United States
Environmental Protection
Agency    '
Office of Air Quality     EMB R6POrt 80-BYC-T
Planning and Standards   March 1981
Research Triangle Park NC 27711
Air
Benzene
Coke Oven By-Product
Plants

Emission Test Report
Bethlehem Steel
Bethlehem,
Pennsylvania

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vvEPA
           United States
           Environmental Protection
           Agency
          Office of Air Quality    EMB Report 80-BYC-l
          Planning and Standards   MiTCh 1981
          Research Triangle Park NC 27711
           Air
Benzene
Coke Oven By-Product
Plants

Emission Test  Report
Bethlehem Steel
Bethlehem,
Pennsylvania

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                            SET 1957 05 1280
                        BENZENE SAMPLING PROGRAM
                   AT COKE BY-PRODUCT RECOVERY PLANTS:
                       BETHLEHEM STEEL CORPORATION
                         BETHLEHEM, PENNSYLVANIA
                        EPA Contract 68-02-2813
                          Work Assignment 48
                            ESED Number 74/4J
                              Prepared For:

                            Mr. Daniel Bivins
                  U. S. Environmental Protection Agency
              Office of Air Quality Planning and Standards
                Emission Measurement Branch, ESED, MD-13
              Research Triangle Park, North Carolina 27711
                               March 1981
                      SCOTT ENVIRONMENTAL SERVICES
                              A Division Of
                  SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
                  Plumsteadville, Pennsylvania  18949
Scott Environmental Technology Inc.

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                             TABLE OF CONTENTS
                                                                      Page
1.0  INTRODUCTION	   1-1
2.0  SUMMARY OF RESULTS	   2-1
3.0  RESULTS AND DISCUSSIONS	   3-1
     3.1  COOLING TOWER	   3-1
     3.2  TAR DECANTER	   3-4
     3.3  LIGHT OIL CONDENSER VENT	   3-6
     3.4  NAPHTHALENE DRYING TANK	   3-8
     3.5  DENVER FLOTATION UNITS  	   3-10
     3.6  NAPHTHALENE MELT PIT	   3-14
4.0  PROCESS DESCRIPTIONS 	   4-1
5.0  FIELD SAMPLING AND ANALYSIS METHODOLOGY  	   5-1
     5.1  DETERMINATION OF BENZENE FROM STATIONARY SOURCES:
          EPA METHOD 110 AND MODIFICATIONS	   5-1
     5.2  TRACER TESTING	   5-4
     5.3  SAMPLE HANDLING	   5-4
     5.4  FIELD ANALYSIS	   5-5
6.0  FIELD SAMPLING PROCEDURES  	   6-1
     6.1  COOLING TOWER-DIRECT WATER FINAL COOLER 	   6-1
     6.2  TAR DECANTER	   6-3
     6.3  LIGHT OIL CONDENSER VENT	   6-5
     6.4  NAPHTHALENE DRYING TANK	   6-7
     6.5  DENVER FLOAT UNITS  	   6-11
     6.6  NAPHTHALENE MELT PIT	   6-16
7.0  LABORATORY SAMPLE ANALYSIS 	   7-1
     7.1  SAMPLE PREPARATION  	   7-1
     7.2  PURGE AND TRAP PROCEDURE FOR EXTRACTION OF BENZENE FROM
          LIQUID PHASE TO GASEOUS PHASE 	   7-2
     7.3  GAS CHROMATOGRAPH	   7-4
8.0  QUALITY CONTROL AND QUALITY ASSURANCE  	   8-1
     8.1  FIELD ANALYSIS PROCEDURES 	   8-1
     8.2  PROCEDURES FOR ANALYSIS OF PROCESS LIQUIDS  	   8-2
Scott Environmental Techndosy Inc

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                             Table of Contents
                                (Continued)
                                                                      Page
APPENDIX A - SAMPLE CALCULATIONS	    A-l
APPENDIX B - FIELD DATA SHEETS	    B-l
APPENDIX C - LABORATORY DATA SHEETS	    C-l
APPENDIX D - TRACER GAS METHOD DEVELOPMENT 	    D-l
APPENDIX E - FIELD AUDIT REPORT  	    E-l
APPENDIX F - PROJECT PARTICIPANTS  . .  .	    F-l
APPENDIX G - EPA METHOD 110	    G-l
 Scott Environmental Technology Inc.

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     SET 1957 05  1280                                            Page 1-1






                                1.0   INTRODUCTION






               Scott Environmental Services,  a  division  of  Scott Environmental




     Technology,  Inc.  conducted a testing  program at Bethlehem Steel  Cor-




     poration,  Bethlehem,  Pennsylvania  to  determine benzene emissions from




     six sources  in the coke byproduct  recovery plant.   The work was  per-




     formed for the United States Environmental Protection  Agency,  Emissions




     Measurement  Branch,  under  Contract No.  68-02-2813,  Work Assignment  48.




     Data collected from this plant  and six  others are being used  for the




     development  of a  possible  National Emission Standard for  Hazardous




     Air Pollutants for benzene.




               Sampling was conducted at Bethlehem Steel from  July  7th to




     24th,  1980.   Integrated air samples and liquid samples for benzene




     analysis were collected from the following processes:   Denver




     flotation  unit, naphthalene melt pit, naphthalene drying  tank,




     cooling tower - direct water final cooler, light oil condenser vent,  and




     the tar decanter  from #5 battery.
Scott Environmental Technology Inc.

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    SET 1957 05 1280
                                       Page 2-1
    Process
    Cooling Tower
    Tar Decanter
    Light Oil Condenser Vent
    Naphthalene Drying Tank
    Denver Float Units
    Naphthalene Melt Pit
2.0  SUMMARY OF RESULTS
                 Benzene Emission Rate
                   Ib/hr.     kg/hr.
                   73.4       33.3
                    2.6        1.2
                   28.8       13.1
                    0.04*      0.02*
                   28.2       12.8
                   19.8*       9.0*
    *Not a continuous process.
Scott Environmental Technology Inc.

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SET 1957 05 1280              '                                 Page 3-1









                      3.0  RESULTS AND DISCUSSIONS




3.1  COOLING TOWER




          The cooling tower circulates the hot water from the direct water




final coolers after the naphthalene is removed via the Denver float units.




The tower is about 30 feet high and has four 13-foot diameter fans on top




for pulling air countercurrent to the falling water.  Benzene which is




contained in the final cooler water is in part released as a vapor as it




passes downward through the cooling tower.  This benzene is picked up as




a contaminant in the final cooler spray towers.




          The three tests run on the cooling tower were fairly consistent,




ranging from 66 to 79 lb/hr., with an average result of 73.4 Ib/hr.  The




stack velocities for each run reported in Table 3-1 are an average of the




velocities measured across the 24-point traverse.  The velocities measured




were generally lower near the stack wall and in the center over the hub of




the fan, as would be expected.  Field data (showing the measured velocities)




can be found in Appendix B.




          All stack flow rates were corrected to the average conditions at




which the benzene concentrations were measured in the Tedlar bags; assumed




to be saturated at 68°F and 29.92 inches Hg (2 1/2 % moisture).  Example




calculations are shown in Appendix A.




