered at the platform and any stairwell leading directly to the platform
should be equipped with a safety bar (or the equivalent) at the opening.
4. Platform loading — The work platform should be able to support at least three
men and 200 pounds of test equipment (at least 800 pounds total). If the stack exits
through a building roof, the roof may suffice as the work platform, provided the minimum
test site requirements are still met. In such cases, all other requirements are the same as for
a remote stack.
Clearance Zone — A three-dimensional, obstruction-free clearance zone should be provided
around each port. The zone should extend 1 foot above the port, 2 feet below the port, and
2 feet to either side of the port. The zone should extend outward from the exterior wall of
the stack to a distance of at least one stack ID plus one port length (inside wall to end of
port extension) plus 3 feet. The clearance zone is illustrated in Figure 5-5.
Power Supply - Power sources shall be as follows:
1. Platform — One 115-volt, 15-amp, single-phase, 60-Hz AC circuit with a grounded,
two-receptacle weatherproof outlet. Receptacles should accept standard, three-prong,
grounded, household-type plugs, or else suitable adapters shall be provided.
2. Stack base — One 115-volt, 30-amp, single-phase, 60-Hz AC circuit with a grounded,
two-receptacle weatherproof outlet. Receptacles should accept standard, three-prong,
grounded, household-type plugs, or suitable adapters shall be provided.
Vehicle Access and Parking — Except for situations in which sampling operations must be
conducted from a rooftop or similar structure, stack sampling is sometimes coordinated and
controlled from a cargo van or trailer, which is parked near the base of the stack for the
duration of the sampling period. Vehicle access and parking space must be provided, since
various umbilical, communications, and equipment transport lines will be strung from the
van or trailer to the stack platform and will remain in position during the operations.
Compliance With Safety Standards — Stack sampling facilities must meet all applicable
Occupational Safety and Health Administration (OSHA) requirements and must conform to
any other relevant safety guidelines.
Optional Permanent Monorail System — Some plants may wish to install a permanent
monorail system to facilitate self-monitoring. Persons considering such installations should
be aware that commercially available test equipment varies in size and configuration and will
not necessarily operate on a permanent monorail system as shown in Figure 5-6.
5-17
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SAMPLING PORTS
A. 2 PORTS, 90° APART WYOIAM-
ETER LESS THAN 10' + PORT
LENGTH
4 PORTS, 90° APART W/DIAM-
ETER OVER 10' +• PORT LENGTH
AT LEAST TWO STACK DIAMETERS
BELOW STACK EXIT
AT LEAST EIGHT STACK DIAMETERS
ABOVE LAST OBSTRUCTION
WORK AREA CLEARANCE
WORK PLATFORM
PORT DIMENSION REQUIREMENTS
(OUTSIDE}
2"MIN.
8" MAX. UNLESS GATE VALVE
INSTALLED
3" I.D. (MINI INDUSTRIAL FLANGE
CAPPED WHEN NOT IN USE
INSTALL GATE VALVE IF STACK
CONTAINS DANGEROUS GASES
OR GASES OVER 200°F UNDER
POSITIVE PRESSURE
STRENGTH REQUIREMENTS
50 IBS, SIDE LOAD
50 LBS.RADIALTENSION LOAD
200 LBS. VERTICAL SHEAR LOAD
750 FT. LBS. MOMENT
AT LEAST ONE STACK DIAMETER
PLUS 3' FROM STACK CIRCUMFERENCE
A.
C.
AT LEAST 3- WIDE (4' WIDE FOR
STACKS WITH 10' OR GREATER
I.D.) AND CAPABLE OF SUPPORT
ING 3 PEOPLE AND 200 LBS. OF
TEST EQUIPMENT
SAFE GUARDRAIL ON PLAT-
FORM WITH ACCESS BY SAFE
LADDER OR OTHER SUITABLE
MEANS. IF LADDER IS USED,
LADDER WELL MUST BE
LOCATED AT LEAST 3' FROM
PORTS
NO OBSTRUCTIONS TO BE
WITHIN 3' HORIZONTAL
RADIUS ON PLATFORM
BENEATH PORTS
POWER SOURCE
115V, 15A, SINGLE PHASE, 60 HZ AC
LOCATED ON PLATFORM
FIGURE 5-5
TYPICAL SAMPLING PROVISION
Miscellaneous Requirements — In addition to the specific requirements described in this
section, other requirements may be specified for sources with very large stacks or
nonstandard sampling locations. Examples of such requirements are:
1. Power hoists for sampling equipment when the platform is in excess of 200 feet
above ground level.
2. Additional attachment points above and to each side of the ports for supporting
very long monorails.
3. Provisions for sampling vertically in horizontal ducts.
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FIGURE 5-6
MONORAIL SYSTEM
Excess Air — In addition to the above requirements, certain processes (such as sulfur
recovery units) may require provisions for determining the composition and flow rates of
feedstock streams. This information, taken at the time of sampling, is needed to determine
the amount of excess air in the stack effluent.
Stack Extensions — Many times the maximum straight run of stack is not sufficient to meet
the agency requirements or the stack is lined and ports cannot be cut into the stack. A
simple solution applicable to some smaller-diameter stacks is the use of a stack extension as
shown in Figure 5-7. Stack extensions need not be permanent and can be made out of sheet
metal or plywood for testing purposes only.
5.3.4 Conducting the Emissions Tests
At the time of the compliance test, the plant representative has two major responsibilities:
(1) to ensure that process operations are in accordance with the representative conditions
established in the test program, and (2) to ensure that the emissions sampling is performed
as planned. Although the latter is the direct responsibility of the test team supervisor, the
plant representative should observe these sampling operations closely enough to be
confident that the specified procedures are followed. Again, the use of checklists is advised;
these can be used by an in-house test team for quality control.
5-19
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FIGURE 5-7
STACK EXTENSION
Starting the Test - The plant representative should be present when the test team starts
preparations. They will unpack the test equipment, check for possible damage, set up the
sample recovery lab, and assemble the sampling train. If an agency observer is present, he
will give close attention to these initial operations. His monitoring of test procedures
protects the interests of both the agency and the operating facility. If the test team requires
considerable direction and assistance from their supervisor, this is an indication of
inexperience and a signal to the plant representative to observe test operations as well as
process operations. In such a case, he may request the assistance of another plant official
during the test. A standard test team and equipment for particulate sampling is shown in
Figure 5-8. A checklist for observation of calibration, sample apparatus assembly, and final
checks is shown in Appendix B. If testing is performed improperly, the agency observer may
require performance of another sample run. Any additional sampling necessitated by
improper sampling techniques should be performed at the expense of the testing firm as part
of the contract agreement. Any responsible testing firm will be willing to guarantee that all
sampling procedures will be acceptable to the control agency.
In the course of the test, all parties are expected to perform their duties quietly and
thoroughly, with as little conversation as possible. The plant representative should instruct
all process operators to deal solely through him during the test and to discourage queries or
comments from any of the nonplant personnel. In particular, the operators should make no
5-20
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FIGURE 5-8
TEST TEAM AND EQUIPMENT
process change, even at the request of the agency observer or test team supervisor, without
approval of the plant representative. The same courtesy should be extended to the test
team, who should not be questioned or instructed by any person except their supervisor.
Monitoring Facility Operations - With some assurance that the test team is functioning as
planned, the plant representative will give his major attention to facility operations during
the test. Plant personnel are responsible for these functions: (1) monitoring and recording
the process parameters as specified in the test program, (2) collecting process raw materials
for subsequent analysis, and (3) monitoring the operation of control equipment. Functions
of the test team are clearly defined and should not interfere with process operation The
cluef responsibilities of the agency representative are to observe and to record data.
It is not possible to formulate for all industrial operations a general checklist of process
parameters. These are highly particular to the plant process and are dictated also by the
5-21
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applicable control regulations. One can, however, consider examples of process data
checklists for specific industries. The process parameters that are monitored and recorded
should demonstrate whether the facility is operating in a manner that is considered normal
for future operations.
If an equipment malfunction or upset should occur, the agency observer and test team
leader should be notified immediately. The resulting sample run should be invalidated and
no analysis performed. A charge of noncompliance could result from use of data taken
during upset conditions. For this reason, the plant representative should in no circumstances
allow the subsequent analysis of samples obtained during malfunction or upset. The cost of
performing an additional sample run while the test team and sampling gear are on site is
small compared with the cost of retesting at a later date.
Monitoring Control Equipment - Plant personnel are responsible for monitoring and
recording control equipment parameters during the compliance test. Because of the broad
range of control devices and techniques that are applied to industrial operations, the
discussion and examples given here are directed toward particulate sampling only.
Particulate control equipment can be categorized in several groups, based on similarities ,n
the several types of equipment within each group. Typical checklists for basic categories of
particulate control equipment are given in Appendix C, covering electrostatic precipitators
fabric filters, centrifugal collectors (dry mechanical collectors), and scrubbers (wet
mechanical collectors), respectively. These checklists include most of the control equipment
parameters that should be monitored and recorded during a compliance test.
Completing the Compliance Test - At the conclusion of each test run, the sample is
recovered for laboratory analysis. Several types of errors can occur during sample recovery.
The plant representative may refer to a sample recovery checklist (Appendix B) as a guide to
evaluating the performance of the test team in these critical operations.
Many errors can be detected by simple observation. Spillage during sample removal, use of
solvents in plastic containers, and handling of samples in an improper environment are
examples of unacceptable procedures. A filter from a particulate sampling device should be
dry. Where a control device is used and is operating properly, the filter should contain no
distinct particles that are visible to the eye. The color of the sample catch should be
approximately the same in each test run.
During recovery of samples from a compliance test, a chain of custody should be established
and recorded. An example chain of custody sheet is shown in Appendix B. Such a sheet
documents the events of sample recovery and can be used if litigation arises.
Transport of the samples from test site to the laboratory is also documented. A checklist for
the purpose is shown in Appendix B. Except when the plant undergoing the compliance test
is equipped with a suitable analytical laboratory, the plant representative usually docs not
observe the analytical procedures. An analysis checklist, which appears ,n Appendix B,
shows the types of quality controls that are applied to analytical procedures by a
professional testing team.
5-22
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Before the test team leaves the site, the plant representative should obtain copies of all
emission data sheets that have been filled out during the test runs. Similarly, he should if
possible obtain a copy of data records and notes made by the agency observer: if copies are
not available, he should review the observer's notes and data, and initial them. In reviewing
these materials, the plant representative will check for any unusual data values or comments
and for possible inclusion of confidential data. The agency observer is responsible for
maintaining the confidentiality of the emissions values and process operating data, subject
to the possibility of fines or other punitive measures in the event that confidentiality is
violated. In summary, the plant representative should obtain copies of all data, logs,' or
comment sheets that will leave the premises. Alternatively, he should be given 'the
opportunity to examine all such records, to designate any portions considered confidential,
and to initial the records.
Compliance Test Report - The final step in compliance testing is preparation of the test
report. This is the official record of the test, which can become a legal business record
admissible in court. Many control agencies provide a standard report format such as that
shown in Figure 5-9.
After the testing firm completes the test report, copies are forwarded to the client who
requested the tests. The client is usually an industry, although enforcement agencies also
engage consultants to perform emission tests. The industry funding the tests will have
representatives review the report prior to submission to the control agency. The plant
representative should review these reports closely and perform data validation checks as
appropriate. These would include the same elements that are involved in a preliminary
emission estimate: calculation of mass balances, process temperatures and pressures, fan
curves, design parameters, and stoichiometry. Review of these elements will indicate any
significant discrepancy in the test report data.
5.4 Specified Methods for Measurement of Pollutants
This section deals with the methods specified for sampling of particulates, sulfur dioxide
nitrogen oxides, fluorides, carbon monoxide, and hydrocarbons. It also briefly describes
determination of velocity and volumetric flow rate, moisture content, and molecular weight
of a gas stream. In all sampling procedures, the main concern is to obtain a representative
sample; the U.S. EPA has published reference sampling methods for all of these pollutants
except hydrocarbons so that uniform procedures can be applied in testing to obtain a
representative sample.
Each sampling method requires the use of complex sampling equipment which must be
calibrated and operated in accordance with specified reference methods. Additionally the
process or source that is being tested must be operated in a specified manner, usually at
rated capacity, under normal procedures. Calibration/operation of equipment and process
operation are not considered in the brief descriptions that follow; they are nonetheless
important in the emissions test.
5-23
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SOURCE TESTING REPORT FORMAT
Cover
1. Plant name and location
2. Source sampled
3. Testing company or agency, name and address.
Certification
1. Certification by team leader
2. Certification by reviewer (e.g., P.E.).
Introduction
1. Test purpose
2. Test location, type of process
3. Test dates
4. Pollutants tested
5. Observers' names (industry and agency)
6. Any other important background information.
Summary of Results
1. Emission results
2. Process data, as related to determination of compliance
3. Allowable emissions
4. Description of collected samples
5. Visible emissions summary
6. Discussion of errors, both real and apparent.
Source Operation
1. Description of process and control devices
2. Process and control equipment flow diagram
3. Process data and results, with example calculations
4. Representativeness of raw materials and products
5. Any specially required operation demonstrated.
Sampling and Analysis Procedures
1. Sampling port location and dimensioned cross section
2. Sampling point description, including labeling system
3. Sampling train description _ .
4. Brief description of sampling procedures, with discussion of deviations from
standard methods . ,_..*. ffnm
5. Brief description of analytical procedures, with discussion of deviations from
standard methods.
Appendix
1. Complete results with example calculations
2. Raw field data (original, not computer printouts)
3. Laboratory report, with chain of custody
4. Raw production data, signed by plant official
5. Test log
6. Calibration procedures and results
7. Project participants and titles
8. Related correspondence
9. Standard procedures.
FIGURE 5-9
SOURCE TESTING REPORT FORMAT
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5.4.1 Velocity and Volumetric Flow Rate
The U.S. EPA has published Method 2 as a reference method for determining stack gas
velocity and volumetric flow rate. At several designated sampling points, which represent
equal portions of the stack volume (areas in the stack), the velocity and temperature are
measured with instrumentation shown in Figure 5-10.
Measurements to determine volumetric flow rate usually require approximately 30 minutes.
Sampling rates are dependent on stack gas velocity. A preliminary velocity check is usually
made prior to testing to aid in selection of the proper equipment and in determining the
approximate sampling rate for the test.
The volumetric flow rate determined by this method is usually within ± 10 percent of the
true volumetric flow rate. Collaborative tests have shown that skilled test teams using
Method 2 can achieve accuracies within ± 4 percent.
1.90-2.54 CM
(0.75-1.0 IN.)
TEMPERATURE SENSOR
TYPE-SPITOTTUBE
LEAK-FREE
CONNECTIONS
FIGURE 5-10
VELOCITY MEASUREMENT SYSTEM
5-25
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Total cost of the equipment for measuring volumetric flow rate is approximately $4,500;
this cost represents the equipment specified in EPA Methods 2, 3 (molecular weight
determination), and 4 (moisture determination).
An alternative method for determining volumetric flow rate is to use data describing the
exhaust fan. A plot of fan performance (fan curve) provided by the manufacturer can be
used to determine approximate volumetric flow rate. This procedure should be used only as
a check to validate the data obtained by use of Method 2. If a combustion source is being
tested, a stoichiometric calculation can be performed to determine the stack gas flow rate.
A technician could perform this procedure by reading the method description and the
available manuals. It is advisable, however, that the technician attend a training course if
possible.
5.4.2 Molecular Weight and CO2 or O2
The EPA Method 3 is used to determine carbon dioxide or oxygen content and molecular
weight of the stack gas stream. Depending on the intended use of the data, these values also
can be obtained with an integrated or grab sample. Both methods are discussed here.
Grab sampling is used primarily to determine the molecular weight of the gas stream. A
sampling probe is placed at the center of the stack or no closer to the wall than 3.28 feet,
and a sample is drawn directly into an Orsat analyzer or Fyrite-type combustion gas
analyzer. The sample is then analyzed for carbon dioxide and oxygen content. With these
data, the dry molecular weight of the gas stream can then be calculated.
Figure 5-11 shows the equipment used to obtain a grab sample. Total cost of the equipment
for this method is approximately
An integrated sample is required when the analytical results will be used to calculate a
correction factor for pollutant emission rate, such as percent excess air or the "F" factor
(for combustion sources). For an integrated sample, sampling probes are located at several
designated points in the stack, which represent equal areas, and a sample is extracted at a
constant rate. As the gas passes through the sampling apparatus, the moisture is removed
and the sample is collected in a flexible bag. The sample is then analyzed by use of the Orsat
analyzer.
The minimum detectable limit for this method is 0.1 percent. No collaborative tests have
been performed.
Figure 5-12 is a schematic of an assembled apparatus for collection of an integrated stack
gas sample. In addition to this equipment, an Orsat analyzer is required. Total cost for this
equipment is approximately $1,000.
5-26
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PROBE
FLEXIBLE TUBING
T
TO ANALYZER
FILTER (GLASS WOOL)
SQUEEZE BULB
FIGURE 5-11
GRAB SAMPLE SETUP FOR MOLECULAR WEIGHT DETERMINATION
1.9 CM (0.75 IN.
AIR-COOLED
CONDENSER
FILTER
(GLASS WOOL)
QUICK DISCONNECT
n
FIGURE 5-12
INTEGRATED SAMPLE SETUP FOR MOLECULAR WEIGHT DETERMINATION
5-27
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5.4.3 Moisture Content
EPA Method 4 is the reference method for determining the moisture content of the stack
eas. A value for moisture content is needed in some of the calculations for determining
o
pollutant emission rates.
A sample is taken at several designated sampling points in the stack, which represent equal
areas. The sampling probe is placed at each sampling point, and the apparatus is adjusted to
take a sample at a constant rate. As the gas passes through the apparatus, a filter collects the
participate matter, the moisture is removed, and the sample volume is measured. The
collected moisture is then measured, and moisture content of the gas stream is calculated.
No collaborative tests have been conducted on this method, and no minimum detection
limits have been established. This method should not be used if the gas stream contains
liquid droplets since it will produce erroneously high results.
A schematic of the sampling apparatus used in this reference method is shown in Figure
5-13. In addition to this equipment, the following field equipment and supplies are
required:
1. Balance to measure within 1 gram, and
2. Thermocouple and potentiometer or equivalent.
Commercial units are available at a cost of approximately $3,000. Total cost of equipment
for moisture determination is approximately $4,000.