          Liquid samples were collected from the hot and cold wells.  Average




benzene concentrations were 6.8 ppm and 3.5 ppm respectively.  The hot and




cold well temperatures were 86°F and 82°F, indicating that the cooling tower




was not really cooling the water significantly, and as noted on page 6-1,
Scott Environmental "fechnotasy Inc

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                                                TABLE 3-1
                                        COOLING TOWER DATA SUMMARY
Process:  Cooling Tower-direct water final cooler           Stack Diameter:  13
Plant:  Bethlehem Steel, Bethlehem, PA                      Stack Area:  133 ft.
                                                        Flowrate    Flowrate
                          Stack  Barometric  Stack      Stack       Standard
feet (1 of 4 stacks)
2
Benzene  Benzene
Concen-  Emission
                               vo
                               Ul
o
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Run
No.
1
2
3


Sample Temp.
Date Period °F
7/10/80 1034-1140 84
7/10/80 1150-1255 84
7/10/80 1417-1520 83


Standard conditions: Saturated
LIQUID
Sample
SAMPLE DATA SUMMARY
Location
Hot Well
Cold Well
Pressure
(in. Hg)
29.58
29.58
29.56


at 68°F,
Date
7/10/80
7/10/80
Velocity
(ft/min.)
870
905
860


29.92 in Hg.
Time
15:40
15:45
Conditions Conditions
(ACFM) (SCFM)
115,000 109,000
120,000 114,000
114,000 108,000



Sample Temp.
86°F
82°F
tration
(ppm)
12.56
14.38
14.27



Benzene
(ppm by
I'.l] AV<
3-2) .
Rate g
(Ib/hr) °
1 Fan 4 Fans
16.6 66.2
19.9 79.5
18.6 74.5
Ave.
73.4

Concentration
weight)
jrage 6.8

                                                                                                               TO
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SET 1957 05 1280                                              Page 3-3









was due to the malfunction of a faulty level control.  Past plant operating




experience shows that an average temperature reduction from 86°F to 76°F is




experienced during the summer months and from 62°F to 48°F during the




winter months.
Scott Environmental Technolosy Inc.

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SET 1957 05 1280                                              Page 3-4









3.2  TAR DECANTER




          The. tar decanter collects tar and flushing liquor from the #5




battery and from the primary coolers.  It is allowed to settle and the




flushing liquor is decanted off the top while the tar is drained from the




bottom.  The decanter is vented to the atmosphere, and is a potential




benzene emission source.




          The average result for the tar decanter emissions is 2.6 lb/hr.,




with a range of 1.4 to 3.7 lb/hr.  Velocities measured were quite consistent




over all three runs but the concentration of benzene differed considerably,




as shown in Table 3-2.  The large differences between sample runs is




probably due to fluctuations or changes in the process feed streams, as




the samples were not all collected on the same day.




          Liquid samples were collected at three locations:  The surface




liquid in the decanter, the inlet to the decanter from the coke gas cross-




over main from the #5 battery, and the inlet to the decanter from the




primary cooler.  Average benzene concentrations in the liquid samples were:




In the surface samples - 1.6 ppm, in the crossover main samples - 4.9 ppm,




and in the primary cooler samples - 16.4 ppm in the light fraction (flushing




liquor) and 1810 ppm in the heavy fraction (tar).
Scott Environmental Technology Inc.

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%^ TAR DECANTER DATA SUMMARY
Jv Process: Tar Decanter - #5 battery
^ Plant: Bethlehem Steel, Bethlehem, PA
1
t Stack Barometric
Run Sample Temp. Pressure
No. Date Period (°F) (in.Hg)
? 1 7/8/80 1453-1523 158 29.53
2 7/9/80 1020-1121 161 29.71
3 7/9/80 1530-1600 163 29.67
Standard Conditions: 68°F, 29.92 inches Hg.
LIQUID SAMPLE DATA
Sample Location
Flushing liquor on surface
Flushing liquor inlet from coke
gas crossover main
Inlet to decanter from primary cooler
Heavy fraction (tar)
Light fraction (liquor)
Stack Diameter: 10-1/8"
2
Stack Area: 0.559 ft.

Stack
Velocity
(ft/min.)
500
490
490

Date
7/8/80
7/8/80
7/9/80
7/9/80
7/9/80

Flowrate
Stack
Conditions
(ACFM)
280
275
280

Time
1525
1600
1415
1545
1545

Flowrate Benzene
Standard Concen-
Conditions tration
(SCFM) (ppra)
170 1447.2
160 717.8
150 1975.0

Sample Temp. ( F)
176
180
N.A.
140
140

Benzene
Emission
Rate
(Ib/hr)
2.9
1.4
3.6
Ave.
2.6
Benzene Cone.
(ppm by Weight)
5.6
4.2 Ave. 4.9
1.6
1736
1888 Ave*
16.4 . ., ,
16.3 Ave' 16'4
w
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H
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   SET 1957 05 1280                                             Page 3-6






   3.3  LIGHT OIL CONDENSER VENT






              Benzene in  the wash oil is removed by heating  the wash




   oil and condensing out  the benzene.  Noncondensibles  in the wash




   oil, possibly including some benzene, are vented to the atmosphere.




   For this reason the  light oil condenser vent was considered a




   potential benzene emission source.




              The average  of the three  good runs on the  light oil




   condenser vent (Run  3 was voided) was 28.8 lb/hr., as shown in




   Table  3-3.  Although the flow rate was very low, the  benzene con-




   centration was approximately 10% so  the mass emission rates were




   comparable to higher flow sources.
Scott Environmental Technology Inc.

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n
5T
                                                TABLE 3-3
                                  LIGHT OIL CONDENSER VENT DATA SUMMARY
Process:  Light Oil Condenser Vent                                 Stack Diameter:  6"
Plant:  Bethlehem Steel, Bethlehem, PA                             Stack Area:  0.20 ft,
         *Run 3 not included in calculations due to sampling system leak.
         Standard Conditions:   Saturated at 68°F,  29.92 in.  Hg.
         NOTE:  No liquid samples were taken at this source.
                                                                                                                   w
                                                                                                                   H
Run
No.
1
2
3
4


Date
7/11/80
7/11/80
7/11/80
7/11/80


Sample
Period
1015-1045
1056-1126
1212-1242
1600-1630


Stack
Temp.
(°F)
95
96
109
104


Barometric
Pressure
(in. Hg)
29.51
29.51
29.51
29.49


Stack
Velocity
(ft/min.)
120
130
120
120


Flowrate
Stack
Conditions
(ACFM)
24
25
23
24


Flowrate
Standard
Conditions
(SCFM)
23
23
21
22


Benzene
Concen-
tration
(ppm)
91,900
109,800
53,300
110,500


Benzene
Emission
Rate
(Ib/hr.)
25.3
31.1
*
29.9
Ave.
28.8
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   SET 1957 05 1280                                             Page 3-8






   3.A  NAPHTHALENE DRYING TANK






              The drying tank collects the melted naphthalene after




   the melt process, and steam is applied to the tank to drive off any




   water present in the naphthalene.  This is a batch process and runs




   for approximately 12 to 14 hours, during which time benzene is




   emitted along with the steam, through the open process vents on the




   tank.




              Testing the" naphthalene drying tank involved a special test




   modification using impingers which is described in detail in Section




   6.4.  The test method was given a trial run on July 18, and the




   resulting total emission rate (stack plus vent) was 1.57  Ib/hr.  A




   series of 8 tests were run on July 22 over a 15-hour period, and the




   average for these runs was 0.04 Ib/hr.  The results of the 8 tests




   varied widely since the drying cycle is a batch process.  As expected,




   the emissions dropped off as the cycle progressed and the water was




   driven off the naphthalene, and emissions increased when the tank




   temperature increased, as seen in Table 3-4.  Vent "A" refers to the




   process vent stack, and "B" is the large opening in the tank for steam




   lines, which was tested as a vent.




              The benzene emissions from the drying tank vary widely from




   day to day depending on how long the naphthalene was heated in the




   melt pit prior to transferral to the drying tank.  Ideally the melt




   process and the drying tank should be sampled on the same day to de-




   termine benzene emissions from the naphthalene handling processes as




   a whole.











Scott Environmental Technology Inc.

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                                                 TABLE  3-4

                                    NAPHTHALENE DRYING  TANK DATA SUMMARY
Process : Naphthalene Drying Tank
Plant: Bethlehem Steel, Bethlehem, PA
Run
No.
T
1
2
3
4
5
6
7
8

Date
7/18/80
7/22/80
7/22/80
7/22/80
7/22/80
7/23/80
7/23/80
7/23/80
7/23/80

Test
Period
1353-1423
1337-1410
1610-1640
1813-1843
2130-2200
2415-2445
0220-0300
0255-0320
0404-0455

Stack
Temp.
206
209
210
202
195
192
190
210
199

Stack
Velocity
(fpm)
A B
630 350
850 610
730 110
690 *
590 *
540 *
590 *
780 100
660 *

Stack Diameter: A:
Stack Area: A:
Barometric Pressure
Stack
Flowrate
(ACFM)
A
120
170
140
140
110
110
120
150
130

B Total
560 680
980 1150
170 310
* 140
* 110
* 110
* 120
250 400
* 130

6" B: 22"
0.196 ft2 B: 1.6 ft.
: 29.5 in. Hg.
Standard Benzene
Flowrate Concen-
(SCFM) tration
Total (ppm)
71
106
3
18
27
27
34
14
22

1824
168.60
428.11
32.34
16.09
40.78
45.40
218.16
117.05

Benzene
Emission
Rate
(Ib/hr.)
1.57
0.217
0.016
0.007
0.005
0.013
0.019
0.037
0.032
Ave. 0.043
                                                                                                                  to
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                                                                                                                  OO
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Standard Conditions:  Saturated at 68 F, 29.92 in. Hg.
NOTE:  No liquid samples were collected at  this source.
* No flow detected with anemometer.
                                                                                                                  Pi
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    SET  1957  05  1280                                             Page 3-10






    3.5   DENVER  FLOTATION  UNITS






              The  Denver  units  skim naphthalene from the surface of the




    hot  water collected  from the final  coolers.  The skimming is accom-




    plished by blades  rotating on a shaft  that spans the length of  the




    flotation tank.  The system  is comprised of four adjacent units, three




    of which  are in operation at any given time.  This  is a  constant




    operation and constitutes a  potential  benzene emission source because




    the  impure naphthalene is contaminated with benzene and  the Denver




    units are agitated and at temperatures above ambient level.




              The  results of the tests of the Denver float  units are




    presented in Table 3-5.   The tracer gas sampling strategy and sampler




    locations for each test are  detailed in Section 6.5.  Each test




    consisted of two runs, with  the second run designed to estimate the




    contribution of the  unit adjacent  to the test unit  (#2)  to the




    total being  measured from the test  unit (#1).  This became irrelevant




    in  tests  2 and  3 because unit 2 was not in operation.




              In tests  2  and 3  the data from sampler 3 was  rejected




    because the  sampler  was inadvertently  located adjacent to a "hot




    spot" benzene emission point in the naphthalene melt pit.




              In each test the  benzene/isobutane ratio is lower for the




    center sampler  than  the outer samplers. This would be expected




    because the  tracer discharge manifold  was not long  enough to cover




    the entire tank axis.   Thus, the center portion of  the tank shows a




    higher relative isobutane concentration.
Scott Environmental Technology Inc.

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  SET 1957  05 1280
                                                        Page 3-11
                                   TABLE 3-5

                               DENVER FLOAT UNITS
  Test 1, Run 1
  Tracer on Tank //I
  Isobutane release rate - 1.39 Ib/hr
                                       Denver Units Operating: 1, 2, 3
                                       Date:  7/8/80
                                       Test Start:  11:24
  Sample
  Loc.

    1
    2
    3
Cone, of
Benzene
(ppm)

  3.51
  8.61
 14.51
Cone, of
Isobutane
(ppm)

  0.50
  1.72
  2.02
Mass to Mass
Ratio d>/ic,
	1	4_^

   9.38
   6.73
   9.66
  F*
Ib/hr
Benzene
 0.739     9.60
 0.789     7.35
 0.665     8.91
kg/hr
Benzene

 4.36
 3.34
 4.05
  Test 1,  Run 2
  Tracer on Tank #2
  Isobutane. release rate - 1.25 Ib/hr
                                                     Avg. 8.62  Avg. 3.92
                                       Date:   7/8/80
                                       Test Start:  12:09
1
2
3
3.03
7.69
16.61
0.15
0.40
1.13
  Test  2,  Run 1
  Tracer on Tank #1
  Isobutane release  rate  -  1.27 Ib/hr
                                      Denver Units Operating: 1, 3, 4
                                      Date:  7/15/80
                                      Test Start:  10:30
    1
    2
    3
  5.16
  5.42
18.96
  1.02
  1.09
  1.16
   6.80
   6.68
  21.94**
1.00     8.64
1.00     8.48
1.00    27.86**
           3.93
           3.85
          12.66**
 Test 2, Run  2
 Tracer on Tank #2
 Isobutane release rate - 1.25
                                         Avg.  8.56   Avg. 3.89


                                       Date:   7/15/80
                                       Test Start:   11:19
   1
   2
   3
 4.42
 5.68
18.45
 0.20
 0.48
 2.40
 * Fraction from Tank #1.

** Data rejected, interference from another source.
 Scott Environmental Technology Inc.

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SET 1957 05 1280
                                                       Page 3-12
                                 Table 3-5
                                (Continued)
Test 3, Run 1
Tracer on Tank #2
Isobutane release rate - 1.28 Ib/hr
                                      Denver  Units  Operating:  1,  3,  4
                                      Date:   7/15/80
                                      Test  Start:   13:30
Sample
LOG.

  1
  2
  3
Cone, of
Benzene
(ppm)

  7.13
  8.39
 14.00
Cone, of
Isobutane
  0.22
  0.50
  1.97
Mass to Mass
Ratio 4>/ic,
                            F*
        Ib/hr
        Benzene
         kg/hr
         Benzene
Test 3, Run 2
Tracer on Tank 1
Isobutane release rate 1.28 Ib/hr
                                       Date:   7/15/80
                                       Test Start:   14:00
  1
  2
  3
  6.64
  7.16
 13.67
  0.95
  1.26
  1.24
   9.45
   7.66
  14.83*
1.00
1.00
1.00
12.10
 9.80
18.98**
5.5
4.45
8.63**
                                                   Avg. 10.95 Avg. 4.98
 * Fraction from Tank #1.
** Data rejected, interference from another source.
Scott Environmental Technology Inc.

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     SET  1957  05  1280                                            Page 3-13






               The benzene  emission  rates for a  typical Denver Float Unit




     tank were determined to be  8.6,  8.6 and 11.0 pounds per hour.  While




     statistical  determination of  confidence limits is not possible, the




     relative  good agreement of  data points and  the small estimated error




     due  to  the assumptions made in  the calculations lead to the judgment




     that the  emission  rates are within one pound per hour of the true rate




     at each process/ambient condition tested.   The total emissions from the




     Denver  unit  with three tanks  in operation would be 26, 26 and 33 pounds




     per  hour.




               Test  3 was performed  on the same  day as Test 2 and under the




     same experimental  conditions  except that the ambient temperature was




     approximately 5 F  higher in Test 3.  A comparison of corresponding




     Test 2  and Test 3  data (2-1 to  3-2 and 2-2  to 3-1) shows that the




     isobutane tracer concentration  changed very little from test to test.




     Yet, the  benzene is clearly higher at Sampling Locations 1 and 2 in




     each case.   This indicates  that the higher  emission rates in Test 3




     can  be  attributable to the  higher ambient temperature.
Scott Environmental Techndosylnc

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     SET 1957 05 1280                                            Page 3-14







     3.6  NAPHTHALENE MELT PIT







               The melt pit collects the naphthalene slurry that was skimmed




     off in the Denver units, and once a day steam is applied to melt the




     naphthalene to facilitate pumping into a drainage tank.  Benzene con-




     tained in the naphthalene cake is released when the steam is applied




     to the melt pit.