Method 4 also provides an alternative procedure, which is an approximate method for
determining moisture content of a gas stream. Figure 5-14 shows a schematic of the
sampling apparatus used in the approximate method. The probe is placed in the stack, and a
sample of approximately 30 liters is pulled through the sampling apparatus. As the gas
passes through the sampling apparatus, a filter collects the particulates, the moisture is
removed, and the sampling rate is measured. The amount of moisture removed is measured
and the approximate moisture content is calculated. This approximate method should be
used only to estimate moisture content.
If the gas stream contains liquid droplets, the following method is used. Determine the stack
gas temperature at several designated points in the stack. The moisture content can then be
determined by assuming that the gas stream is saturated and by using a psychrometric chart
or saturation vapor pressure tables.
5.4.4 Particulates
Procedures for taking a participate source test are more detailed than those used in sampling
gases. Because particulates exhibit inertia! effects and are not uniformly distributed within a
stack, sampling to obtain a representative sample is more complex than for gaseous
5-28
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1-9 CM (0.75 IN.} PROBE
PITOTTUBE^ i—* * _
FILTER
{EITHER IN STACK
OR OUT OF STACK)
REVERSE-TYPE
PITOTTUBE
f
STACK
WALL
CONDENSER-ICE BATH
SYSTEM INCLUDING
SILICA GEL TUBE
AIR-TIGHT
PUMP
FIGURE 5-13
MOISTURE SAMPLE TRAIN
SILICA GELTUBE
RATE METER
HEATED PROBE
FILTER
(GLASS WOOL)
MIDGET IMPINGERS
PUMP
FIGURE 5-14
APPROXIMATE MOISTURE SAMPLE TRAIN
pollutants. EPA Method 5 (as shown in Figure 5-15) is the most widely used procedure for
determination of participate emissions from a stationary source. In-stack sampling guidelines
are presented in EPA Method 17.
5-29
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5-30
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According to Method 5 (except as applied to fossil-fuel-fired steam generators), a partieulate
is defined as any material collectible at 250°F on a filtering medium. The sampling
apparatus used in Method 5 is designed to catch partieulate matter at this specified
temperature. Most states accept Method 5, even though they define particulate differently.
Ihe sampling apparatus, however, may have to be modified to conform with the state's
definition of particulate. For example, a state may define particulate as any material
collectible at stack conditions, a definition that would allow the filt™ media to be
located in the stack.
In performing a particulate source test, samples are taken at several designated sampling
points in the stack, which represent equal areas. At each sampling point, the velocity
temperature, molecular weight, and static pressure of the particulate-laden gas stream are
measured. The sampling probe is placed at the first sampling point, and the sampling
apparatus adjusted to take a sample at the conditions measured at this point. The sampling
probe is then moved to the next point, and the process is repeated continuously until a
sample has been taken from each designated sampling point. To achieve valid results in a
particulate source test, the sample must be taken under the same conditions at each
sampling point in the stack. This is commonly referred to as isokinetic sampling.
Measurement of stack conditions allows adjustment of the sampling rate to meet this
requirement.
As the gas stream proceeds through the sampling apparatus, the particulate matter is trapped
on a filter, the moisture is removed, and the volume of the sample is measured. Upon
completion of sampling, the collected material is recovered and sent to a laboratory for a
gravimetric determination or analysis.
The time required for collection of a particulate sample depends on the number of sampling
points required, the sampling time per point, and the sample volume required. A minimum
sampling time of 2 minutes per point is recommended. Generally the sampling time is at
least 1 hour but less than 4 hours. Three particulate samples per source are required.
Commercial sampling units are available at a cost of approximately $3,500. Following is a
list of the additional equipment required for a particulate source test and analysis:
Sampling equipment and supplies
1. Orsat analyzer or equivalent,
2. Thermocouple and potentiometer,
3. Brushes to clean probe,
4. Glass wash bottles (two),
5. Glass sample storage containers (500-ml),
6. Petri dishes (glass or polyethylene),
7. Graduated cylinder,
Plastic storage containers,
8.
9. Funnel and rubber policeman,
5-31
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10. Filters (glass fiber)
11. Silica gel,
12. Crushed ice,
13. Stopcock grease, and
14. Acetone (reagent grade).
Sample analysis equipment and supplies
1.
2.
3.
4.
5.
6.
7.
8.
Glass weighing dishes,
Desiccator,
Analytical balance (to measure within 0.1 mg),
Balance (to measure within 0.5 g),
Beakers (250-ml),
Hygrometer,
Temperature gauge, and
Desiccant (anhydrous calcium sulfate, indicating type).
probe is required; this will add to the overall cost. Total eost of equipment for a complete
particulate stack test is approximately $10,000.
Different methods of sampling for peculates are based on
matter. The sampling apparatus is modified to coUect the P
collection at a relatively lower temperature generally ylelds h^her values.
5.4.5 Sulfur Dioxide
e, EPA Method 6 is the reference method for
(S02 ) from all stationary sources except sulfunc acid plants.
.
of sulfur
in stack gas velocity.
As the 2as zoes through the sampling apparatus, the sulfuric acid mist and sulfur trioxide are
5-32
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mist and sulfur trioxide are discarded, and the collected material containing the S09 is
recovered for analysis at the laboratory. The concentration of S02 in the sample is
determined by a titration method.
For determination of the total mass emission rate of S02, the moisture content and the
volumetric flow rate of the exhaust gas stream must be measured.
For Method 6, the minimum sampling time is 20 minutes per sample and two separate
samples consWute a run. Three runs are required, resulting in six separate samples. An
interval of 30 minutes is required between each sample. Longer sampling times may be
required if a larger sample is needed.
Stack concentrations of 50 to 10,000 parts per million of sulfur dioxide can be determined
with this method. The minimum detectable limit has been determined to be 3.4 milligrams
of S02 per cubic meter of gas (2.1 x 10-7 pound of S02 per cubic foot of gas).
Collaborative tests have shown that an experienced test team using quality controls can
conduct a source test for sulfur dioxide with accuracy within ±4 percent
Figure 5-16 is a schematic of an assembled sulfur dioxide sampling apparatus. Commercial
units are available at a cost of approximately $1,700. In addition to this apparatus, the
toiiowing equipment and supplies are required:
Sampling equipment and supplies
1. Glass wool (borosilicate or quartz),
2. Stopcock grease,
3. Vacuum gauge,
o D 7
4. Wash bottles (polyethylene or glass),
5. Storage bottles (polyethylene),
6. Thermocouple and potentiometer,
7. Pipettes (one each: 5-ml, 20-ml, and 25 ml),
Volumetric flasks (100-ml and 1,000-ml),
Burettes (5-mI and 50-ml),
Erlenmeyer flask (250-mI),
Dropping bottle (125-ml), and
8.
9.
10.
11.
12. Graduated cylinder.
Sampling analysis supplies
1.
Deionized, distilled water,
2. Isopropanol (80 percent),
3. Hydrogen peroxide (3 percent),
Thorin indicator (l-(o-arsenophenylazo)-2-napthol-3,6-disulfonic acid, disodium
salt, or equivalent),
Barium perchlorate solution (0.01 N), and
Sulfuric acid standard (0.01 N).
4.
5.
6.
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LU
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Because of breakage it is advisable to provide spare sets of all glassware. Total cost of the
equipment for a source test for sulfur dioxide is approximately $3,000.
Other sampling methods utilize different chemical solutions, such as a sodium hydroxide
solution, to trap the sulfur dioxide; a different analytical procedure is required. Also EPA
Method 8 may be used as an alternative method for determining S02 emissions from
stationary sources.
Some states specify a sampling method that collects sulfuric acid, sulfur trioxide, and sulfur
dioxide. The analysis then gives total sulfur oxides. This method usually yields values only
about 1 to 5 percent higher than those obtained with Method 6 in which the sulfur trioxide
and sulfuric acid are discarded.
Plant operators should be aware that with the use of Method 6 for sulfur dioxide and
application of the F factor to obtain values in pounds of sulfur dioxide per million BTU of
heat input, it is critical that an accurate oxygen measurement be made at the same sample
point and at the same time that the sulfur dioxide sample is obtained.
Although a technician could learn to sample for sulfur dioxide by reading manuals, it is
advisable that testing personnel take a formal training course.
5.4.6 Nitrogen Oxides (NOX)
EPA Method 7 is the reference method for determining emissions of nitrogen oxides from
stationary sources. Sampling for NOX by this method is relatively simple with the proper
equipment.
A sampling probe is placed at any location in the stack, and a grab sample is collected in an
evacuated flask. This flask contains a solution of sulfuric acid and hydrogen peroxide, which
reacts with the NOX. The volume and moisture content of the exhaust gas stream must be
determined for calculation of the total mass emission rate. The sample is sent to a
laboratory where the concentration of nitrogen oxides, except nitrous oxide, is determined
colorimetrically.
Each grab sample is obtained fairly rapidly (15-30 seconds), and four grab samples
constitute one run. A total of 12 grab samples is required for a complete series of three runs.
An interval of 15 minutes between each grab sample is required. The range of this method
has been determined to be 2 to 400 milligrams NOX (as N02) per dry standard cubic meter
(without dilution). Collaborative tests have shown that an experienced test team can
conduct a source test for nitrogen oxides with accuracy within ±6.6 percent.
Figure 5-17 shows a schematic of the sampling apparatus for an NOX source test.
Commercial units are available at a cost of approximately $1,200. Glassware needed to
conform to EPA Method 7 is available from several glass manufacturers. In addition to the
apparatus as shown, the following equipment is required:
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Equipment and supplies
1. Heating tape capable of maintaining 250°F in the probe,
2. Type-Spitottube,
3. Stopcock grease,
4. Inclined manometer or equivalent,
5. Connecting tubes for pitot to manometer,
6. Sling-psychrometer,
7. Glass wash bottle,
8. Steam bath,
9- Beakers (250-ml, one for each sample and standard (blank)),
10. Volumetric pipettes (1-, 2-, and 10-ml),
11. Volumetric flask (100-ml, one for each sample and 1,000-ml for the standard
blank),
12. Spectrophotometer to measure absorbance at 420 nm,
13. Graduated cylinder (100-ml with 1.0-ml divisions), and
14. Analytical balance to measure to 0.1 mg.
Reagents
1. Concentrated, reagent-grade sulfuric acid,
2. Distilled water,
3. Hydrogen peroxide,
4. Sodium hydroxide,
5. Red litmus paper,
6. Deionized, distilled water,
7. Fuming sulfuric acid (15 to 18 percent by weight),
8. Free sulfur trioxide,
9. Phenol (white solid reagent grade), and
10. Potassium nitrate.
Total cost of the equipment for conducting a source test for NOX emissions is
approximately $2,500.
An accurate oxygen measurement must be made at the same sample point and at the same
time the sample is obtained when the F factor calculation is used to determine values in
pounds of NOX per million BTU of heat input. NOX sampling requires less skill, training,
and time than most sampling procedures.
5.4.7 Carbon Monoxide (CO)
EPA Method 10 is the reference method for determining emissions of carbon monoxide
from stationary sources. An integrated or a continuous gas sample may be required,
depending on operating conditions. Both methods are discussed.
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When the operating conditions are uniform and steady (no fluctuations in flow rate or
concentration of CO in the gas stream), the continuous sampling method can be used. A
sampling probe is placed in the stack at any location, preferably near the center. The sample
can be extracted at any convenient and constant sampling rate. As the gas stream passes
through the sampling apparatus, any moisture or carbon dioxide in the sample gas stream is
removed. The CO concentration is then measured by a nondispersive infrared analyzer,
which gives direct readouts of CO concentrations.
Figure 5-18 is a schematic of an assembled sampling apparatus used to determine CO
concentrations by the continuous sampling method.
An integrated sampling method is required when operation of the source is uniform but
unsteady (fluctuations in flow rate can occur). For an integrated sample, the sampling probe
is located at any point near the center of the stack, and the sampling rate is adjusted
proportionately to the stack gas velocity. As the stack gas passes through the sampling
apparatus, moisture is removed and the sample gas is collected in a flexible bag. Analysis of
the sample is then performed in a laboratory with a nondispersive infrared analyzer. Any
carbon dioxide or residual moisture in the sample must be removed before the sample is
passed through the nondispersive infrared analyzer.
Figure 5-19 is a schematic of an assembled apparatus for integrated sampling of CO. Figure
5-20 also shows the analytical equipment.
AIR-COOLED CONDENSER
TO ANALYZER
PROBE
\
FILTER {GLASS WOOL)
FIGURE 5-18
CONTINUOUS SAMPLE TRAIN FOR CO
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FILTER
(GLASS WOOL)
RATE METER
\
VALVE
AIR-COOLED
CONDENSER
VALVE
QUICK DISCONNECT
BAG
FIGURE 5-19
INTEGRATED SAMPLING TRAIN FOR CO
NEEDLE
VALVE |f=
SAMPLE
RATE METER
NON-DISPERSIVE
INFRARED ANALYZER
(NDIR)
ZERO SPAN
CALIBRATION GASES
FIGURE 5-20
SAMPLING APPARATUS FOR CO
A 1-hour sampling period is generally required for this method. Sampling periods are
specified by the applicable standard, e.g., standards for petroleum refineries require
sampling for 1 hour or more.
For Method 10, the minimum detectable concentration of CO has been determined to be 20
ppm in a range of 1 to 1,000 ppm. Collaborative tests have shown that this method can be
executed with accuracies within ±101 milligrams of CO per cubic meter.
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Sampling equipment and supplies
1. Pitot tube (type S),
2. Inclined manometer or equivalent, and
3. Tubing to connect pitot tube to manometer.
Analytical equipment and supplies
CaUbration gases: N2 with a known CO concentration, prepurified grade of N3
and two adtoonal N2 with CO concentrations corresponding to 30 and 60
percent of span of the nondispersive infrared analyzer.
used " the field should be provided- Total cost of the
An Orsat analyzer or detector tubes may be used to determine the presence of carbon
rrtabt STo r r hod%hrever' are not acceptabie *™™ ^ ">™
detectable bmrt of the Orsat analyzer ls 1,000 ppm and the detector tubes are not accurate
enough.
Collection of CO for nondispersive infrared analysis presents no special problems and
requires no great degree of training. However, operaLi of the analyzer VoeXuTre
training and experience. * require
5.4.8 Fluorides
Two EPA reference methods, Method 13A and Method 13B, can be used to determine total
fluoride emissions from a stationary source. The difference in the two methods is the
analytical procedure for determining total fluorides. Fluorides can oecur as peculates or as
gaseous fluorides; the particulates are captured on a filter and the gaseous fluorides are
captured in a chemical reaction with water.
Meod fo ure o-n
Method 5 for particulates. As the gas stream passes through the sampling apparatus the
gaseous fluorides are removed by a chemical reaction with water, the p'artLFate fluorides
th , T \ ; and l,he Sample VOlU*e " meaSUreA The SamPle is — ed and
2 II analyS1S- PrOCedures of M«*ods 13A and 13B are complex and
Method n^,™ " a" eXPerienCed chemfat- Method 13A is a colorimetric method, and
Method 13B utilizes a specific ion electrode.
, f°r b°th methods' SamPH"g Periods are
by the applicable standard, e.g., standards applicable to triple superphosphate
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plants require sampling of 1 hour or more. The standard may also specify a minimum
sample volume which will dictate the minimum length of the sampling period.
The determination range of Method ISA is 0 to 1.4 micrograms of fluoride per milliliter; the
range of Method 13B is 0.2 to 2,000 micrograms of fluoride per milliliter.
Collaborative tests are currently being performed and evaluated. Preliminary results indicate
that the field sampling phase of Methods 13A and 13B is generally reliable.
Figure 5-21 is a schematic of an assembled fluoride sampling apparatus used in Methods 13A
and 13B. Commercial units are available at a cost of approximately $3,500. In addition to
this apparatus, the following equipment/supplies are required:
Field equipment and supplies
1. Filter heating system capable of heating the filter to ~250°F,
2. Brushes to clean probe,
3. Glass wash bottles (two),
sample storage bottles (wide-mouth, high-density polyethylene, 1-liter),
4. Plastic storage containers,
5. Graduated cylinder (250-ml), and
6. Funnel and rubber policeman.
Sampling supplies
1. Filters (Whatman No. 1 or equivalent),
2. Silica gel (indicating type),
3. Distilled water,
4. Crushed ice, and
5. Stopcock grease.
Sample analysis for Method 13A or 13B
1. Distillation apparatus shown in Figure 5-22,
2. Hot plate (capable of heating to 500° C),
3. Electric muffle furnace (capable of heating to 600° C),
4. Crucibles (nickel, 75- to 100-ml capacity),
5. Beaker (1,500-ml),
6. Volumetric flask (50-ml),
7. Erlenmeyer flask or plastic bottle (500-ml),
8. Constant-temperature bath (capable of maintaining a constant temperature of
±1°C in room-temperature range),
9. Balance (300-g capacity to measure ±0.5 g),
10. Calcium oxide (certified grade containing 0.005 percent calcium),
11. Phenolphthalein indicator (0.1 percent in 1:1 ethanol-water mixture),
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1.9cm 10.75 IN-)
TEMPERATURE
PROBE
1.9cm (0.75 IN.)
PITQt TUBE
OPTIONAL
FILTER HOLDER
LOCATION
THERMOMETER
FILTER HOLDER VALVE
REVERSE TYPE
PITOTTUBE
ORIFICE MANOMETER
AIRTIGHT
PUMP
FIGURE 5-21
SAMPLING APPARATUS FOR FLUORIDE
CONNECTING TUBE
12-mm ID
124/40
THERMOMETER TIP MUST EXTEND BELOW
THE LIQUID LEVEL
HEATING
MANTLE
T 24/40
CONDENSER
250ml
VOLUMETRIC
FLASK
FIGURE 5-22
DISTILLATION APPARATUS
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12. Sodium hydroxide (pellets, ACS reagent grade or equivalent),
13. Sulfuric acid (concentrated, ACS reagent grade or equivalent),
14. Filters (Whatman No. 541 or equivalent), and
15. Sodium fluoride (reagent grade).
Additional sample analysis equipment or supplies for Method ISA only
1. Spectrophotometer (to measure absorbance at 570 nm, providing at least a 1-cm
light path),
2. Spectrophotometer cells (1-cm),
3. Silver sulfate (ACS reagent grade or equivalent),
4. Hydrochloric acid (concentrated, ACS reagent grade or equivalent),
5. SPADNS solution, and
6. Zirconyl chloride octahydrate.
Additional sample analysis equipment or supplies for Method 13B only
1. Fluoride ion activity sensing electrode,
2. Reference electrode (single junction, sleeve type),
3. Electrometer (a pH meter with millivolt scale capable of ±0.1 mv resolution, or a
specific ion meter made specifically for specific ion measurements),
4. Magnetic stirrer and TFE-fluorocarbon-coated stripping bars,
5. Glacial acetic acid,
6. Sodium chloride, and
7. Cyclohexylene dinitrilo tetraacetic acid.
It is advisable to provide a spare set of the glassware used in field sampling. If the source to
be tested has a large stack (greater than 5 feet in diameter), a longer sampling probe is
required; this will add to the cost. Total cost of equipment for a complete fluoride stack test
is approximately $10,000.