               The results of the four tracer gas tests on  the naphthalene




     melt pit during melt operations are shown in Table 3-6.  For each test




     the first half-hour.run was conducted while the cake was still melting.




     The second run was made after ammonium sulfate salt had been added to
                                               *



     the melt and prior to its being pumped to the drying tank.  There are




     considerable test to test differences in benzene emission rates.




     It is believed that the differences are real, and that they are the




     result of variations in the process step timing, the portion of the




     process cycle sampled and ambient conditions.




               A test was performed on 7/17/80 after the melt was com-




     pleted and the pit was beginning to refill.  The results of this test




     are presented in Table 3-7.  This test serves as the basis for estimates




     of emissions from the pit at times other than when the melt was in




     progress.  This test was planned to assess the contribution of the




     Denver float unit to the melt pit emissions measured during the melt




     cycle.  However, it became apparent that the melt pit made a substantial




     contribution to the benzene found in this test.  On 7/22/80, three sets




     of grab air samples were collected over the melt pit at ground level.




     The results areas follows.
Scott Environmental Technology Inc.

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SET 1957 05  1280
                       Page  3-15
                                 TABLE 3-6

                           NAPHTHALENE MELT PIT
Date:  7/15/80
Tracer Test #1, Run #1
Test Start - 8:00 a.m.
Isobutane Emission Rate:  1.16 Ib/hr
                          0.53 kg/hr
Weather Conditions:  Wind SSW 0-5 mph
                     Temp  75°F
Cone, of Cone, of
Sample Benzene Isobutane Mass to Mass Ib/hr kg/hr
Loc. (ppm) (ppm) Ratio 4>/ic, Benzene . Benzene
1 11.48
2 17.54
3 16.58
Upwind 0.71
Date: 7/15/80
Tracer Test #1,' Run #2
Test Start - 8:35 a.m.

1 ' 9.45
2 13.48
3 14.90
Upwind 1.03

Date: 7/16/80
Tracer Test #2, Run #1
Test Start: 7:30 a.m.

1 14.99
2 15.18
3 10.22
Upwind 1.02

Date: 7/16/80
* Tracer Test #2, Run #2
Test Start - 8:09 a.m.

1 11.35
2 5.48
3 8.87
Upwind 0.77

* Run voided due to leak
0.713
1.02
0.93
ND



0.977
1.32
1.49
ND

21.66 25.13
23.06 26.75
23.97 , 27.81
Avg. 26.56 Avg.
Isobutane Emission Rate:
• •
Weather

13.01
13.75
13.45



Cond i t ions : Wind
Temp
15.10
15.95
15.60

Avg. 15.55 Avg.
Isobutane Emission Rate:



1.25
1.52
0.754
ND


Weather

16.16
13.41
18.24



Conditions: Wind
Temp
20.86
17.16
23.35

Avg. 20.46 Avg.
Isobutane Emission Rate:



1.54
2.12
1.39
ND

in flowmeter.

Weather

9.93
3.47
8.57
—



Conditions: Wind
Temp
11.22
4.55
11.23

Avg. 9.00* Avg.

11.42
12.16
12.64
12.07
1.16 Ig/hr
0.53 kg/hr
SSW 0-5 mph
75°F
6.86
7.25
7.09

7.07
1.28 Ib/hr
0.58 kg/hr
SSW
75°F
9 .40
7.80
10.61

9.30
1.31 Ib/hr
0.60 kg/hr
SSW
75°F
5.10
2.07
5.10

4.09*

• f-fty
^\j Scott Environmental TechnoJosy '"C-
••T**

-------
SET 1957 05  1280
                       Page 3-16
                                 TABLE  3-6
                                (Continued)
Date:  7/17/80
Tracer Test #3, Run #1
Test Start - 7:15 a.m.
Isobutane Emission Rate:  1.26 Ib/hr,
                          0.57 kg/hr
Weather Conditions: Wind - Variable
                    Temp.  75°F

Sample
Loc.
1
2
3
Upwind
Cone, of
Benzene
(ppm)
6.56
6.86
6.80
0.49
Cone, of
Isobutane
(ppm)
0.80
1.41
1.78
ND

Mass to Mass
Ratio /icy
11.03
6.54
5.14
—

Ib/hr
Benzene
13 . 90
8.24
6.48


kg/hr
Benzene
6.32
3.75
2.95

Date:  7/17/80
Tracer Test #3, Run #2
Test Start - 8:18 a.m.
          Avg. 9.54   Avg. 4.34


Isobutane Emission Rate:  1.24 Ib/hr
                          0.56 kg/hr
Weather Conditions: Wind - Variable
                    Temp.  75°F
1
2
3
Upwind

5.28
5.61
6.16
0.61

0.261
0.430
0.421
ND

27.18
17.64
19.71


33.70
21.87
24.44

Avg. 26.67
15.32
9.94
11.11

Avg. 12.12
Date:  7/18/80
Tracer Test #4, Run //I
Test Start - 7:36 a.m.
1 18.60
2 19.68
3 19.44
Upwind 1.83
Date: 7/18/80
Tracer Test #4,
3.31
6.84
4.79
0.087

Run #2
Test Start - 8:30 a.m.
1 4.41
2 5.70
3 6.18
Upwind 2.83
{\} Scott Environmental
2.57
3.99
4.50
ND
Technology Inc.
Isobutane Emission Rate:  1.29 Ib/hr
                          0.59 kg/hr
Weather Conditions: Wind N, Steady
                                         7.56
                                         3.87
                                         5.46
               9.75
               4.99
               7.04
4.43
2.67
3.20
                                                   Avg. 7.26   Avg. 3.43
                                         Isobutane Emission Rate:  1.29 Ib/hr
                                                                   0.59 kg/hr
                                         Weather Conditions:  Wind N, Steady
                                         2.31
                                         1.92
                                         1.85
               2.98
               2.48
               2.39
1.35
1.13
1.09
                                                   Avg. 2.62   Avg. 1.19

-------
 SET 1957 05 1280
                                                      Page 3-17
                                  TABLE 3-7
                     BACKGROUND FOR NAPHTHALENE MELT PIT
 Date:  7/17/80
 Tracer Test //I, Run //I
 Test Start - 11:22 a.m.

Sample
Loc.
1
2
3
Upwind
Cone, of
Benzene
(ppm)
14.65
15.21
9.71
0.56
Cone, of
Isobuta'ne
(ppm)
3.01
3.89
2.04
ND
 Date:  7/17/80
 Tracer Test #1, Run #2
 Test Start - 11:55 a.m.
   1
   2
   3-
Upwind
13.49
15.82
13.43
0.25
1.52
3.5.4
3.75
ND
                       Denver Units Operating - 1,  2,  3
                              Isobutane Emission Rate: 1.28  Ib/hr
                                                       0.58  kg/hr
                              Weather Conditions:  Wind SSW,  0-5 mph
                                                   Temp  80°F
                                       Mass to Mass
                                       Ratio 4>/ic,

                                           6.55
                                           5.25
                                           6.42
Ib/hr
Benzene
8.38
6.72
6.94
kg/hr
Benzene
3.81
3.05
3.15
                                                    Avg.  7.35   Avg.  3.34
                       Denver Units Operating - 1, 2, 3
                              Isobutane Emission Rate:
                                          Weather Conditions:
11.93
 6.01
 4.82
               1.28 Ib/hr
               0.58 kg/hr
          Wind SSW, 0-5 mph
          Temp  80°F

    15.27       6.94
     7.69       3.50
     6.17       2.80

Avg. 9.71  Avg. 4.41
 Scotr Environmental Technology Inc

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    SET 1957 05 1280                                   .         Page 3-18

                  BENZENE OVER MELT PIT AT GROUND LEVEL
                      Grab Samples Collected 7/22/80
              Time                    Benzene Concentration (ppm)
              	           Edge of Pit           Middle of Pit
              1330                   46                   27
              1800                   67                   36
              2300                  116                  ' 42

              It can be seen that the benzene concentration was higher
    at the edge of the pit, which was above the point where incoming
    slurry splashed into the pit, than at the center of the pit.  In
    addition, the concentrations increased with time as the pit filled.
              The contribution of the Denver unit to the samples
    collected during the melt tests was estimated to be negligible be-
    cause the plume rise from the heated pit caused the emissions from
    the Denver unit to rise well above the samplers.  Furthermore, the top
    of the Denver unit from which point the Denver unit's emissions emanated
    was  approximately six feet above ground level (top of melt pit).
    Thus, it is quite unlikely that the Denver unit emissions could reach
    the samplers during the tests on the melt pit when the melt was in
    progress.
              The following engineering estimates of overall daily naphthalene
    melt pit emissions are based on all of the data collected.  The benzene
    emission rate from the melt pit is highest during the time when the
    naphthalene cake is being melted.  The emission rate during this half
    hour period is from 20 to 30 pounds per hour.  During the following
    half hour the emissions decrease to the 10 to 20 pounds per hour range.
Scott Environmental Technology Inc.

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     SET 1957 05 1280                                            Page 3-19






     The emissions continue to decrease over the period that the melted




     naphthalene remains in the pit and the benzene content in the mix




     becomes depleted.   Once the melt has been transferred to the drying




     tank and filling of the pit with slurry from the Denver units resumes,




     benzene emissions begin at the rate of three to six pounds per hour.




     As filling continues and the liquid level in the pit rises,  the




     emission rate increases to the order of 10 pounds per hour or more




     until the next melt is started.  These emission rates can easily




     vary by a factor of 2 or 3 from day to day.  The temperature of the




     material in the pit is the primary variable which affects the benzene




     rate at any given time.
Scott Environmental Techndosylnc

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SET 1957 05 1280                                                Page 4-1









                  4.0  PROCESS DESCRIPTION AND OPERATION




4.1  PROCESS DESCRIPTION




           The by-product recovery operations for tar and flushing liquor at




Bethlehem Steel Corporation, Bethlehem, Pennsylvania are two separate systems;




Batteries 2, 3, and A as well as a separate system for Battery 5.  These gas




streams combine before entering the ammonia saturator.  Batteries 2 and 3




have 102 ovens each and were constructed in 1941-43 using a Koppers-Becker




design.  Battery A has 80 McKee-Otto ovens that began operation in 1976.




Batteries 2 and 3 produce a heavy tar because the hot top of the oven cause's




cracking of the carbon compounds in the coke oven gas.  The specific gravity




of the heavy tar is in the range of 1.25.  Battery 5 has 80 Koppers ovens




with horizontal flues that were constructed in 1953.  Battery 5 produces




light tar with a specific gravity of approximately 1.19.




           The processes used at the Bethlehem plant for coke oven gas




recovery are primary cooling, tar decanting, exhausting, tar electrostatic




precipitation, ammonia still and saturator, final cooling, light oil scrubbing




and rectifying, and Sulfiban desulfurization with Glaus recovery.  A process




flow diagram of the gas and liquid streams is depicted in Figure 4-1.




           The gas leaving the ovens is collected in the collecting mains




where it is sprayed with flushing liquor.  The gas and flushing liquor leave




the battery area and are transported from the collecting main through cross-




over mains into the suction main and into the by-product recovery area.  The




gas and liquor initially separate at the downcomer where the flushing liquor




falls out and the gas continues to the primary coolers.  The flushing liquor




from Batteries 2 and 3 enters an interceptor pit before being pumped to the
  Scott Environmental Technology Inc.

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LEHEM STEEL CORPORATION, BETHLEHEM, PA



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-------
SET 1957 05 1280                                                Page 4-3









tar decanter because ground elevations will not allow for gravity flow.  The




interceptor pit removes some sludge which is stored in a dumpster before




disposal.  The detention time in the interceptor pit is very short with a




flow rate of 189 1/s (3000 gpm).  The flushing liquor from Battery A does




not enter this pit, but flows by gravity to the tar decanter.




           As previously stated the tar and flushing liquor operations are




two separate, but similar systems.  This discussion will address the operations




for Batteries 2, 3 and A because the plant tour surveyed this system.  The




gas stream from Battery 5 joins the gas stream from Batteries 2, 3 and A




before the ammonia saturator.  Excess flushing liquor from both systems are




steam stripped in the same 'ammonia still.




           The dirty flushing liquor enters the two parallel tar decanters




where it is separated into liquor, tar, and sludge.  Liquor from the over-




flow pit is also separated in the tar decanters.  The flushing liquor flows




by gravity to a surge tank before returning to the spray system on the




collecting mains.  Excess flushing liquor from the surge tank is treated




with lime before stripping in the ammonia still.  The flushing liquor




ammonia concentration is approximately 3000 mg/1 before the still.  The




ammonia rich vapors exit at the top of the ammonia still and combine with




the main gas stream before the ammonia saturator.  The ammonia concentration




in the effluent from the ammonia still is 1.2 mg/1 before entering the




aeration basins.  In the future the plant will increase the ammonia concen-




tration to approximately 40 mg/1 to enhance the biological wastewater




treatment process.
  Scott Environmental Techndosy I"0

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SET 1957 05 1280                                                Page 4-4









          The tar layer from the tar decanter is pumped to tar storage.  The




water content of the tar is approximately 10-12% from the tar decanter and




3-4% after tar storage.  The water content of the tar from the tar decanter




could increase to approximately 35% when charging problems occur.  The tar




in storage is heated to 94°C for several days before shipping.  Heavy tar




from Batteries 2, 3, and A is produced at a rate of 181.7 cubic meters




(48,000 gallons) per day.  Light tar from Battery 5 is produced at a rate




of 45.4 cubic meters (12,000 gallons) per day.  The sludge layer from the




tar decanter is pulverized in a ball mill before storage and disposal.




          The gas stream enters four parallel primary coolers at 77°C where




it is sprayed with circulating liquor.  During the visit two old primary




coolers were not operating due to reactivation.  The circulating liquor is




cooled by indirect coolers before recirculating in the primary coolers.




Excess circulating liquor and tars are drained to the overflow sump from




the old primary coolers.  The excess liquor from the new primary coolers




goes directly to the decanters.  The gas leaves the primary coolers at




approximately 44°C.




          The gas stream enters the exhausters where the prime motive




power for the system is supplied.  The gas then enters four parallel tar




electrostatic precipitators where additional tar is removed from the gas




and drained to the overflow pit (drain pit).




          The gas from the tar electrostatic precipitators is combined with




the gas stream from Battery 5 and the vapors from the ammonia still before




entering the ammonia saturator.  The ammonia saturator is an Otto design




that sprays 2% sulfuric acid through the gas as it rises in the saturator
 Scott Environmental Technology Inc.

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SET 1957 05 1280                                                Page 4-5









column.  The system produces 65.3 metric tons (72 tons) of ammonium sulfate




per day.  Before the ammonia still was installed the plant produced 54.4




metric tons (60 tons) of ammonium sulfate per day.




          The gas leaving the ammonia saturator is approximately 55-60°C




before entering the final coolers.  The final coolers are arranged in three




parallel rows with two rows having two coolers each in series and one row




having one cooler.  There is normally one cooler in each row in service at




any given time.  The final coolers circulate water which is indirectly




cooled before respray.  The naphthalene/water slurry from the bottom of




the final coolers is conveyed to a Denver flotation unit via an open trough.