Other sampling methods for fluorides use chemical solutions to remove gaseous fluorides
from the sample and require different analytical procedures. As an example, the Los
Angeles County method utilizes sodium hydroxide to remove the fluorides. The lower
detectable limit for this method is approximately 16 micrograms of fluoride in 1.7 cubic
meters of sample gas.
Fluoride sampling requires skilled and trained sampling personnel. The analytical
procedures require only normal laboratory skills.
5.4.9 Hydrocarbons
The U.S. EPA has not published a reference source testing method for hydrocarbons.
Each state or local control agency that regulates emissions of hydrocarbons selects a source
test method. If source testing for hydrocarbons is required, the control agency should
specify the sampling and analytical method.
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Hydrocarbon emissions may contain both condensible and noricondensible hydrocarbons.
Noncondensible hydrocarbons are simply gases; condensible hydrocarbons can occur as
gases at certain temperatures and as liquids or even solids at lower temperatures. The
sampling method must be designed for the type of data that is needed, e.g., total
hydrocarbons (condensible + noncondensible), coudensible hydrocarbons only, or noncon-
densible hydrocarbons only, A sampling method for each is described briefly. Some
hydrocarbons are photochemically reactive and some are not reactive. No hydrocarbon
standards are usually specified for nonreactive hydrocarbons.
1. Continuous method for determination of total hydrocarbons. A sample probe is
located at any point in the stack, and the stack gas is drawn through a heated
sample line to a gas chromatograph with a flame ionization detector (GC-FID).
Concentrations are read from a potentiometric recorder.
2. Grab sampling for determination of noncondensible hydrocarbons only. Grab
samples of stack gas are collected with evacuated dry flasks in the same manner
as described for nitrogen oxides. A stainless steel sampling probe and evacuated
flask should be used instead of glass in the sampling apparatus. Samples ma\
also be collected in the same manner as the CO-integrated bag sample. Analyses
may be performed with an infrared spectrophotometer or a gas chromatograph.
3. Adsorption techniques for sampling of condensible h) drocarbons only. A
sample is obtained in the same manner as described previously for sulfur
dioxide. Chemical solutions that will collect the hydrocarbons are placed in the
sampling apparatus. Analysis of the sample can be made with a gas
chromatograph. Depending on the chemical solutions, condensible hydrocarbons
with boiling points 320°F and greater can be sampled.
4. Adsorption technique for sampling of specific hydrocarbons. A sample may be
adsorbed on some collection medium such as silica gel, activated charcoal, or
packing. The adsorption medium and sample are brought to the laboratory for
analysis. The hydrocarbons are then desorbed into the analyzer. This method is
relatively more accurate and reliable when the types of hydrocarbons are
known and standard solutions of the anticipated hydrocarbon can be used to
calibrate the analytical instruments. When the specific hydrocarbon compounds
are not known, the analysis is usually less representative and determination of
exact compounds is much more costly.
Selection of the sampling method is critical in sampling for hydrocarbons. Very
significant errors, involving both positive and negative bias, can occur. Knowledge of the
specific types of hydrocarbons in the exhaust gases will aid in selecting the appropriate
sampling method. Total costs, required equipment, sampling times, and detection limits
depend on the specific method used.
544
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5.5 References
1. Journal of the Air Pollution Control Association, 26(7):713-724, July 1976.
2. Schulze. R.H. The Economics of Environmental Quality Measurement, Journal of
the Air Pollution Control Association, 23(8):671-675; August 1973.
3. Gerstle, R.W., and DeWees, W., Safety Aspects of Emission Testing, Stack Sampling
News, March 1976.
5-45
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CHAPTER 6
AMBIENT AIR MONITORING/CONTINUOUS
STACK MONITORING
6.1 Introduction
This chapter deals with monitoring of the ambient air around industrial plants and with
continuous monitoring as it applies to point sources of pollution. It is intended as a guide
for industrial planners who may be relatively unfamiliar with the purposes of monitoring
and the uses of monitoring data.
G
The basic concept of ambient air monitoring, as in emission testing, is measurement of a
representative sample. In emission testing, the cross-sectional area of the gas stream is
fixed, and results are generally representative of the total volume of stack effluent. In
ambient air monitoring, however, the measurements are indicative of only a small portion
of the atmosphere and cannot be assumed to be representative of the total atmosphere.
In theory, the pollutant concentrations measured in ambient air monitoring could be
entirely different if the monitoring instruments were located a short distance away. To
obtain a truly representative sample of ambient air, one would have to place man)
monitors in a given area, but such a svstem would be economically unfeasible.
A company may conduct ambient air monitoring for several reasons. Some state
regulations require that industries monitor for particular pollutants, such as fluorides, and
some states permit ambient monitoring in lieu of complying with a specified emission
limitation. Some regulations include provisions that limit the concentration of a pollutant
at the property line, which must be monitored. Some companies perform air monitoring
simply to measure the impact of a plant's emissions on local air qualit). Ambient
monitoring also can provide information that is useful in determining the normal or
background level of air quality, in following air quality trends, and in providing guidance
for emergency control procedures during air pollution episodes. Regardless of the reason,
ambient monitoring is usually performed with respect to a particular polluting source or
group of sources to provide measurements of a specific pollutant.
Under the 1970 Amendments to the Clean Air Act, EPA in December 1974 issued final
regulations preventing significant deterioration of air quality in areas cleaner than the na-
tional ambient air quality standards. These rules went into effect nationwide in June 1975.
On August 7, 1977, the new Amendments to the Act generally toughened and expanded the
scope of this program.
Basically, the new Amendments require each state to classify clean air areas as either
Class I (where air quality has to remain virtually unchanged); Class II (where moderate in-
dustrial growth would be allowed); and Class III (where more intensive industrial activity
would be permitted). The air quality in each of the three types of areas will be allowed to
6-1
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deteriorate only be specific amounts fixed by the Amendments. In no case, however, will
air quality by allowed to exceed federal health standards.
The final rulemaking implements provisions of the Amendments intended by Congress to be
immediately effective as of the August 7, 1977 enactment date. Only pollution sources
which commenced construction before August 7 are exempt from the immediate changes.
Among these changes is the immediate application of the new ambient air increments men-
tioned above. These increments are more stringent than those allowed under EPA's old
significant deterioration regulations.
These final rules also immediately designate certain areas as Class I, and forbid states to re-
designate them into either of the other two classes. They are: (1) international parks,
(2) national wilderness areas exceeding 5,000 acres, (3) national memorial parks exceeding
5,000 acres, and (4) national parks exceeding 6,000 acres.
With only a few exceptions, all areas of the United States have been placed in Class II, but
may apply for classification as Class I or Class HI. In areas designated Class I or Class II,
increases in pollutant concentrations will be permitted as shown in Table 6-1.
TABLE 6-1
ALLOWABLE DETERIORATION IN CLASSES I AND II
(Mg/m3)
Pollutant
Class I
Class II
Particulate
Annual geometric mean
24-hour maximum
Sulfur dioxide
Annual arithmetic mean
24-hour maximum
3-hour maximum
5
10
2
5
25
10
30
15
100
700
Under the nondegradation scheme, only these incremental amounts may be added to the
existing background air quality. Once the increment has been added to the background
pollutant concentration, no further industrial or other expansion may take place in this
area. Allocations of the allowable increments will be on a first-corne/flrst-served basis.
6-2
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Review of pollution sources before they are built has been proposed to insure they do not
violate the new deterioration increments in actual operation. As required in Section 165 of
the Amendments, EPA's proposal will require a preconstruction permit for any of the 28
major pollution source categories named in the Amendments that have potential air pollu-
tion emissions of 100 tons per year, or for any other pollution sources that have potential
emissions of 250 tons per year. EPA's current regulations cover only 19 source categories
(including power plants, steel mills, and other stationary sources).
6.2 Selection of Sites for Ambient Air Monitoring
The number of sites to be incorporated into an ambient air monitoring network will
depend largely on the amount of data required to meet the objectives. At a small source
where one wind direction usually predominates, monitors are usually operated at two
sites: one to monitor the effects of the source, and the other to provide upwind or
background concentrations. Where wind directions are variable, or other similar emission
sources are operating nearby, additional samplers will be required to identify the
concentrations that are attributable to a specific source.
Because ambient air monitoring deals with an open, unconfined volume of air rather than
with a volume that is enclosed in a stack, there are no detailed specifications for location
of ambient air monitors. Other than such obvious considerations as accessibility,
availability of electrical power, and relationship to possible interfering pollutant sources,
the principle factors in site selection are meteorology and topography.
6.2.1 Meteorology
Because wind movement accounts for dispersion of the pollutants from the source, it is
important to obtain detailed information about local meteorology, and in particular
about the local wind patterns. Following are possible sources of meteorological data:
1. Local offices of the U.S. Weather Service
2, Local airports,
3. Stations of the State Fire Weather Service,
4. Military installations,
5. Public utilities and industrial complexes,
6. High schools, colleges, universities, and
7. National Weather Records Center (Ashville, N.C.).
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The National Weather Records Center can provide by far the most comprehensive records
of meteorological data. In addition to providing current data, the Center will also
prepare, on request, a summary of all pertinent data available for a given geographical
area. Queries and requests may be addressed to:
Director, National Climate Center
National Oceanographic and Atmospheric Administration
Federal Building
Ashville, North Carolina 28801
At some facilities, none of the seven sources may be available or they may not be
applicable. In areas which are topographically much different from the source of
meteorological data that have been collected by other groups, it may be necessary, in fact,
to monitor the local micro meteorology and conduct upper air studies in varying degrees
of intensity either to verify that the published sources accurately predict the local wind
patterns or to verify the differences.
The controlling factor in site selection is movement of the winds. With some knowledge
of the predominant wind direction in an area, the path of pollutants from the emission
source to the point of ground-level impact can be predicted roughly and the most
suitable location for an air monitoring site can be determined. The most convenient
method of performing this analysis is by the use of a wind rose of the type shown in
Figure 61.
An annual wind rose of this type can be used for site anal) sis. The lengths of the lines
for each of the 16 wind directions represent the percentage of the time that the wind is
blowing from that direction. The percentage value is shown at the end of each line, hi
this example, the wind comes from the south 24 percent of the time; since this is the
highest single percentage, south can be considered the predominant direction. The second
most frequent direction is west-northwest, with a frequenc) of 12.9 percent. If wind
direction is the only criterion for site planning, the most logical location for an air
monitor in this example is due north of the facility, where the monitor would experience
the maximum impact from the source. The second, or background, station would be
placed west-northwest of the facility because the wind blows toward this direction the
least during the year, and the station would receive impact from the east-southeast only
1.1 percent of the time.
When more precise information is required for site location, computerized atmospheric
dispersion models can yield such information. Several models in current use predict for
a given situation such things as ground-level concentrations at various points around a
source, location of the maximum concentration of pollutants from a source, the
combined effects of several sources, and the concentration for any time period from 1
hour to 1 year, at an\ ground-level receptor, resulting from any source or combination of
sources.
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12.9%
W 8.9%
5.3%
9.8% CALM
24.0%
FIGURE 6-1
EXAMPLE OF ANNUAL WIND ROSE
6-5
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The basis of these models is the Gaussian plume assumption, which says that every
plume, regardless of the source, will take on a characteristic shape depending upon the
stack parameters and meteorological conditions. This concept is illustrated in Figure 6-2.
The Gaussian concept says that pollutant concentrations in the horizontal and vertical
directions, relative to the plume centerline (x-axis in Figure 6-2) assume a normal or
Gaussian distribution (1).
Because it is desirable to place an air monitor in the area most likely to receive the
highest ground-level concentration of pollutants, most modeling efforts are designed to
predict where this maximum concentration will occur. Although these models are not
totally accurate, they provide valuable guidelines in selection of monitoring sites.
-y,z)
y,0)
FIGURE 6-2
COORDINATE SYSTEM SHOWING PLUME DISPERSION (1)
6-6
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6.2.2 Topography
The transport of air pollution is also affected by topographical features. Under conditions
of irregular topography, application of the standard Gaussian dispersion equation is often
invalid. Obstructions such as hills, mountains, and river valleys have a profound effect on
the dispersive capability of the atmosphere. Because none of the current dispersion
models do not adequately account for these effects, a certain amount of intuitive judg-
ment is required in choosing an air monitoring site in complex terrain. For example, slopes
and valleys are generally poor sites for air monitors because pollutants are generally not well
dispersed and the measured concentrations would not be representative. Monitors placed
on shorelines usually do not give meaningful results because local circulation patterns
(lake and sea breezes) are created by bodies of water (2). Hillsides and mountains cause
turbulence and as a result could bias site readings. A manmade obstruction, such as a
building, also tends to cause downwash on the leeward side of the building (3). When
locating a monitor near a source of ground dust, it is advisable to elevate the equipment
above the level of maximum ground turbulence or simply to place it as far as possible
from the source. Again, personal judgment is always required, based on a visual
inspection of the site.
6.3 Equipment for Ambient Air Monitoring
Most industries organizing an ambient air monitoring program will need to measure
concentrations of sulfur dioxide and particulates in a manner that corresponds as far as
possible with the methods and averaging times specified in local, state, and federal
regulations.
Particulate monitoring is usually done with a high-volume air sampler, a vacuum-type
device that provides average concentrations over a 24-hour period. Monitoring for gaseous
pollutants can be done with static samplers that give averages over a 30-day period and
with d>namic samplers that give 24-hour averages. A typical industrial network would
consist of the following:
1. One or several high-volume air samplers;
2. Special monitoring equipment, e.g., for measuring fluorides, corrosion studies,
or vegetation sampling; and
3. Several dynamic S02 and/or one continuous S02 monitor.
Almost all ambient air monitoring programs are accompanied b> meteorological
monitoring of wind direction and velocity; where it is appropriate and economical!)
feasible, temperature-sensing devices can be operated at various elevations to indicate
stability of the air mass.
6-7
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6.3.1 Participate Monitoring - Total Suspended Participates (TSP)
The high-volume sampler, shown in Figure 6-3, has gained wide acceptance in the
measurement of concentrations of suspended particulates. This sampler is a rugged,
reasonably inexpensive device with good filtering efficiency that can be operated for long
periods with minimum maintenance. It has been used in the National Air Sampling
Network (NASN) since 1953.
The NASN periodically reports air quality data for all parts of the country including
urban and nonurban areas. The nonurban data provide an estimate of the background
concentrations of suspended particulates. Long-term averages of NASN data from urban
areas can be used for estimating the relative degree of particulate pollution in the air of
various communities; the data may also be used for correlation of air quality with
population, geographic location, and extent of industrialization. When used in this way,
NASN data can be a valuable aid in estimating the degree of pollution in the area being
studied.
A high-volume sampler uses a vacuum-cleaner type of motor and blower to draw large
volumes of air through a filter on which particulates are collected for measurement and
analysis.
A high-volume sampler will handle 30 to 70 cubic feet of air per minute, or 50,000 to
75,000 cubic feet in a typical 24-hour period. The rate of flow varies somewhat,
depending on the make of sampler and the type of filter. Ordinarily, the rate of flow
falls off considerably as particulate matter collects and builds up on the filter. This is of
twofold concern. First, the high-speed motor in the sampler usually requires 25 to 30
cfm of air for proper cooling; if the sampler is operated for extended periods with lower
airflow, the motor may overheat and fail. Second, the total volume of air sampled must
be estimated with fair accuracy to allow accurate calculation of particulate concentration.
The total airflow through the sampler is determined from rotameter readings at the
beginning and end of the operating period. This procedure assumes that the decrease in
flow rate is linear with time and that the average rate is representative of the entire
sampling period. Figure 6-4 illustrates a typical data sheet.
The high-volume air sampler should provide the following information:
1. Daily 24-hour readings for TSP,
2. Maximum 24-hour values for TSP, and
3. Annual geometric mean value for TSP.
6-8
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FIGURE 6-3
HIGH-VOLUME AIR SAMPLER
Courtesy: General Metal Works, Inc.,
Cleves, Ohio
6-9
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HI-VOLDATA RECORD
HI-VOLDATA RECORD
(Continued)
STATION LOCATION
CITY & STATE _
SITE ADDRESS
PROJECT
.SITE NO..
INSTRUMENT LAST CALIBRATED.
SAMPLER IDENTIFICATION NO.
FILTER NUMBER
START SAMPLING
mo day yr hr min CFM
STOP SAMPLING.
WIND:.
.calm,.
VISIBILITY:
SKY: clear,.
HUMIDITY:
.clear,.
mo day yr
— light, gusty
hr min CFM
.hazy
scattered, overcast
.dry, moderate, h um id
TEMPERATURE °F: <20 20-40 41-80 61-80 >80
— Faceplate must be hand tight
- Flow rate must be ±10% of established flow rate
— Faceplate gasket must be in good condition
- Rotameter must be free of foreign material
- Rotameter operation must be stable
- Sampler motor brushes must be changed every 400 hrs of operation
Sample was collected in accordance with
the above guidelines
signature
REMARKS.
Net Paniculate Wgt._
Air Volume
Paniculate Concentration.
Total Sampling Time
hours
REMARKS.
FIGURE 6-4
FIELD SHEET FOR HIGH-VOLUME AIR SAMPLER
.grams
.m-
6.3.2 Monitoring for SO2
Sulfur dioxide (SO2) may be monitored by a variety of techniques:
Type monitor Monitoring techniques Average time
Static Sulfation plate 30 days
Dynamic Bubbler train 24 hours
Continuous
Various instrumental
techniques
Variable
6-10
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The static sampling data can be correlated with the dynamic and/or continuous
monitoring data. The correlation relationships, however, vary with meteorological
conditions, and data from one location may not be applicable to another location. This
technique has, to a greater degree, been replaced by the use of computer modeling
techniques that are beyond the scope of this document. The static sampler (sulfation
plate, Figure 6-5) is made by coating the inside of a 4.8-cm-diameter, plastic petri dish
with lead dioxide paste. To expose a sulfation plate, the lid is removed and the plate is
placed in a bracket that will secure the plate in an upside-down position. The petri dish
serves as the shelter, shipping container, and lead dioxide support.