In the Denver unit the naphthalene slurry is floated and scraped from the




surface and then drained to a melting pit.  The naphthalene slurry is




heated in the melting pit before pumping to the draining tank.  From the




draining tank the naphthalene goes to a drying tank and then to a shipping




tank.  The water from the Denver flotation is pumped to the atmospheric




cooling tower for the final coolers.  All operations are vented to the




atmosphere.




          The gas leaves the final coolers and enters the light oil scrubbers




at 18°C in the winter but rises as high as 32°C in the summer.  The wash




oil scrubbers are arranged in three parallel rows with two rows having four




scrubbers each in series and one row having two scrubbers in series.  In the




light oil scrubbers the wash oil flows are countercurrent to the gas stream




and remove the light oil from the gas stream.  The benzolyzed wash oil is




then stripped of the light oil in the wash oil still.  The debenzolyzed wash




oil from the wash oil still is indirectly cooled in the wash oil chillers
 Scott Environmental Technology Inc.

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SET 1957 05 1280                                               Page 4-6









before the wash oil decanter.  In the wash oil decanter entrained water is




periodically separated from the wash oil and flows by gravity to the Gale




oil sump (see Figure 4-2).  The wash oil from the wash oil decanter is then




returned to the light oil scrubbers for reuse.




          The light oil vapors from the wash oil still enter a rectifier




which fractionates the light oil into primary and secondary oil.  The




separation between primary and secondary oil occurs at 140°C (284°F).  The




crude secondary oil is the BTX fraction of the light oil and is shipped to




the Sparrows Point plant operated by Bethlehem Steel Corporation for further




refining.  The primary oil is the heavy fraction of the light oil and is




burned with bunker oil throughout the plant.  The plant in the past has




refined the secondary crude oil, but in the fall of 1977 the unit was moth-




balled.  The refining operations produced a caustic and acid sludge at 3.8




cubic meters (10,000 gallons) per day each and cost for the ultimate




disposal of these sludges made the refining operation economically impractical.




          The Gale oil sump receives waste stream inputs from the final




cooler, wash oil still, wash oil chiller, wash oil decanter, rectifier,




primary light oil storage, secondary light oil storage, desulfurization




blowdown or condensate, and miscellaneous runoffs.  The Gale oil sump




separates the wastewaters into oil and water layers.  In the future the




water layer will be pumped to the influent to the aeration basins.  The




oil layer is pumped to a tank car.   If the Gale oil sump receives excessive




inputs the overflow flows to quench.




          The gas stream from the light oil scrubbers then enters the




Sulfiban desulfurization process.  The gas stream initially enters two
 Scott Environmental Technology Inc.

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 SET 1957 05 1280
                                                Page 4-7
                  GRAB _
                 SAMPLE*
                 SPRAYS
            tm




         5
                        Q
                '(HIGHER

                 LEVEL)
                                WATER

                             (LOWER LEVEL)
                                           OIL
                                       TO TANK CAR
                                                 31T
ScXDtt
Environmental
Technology
Inc.
FIGURE 4-2   GALE OIL SUMP (TOP VIEW)

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SET 1957 05 1280                                                Page 4-8









packed contact columns for absorption of the sulfur and the "sweet" coke




oven gas exits the top of the contact columns for reuse.  The absorbing




solution is 15% monoethanolamine (MEA) in water.  The rich MEA is stripped




in the still column to lean MEA which is returned to the contactor columns.




In the still column the acid gases exit the top and are passed through a.




heat exchanger before entering the cyanide destructor.  Some of the con-




densate or reflux from the still column condenser and heat exchanger are




pumped to the Gale oil sump.  The acid gases enter the cyanide reactor at




approximately 149°C (300°F) and the cyanide is destroyed by heating to




approximately 233°C (450°F) with the aid of bauxite and activated alumina




catalyst bed.  The acid gases leaving the cyanide reactor are then processed




in a Glaus sulfur recovery system which produces elemental sulfur and




incinerates the tail gas.




          The sweet coke oven gas after the contactor columns is held at




25 inches of water by a system that supplies natural gas at 23 inches of




water and flares at 27 inches of water.  The coke oven gas is used at the




coke ovens and at other places within the steel mill.  The heat value of




the gas is approximately 530 Btu per cubic foot.




4.2  PROCESS OPERATING PARAMETERS




          During the two-week test period, the plant average coke production




rate was 3,900 tons per day.  This resulted in generation, on the average,




of 78 x 10  cubic feet of raw coke gas per day.  Thus, we can state that




the plant was operating at about 75% capacity.  This capacity factor was




discussed with Bethlehem personnel.  While it was acknowledged that some
 Scott Environmental Technology Inc.

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SET 1957 05 1280                                                Page 4-9









variations result from the longer coking cycles, there is no reason to




believe that the benzene emissions, per ton of coke produced, would be




significantly different from when the plant is at full capacity.




          Other process operating data are presented in Table 4-1.
 Scott Environmental Technology Inc.

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                                         TABLE 4-1

                    PROCESS DATA,  BETHLEHEM STEEL CORP.,  BETHLEHEM,  PA

                               Weeks of  July 7 and 14,  1980
              Oven Flue Temperatures (Avg.,  °F)
       Batt. A     .     2            3
2,409
2,410
2,413
2,415
2,384
2,411
2,390
2,383
2 , 380
2,256
2,260
2,247
2,235
2,234
2,250
2,240
2,233
2,232
2,230
2,220
2,238
2,236
2,199
2,272
2,234
2,236
2,221
2,262
2,252
2,240
2,240
2,251
2,269
2,256
2,263
2,246
710
745
725'
720
740
704
657
688
707
                                                        Coke Production (TPD)
                                                 Batt. 5        Total        Breeze
                                                                            3,995
                                                                            4,098
                                                                            3,828
                                                                            4,074
                                                                            3,928

                                                                            3,974
                                                                            3,718
                                                                            3,567
                                                                            3,887
                                                                               101
                                                                               101
                                                                               101
                                                                               101
                                                                               101

                                                                               182
                                                                               151
                                                                               151
                                                                               151
                                                                                             CO
                                                                                             w
                                                                                             H
                                                                                                         Ui
                                                                                                         •^J
                                                                                                         O
                                                                                                         N>
                                                                                                         oo
                                                                                                         o
July
Date

  7
  8
  9
 10
 11

 14
 15
 16
 17
Coke-Oven
Gas (MSCF)
 Tar
(GPD)
Light Oil
  (GPD)
80,170
78,630
77,070
80,840
77,170
77,820
78,200
73,820
74,600
60,093
66,896
31,365
42,911
45,338
37,403
47,900
45,200
44,263
26,500
10,500
17,700
12,500
15,100
11,. 000
10,000
10,000
9,000
Primary Oil
   (GPD)

   1,032
   1,000
     766
   1,400
   2,500

   1,100
   1,000
   1,000
   3,500
Naphthalene
   (GPD)

    600
    500
    700
    900
    800

  1,200
    700
    500
    800
                                                                                             oo
                                                                                             ID
                                                                                                         I
                                                                                                         (-•
                                                                                                         o

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SET 1957 05 1280                                                Pase -~
               5.0  FIELD SAMPLING AND ANALYSIS METHODOLOGY
  5.1  DETERMINATION' OF BENZENE FROM STATIONARY SOURCES:
      EPA METHOD 110 AND MODIFICATIONS
           EPA Method 110 consists of drawing a time-integrated stack gas

  sample through a probe into a Tedlar* sample bag, which is enclosed in a

  leak-free drum, by use of a pump hooked to the drum outlet which slowly

  evacuates the drum, causing the bag to fill.  A copy of the method is

  included in Appendix D.

           The method was modified by Scott because as it stands the

  method doesn't account for moisture in the sample stream, and is only

  designed to measure benzene concentration, not mass emission rate.  The

  following modifications were made to all tests done using Method 110:

           1.  To obtain mass emission rates, velocity and temperature

  readings were taken at the top of the stack at 5 minute intervals during

  the 30-minute sampling runs.  This information was used to calculate flow-

  rate', which was used in conjunction with the benzene concentration to

  yield the mass emission rate.  Velocity readings were made using a vane

  anemometer with direct electronic readout.

           2.  A personnel sampling pump was substituted for the pump,

  needle valve, and flowmeter of the method.  The personnel pumps have

  built-in flowmeters and rate adjustment screws and have the further

  advantage of being intrinsically safe, as required in many areas of

  the coke plant.
  * Mention of trade names or specific products does not constitute  endorsement
   by  the U.S. Environmental Protection Agency.
Scott Environmental Technofosylnc

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 SET 1957  05 1280                                               Pa§e 5~2









           3.  Swagelok fittings were used in place of quick-connects.




           4.  Rather than discarding Teflon sample lines after each set




 of samples, they were washed with propylene carbonate and/or acetone and




 flushed with nitrogen before reuse.




           5.  An orifice and magnehelic gauge were inserted in the sampling




 line before the Tedlar bag to indicate that air flow was reaching the




 bag.




           6.  A water knockout trap was inserted between the probe and




 magnehelic gauge to collect any condensate in the sample line.




           7.  The following cleanup procedures were followed:




           If any condensate was collected in the trap or sample line, it




 was measured and saved for analysis..  The probe, line and trap were then




 washed with propylene carbonate, which was also saved for analysis.  Any




 benzene found in these washes and water catches was added to the total found




 in the sample bag to determine mass emission rates.




           Bag volumes were measured whenever water was collected in the




 trap by emptying the bag through a dry gas meter after the sample was




 analyzed.  The volume of water collected in the trap was then converted




 to an equivalent air volume and was added to the volume in the bag to




 determine the percent moisture in the sample stream.




           After the probe, line and trap washes were completed, the lines




 were washed with acetone to remove the propylene carbonate film and flushed




 with nitrogen to dry.




           Figure 5-1 shows the modified Method 110 setup.
Scott Environmental Technckxjy Inc

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SET 1957 05 1280
                               Page 5-3
                               FIGURE 5-1
                Stainless Steel  Probe

                     Swagelok Fittings
Stack
Teflon Sampling Line

    Water Knockout Trap
           /Magnehelic Gauge
                                                      Tygon Tubing
                                                        Personnel Sampling
                                                            Pump
                                                          Leak-proof Barrel
                                Tank
            Inc.
                       MODIFIED METHOD 110 SAMPLING TRAIN

-------
 SET 1957 05 1280                                               Page 5"'*
5.2  TRACER TESTING         .  .      .....-•
          The tracer gas method is a practical procedure for quantifying
mass emissions of volatile organics from sources which are essentially
open to the atmosphere without disturbing flow,  dispersion patterns or
the source operation.  This method utilizes the release of a tracer gas
directly over the source of interest;  the tracer gas will then follow the
same dispersion patterns as the emissions from the source.  The mass of
tracer released over the sampling period is known and the mass to mass
ratio of benzene  to  the  tracer gas  in the sample is determined by gas
chromatography.   The  emission rate  of benzene can be calculated with this
information.
          This method is based on the principle that*- the chosen tracer gas
will model the dispersion of benzene from the source.  The tracer gas
chosen for this project was isobutane because it was not present in the
sources to be tested and it could readily be separated from other source
trace components by the same column used for benzene.  In addition, isc-
butane is. a non-toxic gas that can readily be dispensed from a pressurized
cylinder at a uniform measured rate.
          When this method was used triplicate tests were performed.  Each
test consisted of two 1/2 hour runs.  For each run clean and backgrounded ten-
liter Tedlar bags were used.  Integrated samples were collected using
Emission Measurements, Inc. Air Quality Sampler II systems.  The AQS II
samplers are self-contained units capable of collecting one or more inte-
grated samples at a preset rate.   For tracer tests the sampling rate used
was ten liters per hour.
5.3  SAMPLE HANDLING
          After being collected the gas samples were immediately transported
to the gas chromatograph and analyzed.   The elapsed time between sample
collection and analysis never exceeded  one hour.  To verify that there was
no sample degradation in samples  of this type some of the samples were
retained for 24 hours and reanalyzed.   The loss of benzene and isobutane
observed was typically less than  5%.
 Scott Environmental Technology Inc.

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 SET 1957  05 1280            .                                   Page 5"
5.4  FIELD ANALYSIS
          All gas samples collected  were analyzed using a Shiraadzu GC Mini 1
gas chromatograph equipped with dual flame inoization detectors,  dual
electrometers, heated sample loop, and a backflush system.  Figure 5-2 shows
a schematic of the backflush apparatus.  The backflush system is  composed
of ten port sequence reversal valve  and two columns,  a scrubber column for
retaining, high molecular weight compounds and an analytical column.  When
the system is.in the inject mode the scrubber column and the analytical
column are connected in series allowing sample components to move from the
precolumn to the analytical column.   In the backflush mode the columns are
disconnected from each other and become two separate systems each with its
own carrier gas source.  This arrangement allows the separation and
measurement of low molecular weight  compounds while the scrubber  column
is being backflushed of heavier sample components.  Backflush times for
different mixtures of sample components must be predetermined to  insure that
the compound(s) of interest are transferred to the analytical column before'
backflushing is started.
          Samples for chromatographic analysis were drawn into a  20 cc glass
syringe then introduced to the sample loop inlet.  The samples once in the
sample loop were allowed to come to  atmospheric pressure by waiting 15
seconds prior to the injection.  When only benzene was of interest the
following chromatographic conditions were maintained:
                 Column Temperature  (isothermal)   - 100°C
                 Injector and Detector Temperature - 200°C
                 5 ml Sample Loop, Temperature     - 50°C
                 Carrier Gas Flow Rate             - 32 cc/min
                 Hydrogen Flow Rate                 - 40 cc/min.
                . Air Flow Rate                     - 240 cc/min.
                 Analysis Time                     - 5 min.
                 Detector                          - Flame lonization
 Scott Environmental Technology Inc.

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Q
Ul
Is)
             CARRIER GAS A
                                                                      CARRIER GAS B
                       PREP, COLUMN
             ANALYTICAL COLUMN
             SAMPLE  INJECTION
   INJECT
A, D, E OPEN
B, C CLOSED
  *
   BACKFLUSH
A, E CLOSED
B, C, D OPEN
                        GC COLUMN  CONFIGURATION  WITH  BACKFLUSH
                                                                              DETECTOR
                                                                                                 r?
                                                                                                 r.
                                                                                                 wi
                                                                                                 i

-------
 SET 1957 05 1280
                                                                Page 5-7
          The columns used for field analysis were:
                A - Scrubber Column
                    10% FFAP on Supelcoport 80/100
                    1/8" x 1 m Stainless Steel
                B - Analytical column
                    20% SP-2100,  0.1% Carbowax 1500
                    100/120 Supelcoport
                    1/8" x 10' Stainless Steel
          When samples from tracer tests were analyzed the chromatographic
conditions were changed to provide adequate separation of the isobutane
tracer from the other light components of the sample.   The temperature
program used for this analysis was:
          1)  Start at room temperature with external  cooling fan
              on and oven door open.
          2)  Inject @ 0.0 min.
          3)  Turn external cooling fan off @ 1.0 min.
          4)  Eackflush @ 1.8 min.
          5)  Isobutane elutes @ 2.3 min.
          6)  Close oven door @ 3.0 min. with oven temperature
              set at 100°C.
          7)  Benzene elutes @ 7.0 min.
          8)  After the elution of benzene, open the oven door and
              turn on the cooling fan.  The next injection can be
              made after 2 minutes of cooling:
          9)  When the tracer gas is used analysis time will be
              approximately 10 minutes.