8 mm
48 mm I.D.
-PLASTIC PETRIE DISH
LEAD DIOXIDE PASTE
REMOVABLE PLASTIC COVER
-<)—dD-
SULFATION PLATE HOLDER
1/8"PLEXIGLAS
FIGURE 6-5
SULFATION PLATE AND HOLDER
6-11
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The dynamic and continuous sampling units usually consist of a system incorporating
several components, as shown in Figure 6-6. The system for a dynamic gaseous collection
unit consists of:
1. Inlet section,
2. Absorption section,
3. Flow regulation device, and
4. Prime mover (usually a pump).
Typical of the absorption devices used in a dynamic sampling train are the midget and
Greenberg-Smith impingers. Other devices available are listed in Table 6-2.
The equipment for a continuous monitoring system for gases might consist of:
1. Inlet section,
2. Gas pretreatment section,
3. Detector,
4. Pho to multiplier,
5. Spectrometer, and
6. Readout device.
Pretreatment of the gas stream, depending upon the conditions and gas to be monitored,
could include techniques for:
1. Pressure adjustment,
2. Removal of particulates (usually a filter),
3. Removal of moisture (usually a silica gel column), and
4. Temperature adjustment (usually a condenser).
Recommended manual and instrumental monitors for gaseous pollutants are listed in
Table 6-3.
6.3.3 Meteorological Monitoring
Many industries will wish to establish meteorological monitoring stations to provide data
6-12
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6-13
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for dispersion modeling, for plotting a pollution rose, for correlation with ambient air
sampling data, and for validation of complaints. As discussed earlier, most systems will
monitor wind direction and wind velocity as a minimum, with possible addition of a
temperature tower to obtain atmospheric stability information. Wind speed is measured
with an anemometer, and wind direction with a wind vane; a temperature tower is
equipped with resistance thermometers and thermocouples.
TABLE 6-2
ABSORPTION SAMPLING DEVICES
Principle of operation
Simple gas-washing
bottles. Gas flows from
unrestricted opening
into solution. Glass,
conical or cylindrical
shape.
Modified gas-washing
bottles
Large bubbler traverses
path extended by spiral
glass insert.
Impingers. designed
principally for collection
of aerosols. Used for
collection of gases.
Restricted opening.
Fritted tubes available
which allow use as
bubbler.
Smog bubbler
Devices
Standard
Drechsel
Fleming
Fritted
bubbler
Glass bead
bubbler
Fisher
Milligan
bottle
Greiner-
Friedrichs
Greenburg
Smith
Midget
Fritted
bubbler
Capacity
(ml)
125-500
125-500
100
100-500
100-500
275
100-200
500
100
10-20
Sampling
rate
(1/min)
1-.5
.1-.5
.1-.5
.1-1.5
.1-.5
.1-.5
.1-.5
.1-.5
.1-.5
1.0-4.0
efficiency
90 - 100
90 - 100
90 - 100
95 - 100
90 - 100
90 - 100
90 - 100
90 - 100
90 - 100
95 - 100
Comment
Bubblers are large.
Reduction of sampling
rate increases efficiency-
Several units in series
raises efficiency.
Similar to above
Difficult to clean
Fritted tubes available
for simple gas-washing
items above. Smaller
bubblers provide in-
creased gas-liquid
contact.
Provides for longer
gas-liquid contact;
smaller bubbles.
Similar to Fisher
Milligan
Cylindrical shape
6-14
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TABLE 6-3
RECOMMENDED SAMPLING METHODS
Pollutants
Ambient sampling
Manual procedure^
Instrumental**
Sulfur dioxide (S0?)
Nitrogen dioxide (N02)
Carbon monoxide (CO)
Photochemical oxidants
(ozone)
Pararosaniline - colorimetric
(modified West Gaeke pro-
cedure)
Sodium hydroxide-sodium
arsonite method by A.A.
Christe et al. Analyst, 519-524
(1970)
Evacuated flask or bag with
nondispersive infrared
Neutral buttered potassium
iodide
Colorimetric (modified West
Gaeke procedure)
Coulo metric
Flame photometric
Colorimetric
Coulometric
Electrochemical
Chemiluminescent
Continuous sampling, non-
dispersive infrared
Chemiluminescent - specific
Coulometric - most instru-
ments
Colorimetric - not specific
for00
*Federal Register 36: 8186 April 30, 1971 (official recommendation).
**Hochheiser, Environmental Science and Technology, Volume 5-678,1971 (not an official
recommendation).
6.4 Continuous Stack Monitoring
Continuous stack monitoring as applied in industry is not to be confused with programs
of continuous air monitoring. Continuous monitoring of ambient air is seldom conducted
by organizations other than control agencies or research groups, or in large-scale operations
such as those of the Tennessee Valley Authority. The required equipment is costly and a
high degree of technical skill is required for calibration, operation, and maintenance of the
automated sampler/analyzers. Continuous monitoring by an industry consists of monitoring
emissions at the source (stack) by means of a variety of detectors, which are described later
in this section.
The New Source Performance Standards (NSPS) require continuous monitoring of specific
pollutants by certain industries (1). At present, the number of industries required to
monitor continuously is quite small. Because continuous monitoring provides more
comprehensive emissions data than are obtained by manual source test methods, the number
of industries required to install monitors will probably continue to increase. Only those in-
6-15
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dustries affected by the NSPS as of February 1977 are discussed here. Since additional con-
tinuous monitoring may be required by state and local regulations, it is suggested that in-
dustry officials maintain contact with the local control agencies as to current and anticipat-
ed requirements.
In addition to meeting NSPS, continuous emissions monitoring can serve as a useful tool
for optimization of process and control equipment (2). Unlike manual source tests,
continuous monitoring allows the observation of real-time changes in emissions while
adjustments are made in process and control equipment. Thus the process operations can
be optimized to obtain and maintain maximum efficiency.
In many industries, product lost up the stack is profit blown away. This is true of
sulfuric acid plants and other industries. At petroluem refineries where excess particulate
emissions from the catalyst regenerator of a catalytic cracking unit may cause loss of
valuable catalyst, continuous monitoring could prevent such losses (3). Monitoring of
C02 or 02 in stack gases of a power plant can lead to improvements in combustion
efficiency (2). Monitoring also serves as an alarm system to alert plant operators when a
process malfunction occurs. Primary zinc, lead, and copper smelters can use data obtained
from properly operated continuous monitors to demonstrate compliance (1). If utilized
properly, the investment in continous stack monitors not only will aid in meeting NSPS
requirements but also will pay dividends.
Only industries required by the NSPS to continuously monitor emissions, as of February
1977, are considered in this section. Those industries and pollutants for which continuous
monitoring is now required are listed in Table 6-4. Monitoring requirements for new or
modified industries affected by NSPS are given in the Code of Federal Regulations (CFR),
Vol. 40, Part 60, Standards of Performance for New Stationary Sources. (These require-
ments were also published in the Federal Register of October 6, 1975.)
Continuous monitoring systems to meet NSPS requirements fall into two categories:
opacity monitoring for particulates, and continuous (extractive and in-stack) monitoring for
gases. Both systems are described briefly in this section; detailed information on specific
systems can be obtained from the manufacturer. Regardless of which system is used, all as-
pects from location of the sampling point to the recording of data should he considered in
detail by the purchaser before any purchase is made. Savings on the original purchase are
often lost to repeated maintenance of poorly designed and installed continuous monitoring
systems.
Industrial planners should consider continuous monitoring as a process control technique
as well as an environmental monitoring requirement. Continuous monitoring is expensive;
it requires considerable attention, on a continuous basis, to calibration/certification
procedures, operation and maintenance, and data handling. If it becomes necessary to
consider continuous stack monitoring, a systematic approach should be considered for all
aspects of the system. Such an approach is illustrated in Figure 6-7.
6-16
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Data recording, processing, presentation, and storage are all very important aspects of the
continuous monitoring program. There are many methods of data handling, as illustrated
in Figure 6-8.
6.4.1 Opacity Monitoring for Particulates
Opacity is a measure of the degree to which the emissions from a stack obscure the view
of an object in the background. Opacity readings (in percent) indicate the visibility-
obscuring properties of the total gas stream, not the particulates alone. The opacity
monitor does not provide a reading of particulate concentration (Mg/m3 or other units);
most stack monitoring that does measure particulate concentration is still done by
manual methods. Sampling trains incorporating various procedures collect a sample over
a specified period of time (e.g., a minimum of 1 to 2 hours); the total sample collected
in this time period is called an integrated sample, whose analysis yields a composite pic-
ture of the particulate concentrations during the sampling period.
Equipment for instrumental continuous monitoring of particulates has been in
development for several years. A promising commercial unit now on the market uses a
filtration beta radiation attenuation technique. This unit incorporates components for di-
TABLE 6-4
INDUSTRY-MONITORING REQUIREMENT MATRIX
Facilities required to
monitor emissions
Fossil -fuel -fired steam
generator
Nitric acid plant
Sulfuric acid plant
Petroleum refinery
Primary copper smelter
Primary lead smelter
Primary zinc smelter
Steel plants, electric arc
furnace
Ferroalloy production
facility
Opacity
X
X
X
X
X
X
X
S02
X
X
X
X
X
X
N0x
X
X
02 or
C02
X
CFR
references
60.45
60.73
60.84
60.105
60.165
60.185
60.175
60.273
60.264
6-17
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lution, filtration, detection of the attenuation of beta radiation, and recording of data.
Research and development of monitoring instrumentation is also producing other advanced
systems and new measurement techniques. In this discussion, however, we are focusing on
the requirements set forth in the NSPS for industry, and therefore on the theory and uses
of opacity monitoring instruments, which are specified in those requirements.
In manual determinations of opacity, the degree of obscurity is determined by trained
personnel who visually observe the emissions plume. In commercial opacity monitors, the
trained observers are replaced by a light source and a light detector. A beam of light
from the source is directed through the emissions to be measured and into the detector.
If the emissions do not obscure or diminish the light, then 100 percent of the light
reaches the detector and the opacity is zero. If the emissions completely obscure the light
so that none of it reaches the detector, then the opacity is 100 percent. By use of filters
that absorb known percentages of light, the monitor can be calibrated to determine
various degrees of opacity. Readings are corrected to stack exit conditions for comparison
with visually observed opacity. Opacity monitors are also referred to as transmissometers
or smoke monitors.
Commercial opacity monitors are of two types: single-ended and double-ended (Figure
6-9). Both types operate on the principal of measuring the amount of visible light being
absorbed by the emissions. On the double-ended monitor, the light source is located on
one side of the stack and the detector on the other side, opposite the source. The light
beam makes one pass through the emissions before reaching the detector. The
double-ended opacity monitor has been in use the longest and is the least expensive. It
does, however, have some inherent problems. Because the source and detector are on
opposite sides of the stack, it is difficult to maintain the fine degree of alignment that is
required for proper operation. Changes in line voltage between the source and detector will
cause changes in opacity readings. Zero and span checks are more difficult with this type of
monitor than with a single-ended system.
With the single-ended opacity system, the light source and detector are located on the
same side of the stack. A mirror or some type of reflecting device is then located on the
other side of the stack, opposite the source. A light beam from the source makes two
passes through the emissions before reaching the detector. This doubling of the light path
allows for increased sensitivity. Because both the light source and detector are on the
same side of the stack, it is a simple matter to make a relative or differential
measurement between the light source intensity and the amount of light reaching the
detectors. Problems such as voltage variations and electronic drift are cancelled out in this
type of relative measurement.
In both types of opacity monitoring systems, the optical windows require a constant
purging of clean air to prevent buildup of dust, which reduces sensitivity and induces
errors in the readings.
6-20
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Opacity monitoring systems must be capable of measuring opacities at a minimum of once
every 10 seconds. Average readings are to be recorded at least once every 6 minutes by
an appropriate strip-chart recorder or data-logging device.
Before being placed in operation, the opacity monitoring system must undergo 168 hours
of performance testing. Calibration is performed by using certified filters, which give
opacity readings at low, mid, and high points. The specifications listed in Table 6-5 must
be met during the testing period.
Once an opacity monitor is put into operation, a record of each consecutive 6-minute
average, calculated manually or automatically, must be kept for reporting purposes. To
assure proper operation, zero and span checks are made daily. Maintenance, cleaning, and
optical alignment are performed as needed.
TABLE 6-5
PERFORMANCE SPECIFICATIONS FOR OPACITY MONITORS
Parameters
Calibration error
Zero drift (24 hours)
Calibration drift (24 hours)
Response time
Specifications
< 3^ opacity
< 2% opacity
< 2% opacity
10 sec (maximum)
The following questions should be considered in selection of a site for monitoring
opacity.
1. Is the monitor located so that the representative emissions from the designated
process will be measured?
2. Will the emissions being measured be representative of those being emitted
from the stack?
3. Is the site easily accessible?
4. Will the monitor be protected from adverse conditions?
Because at many facilities only certain specific sources must be continuously monitored,
site locations are made in relation to these processes. If the process has a control device,
the opacity monitor must be located after the device. Facilities with multiple sources
using a common stack may be able to use a single monitor if all sources are subject to
the same standards. Where multiple sources are using the same stack but are subject to
different standards, individual opacity monitors must be used.
6-22
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Monitoring locations must be selected such that the facility can demonstrate that a
representative sample of the emissions is being observed. Areas to be avoided are
locations where stratification or layering of dust in the gas stream may occur and areas
where water droplets will cause interference. Stratification is common in horizontal ducts
as the heavier particles tend to settle toward the bottom (Figure 6-10). Other areas to be
avoided are sharp turns, obstructions, or changes in the cross-sectional area of the duct.
Junction of two or more gas streams will also cause stratification, even in vertical ducts.
Any site under consideration should be thoroughly tested for stratification prior to the
installation of an opacity monitor.
Water droplets in the gas stream will have the same effect on the opacity monitor as
particulates. If water droplets are a problem, alternative monitoring requirements must be
considered.
Accessibility to the opacity monitor is not only good sense but is a requirement of the
NSPS (1). Personnel should be able to service the monitor without spending unnecessary
time looking for a ladder or climbing over equipment. Some zero and span checks require
daily visits to the monitoring site; some opacity monitoring models conduct zero and
span checks automatically.
Frequent changes in optical alignment will require unnecessary maintenance. In order to
minimize this problem, opacity monitors should be located in areas free from excessive
vibration. Another cause of alignment problems is thermal expansion and contraction of
the monitor supports.
Even though most opacity monitors are designed to withstand adverse conditions, it is
best to provide adequate shelter for both the instrument and personnel.
6.4.2 Continuous Monitoring for Gases
Current technology for continuous monitoring of stack gases is in a state of flux. Most
units are prone to interferences from pollutants other than that being analyzed, and they
are also subject to electronic instability.
The general considerations for a continuous monitor of gaseous pollutants are listed in
Table 6-6.
6.4.3 Instrument Specifications and Certification
The EPA has issued specifications for monitoring instruments that are used to determine
compliance with the NSPS for specific industries; these are listed in Table 6-7.
Each continuous monitor installed must be tested to certify that it meets the
requirements of Vol. 40 CFR Part 60 (as published in the Federal Register, October 6,
1975). Typical of these certifications are the requirements for S02 monitors on sulfuric
6-23
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I
o
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-0
HORIZONTAL DUCT, STRATIFICATION DUE TO SETTLING
0 e
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. 6 . *
. 9
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TURNS AND OBSTRUCTIONS, STRATIFICATION DUE TO
INERTIA OF PARTICLES AND TURBULENCE
FIGURE6-10
STRATIFICATION OF PARTICLES IN DUCTS
6-24
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TABLE 6-6
CRITERIA FOR CONTINUOUS MONITORS FOR GASES
Specificity
Sensitivity, range
Stability
Precision, accuracy
Sample average time
Reliability, feasibility
Calibration
Response
Effect of ambient
conditions
Data output
Response should be only to trace material(s) of
interest.
Method must be sensitive over the concentration
range of interest.
Sample must be stable in the analyzer.
Results must be reproducible, and must represent
the actual stack concentration when compared with
the reference method gases.
Method must fit into the required sample averaging
time for control.
Instrument investment and maintenance costs,
analysis time, and manpower must be consistent
with needs and resources.
Instrument should not drift; calibration and other
corrections should be automatic.
Instrument must function rapidly enough to
record significant process changes as they occur.
Changes in temperature and humidity must not
affect the accuracy of the observed results.
For some applications, output of the analyzer
should be in a machine-readable format.
acid plants. Certification of the continuous monitor's accuracy must be completed in
the seven steps outlined below:
Step 1. Analysis of calibration gases. The monitoring instrument must be calibrated
at three concentrations of sulfur dioxide: 0, 50 percent, and 90 percent of
span. Each calibration gas must be analyzed in triplicate by the EPA ref-
erence method.
Step 2. Calibration check. The three calibration gases must be analyzed by the
monitor for a total of 15 readings.
6-25
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Step 3. Zero drift check. The zero must be offset by at least 10 percent of the
span to check negative zero drift.
Step 4. Operational test. The monitor must be operated an additional period to
verify proper operation.
Step 5. Accuracy test. Gas samples are extracted from the stack and analyzed for
S02 by the manual reference method. At least nine samples must be
collected.
Step 6. Field calibration check. The zero and span drifts must be checked for a
minimum of 15, two-hour periods. This check can be simultaneous with
the accuracy test.
Step 7. Response time check. With the monitor in place, the time for the
instrument to respond from a zero reading to maximum concentration is
measured.
Typical procedures used in a certification program for an S02 monitor are as follows:
1. Certification Procedure Development
After a detailed review of the monitoring requirements, a stepwise procedure
will be prepared for certification of the S02 monitor. This procedure will be
specific to plant requirements and operations, and will include log sheets to
record data from each step of the certification.
2. Calibration Check of Monitor
First, the standard gases will be sampled and analyzed to verify their S02
concentrations. A minimum of three samples is required by EPA. Each
analyzed concentration must be within 20 percent of the mean for that gas.
After analysis of the standard gases, the monitor must measure the gases at
least 15 times to verify its calibration. The monitor's response time will also be
measured a minimum of three times (Steps 1, 2, and 7).
3. Operational Check of Monitor
After installation, the monitor must be operated for at least 2 weeks for an
initial check of all operations. The first week is solely for checking the zero
drift. The second week of operation is required to demonstrate the monitor's
initial reliability (Steps 3 and 4).
4. Field Accuracy Check of Monitor
The accuracy of the monitor is established by collecting samples of the stack
gas, analyzing the samples by the reference method for SO2 and comparing
6-26
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the analytical results with the monitor averages for the sampling periods. A
minimum of 9 samples over a 9-hour period will be collected for laboratory
analysis. Concurrent with this sampling, the monitor will be checked for zero
drift and span drift. The drifts will be determined for at least fifteen, 2-hour
periods.
TABLE 6-7
INSTRUMENT SPECIFICATIONS
S02 and NOX Monitors:
Accuracy*
Calibration error*
Zero drift (2-hour)*
Zero drift (24-hour)*
Calibration drift (2-hour)*
Calibration drift (24-hour)*
Response time
Operational period
02 or C02 Monitors:
Zero drift (2-hour)*
Zero drift (24-hour)*
Calibration drift (2-hour)*
Calibration drift
Response time
Operational period
< 20% of mean value of reference method
test data
< 5% of each (50%, 90%) calibration gas
mixture
2% of span
2% of span
2% of span
2.5% of span
15 minutes maximum
168 hours maximum
0.4% Go or CO,
<0.5%00 or CO,
<0.4%02 orC02
<0.5%02 orC02
10 minutes
168 hours
^Expressed as a sum of absolute mean value plus 95% confidence interval of a series of tests.
6-27
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5. Report Preparations
All data generated will be tabulated and reduced to a format for comparison
with EPA specifications. The results of laboratory analyses will be compared
directly with the monitor record. The final report will include the data
collected, calculations, and certification of the acceptability of the monitor.
It is apparent that industries must expend considerable time and money in coordinating
the certification of stack monitoring equipment to meet the NSPS.
Misinformation about continuous stack monitoring is widespread. Because some in-stack
monitors (such as the transmissometers) are available, many persons believe that the
average monitoring system also is an in-stack device attached to a detector and recorder.
Most stack monitoring systems, however, are extractive rather than in-stack devices.
Several pollutants can be analyzed using an extractive system, whereas most in-stack moni-
tors are limited to analyzing a single pollutant. The extractive system, however, presents
a serious problem of gas conditioning. For proper operation, the detector must receive gas
that is at ambient pressure and temperature, with negligible moisture content. Thus, in an
extractive system, the gas entering the detector must be preconditioned to prevent
erroneous readings and/or malfunction of the detector.
The average detector for gas monitoring is small and costs in the range of $3,500 to $5,500.
D o o ^
The conditioning system, however, requires both a considerable amount of space and a
sizable investment. The cost of the conditioning system may well be two to three times
the cost of the detector. Care must be taken to select a conditioning system that is compat-
ible with the detection device.
Another significant factor in stack monitoring for gases is location of the monitor; as in
particulate sampling, the stratification of gases in ducting and stack must be considered.
Most stack sampling (manual or continuous) is conducted at a location where there is
undisturbed flow. The concept of isokinetic sampling for particulates does not necessarily
apply to gaseous sampling. It is advisable to conduct a series of exploratory tests across a
stack to determine whether the gas being measured is uniform in concentration or is
stratified.
If the exploratory examination reveals that the gases are stratified, another location
should be considered. In gas sampling, the monitor may be placed at, or following, a
turbulent zone, so that mixing of the gases takes place before the gas stream is sampled.
Sulfur Dioxide Instrumentation - Many types of instruments are in current use for contin-
uous analysis of S(>2 gas, including spectrometers and electrochemical sensors. Wet chemi-
cal analyzers are not practical for stack monitoring, since they are subject to fouling by mist
and particulates and to interference from unremoved gases and water vapor.
6-28
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The spectrometer using the infrared (IR) or ultraviolet (UV) region of the SO2 spectrum
is the monitor most commonly used, since other types of monitors require withdrawal of
a sample from the stack. These monitors use the stack as their optical paths and thereby
provide cross-stack average measurements. The S02 absorption spectrum is matched
against a reference pattern in such a way that other materials do not interfere.
Electrochemical instruments can detect both sulfur dioxide and nitrogen oxides. A fuel
cell sensor generates an electric current by electro catalytic oxidation or reduction of S02;
the current is directly proportional to the S02 concentration in the sample of the gas
stream. These sensors must be replaced periodically to provide accurate readings.
The inspector can calibrate the instruments by inserting known concentrations of
calibration gas into the analyzer. Two known concentrations can be carried in small
sample cylinders and calibrations performed according to the manufacturer's specifica-
tions at operating temperatures and pressures. Periodic maintenance is required to remove
dust, oil, and condensation from the system.
Nitrogen Oxides and Other Instrumentation - The NSPS for NOX emissions from new and
modified steam generators apply to both NO and N02, although less than 5 percent of the
NOX is present as N02. Therefore, measurement of the NO content of the stack gas is ade-
quate for monitoring purposes (unless too much excess air is introduced into the exhaust gas
stream).
Nitrogen oxides instrumentation includes photometric and spectroscopic analyzers,
electrochemical devices, and chemiluminescent detectors. Wet analysis instruments are not
practical for in-stack monitoring.
Photometric and spectroscopic analyzers measure light transmission at a specific
wavelength. Since these instruments depend upon light transmission, they may give
erroneous readings as a result of absorption of radiation by particulate matter or
condensates in combustion gases.
Electrochemical instruments, discussed earlier concerning monitoring of S02, may give
high N0x readings as a result of the presence of S02. An absorber can be installed at the
sample inlet system to remove S02 from the sample.
Nitric oxide is detected by the chemiluminescent reaction of NO with ozone-producing
light (Figure 6-11). The intensity of the light, which is detected by a photo multiplier
tube, is proportional to the NO concentration. The instrument is calibrated with standard
concentrations of NO by techniques similar to those mentioned for S02 calibration.
These are the most common instruments in current use. Depending upon the source,
additional continuous monitoring instruments may be required. For combustion sources,
it may be necessary to determine combustion efficiency of excess air. This is done by
6-29
-------
monitoring carbon dioxide or carbon monoxide by nondispersive infrared (NDIR)
detection, or by monitoring oxygen with paramagnetic techniques. A schematic of the
NDIR system is illustrated in Figure 6-12. At refineries, petroleum storage facilities, or
bulk loading facilities for organic chemicals (all of which must be monitored for
hydrocarbons), a gas chromatographic system is used. A typical schematic is illustrated in
Figure 6-13.
NOX GAS FLOW
OZONE GENERATOR
hv-
»
REACTION
CHAMBER
PHOTOMULTIPLIER
TUBE
SPECTROMETER
READOUT
REACTION:
NO + 03 -* N02 + 02
FIGURE6-11
SCHEMATIC OF CHEMILUMINESCENT TECHNIQUE
NDIR SPECTROMETER'
RECORDER
CO2 GAS FLOW
CONDITIONER
STANDARD GAS
'SET AT A GIVEN WAVE LENGTH FOR A PARTICULAR GAS
FIGURE 6-12
SCHEMATIC FOR NONDISPERSIVE INFRARED DETECTION
6-30
-------
CHROMATOGRAPH
— M
H
~»
CONDITIONER
REACTION:
HC+ FLAME
£
ION DETECTOR
^ rt
H2 FLAME ELECTROMETER READOUT
. • {CHROMATOGRAPH)
•* HC(ION)
FLAME IONIZATION DETECTOR
FIGURE 6-13
SCHEMATIC OF CHROMATOGRAPH
6.5 References
1. Turner, D.B., Workbook of Atmospheric Dispersion Estimates, U.S. Department of
Health, Education, and Welfare, Cincinnati, Ohio, 1970.
2. Munn, R.E., Descriptive Micrometeorology, Chapter 13, pp. 118-128, Academic
Press, New York, New York, 1966.
3. Slade, D.H., Meteorology and Atomic Energy, U.S. Atomic Energy Commission,
Office of Information Services, Washington, D.C., July 1968.
6-31
-------
-------
CHAPTER 7
THE CONTINUING PROGRAM
7.1 Introduction
Following the establishment of an air quality management program and a successful
compliance test, an industrial organization must conduct an active, continuing program
to maintain compliance with regulatory requirements. Some of the routine activities of a
state and/or local regulatory agency can have a direct effect on the operation of a contin-
uing compliance program. These control activities include scheduling inspections for per-
mit renewal, patrolling industry operations and investigating complaints, and scheduling
additional source testing, as circumstances may require.
In order to meet the continuing requirements of regulatory agencies, industrial planners
must consider:
1. Plant and control equipment operation,
2. Equipment maintenance,
3. Changes in processes and control equipment, and
4. Testing to verify compliance with emission standards.
This chapter describes the interactions that can be expected with various regulatory
agencies and the several facets of an effective industrial program that will ensure
compliance with regulations and will promote acceptance by citizens of the community.
Much of the activity of industrial air pollution control programs to date has been
directed toward installation of air handling and control systems that will enable the
industry to:
1. Comply with state and local pollution control regulations and ordinances,
2. Meet federal NSPS,
3. Assist in meeting the air quality goals set forth in state implementation and
maintenance plans, and
4. Comply with the intent of the nondegradation planning concept.
The Council on Environmental Quality, in their seventh annual report to the President,
indicated that the cost of operating and maintaining air pollution control equipment for
industrial sources alone would be $1.2 billion in 1975 and predicted an increase to $3.1
7-1
-------
billion in 1984. The cumulative cost for operation and maintenance from 1975 through
1984 would be $21.7 billion. This expense may be significantly increased in many
situations because of a lack of information regarding installation, operation, and
maintenance of control equipment.
7.1.1 Process and Raw Material Changes
Often an industry can reduce its air pollutant emissions by process changes, as when a
paper mill adds a black liquor oxidation system for odor control, or by a change of
process materials, as when a paint spray operation substitutes a solvent containing
nonreactive rather than reactive hydrocarbons.
A combination of process modification and raw material changes might be substituted for
processes and materials now used in making water-base paints; powder coatings might be
substituted for solvent-based paints. Many industrial operators such as printers, lithogra-
phers, and makers of cans and barrels can use coating solutions of this type. Pilot studies
are needed to determine the feasibility of such changes and to maximize possible economies.
Process Changes-Industry is looking toward process changes as a way to reduce the load
on pollution control systems or, preferably, to eliminate the problem at its source. The
kraft paper industry is discussed here as an example of pollution reduction by changes in
the process. For years the odors from kraft paper mills have been a source of community
nuisance complaints. One source of odors is the direct contact evaporator prior to the
recovery furnace. The normal flow of black liquor from the digester after blowdown is to
the multiple-effect evaporators for concentration, then on to the cascade evaporator
(direct-contact evaporator) for further concentration, and then to the recovery furnace
for product recovery. Add-on control devices used to control odors from this process are
becoming very expensive, and any further reduction in air emissions probably must be
accomplished through process modification.
The kraft mill is just one of many examples of process modifications and in-plant changes
that reduce or eliminate emissions. Pollutant emissions are affected not only by major
process changes of the type just described, but also by relatively minor modifications
within a process operation. This is shown in Table 7-1, which defines the effects on
emissions of such process variables as fuel temperature and amount of excess air.
Raw Material Changes-A good example of a raw material change that can affect many
smaller industrial operations is the type and quality of fossil fuel burned in the boiler. As
conversions were made from coal firing to firing of oil and gas, it was believed that
emissions would continue to decrease. In recent years, however, with the crisis in
availability and cost of fuels, many installations are making fuel substitutions in the
reverse direction. Several factors are involved. First is the conversion of equipment
required for an oil-burning installation to burn coal. Second, emission control modifica-
tions usually are required to prevent an increase in emissions after the substitution of
coal for a cleaner fuel.
7-2
-------
TABLE 7-1
EFFECTS ON EMISSIONS BY INCREASING VALUES OF
SELECTED OPERATING VARIABLES (FUEL OIL COMBUSTION^
Operating variable
Percent load
Fuel temperature
Fuel pressure
Excess air
Percent C02 in stack
Dirt in firebox
Flue gas recirculation
Flame temperature
Stack temperature
Percent sulfur in oil
Percent ash in oil
Effect of increase on pollutants
NOX
I
D
D
I
D
I
D
I
—
—
S02
_
__
—
—
—
—
_
—
—
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D
—
I
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I
D
Participates
D
D
D
I
I
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D
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*I - increase
D - decrease
— - no change
7.1.2 Process and Control Equipment Malfunctions
Emissions from an industrial process may meet emission standards during normal
operation but far exceed the standards when a malfunction occurs. Malfunctions result
from either equipment breakdown or operator error (See Figure 7-1).
Not all malfunctions substantially increase emissions. For example, in a combustion
process such as operation of an incinerator or a cement kiln, a failure or malfunction of the
refractory would not cause excess emissions but a change in combustion air flow could in-
crease emissions. The factors of concern in regard to malfunctions are:
1. Frequency of occurence,
2. Duration,
3. Effect on emission rate, and
4. Means of minimizing excess emissions.
Various factors related to each industry and process can affect emission rates from
malfunctions. Typical malfunctions that can occur with an incinerator are listed in Table
7-2.
7-3
-------
INDUSTRIAL
PROCESS
MALFUNCTION
NORMAL
OPERATION
1
EQUIPMENT
BREAKDOWN
OPERATOR
ERROR
PROCESS
EQUIPMENT
i
CONTROL
DEVICE
i
EMISSIONS
REMAIN
UNCHANGED
EXCESS
FIGURE 7-1
TYPES OF VARIATION IN PROCESS OPERATION
74
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To correct a malfunction in the air pollution control system, the entire process is either
shut down or the control device is bypassed. When the malfunction is in the process
(depending upon its severity and its effect on air emissions), operation will continue until
the normal shutdown period or the process will be shut down for temporary or complete
repair. The process may also continue to operate, but it may be necessary to bypass the
control device. Certain types of malfunctions cause a temperature increase or excess
moisture that could adversely affect a baghouse as well as the air emissions.
Malfunctions often occur during the initial startup of a process. During this time most
turnkey plants and control equipment are under warranty; the equipment company/
contractor should make the necessary adjustments or modifications that will enable the
system to meet the design capacity of the plant and the emission control guarantees.
Generally, the purchaser withholds monies during this initial startup period until the
process and/or control equipment are functioning satisfactorily and the guarantees are
fulfilled. With respect to guarantees on air pollution control equipment it is important
that:
1. The air emission test procedures specified in the guarantee are acceptable to all
of the regulatory agencies involved; and
2. The emission limitations stipulated in the guarantee are acceptable now and in
the forseeable future, to all of the regulatory agencies involved.
7.1.3 Startup/Shutdown and Upset Operating Conditions
Often a malfunction results in the temporary shutdown of a process. The length of the
shutdown may have a marked effect on the emissions, as in the shutdown of a sulfuric
acid plant. As listed in Table 7-3, the longer a sulfuric acid plant is shut down, the
greater will be the sulfur dioxide emissions during startup.
TABLE 7-3
EFFECT OF SHUTDOWN DURATION ON
EFFLUENT S02 CONCENTRATIONS DURING STARTUP
Shutdown duration,
hours
<1
1-2
2-6
6-10
10-15
15+
Peak S02 during startup,
ppm by volume
185
520
1,920
1,600
2,250
2,970
7-6
-------
In most industrial processes, the shutdown poses no particular problem if normal
operating procedures are followed. Shutdowns of most processes do not cause excess
emissions. Upset conditions are generally documented on forms such as that illustrated in
Figure 7-2.
A cold startup of an industrial process will generally result in excess emissions until the
process reaches a stable condition for a given production rate. At startup of a power
plant, the particulate emissions and opacity readings will be higher than normal and will
continue high until the operation is stabilized (see Figure 7-3). The factors involved in
stability of operation include operating temperature, feed rates, air flow, and chemical
reactions. The predominant types of air pollution control equipment installed on
industrial processes are: (1) baghouse filters and electrostatic precipitators (ESP) for
control of particulates, and (2) scrubbers for control of gaseous pollutants.
Procedures for startup of a baghouse system depend upon the equipment and the process.
An important basic guideline for any process in which hot moist gases are generated is to
preheat the baghouse. This is done to prevent condensation which results in mudded
bags. Mudded bags must either be dry-cleaned or replaced. The other condensation hazard
is corrosion of the baghouse materials. After the baghouse is preheated, the process can
be put into full operation and all functions of the baghouse can be operated. In processes
where the acid dewpoint is of concern, the baghouse should be bypassed during startup
until the acid dewpoint has been passed.
Startup of an ESP is more complex, requiring a pre-startup inspection as well as specific
startup procedures. Details of the pre-startup inspection, routine startup, and routine
shutdown are given in Appendix D.
7.2 Control Equipment Maintenance
Although installation of control equipment can aid in maintaining compliance with
emission regulations, continuing compliance will not be realized unless the control
systems are properly operated and maintained. Industries in the NSPS categories must
regularly submit reports to EPA on emission violations and production rates. These
reports will reflect satisfactory compliance efforts only where the industry conducts a
systematic operation and maintenance program, including the following procedures:
1. Early detection of malfunctions,
2. Prediction and prevention of equipment failures,
3. Identification and correction of problems as they occur,
4. Prevention of damage to equipment, and
5. Reduction of emissions, with increase in product recovery.
7-7
-------
SOUTHERN CALIFORNIA APCD —METROPOLITAN ZONE
ENFORCEMENT DIVISION - UPSET/BREAKDOWN REPORT
Report No. Time Firm Reported to HQ Date_
Company Name
Address City
Sector ~ Phone No(s)
All of the following questions must be answered in order to evaluate this Upset/Breakdn.
1. Description:
Unanticipated Process Upset / / Operational Change / _/
Equipment Failure / / Startup/Shutdown / /
Utility System Failure / / Scheduled Maintenance / /
Accidental Fire T'^ I Variance No.
Other (describe) ^ _^_ _
2. Equipment description ~
3. Permit or Application No(s) ._
4. Arrival time at plant Person contacted Title
5. Type of contaminants emitted? ,
6. Permit or A/C conditions violated"?Describe
7. Estimated volume and/or weight of contaminants emitted, if available^
8. Visible emissions: Opacity Time Length of plume_
9. Odors. Description
10. Intensity Wind direction Speed
11. Description of violations observed or suspected
12. Was a violation notice issued? Notice number Rule or Sec.
13. Did the excessive emission(s) result from operator error or improper operating or
maintenance procedures? Describe (why)
14. Were all reasonable steps taken to correct the condition ieading to the excessive
emissions and to minimize the emission itself? Describe action taken
15. When was company first aware of UpsetTBreakdown ~
16. Starting time of incident causing excessive emissions or odors
Estimated total duration of incident
17. Estimated duration of emissions
18. Can equipment be shut down immediately without creating a hazard, or without
causing a hardship to the firm or its employees ? Yes / / No T~'l
19. Will equipment be shut down? Yes / / No / /
20. Can it be operated at a reduced rate?
21. What effect would shutdown or cutback have on total plant operation?
40D504R
FIGURE 7-2
UPSET/BREAKDOWN REPORT FORM
7-8
-------
22. Are operating records available? Yes I / No 7 / What do they indicate?
23. Describe measures which can or have been taken to reduce the frequency, duration,
and intensity of these incidents and the time table for taking these measures
24. Does company have a preventative maintenance program?
25. How is it being followed?
26. Were any samples taken?
27. Describe: Sample Source
28. Was equipment in operation?
29. Were complaints received? Complaint numbers
30. Number of nuisance complaint forms received
31. Will company file for a variance ? WhenT"
32. ADDITIONAL INFORMATION
(Use I. R. for further additional information)
Inspector's Signature Departure Time
SUPERVISOR'S REVIEW
Should reinspection be made? By whom ? When
Are all breakdown criteria meT?Yes 7 T No~7 7 Issue notice of viol?
Supervisor's recommendations or summary ~~
Ex-parte variance filed Variance requested from
rule(s) or section(s)
What final action was taken?
Immediate Supv. Signature Date
Immediate Head Inspector's Signature' Date"
Plant Supv. Signature Date'
Head Inspector Signature Date"
Reviewed by Asst. Chief Date
FIGURE 7-2 (Com.)
UPSET/BREAKDOWN REPORT FORM
7-9
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7-10
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Industrial managers should also be aware of the benefits of such a program, which may
include:
1. Reduction of operating costs through reduction of operator time, power, fuel,
services, equipment replacement, and parts inventory,
2. Compliance with emission regulations/standards,
3. Extension of operating life of control equipment, and
4. Recovery of valuable products.
Preventive maintenance is more efficient and more economical than repair after
breakdown and also keeps production moving. Preventive maintenance includes estab-
lishing priorities, organizing the maintenance system, scheduling, and checking control
costs. A systematic approach to operation and maintenance of typical control equipment
is shown schematically in Figure 7-4. Some of the items that should be part of a system
maintenance inspection for air pollution control systems are listed below:
1. Air infiltration
a. Process equipment,
b. Breaching and ducts,
c. Access doors and panels, and
d. Expansion joints.
2. Induced-draft fan
a. Vibration,
b. Bearing temperature,
c. Bearing lubrication,
d. Coupling lubrication,
e. V-Belt condition,
f. Motor bearing lubrication,
g. Foundation bolts, and
h. Variable speed drive.
3. Thermal insulation
a. Integrity, and
b. Cold spots.
4. Dampers
a. Function, and
b. Lubrication.
7-11
-------
L— TROURI F — -
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SELECTIOt
1— CORRECTIVE _J
' ROUTINE
INSPECTION
*
ELECTROSTATIC
0 SCRUBBER PRECIPITATOR
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FIGURE 7-4
SYSTEMATIC APPROACH TO TYPICAL AIR POLLUTION CONTROL
EQUIPMENT OPERATION AND MAINTENANCE
7-12
-------
5. Temperature elements
a. Thermocouples,
b. Pyrometers, and
c. Hot wires.
6. Pressure sensors
a. Taps and lines, and
b. Transmitters.
We have considered some of the ways in which process operation can affect pollutant
emissions. Similarly, the maintenance of process equipment strongly affects the process
effluent, since malfunction of this equipment can virtually negate the effectiveness of the
air pollution control system. The detailed discussion that follows concerns the
maintenance of control equipment rather than of process equipment. Further, it is
limited to the devices that are most efficient in control of fine particulates: the baghouse
filter, the venturi scrubber, and the electrostatic precipitator. These are the units most
often installed in industrial facilities for the purpose of achieving and maintaining
compliance with current and possible future regulations. Systems for control of gaseous
pollutants include those based on adsorption, combustion, and oxidation techniques. An
afterburner which incinerates solvent fumes is shown in Figure 7-5. These are to be
considered in industrial guides for control of process gases.
In describing the maintenance of these three major pollution control systems, this section
first discusses briefly the operation of the system, then presents such factors as inspection
procedures, trouble-shooting and corrective measures, spare parts requirements, and
manpower requirements. These are discussed in enough detail that managers of industrial
operations controlled by these devices can visualize the extent of maintenance time/cost
required to keep them operating efficiently.
7.2.1. The Baghouse
Basically, a baghouse is a large metal box divided into two chambers or plenums, one for
dirty air and one for clean air. Rows of cloth bags form a partition or interface between
the plenums. A polluted gas stream is ducted into the dirty air plenum where it is
distributed evenly to the bags. The gas passes through the bags, enters the clean air
plenum, and is exhausted into the atmosphere through a stack. Almost 100 percent of
the particulate matter in the process effluent can be filtered out by the bags if the
system is designed, operated, and maintained properly.
When a new baghouse is first started up with factory-fresh bags, some stack emissions are
usually visible. This is because the filtering medium (which is the fabric of the bags) is
porous and allows a certain amount of very fine particulate matter to pass through the
interstices between the fibers. After a short period of operation, a dust cake builds up on
the surface of the bags and becomes the actual filtering medium. The bags, in effect, act
primarily as a matrix to support the dust cake.
7-13
-------
The dust cake is desirable only up to a point; when that point is reached, the bag must
be cleaned. If it is not cleaned properly, the pressure drop through the filter system will
continue to increase. At high pressure drops, particles of dirt can be forced into the bag
fiber, causing the bags to become blinded. When this happens, air flow is restricted and
the bags may have to be replaced or removed and cleaned to restore proper operating
capacity. In addition to the costs of replacement or cleaning, a high pressure drop
increases the cost of moving air through the system. An installation of a typical baghouse
is shown in Figure 7-6.
Routine Inspection and Troubleshooting-The key to baghouse maintenance is frequent
and routine inspection. It is essential that a regular program of routine maintenance be
established and followed. Records should be kept of all inspections and maintenance.
Inspection intervals will depend on the type of baghouse, the manufacturer's recom-
mendation, and the process on which the unit is installed. The important thing is to be
sure that the checks are performed regularly and as frequently as necessary, and that no
components are neglected.
Table 7-4 lists the items requiring regular inspection and what to look for. When troubles
are located and isolated during routine or other inspection, it is important that
corrections are made as quickly as possible to avoid possible equipment downtime or
excess emissions due to bypassing the control system. When there is a baghouse failure,
the unit is usually shut down and/or bypassed and the malfunction is corrected.
Plant managers should expect that considerable maintenance time will be expended on
troubleshooting and correction of baghouse malfunctions. Maintenance personnel must
learn to recognize the symptoms that indicate potential problems, to determine the cause
of the difficulty, and to remedy it, either by in-plant action or by contact with the
manufacturer or other outside resource. High pressure drop across the system exemplifies
one symptom for which there are many possible causes, e.g. difficulties with the
bag-cleaning mechanism, low compressed-air pressure, weak shaking action, loose bag
tension, or excessive reentrainment of dust. Many other factors can cause excessive
pressure drop, and several options are usually available for corrective action appropriate
to each cause. Thus the ability to locate and correct malfunctioning baghouse
components requires a thorough understanding of the system. A detailed tabulation of
troubleshooting and corrective measures is given in Appendix E.
The frequency of failure or breakdown of basic parts is presented in Table 7-5. which
includes requirements for frequency of inspection and inspection time as well as the
times required for repairs.
Spare Parts-Every baghouse maintenance program includes an inventory of spare or
replacement parts. Table 7-6 lists the typical items that should be stocked, the
approximate quantities, and, if the parts are not stocked, the approximate delivery time
and cost.
7-14
-------
FIGURE 7-5
INCINERATOR USED TO CONTROL SOLVENT FUMES
FIGURE 7-6
BAGHOUSE INSTALLATION ON AN ASPHALT BATCH PLANT
7-15
-------
TABLE 7-4
CHECKLIST FOR ROUTINE INSPECTION OF BAG HOUSE*
Component*
Checklist
Shaker mechanism (S)
Bags
Magnehelic gauge or
manometer
Dust removal system
Baghouse structure
(housing, hopper)
Ductwork
Solenoids, pulsing valves
(RP)
Compressed air system
(RP, PP)
Fans
Damper valves (S, PP, RF)
Doors
Baffle plate
Proper operation without binding;
loose or worn bearings, mountings,
drive components; proper lubrication.
Worn, abraided, damaged bags; con-
densation on bags; improper bag
tension (S) (RF); loose, damaged,
or improper bag connections.
Steadiness of pressure drop
(should be read daily).
Worn bearings, loose mountings,
deformed parts, worn or loose drive
mechanism, proper lubrication.
Loose bolts, cracks in welds; cracked,
chipped, or worn paint; corrosion.
Corrosion, holes, external damage,
loose bolts, cracked welds, dust
buildup.
Proper operation (audible
compressed air blast).
See above; proper lubrication of com-
pressor; leaks in headers, piping.
Proper mounting, proper lubrication
of compressor; leaks in headers,
piping-
Proper operation and synchronization;
leaking cylinders, bad air connections,
proper lubrication, damaged seals.
Worn, loose, damaged, or missing
seals; proper tight closing.
Abrasion, excessive wear.
*Refer to Appendix E for detailed troubleshooting procedures.
**RP _ reverse pulse; PP - plenum pulse; S - shaker; RF — reverse flow.
7-16
-------
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7-18
-------
Perhaps the major maintenance item, and the most costly because of the numbers
involved, is the filter bag. Baghouses are often classified according to collection of the
particulate on the inside of the bags. Table 7-7 lists the cost of various materials for
inside and outside type units on a per-square-foot basis.
7.2.2 Venturi Scrubber
The total venturi scrubber system consists of a fan, the venturi section, the separator
chamber, a mist eliminator, and the appropriate duct work. In discussing maintenance of
the venturi scrubber, various parts of the system must be considered because of the
special corrosion and abrasion problems associated with the wet system; these problems
do not occur with the baghouse or the ESP, which are essentially dry particulate handling
systems. A typical scrubber installation is shown in Figure 7-7.
TABLE 7-7
COST OF BASE REPLACEMENT
IN FABRIC FILTERS
(Information supplied by R. P. Bundy, Standard Havens, Inc.)
Type material
Acrylic
Cotton
Glass
Nomex
Polyester
Polypropylene
Teflon
Cost of material
(per square foot)
Inside bag
collector
$0.19
.19
.40
.80
.16
.31
2.89
Outside bag
collector
$0.38
N/A
.50
.88
.25
.30
5.70
Note: Cost differences are because of the type or weight of material. Outside bags
are usually 14 oz. Feltco material and inside bags are 8-12 oz. woven material.
Maintenance-The major problems with the scrubber from a maintenance standpoint are
corrosion, scaling, and plugging. Corrosion is best prevented by a proper pressure/
temperature balance in the system; when problems do arise, maintenance entails
replacement of parts and/or patching of the unit. Scaling results from an improper
chemical balance in the system and is corrected by chemical or hand cleaning. Plugging
occurs as solids build up at transition points in the system. Table 7^8 indicates the
manpower requirements for maintenance that involves scaling and plugging for both the
wet approach and liquid injection venturi scrubbers.
7-19
-------
The venturi scrubber unit is used for a variety of applications. Table 7-9 lists the
maintenance requirements for two ranges of pressures, various lining materials, and gas
characteristics. This table should be useful in the selection of scrubber liners for venturi
units in various applications.
TABLE 7-8
MAINTENANCE FOR PLUGGING AND SCALING
VENTURISCRUBBER
(From interview with P. Wechselblatt — Chemico)
Type of
venturi
scrubber
Wet
approach
Liquid
injection
Type of problem
Plugging
Mechanical
cleaners
1 Man/shift/
month
1 Man/shift/
month
Cylinder
cleaners
1 Man/shift/
month
1 Man/shift/
month
Scaling
Chemical
cleaning
3 Men/shift/
week
3 Men/shift/
week
Hand
cleaning
1 Man/shift/
week
1 Man/shift/
week
Spare Parts-The minimum inventory of spare parts is one each for each venturi scrubber.
The spare parts inventory for a venturi system is given in Table 7-10.
Manpower Requirements-This section has indicated the maintenance items, maintenance
times, and spare parts inventory for a venturi scrubber system. Table 7-11 completes this
picture by presenting the types of personnel generally required to perform maintenance
on various parts of the venturi scrubber system.
A great variety of wet scrubbers, ranging from low- to high-energy systems, can remove
various size particles and gases. Attention is directed to high-energy systems, which
remove very fine particulates and thus satisfy the more stringent air pollution control
codes. The high-energy venturi scrubber is one example. Maintenance procedures
applicable to this type of system can be easily adapted to other scrubber systems.
When gas containing dust is swept through an area containing liquid droplets, dust
particles will strike or impinge upon the droplets: if they adhere, the particles will be
collected by the droplets. The collecting liquid is called droplets and the material in the
gas stream that is to be collected is called particles, whether it is solid or liquid. In
general, the collection effect is most efficient when the size of the liquid droplet is
approximately 100 to 300 times the size of the dust particle (range from 100 to 1,000
microns), allowing for large numbers of collisions.
7-20
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7-23
-------
In a venturi scrubber, the gas velocity is increased in the venturi (or constricted section),
and water may be injected under pressure to provide intimate contact between the gas
stream and water particles.
The wet-dry line area must be periodically inspected to be sure that solids buildup is not
occurring. Spray nozzles and liquid inlets must be checked to see that they are open and
distributing the liquid properly. The inspector should especially watch for corrosion
underneath scale buildup.
The second major problem in most high-energy scrubbers is associated with abrasion.
High-velocity liquid containing dust strikes the impingement surfaces in the venturi
scrubber, especially at the highest-velocity area, i.e., the venturi or throat of the unit.
Places susceptible to corrosion and abrasion must be inspected frequently. These include
throats, orifices, elbows, and other high-wear areas. Any wearing of coatings and metals
should be repaired as needed.
Failure of wet scrubbers rarely involves the scrubber itself, since many scrubbers have few
moving parts or none. The other system components must be investigated, i.e., the
connecting duct work, dampers, fans, centrifugal pumps, valves, and piping. Each of these
components provides the designer with unique problems and must be monitored carefully
during inspection.
7.2.3 The Electrostatic Precipitator
An electrostatic precipitator (ESP) consists very basically of a precipitator chamber and
an electrical unit (see Figure 7-8). The precipitator chamber includes discharge and
collection electrodes, an electronic cleaning system, gas distribution devices, and a
precipitator shell and hopper. The electrical unit is made up of a power supply, high
voltage transformers, rectifiers, and precipitator bus sections.
ESP is a physical process by which a particulate suspended in a gas stream is charged
electrically and then, in the influence of an electrical field, is separated and removed
from the gas stream. The system that does this consists of a positively charged collecting
plate in close proximity to a negatively charged electrode. A high-voltage charge is
imposed on the electrode, which establishes an electrical field between the electrode and
the grounded collection surface. The dust particles pass between the electrodes, where
they are negatively charged and diverted to the positively charged collection plate(s).
Periodically, the collected particles must be removed from the collecting surface. This is
done by vibrating (usually by rapping) and/or water washing the surface of the collection
plates to dislodge the dust. The dislodged dust drops into a dust removal system and is
collected for disposal.
7-24
-------
FIGURE 7-7
WET SCRUBBER INSTALLATION ON AN ASPHALT BATCH PLANT
FIGURE 7-8
ELECTROSTATIC PRECIPITATOR INSTALLATION ON POWER BOILER
7-25
-------
The advantages and disadvantages of electrostatic precipitators are summarized below:
Advantages
1. High collection efficiency is obtained on particles as small as 0.01 micron;
range of collection efficiency is 80 to 99.9 percent.
2. Operating costs are low.
3. Low pressure drops of 0.1 to 0.5 inch water are typical.
4. Gas flows as high as 4 million cfm can be handled effectively.
5. Gas pressure and vacuum operating conditions can be used.
6. There is essentially no limit to usage of solids, liquids, or corrosive chemicals.
7. Particulate concentrations from 0.0001 to 100 grains/cubic feet can be handled.
8. Gas temperatures can range as high as 1,200°F.
9- The units handle a wide range of gas velocities.
10. Units of the precipitator can be removed from operation for convenience in
cleaning.
Disadvantages
1. Installed costs are high.
2. Space requirements are high for cold precipitators and even greater for hot
precipitators.
3. Explosions can occur when the precipitator is collecting combustible gases or
p articulates.
4. Ozone (a poisonous gas) is produced by the negatively charged discharge
electrodes during ionization.
5. Operating procedures can be complicated. Great precautions must be exercised
to maintain safety and proper gas flow distribution, dust resistivity, particulate
conductivity, and corona sparkover rate.
Discharge electrode failure is the primary cause of operational breakdown. After this (in
order of highest rate of mechanical failure) are rapper malfunctions, insulator failures,
shorts caused by dust buildup, hopper plugging, and transformer-rectifier failures. Most of
these problems occur when proper preventive measures are not used. For example,
7-26
-------
discharge electrode failures can be reduced if the hoppers are properly discharged and
cleaned to prevent grounding out and burning off of the discharge electrodes. Failure to
inspect rappers over extended rapping cycles also causes discharge electrode breakage
through fatigue failure.
In addition to the electrical and rapping problems, the remaining possible precipitator
problems generally involve gas flow and mechanical systems. Uneven gas flow can cause
erosion of the collection plates and thereby reduce efficiency. Uneven gas flow also can
cause dust fallout and accumulation on turning vanes and on ductwork. This dust buildup
eventually plugs the distribution plates and results in further uneven gas flow and system
upset.
Rapping is a mechanical system for removing particles from the collection and discharge
electrodes. Rapping is effective only if sufficient force is transmitted to the electrodes.
Variations in the design of the supporting structure and in the electrodes themselves can
result in inadequate rapping. In many installations that handle fly ash, rapping
accelerations of 60 g (60 times the gravitational force) are required.
Fly ash buildup on the collecting plates should normally be about 1/8 to 1/4 inch. If the
buildup exceeds this thickness, the intensity of the plate rappers should be increased. If
the collecting plates are clean, this may be an indication of high gas velocity or low
operating voltage.
Collecting plates should be checked for proper alignment and spacing. Hangers and
spacers at the top and bottom should be adjusted so that they do not bind the plates or
prevent proper rapping. It is necessary to check for corrosion.
Hoppers should be checked periodically to be sure they empty properly and to inspect
for corrosion, which is likely to be most severe at points where dust builds up. The
heating system and insulation on the hoppers are checked to prevent condensation.
Insulator compartments and housings must be checked frequently. Leakage of corrosive
gases from the precipitator into this area can cause dirt deposits that result in breakdown
of the electrical insulators.
The spark rate control is inspected to maintain the proper number of sparks per minute;
this control can be adjusted if necessary.
The current and voltage limit controls must be checked and properly adjusted to prevent
damage to the electrical components in the system.
Any electrical surge, overload, and automated systems must be checked.
Transformers are checked to maintain liquids at the proper level.
Relays are disassembled and contacts cleaned once a year; the units are then recalibrated.
7-27
-------
Filter elements in the system must be removed and cleaned or replaced periodically.
Most rectifiers use vacuum tube or solid-state systems. Normal vacuum tube life ranges
from 12,000 to 20,000 hours, and servicing usually involves replacement of defective
tubes. Solid-state rectifiers are usually trouble-free, requiring little maintenance other than
periodic check of transformer oil.
Precipitator wires, which may amount to 30,000 feet of wire per unit, frequently require
servicing even under the best conditions of maintenance and operation.
Inspection should include a check for air leaks and examination of the collecting plates
for evidence of back corona. The precipitator should be maintained above the dew point
to prevent corrosion inside the precipitator.
Inspection and Maintenance—Following is a typical inspection and maintenance schedule.
Figure 7-9 illustrates a systematic approach to an ESP maintenance program.
Annual Inspection
A. Internal inspection
1. Observe dust deposits on collecting plates and wires before cleaning (a 1/4-inch
deposit is normal). If metal plates are clean, there is a possibility that a section
is shorting out- If more than 1/4-inch of dust is on the plates, rappers are not
cleaning.
2. Observe dust buildup and corona tufts on wires.
3. Check for interior corrosion, which could indicate an air leak through housing
or moisture carryover from the air heater washer.
4. Check plate alignment and spacing.
5. Check to see that discharge wire spacers and hanger weights are in place.
Measure to be sure the wires hang midway between plates.
6. Replace broken wires.
B. Hopper inspection
1. Check for dust buildup in corners.
2. Check high tension weights. If one has dropped 3 inches, this indicates a
broken wire.
3. Check hopper valve for debris.
7-28
-------
MAINTENANCE
PERFORMED BY:
COMPANY
STAFF
X
X
X
X
X
X
cc
MANUFACTURE
X
X
X
CONSULTANT
X
X
ESP MAINTENANCE CYCLE
ACTIVITY
COMMENTS
ROUTINE
CHECK
• EXTERNAL SYSTEM
'• DAILY
SHUTDOWN
PERIOD
• REQUIRED FOR SAFE
INTERNAL INSPECTION
INTERNAL
INSPECTION
i
ORDER
PARTS
I
I
USE OF
STANDBY
PARTS
--•SELECT PARTS/
EQUIPMENT
CONDUCT
REPAIRS
START UP
FIGURE 7-9
ESP MAINTENANCE CYCLE
7-29
-------
C. Penthouse inspection
1. Check for corrosion due to condensation and/or leakage of gas into housing
2. Excessive dust in penthouse indicates air sealing pressure too low.
3. Clean all high-tension insulators.
4. Check that all electrical connections are secure.
D. Transformer-rectifier inspection
1. Check liquid level.
2. Clean lines, insulators, bushings, and terminals.
3. Check surge arresters; spark gap should be 1/32 inch.
E. Control cabinet inspection t
1. Clean and dress relay contacts.
F. Check and calibrate all instruments and controls
Quarterly Inspection
A. Rappers
1. Clean, replace, and lubricate distributor switch contacts.
2. Check rapper assembly for free movement.
B. Vibrators
1. Check contacts on load cams.
2. Check vibrators to see that they operate at proper intervals.
Shift Inspection
A. Record electrical reading for each control unit and check for abnormal readings.
B. Check rapper controls.
C. Check vibrator controls.
7-30
-------
Shutdown Procedures and Maintenance of ESP Internals—These steps are necessary
primarily for safety and efficiency. An external inspection of a precipitator is performed
daily. Details of troubleshooting procedures, with probable causes and remedies, are given
in Appendix D.
The internal maintenance inspection of an ESP and the maintenance time requirements
for servicing depend on the interval required before maintenance personnel can enter the
unit after it is shut down. Typical shutdown times are listed in Table 7-12. Because of
the variety of ESP applications, maintenance problems also vary with each installation.
Table 7-13 indicates some typical industrial maintenance operations. The frequency of
parts failure in an ESP is very low; repair times are minimal after diagnosis and
shutdown.
An example of a typical troubleshooting chart for an electrostatic precipitator is
presented in Appendix F.
A further note regarding precipitator maintenance concerns opacity monitors. In addition
to the obvious use of opacity monitors to maintain compliance, industrial users find a
correlation between optical density and the concentration of particulates leaving the
stack. The Pennsylvania Power and Light Company has correlated their emissions with
optical density, as illustrated in Figure 7-10. They have also found that the following
variables which affect precipitator performance can be evaluated by opacity monitoring:
1. Fuel resistivity and ash content,
2. Boiler load,
3. Boiler outlet gas temperature,
4. Boiler excess air level,
5. Precipitator operating voltage,
6. Precipitator rapping intensity and programming, and
7. Precipitator internal conditions.
Many of these variables affect not only emissions but also maintenance of the
precipitators.
7-31
-------
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7-33
-------
O
0.9
0.8
0.7
0.6
0.5
0.4
0.3
0.2
0.1
•ALLOWABLE EMISSION PATE
O.
G
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GRAINS/CU FT
0.25
0.30
0.35
FIGURE 7-10
TEST DATA RELATING OPTICAL DENSITY TO OUTLET GRAIN LOADING
(Example for kraft pulp mill recovery furnace)
BIBLIOGRAPHY
Atmospheric Emissions from Fuel Oil Combustion, Environmental Health Series,
U.S. Department of Health, Education, and Welfare, Public Health Service, November 1962.
Compilation of Air Pollutant Emission Factors (2nd edition), U.S. Environmental Protec-
tion Agency, Office of Air Quality Planning and Standards, EPA AP-42, April 1973.
Environmental Quality - 1976 (The Seventh Annual Report of the Council on Environmen-
tal Quality), Environmental Quality-1976, September 1976.
Handbook for the Operation and Maintenance of Air Pollution Control Equipment, edited
by Frank L. Cross Jr., P.E., and Howard E. Hesketh, Ph.D., P.E., Technomic Publishing
Co., Inc., Westport, Conn., 1975.
Inspection Manual for Enforcement of New Source Performance Standards-Municipal
Incinerators, U.S. Environmental Protection Agency, Stationary Source Enforcement Series,
EPS 340/1-75-003, February 1975.
Sal/uric Acid Plant Emissions During Start-up. Shutdown, and Malfunction, U.S. Environ-
mental Protection Agency, EPA-600/2-76-010, January 1976.
7-34
-------
APPENDIX A
SAMPLE SAROAD AND NEDS FORMS
ENVIRONMENTAL PROTECTION AGENCY
National Aerornetric Data Bank
Research Triangle Park, N. C. 27711
SAROAD Site Identification Form
Form Com
pIptAri Ry flatP |>Jpw
TO BE COMPLETED BY THE REPORTING AGENCY
(A)
1 14-361
State Project
City Name (23 characters)
l37'5" County Name (15 characters)
City Population {right justified)
5Z 5J 54 55 56 57 5B 59
Longitude Latitude
Deg. Mtn. Sec. Deq. Mm. Sec.
0 0
GO 61
ITM Zone
60 61
n
» N |
62 63 64 6S 66 67 63 69 'P 71 n 73 >* I-j 1%
Easting Coord., meters Northing Coord., meters
-
6? 63 64 6$ 68 67 68 69 10 It 11 ?3 '* 75 16
Supporting Agency (61 characters}
Supporting Agency, continued
n
Il4-79i
Optional: Comments that will help identify
the sampling site (132 characters)
n)
1 4-79
=1
1 14-38)
Abbreviated Site Address (25 characters)
DO NOT WRITE HERE
State Area Site
A
' * 3 * S 6 789 m
Agency Project
II II 13
Time
Region Zone Action
77 78 79 BO
State Area Site
B|
1 2 34 £,6 7 B9 >0
Agency Project SMSA Actio
It 1- 13 M !5 16 17 BO
State Area Site
C
I ?3456 780 1O
Agency Project Action
11 I? t3 SO
State Area Site
D
Agency Project
II 12 13
Action
D
80
State Area Site
E
1 2 3 .4 S 6 ; 8 9 10
gency Project Action
I! f 13
(over)
FIGURE A-1
SAROAD SITE IDENTIFICATION FORM
A-1
-------
SAROAD Site Identification Form (continued)
TO BE COMPLETED BY THE REPORTING AGENCY
DO NOT WRITE HERE
(F).
Check the ONE
major category that
best describes the
location of the
sampling site.
1.CH CENTER CITY
2. SUBURBAN
3,1 I RURAL
4Q REMOTE
Specify
units
Address, continued
Next, check the subcategory
that best describes the domi-
nating influence on the sampler
within approximately a 1-mile
radius of the sampling site.
1. Industrial
2. Residential
3. Commercial
4. Mobile
1. Industrial
2. Residential
3. Commercial
4. Mobile
1. Near urban
2. Agricultural
3. Commercial
4. Industrial
5. None of the above
Elevation of sampler above ground
Specify
units _
State
Area
Site
,14-5*1 Sampling Site Address (41 characters)
Agency
Project
Station Type
County Code
57 SS 59 6°
AQCR Number
AQCR Population
6* 6i 68 B7 SB 69
Elevation/Gr
Elevation/MSt
T. 76 77 78
Time
Zone Action
Elevation of sampler above mean sea level
Circle pertinent time zone: EASTERN CENTRAL
MOUNTAIN PACIFIC YUKON ALASKA BERING
HAWAII
FIGURE A-1 (Cont.)
SAROAD SITE IDENTIFICATION FORM
A-2
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A-4
-------
APPENDIX B
SAMPLING AND FACILITY OPERATION CHECKLISTS
TEST PROGRAM MEETING REPRESENTATIVES
Plant Name.
Plant Address.
Source to be Tested.
Plant Representative.
Plant Manager
Test Team Company Name.
Team Representative
Responsible Person
Members of
Test Team _
Agency(s)
Agency Representative.
Responsible Person
Agency
Observers,
Date.
.Phone.
.Phone,
.Phone.
.Phone.
Title
. Phone.
.Phone-
Affiliation
. and Tasks .
FIGURE B-1
TEST PROGRAM MEETING REPRESENTATIVES FORM
(Note: This figure is also shown as Figure 5-1.)
B-1
-------
TEST PROGRAM MEETING PARTICIPANTS
Name Affiliation
FIGURE B-2
TEST PROGRAM MEETING PARTICIPANTS FORM
B-2
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B-3
-------
TEST PROGRAM AGREEMENT ON FACILITY OPERATION
Process
1) Method of process weight or rate determination
2) Process parameters to be monitored and recorded, and their acceptable limits to
document process operation
3) Raw material feed and/or fuel acceptable analyzed values
4) Normal operating cycle or procedures
5) Portions of the operating cycle or procedure that will be represented by each run
Control Equipment
6) Control equipment and effluent parameters to be monitored and recorded, and their
acceptable limits to document control equipment operations
7) Normal operating cycle (cleaning, dust removal, etc.)
8) Normal maintenance schedule
9) Manner in which the control equipment will be operated during test
FIGUREB-4
FORM FOR TEST PROGRAM AGREEMENT ON
FACILITY OPERATION
(Note: This figure is also shown as Figure 5-3.)
B-4
-------
TEST PROGRAM AGREEMENT ON CONTINUING COMPLIANCE CONDITIONS
Process
1) Process parameters that must be recorded and submitted to agency or kept on file
for later inspection
2) Percentage by which each process parameter can exceed the tested rate and on what
time-weighted average
3) Future operating procedures
Control Equipment
4) Control equipment parameters that must be recorded and submitted to the agency
or kept on file for later inspections
5) Normal operating procedures
6) Normal maintenance schedule
7) Frequency of scheduled inspections by agency
#
Reviewed and approved by:
Agency Facility Tester.
FIGURE B-5
FORM FOR TEST PROGRAM AGREEMENT ON
CONTINUING COMPLIANCE CONDITIONS
B-5
-------
FIELD OBSERVATION CHECKLIST
GENERAL/ADMINISTRATIVE
Plant name.
Plant address.
Source to be tested
Plant contact
Observers
Reviewed test program?.
Date.
.Phone
.Affiliation.
.Comments.
Reviewed test program meeting notes?.
.Comments.
Reviewed correspondence?.
.Comments
Test team company name.
Supervisor's name
Other members
Phone.
.Address.
Title
FIGURE B-6
FIELD OBSERVATION CHECKLIST
B-6
-------
GENERAL/SAMPLING SITE
Stack/duct cross section dimensions Equivalent diameter,
Material of construction Corroded? Leaks?_
Internal appearance - Corroded? Caked participate? Thickness.
Insulation? Thickness Lining? Thickness
o
Nipple? I. D Length Flush with inside wall?
Straight run before ports Diameters
Straight run after ports Diameters
Photos taken? Of what
Drawing of sampling location:
Minimum information on drawing: stack/duct dimensions, location and description of
major disturbances and all minor disturbances (dampers, transmissometers, etc.), and cross
sectional view showing dimensions and port locations.
FIGURE B-6 (Cont.)
FIELD OBSERVATION CHECKLIST
B-7
-------
GENERAL/SAMPLING SYSTEM
Sampling method (e.g., EPA 5).
Sampling train schematic drawing:
Modifications to standard method
Pump type: Fibervane with in-line oiler X Carbon vane X Diaphragm X.
Probe liner material Heated? Entire length?.
Type "S"pitot tube:.
.Other
Pitot tube connected to: Inclined manometer
Range Approx. scale length
.Or magnehelic gauge
Divisions
Orifice meter connected to: Inclined manometer Or magnehelic gauge
Range Approx. scale length Divisions
Meter box brand X Sample box brand X
Recent calibration of orifice meter-dry gas meter?
Nozzles Thermometers or thermocouples?
Pitot tubes?.
Magnehelic gauges?.
Number of sampling points/traverse from Fed. Reg.
Length of sampling time/point desired. Time to be used
Number to be used.
X— Not required by regulations
FIGURE B-6 (Cont.)
FIELD OBSERVATION CHECKLIST
B-8
-------
TRAIN ASSEMBLY/FINAL PREPARATIONS Run #
(Use one sheet per run if necessary)
Filter holder clean before test? Filter holder assembled
Correctly? Filter media type Filter clearly identified?.
Filter intact? Probe liner clean before test?
Nozzle clean? Nozzle undamaged?
Impingers clean before test? Impingers charged correctly?.
Ball joints or screw joints? Grease used?_
Kind of grease Pitot tube tip undamaged?
Pitot lines checked for leaks? Plugging?,
Meter box leveled? Pitot manometer zeroed?.
Orifice manometer zeroed? Probe markings correct?.
Probe hot along entire length? Filter compartment hot?
Temperature information available? Impingers iced down?.
Thermometer reading properly? Barometric pressure measured? _
If not, what is source of data AH@ from most recent calibration
AH@ from check against dry gas meter. .
Nomograph check:
If AH@ - 1.80, Tm - 100°F, % H20 - 10%, Ps/Pm - 1.00, C = X (0.95)
If C = 0.95, Ts - 200°F, DN = 0.375, Ap reference X (0.118)
Align Ap = 1.0 with AH-10;@ Ap = 0.01, AH X (0.1)
For nomograph set-up:
Estimated meter temperature X °F. Estimated value of Ps/Pm X
Estimated moisture content X %. How estimated? X
C factor X Estimated stack temperature X F.
Desired nozzle diameter X
Stack thermometer checked against ambient temperature?
Leak test performed before start of sampling? Rate CFM @ in.
FIGURE B-6 (Com.)
FIELD OBSERVATION CHECKLIST
B-9
-------
SAMPLING (Use one sheet for each run if necessary) Run #.
Probe-sample box movement technique:
Is nozzle sealed when probe is in stack with pump turned off?
Is care taken to avoid scraping nipple or stack wall?.
Is an effective seal made around probe at port opening? _
Is probe seal made without disturbing flow inside stack?.
Is probe moved to each point at the proper time?
Is probe marking system adequate to properly locate each point? _
Are nozzle and pitot tube kept parallel to stack wall at each point?—. _
If probe is disconnected from filter holder with probe in the stack on a negative pressure
source, how is particulate matter in the probe prevented from being sucked back into
the stack?
If filters are changed during a run, was any particulate lost? _
Meterbox operation:
Is data recorded in a permanent manner? Are data sheets complete?
Average time to reach isokinetic rate at each point -
Is nomograph setting changed when stack temperature changes significantly?,
Are velocity pressures (Ap) read and recorded accurately? .
Is leak test performed at completion of run? cfm @ in. Hg.
General comment on sampling techniques _ ..
If Orsat analysis is done, was it: From stack From integrated bag
Was bag system leak tested? Was Orsat leak tested?
Check against air?
If data sheets cannot be copied, record: aproximate stack temperature .
Nozzle dia.. in. Volume metercd ACF
First 8 Ap readings
FIGURE B-6 (Cont.)
FIELD OBSERVATION CHECKLIST
B-10
-------
SAMPLE RECOVERY
General environment-clean up area,
Wash bottle Hpan? Brushes clean? Brushes rusty?.
Jars Clean? Acetone grade Residue on evap. spec %
Filter handled OK? Probe handled OK? Impingers handled OK?
After cleanup: Filter holder clean?, Probe liner clean?
Nozzle clean? Impingers clean?__ Blanks taken?
Description of collected particulate . __,
Silica gel all pink? Run 1 _ Run 2 _ Run 3 ,
Jars adequately lahplpH? Jars sealed tightly? _ _
Liquid level marked on jars? Jars locked up?
General comments on entire sampling project:
Observer's name Title,
Affiliation . Signature.
FIGURE B-6 (Com.)
FIELD OBSERVATION CHECKLIST
B-ll
-------
SAMPLE CHAIN OF CUSTODY
Plant
Date Sampled Test number.
Run number.
Sample Recovery
Container Code Description
Person engaged in sample recovery
Signature
Title
Location at which recovery was done.
Date and time of recovery.
Sample(s) recipient, upon recovery if not recovery person
Signature —
Tide .
Date and time of receipt
Sample storage
Laboratory person receiving sample
Signature
Title
Date and time of receipt
Sample storage
Analysis
Date and time Signature of
Container code Method of analysis of analysis analyst
FIGURE B-7
SAMPLE CHAIN OF CUSTODY FORM
B-12
-------
SAMPLE TRANSPORT PARTICIPATE CHECKLIST
Samples are to be the direct responsibility of a senior member of the source test team until
the responsibility is transferred to the laboratory supervisor.
All liquid samples must be air-tight, the liquid level marked and stored upright properly to
prevent spillage or breakage.
All solid samples are sealed and stored to prevent the loss of samples or contamination from
the ambient sources.
All sample containers properly marked on outside to avoid rough handling during transport
of the sample to the laboratory.
All sample containers locked to insure the sample integrity during transport.
The sample log (chain of custody) is initiated during sample recovery to insure quality assur-
ance from the moment of collection.
FIGURE B-8
SAMPLE TRANSPORT PARTICULATE CHECKLIST
B-13
-------
ANALYTICAL PARTICULATE CHECKLIST
Analytical balance should be calibrated with Class S weights at the time of use.
Desiccator contains anhydrous calcium sulfate.
Filter and any loose particles from the sample container desiccated from 24 to 96 hours to
a "constant weight" means a difference of no more than 0.5 mg or \% of total weight less
tare weight, whichever is greater, between consecutive weighings, with no less than 6 hours
of desiccation time between weighings and no more than 2 minutes exposed to the labora-
tory atmosphere (must be less than 50% relative humidity) during weighing.
Record level of liquid in containers on analytical data sheet to determine if leakage occurred
during transport.
Blank filters desiccated to a constant weight. Blank weight should not vary from original
weight by more than ±1.0 mg.
Liquid in sample containers remeasured by the analyst either volumetrically to ± 1 ml or
gravimetrically to ±0.5 g.
Acetone rinse samples evaporate to dryness at ambient temperature and pressure in a tared
250 ml beaker. Prevent dust or objects from entering the beaker by placing a watch glass
over the beaker during evaporation.
The dried sample was desiccated to a constant weight and reported to the nearest 0.1 mg.
The acetone blank was analyzed simultaneously with the acetone rinse using the same pro-
cedures.
Silica gel was weighed to the nearest 0.5g using a balance in the field or laboratory.
Sample beakers covered with parafilm and stored along with used filters until report is ac-
cepted by control agency or until such time as specified by the agency.
Was analysis observed or checklist given to test team leader?
FIGURE B-9
ANALYTICAL PARTICULATE CHECKLIST
B-14
-------
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B-18
-------
Fuel (SIP)
Fuel type
Coal _
Oil _
Gas _
Other.
Percentage
Coal (classified by ASTMD 388-66)
Bituminous subbituminous
Coal feed measurement and location
Automatic conveyor scale
Batch weighing — dumping hoppers
Other (describe) _ _
anthracite
lignite
Location of scale „ _
None
Liquid fossil fuel
Crude residual distillate
Liquid fuel feed measurement and location
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Other (describe) _ . _
Location of meter _
None
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Natural gas propane butane
Gaseous fuel feed measurement and location
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Other (describe) _
other
FIGURE B-10 (Cont.)
FACILITY OPERATING PARAMETERS
DURING TEST PERIOD FOR A POWER PLANT
B-19
-------
Location of meter
None
Other fuel (describe)
Other fuel feed measured by
FUEL ANALYSIS
PROXIMATE ANALYSIS - As-fired solid and liquid fuels
Component
Moisture
Ash
Volatile Matter
Fixed Carbon
Sulfur
Heat value, BTU/lb
% by weight
Typical
Acceptable Range
or ultimate analysis - which includes the proximate analysis plus the following
Nitrogen .
Oxygen , .
Hydrogen
Carbon . —
FIGURE B-10 (Cont.)
FACILITY OPERATING PARAMETERS
DURING TEST PERIOD FOR A POWER PLANT
B-20
-------
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B-22
-------
FUEL INPUT DATA DURING TEST
Automatic weighing or metering
Counter (totalizer) Reading
Time Coal Oil Gas
End test
Begin test _ ^_^__ . _
Difference . . — — . —
Units fed during test ^__ _^_ _
Counter conversion factor .._
Fuel per counter unit tons gal. ft.3
Fuel fed during test tons gal ___^_. ft.3
Fuel sampled during test
Number of samples . -^^^ —^__
Total quantity of sample
Date of last calibration of
automatic metering device . -
Manual weighing or other procedure. Use this space for monitoring procedure and
calculations
FIGURE B-12
FORM FOR FUEL INPUT DATA DURING TEST
B-23
-------
-------
APPENDIX C
DATA SHEETS (ELECTROSTATIC PR ECI PIT AT OR, PARTICULATE SCRUBBER,
FABRIC FILTER, AND CENTRIFUGAL COLLECTOR)
ELECTROSTATIC PRECIPITATOR DATA SHEET -PARAMETERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE
Facilitv.
Monitor Name.
.Boiler No-
Test No. _
Design Efficiency
Test Date.
Recording Interval3
Sampling Time
(minutes)
0
Clock Time
(24 hr. clock)
Representative
design
Operating Voltage (kV)
Field Number
I
2
3
4
Operating Current (mA)
Field Number
1
2
3
4
Spark-
Rate
(Sparks/
minute)
Rapper timing/sequence:
Hopper ash removal sequence:
"Recording intervals — 15-30 minutes.
Representative,
During Test:
Representative.
During Test:
FIGURE C-1
DATA SHEET-ELECTROSTATIC PRECIPITATOR
C-1
-------
PARTICULATE SCRUBBER DATA SHEET - PARAMETERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE
Monitor Namp
HpsioTi EffiriRnr.v
Tpst
Tpst
Recording Interval3
Sampling Time
(minutes)
0
Clock Time
(24 hr. clock)
Static Pressure
(in. H20)b
Inlet
Outlet
Representative
Design
Pressure Drop
Across Scrubber
(in. H2O)
Water
Flow
Rate
(gPm)
a Recording intervals — 15-30 minutes.
If direct reading of pressure drop is not available.
FIGURE C-2
DATA SHEET-PARTICULATE SCRUBBER
C-2
-------
FABRIC FILTER DATA SHEET - PARAMETERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE
Facility
Monitor Name.
Boiler No.,
Test No. _
Design Efficiency.
.Test Date,
Recording Interval3
Sampling Time
(minutes)
Clock Time
(24 hr. clock)
Representative
Design
Pressure Drop
Across
Baghouse
(in. H20)
Design/lN
Temperature range of filter fabric
Pressure Drop
Across
Compartment
(in. H20)
1
ormal
Fan damper position
Fan current (amps)
Cleaning cycle
Total no. of bags in operation
2
3
4
5
During Test (flue gas temp.)
b
yes
yes.
, number
, number.
Are any bags blanked off?b no
Are any bags leaking?1* no
Recording intervals - 10 minutes. If a compartment is isolated sequentially for cleaning
throughout the test timing mechanisms, data readings should be synchronized with cleaning
cycle.
This information is generally not available. It can be obtained during boiler shut-down prior
to or after testing; however, for many constant demand-type boilers, this is not possible.
FIGURE C-3
DATASHEET- FABRIC FILTER
C-3
-------
CENTRIFUGAL COLLECTOR DATA SHEET - PARAMETERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE
Facility.
Monitor Name.
Boiler No-
Test No. _
Design Efficiency.
Test Date.
.
Pressure drop across
collector, in. H2O
Fan motor amperes
•~
Design
^
During test
Beginning
Mid-Point
End
Is the collector sectionalized with dampers for control of Ap
No Yes
If yes, how were dampers positioned during test?
Hopper ash removal sequence:
Representative. .
During test
FIGURE C-4
DATA SHEET - CENTRIFUGAL COLLECTOR
C-4
-------
APPENDIX D
PROCEDURES FOR STARTUP AND SHUTDOWN OF
ELECTROSTATIC PRECIPITATORS
General
1. Visually inspect the mechanical dust collector units, induced draft fans, and dust
handling equipment before the system is operated.
2. Close and secure all access hatches prior to operation.
3. Determine that all system internal areas are completely free of tools, scrap, and
foreign material before the fan(s) is started.
4. Verify that primary power is available to thermostatically controlled heaters if
provided. Circuit breakers for this equipment may have to be energized several
hours prior to system operation.
5. Check all interlocks and voltage control modules.
6. Check main off/test selector switch and place in off position.
7. Check grounding connections.
Rapper System
1. Ground the power unit in the control cubicle.
2. Check distributor switch rapper connections.
3. Check ground return leads for proper connections to sectionalized control
adjustments.
4. Check for proper mechanical adjustment.
5. Adjust each manual sectional control for proper rapping intensity.
6. Check spark rate feed circuit and signals for proper connections.
Rectifiers and Transformers
1. Check all connections, switches, and insulators.
2. Check oil (liquid) levels.
D-l
-------
3. See that high-tension duct vent ports are installed and free.
4. Be sure grounds are completed on transformer-rectifiers, bus duct, and conduits.
Routine Start-Up
If hot gases are to be passed through the precipitator, the system should be warmed up to
operating temperature before gas flows are started.
1. All inspection ports should be closed and dampers adjusted for proper air flow.
2. In wet precipitators, the liquid supply should be turned on and adjusted.
3. High-voltage current should be energized.
4. Start collector and discharge electrode rappers if provided on the system.
5. Turn on product discharge system.
6. Bring fan to full rpm with exit damper closed.
7. Adjust damper for desired gas flow.
8. Record system pressure drop and fan pressure drop.
If the system is not equipped with external heating facilities, reverse the procedures so that
the inlet gases enter before the precipitator is energized. When the precipitator reaches
operating temperature, turn on the high-voltage power.
Most wet scrubbers operate in a similar manner, such that their prestart-up and start-up
procedures are similar. These procedures are as follows:
Prestart-Up Checkout
After installation of equipment is complete, it is advisable to provide about a 2-week
shakedown period in order to be assured that the system is ready for routine start-up. Some
of the items always checked are the following:
1. Bump pumps and fans to check rotation.
2. Disconnect pump suction piping where possible and flush system'with external
sources of water.
D-2
-------
3. Install temporary strainers in pump suctions and commence liquid recycle. These
strainers may be mesh cones installed directly in the lines.
4. With recycle flow on, set valves to determine operating positions for desired flow
rates. Noting valve position at this time is useful in determining pump wear during
operation.
5. The fan is dynamically balanced by the fan vendor and checked for vibration.
Two or three mils is usually an acceptable vibration amplitude.
6. Check and record all system pressure drops under these "clean conditions."
7. Check instrumentation for liquid in impulse lines, level recorder, and other places.
8. Check and follow all lubrication instructions.
9. Shut down fan, drain system, inspect internals, and remove temporary strainers.
10. Review operating instructions with all appropriate plant personnel.
Routine Start-Up
1. Allow vessels to fill with liquid through normal level controls if practical.
Frequently, large volume basins such as thickeners must be filled from external
sources.
2. Start control liquid to all pump glands and fan sprays.
3. Start recycle pumps with liquid bleed closed.
4. Check system isolation dampers and place scrubber in series with primary
operation.
5. Start fan and check vibration. If fan has an inlet control damper, it should be
normally closed until fan reaches speed, usually between one and two minutes.
6. Check most important operating variables, i.e., gas saturation, liquid flows, liquid
levels, fan pressure drop, duct pressure drops, and scrubber pressure drop.
7. Slowly open bleed to pond, thickener or other drain system so that slurry
concentration is allowed to build up slowly. Check final concentration as a
cross-check on bleed rate calculation.
D-3
-------
Routine Shutdown
1. Shut down fan and fan spray water and isolate scrubbing system from operation.
2. Allow liquid system to operate for as long as practical. This will cool the scrubber
and will reduce scrubbing liquid slurry concentrations.
3. Shut off makeup water to system allowing system to bleed normally.
D-4
-------
APPENDIX E
PROCEDURES FOR TROUBLESHOOTING AND CORRECTION OF
BAGHOUSE MALFUNCTIONS
(RP—reverse pulse; PR—plenum pulse; S—shaker; RF—reverse flow)
SYMPTOM CAUSE REMEDY
High baghouse
pressure drop
Baghouse undersized
Bag cleaning mechanism
not adjusted properly
Compressed air pressure
loo low (RP, PP)
Repressuring pressure
too low (RF)
Shaking not strong enough
(S)
Isolation damper valves
not closing (S, RF, PP)
Bag tension too loose
(S)
Pulsing valves failed (RP)
Cleaning timer failure
Consult manufacturers.
Install double bags.
Add more compartments or
modules.
Increase cleaning frequency.
Clean for longer duration.
Clean more vigorously.
Increase pressure.
Decrease duration and/or
frequency.
Check dryer and clean if
necessary.
Check for obstruction in piping.
Speed up repressuring fan.
Check for leaks.
Check damper valve seals.
Increase shaker speed.
Check linkage.
Check seals.
Check air supply on pneumatic
operators.
Tighten bags.
Check diaphragm.
Check pilot valves.
Check to see if tinier is indexing
to all contacts.
Check output on all terminals.
E-l
-------
SYMPTOM
CAUSE
REMEDY
Not capable of removing
dust from bags
Condensation on bags (see
below).
Send sample of dust to manu-
facturer.
Send bag to lab for analysis for
binding.
Dry clean or replace bags.
Reduce air flow.
Low fan motor
amperage/low
air volume
Excessive re-entrainment
of dust
Incorrect pressure reading
High baghouse
Fan and motor sheaves
reverse
Continuously empty hopper.
Clean rows of bags randomly,
instead of sequentially
(PP, RP).
Clean out pressure taps.
Check hoses for leaks.
Check for proper fluid in
manometer.
Check diaphragm in gage.
See above.
Check drawings and reverse
sheaves.
Ducts plugged with dust
Clean out ducts and check duct
velocities.
Fan damper closed
System static pressure
too high
Fan not operating per
design
Belts slipping
Open damper and lock in
position.
Measure static on both sides of
fan and review with design.
Duct velocity too high.
Duct design not proper.
Check fan inlet configuration
and be sure flow is even.
Check tension and adjust.
E-2
-------
SYMPTOM
Dust escaping at
source
Dirty discharge
at stack
CAUSE
Low air volume
Ducts leaking
Improper duct balancing
Improper hood design
Bags leaking
Bag clamps not sealing
Failure of seals in joints
at clean/dirty air
connection
Insufficient filter cake
Bags too porous
REMEDY
See above.
Patch leaks so air does not bypass
source.
Adjust blast gates in branch
ducts.
Close open areas around dust
source.
Check for cross drafts that over-
come suction.
Check for dust being thrown
away from hood by belt, etc.
Replace bags.
Tie off bags and replace at later
date.
Isolate leaking compartment if
allowable without upsetting
system.
Check and tighten clamps.
Smooth out cloth under clamp
and re-clamp.
Caulk or weld seams.
Allow more dust to build up on
bags by cleaning less fre-
quently.
Use a precoating of dust on bags
(S, RF).
Send bags in for permeability
test and review with manu-
facturer.
E-3
-------
SYMPTOM
CAUSE
REMEDY
Excessive fan
wear
Excessive fan
vibration
High compressed
air consumption
Fan handling too much
dust
Improper fan
Fan speed too high
Buildup of dust on blades
Wrong fan wheel for
application
Sheaves not balanced
Bearings worn
Cleaning cycle too
frequent
Pulse too long
Pressure too high
Damper valves not sealing
(PP)
Diaphragm valve failure
See above.
Check with fan manufacturer to
see if fan is correct for
application.
Check with manufacturer.
Clean off and check to see if fan
is handling too much dust
(see above).
Do not allow any water in fan
(check cap, look for con-
densation, etc.).
Check with manufacturer.
Have sheaves dynamically
balanced.
Replace bearings.
Reduce cleaning cycle if possible.
Reduce duration (after initial
shock, all other compressed
air is wasted).
Reduce supply pressure if
possible.
Check linkage.
Check seals.
Check diaphragms and springs.
Check pilot valve.
E-4
-------
SYMPTOM
CAUSE
REMEDY
Reduced compressed
air pressure (RP, PP)
Compressed air
consumption too high
Restrictions in piping
Dryer plugged
See above.
Check piping.
Replace dessicant or bypass dryer
if allowed.
Premature bag
failure —
decomposition
Moisture in
baghouse
Supply line too small
Compressor worn
Bag material improper
for chemical composi-
tion of gas or dust
Operating below acid
dew point
Insufficient preheating
Consult design.
Replace rings.
Analyze gas and dust and check
with manufacturer.
Treat with neutralizer before
baghouse.
Increase gas temperature.
Bypass at start-up.
Run system with hot air only
before starting process gas
flow.
System not purged after
shut-down
Keep fan running for 5-10
minutes after process is
shut down.
Wall temperature below
dew point
Cold spots through
insulation
Compressed air
introducing water
(RP, PP)
Raise gas temperature.
Insulate unit.
Lower dew point by keeping
moisture out of system.
Eliminate direct metal line
through insulation.
Check automatic drains.
Install aftercooier.
Install dryer.
E-5
-------
SYMPTOM
CAUSE
REMEDY
High screw
conveyor wear
High air lock wear
Material bridging
in hopper
Frequent screw
convey or/air lock
failure
Repressuring air causing
condensation (RF, PP)
Screw conveyor under-
sized
Conveyor speed too high
Air lock undersized
Thermal expansion
Speed too high
Moisture in baghouse
Dust being stored in
hopper
Preheat repressuring air.
Use process gas as source of
repressuring air.
Measure hourly collection of dust
and consult manufacturer.
Reduce speed.
Measure hourly collection of dust
and consult manufacturer.
Consult manufacturer to see if
design allows for thermal
expansion.
Reduce speed.
See above.
Remove dust continuously.
Hopper slope insufficient Rework or replace hoppers.
Conveyor opening too
small
Equipment undersized
Screw conveyor
misaligned
Overloading components
Use a wide flared trough.
o
Consult manufacturer.
Align conveyor.
Check sizing to see that each
component is capable of
handling a 100% delivery
from screw conveyor.
E-6
-------
SYMPTOM
High pneumatic
conveyor wear
Pneumatic con-
veyor pipes
plugging
CAUSE
Pneumatic blower too
fast
Piping undersized
Elbow radius too short
Overloading pneumatic
conveyor
REMEDY
Reduce blower speed.
Review design and reduce speed
of blower or increase pipe
size.
Replace with long radius elbows.
Review design.
E-7
-------
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