          The columns and flow rates were the same as  for- isothermal.
 Scott Environmental Technclosy Inc

-------
     SET 1957 05 1280                                            Page 6-1






                       6.0  FIELD SAMPLING PROCEDURES
     6.1  COOLING TOWER-DIRECT WATER FINAL  COOLER






               The cooling tower was sampled on July  10,  1980.   The tower




     has four 13-foot diameter fans on top  as shown in Figure 6-1.




     Sampling was conducted at only one fan and the results  were multi-




     plied by four to obtain mass emission  rates from the whole cooling




     tower.   This approach is expected to yield accurate  emissions  data




     without the necessity of testing at all four fans, because the fans




     were operating under  identical conditions.




               Air sampling was conducted following EPA Method 110  using  a




     24-point  sampling and velocity trayerse across  two  diameters  of the




     fan shroud to obtain  an integrated sample.  At two minutes per point,




     each of the three sampling runs lasted 48 minutes.




               Triplicate  liquid samples were dipped  from the hot and cold




     wells with temperatures of 30 C and 27.8 C respectively (86 F  and




     82 F).   At the time of sampling,  the cold well was mixing back into  the




     hot well at one location due to a faulty level control.   Liquid samples




     were dipped from points well clear of  the mixing area.  The plant



     indicated that average normal operating temperatures for summer are




     86°F and 76°F.
Scott Environmental Technology Inc.

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SET 1957 05 1280
                                                         Page 6-2
                            FIGURE 6-1
                           PLAAJ  VIFW
                             FAM  SHROUD
         FAM
        MOTOR
                     FAKJ
                           SIDF  VIEW
                             2'
Scott
Environmental
Technology
Inc.
COOLING TOWER - DIRECT WATER FINAL COOLER

-------
    SET 1957 05 1280                                            Page 6-3






    6.2  TAR DECANTER






              Three half-hour Method 110 tests were conducted on the tar




    decanter from the #5 battery on July 8th and 9th, 1980.  The tar




    decanter is shown in Figure 6-2.  Problems were encountered with naph-




    thalene plugging the sample line.  The decanter was the first source




    we tested using Method 110, and at the beginning several tests were




    run in which the sample line clogged without our knowledge resulting




    in no sample collection.




              At this point we spent considerable time revising the method




    for application to this project.  The equipment was modified to include




    an orifice and magnehelic gauge in the sample line to register flow




    into the bag and a water knockout trap in the line before the orifice




    to prevent moisture from entering the bag.  Clean-up procedures were as




    described in Section 5.1.




              From here on, all tests referred to as Method 110 include




    these revisions.




              The tar decanter receives tar arid flushing liquor from the




    coke gas crossover main from the #5 battery and also from the primary




    cooler.  A total of five liquid samples were collected as follows:




    Two were dipped from a hatchway on top of the decanter at the outlet




    end, one was collected from the gas crossover main, and two were




    taken from the primary cooler outlet.
Scott Environmental Technology Inc.

-------
SET 1957 05 1280
                          Page 6-4
                FIGURE 6-2
          it
       HOOD
         0
                            ' a't
                           II'?
               HOOD
                              •  u
                           ©
                                    •A
                      TEST V£NT S'
                                    56'
    inc.
BATTERY^ TAR DECANTER
EPA  METHOD HO	

-------
     SET  1957  05  1280                                            Page  6-5






     6.3  LIGHT OIL  CONDENSER VENT






              Four  half-hour EPA Method  110  tests were  conducted on the




     light  oil condenser vent on July  11, 1980.  The results of  the analysis




     showed the benzene concentration  in  the  third sample  to be  about  half




     that found in the first  two, indicating  a possible  leak in  the system.




     Upon inspection of the sample  line,  the  leak was  found to be caused




     by an  improperly seated  gasket in the water knockout  trap,  and the




     third  run was voided.  A fourth test was run, and the analytical




     results were consistent  with those of the first two runs.




              The top of  the existing stack  had a 1/2 inch steam injection




     pipe running into the top, as  shown  in Figure 6-3.  A stack extension




     was  constructed from  a section of steel  stovepipe that extended the




     top  of the stack past the  steam pipe so  we could  accurately




     measure flow rate with a vane  anemometer.




              The plant maintenance crew provided scaffolding for access




     to the testing  site.




              No liquid samples were  collected at this  source.
Scott Environmental Technology Inc.

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 SET 1957  05 1280
                                                 Pa.ge 6-6
                                FIGURE 6-3
                     1/2" Steam
                     Injection -
                     Pipe
                                                6" Diameter
                                                Vent Stack
                           Sampling  Platform
                          •Stack Extension
                         •Slot for  1/2" Pipe
Scott
Environmental
Technology
Inc.
LIGHT OIL  CONDENSER VENT

-------
     SET 1957 05 1280                                            Page 6-7






     6.4  NAPHTHALENE DRYING TANK






               The naphthalene drying tank presented several new problems




     in sampling strategy.  The tank is shown in Figure 6-4 as Draining




     Tank #2.  There is a large opening in the center of the tank with




     steam lines running in, in addition to a tall 6-inch diameter vent




     stack located at the end of the tank.  More emissions come from




     the large opening than from the vent, and an attempt was made to




     cover the opening with plywood and fiberglass packing, but due to the




     pipes in the opening this was not very successful in stopping leaks.




     It was decided to construct a sheet metal collar around the opening,




     with slots to fit around the steam lines, and treat it as a vent




     stack.  Method 110 samples were collected from the tall vent stack .




     and velocity readings were taken at both the stack and the big vent




     opening.  The assumption was made that the concentration of benzene




     is the same at the big vent opening as it is in the stack.  Mass




     emission rates were therefore determined using the benzene concen-




     tration in the stack sample with the flow rates from the stack and




     the vent opening.




               The second major problem encountered was naphthalene plugging




     the sample line and probe.  The line plugged so fast there was no use




     in cleaning the line periodically.  The solution was to bubble the




     sample stream through propylene carbonate to knock out naphthalene,




     using a large diameter glass elbow as a probe.  A bucket containing




     three impingers was hooked on top of the stack.  The first two
Scott Environmental Technology Inc.

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 SET 1957 05 1280
                                               Page 6-8
                              FIGURE 6-4
    From Naphthalene Melt Pit









1




Jt




Draining
Tank














I

//I


































Draining
Tank
#2
P
L22"
Diam.
Steam Line
Opening
r
Test
|


N6" Pipe
t>
Vent
i
i
i









I







l
I
Draining
Tank
#3













I
















Draining
Tank
#4





t
*
*
Shipping Tank
^^^_ ^_^A
bCOt
Environmental
 roiofly
NAPHTHALENE HANDLING TANKS

-------
     SET 1957 05 1280                                            Page 6-9






     impingers contained. 100 ml of propylene carbonate and the third was




     empty.  A Teflon sample line connected the impinger train to the




     sampling drum and the glass elbow used for the probe was connected




     directly to the first impinger (See Figure 6-5).




               Cleanup consisted of saving the impinger catches and washes




     in addition to the sample line and water trap washes.  The sample




     volume contained in the Tedlar bag was measured after the sample was




     analyzed by emptying the bag through a dry gas meter.




               A test run was done on the drying tank on July 18 to verify




     the success of the new procedures.  The bag sample collected was




     analyzed but the propylene carbonate catch was not, as it was just a




     trial run.  Results of the bag analysis are included with the data




     in Table 3-4 for purposes of comparison.  Naphthalene from the melt




     pit is pumped into a draining tank after the melt each morning, and




     the tank is steam heated from about 1:00 p.m. until about 4:00 a.m.




     when a night shift operator shuts it off.  Benzene emissions are not




     expected to be constant over the heating cycle, so in order to measure




     accurately the emissions from the tank it must be tested over the




     entire heating cycle.  We collected eight half-hour Method 110 tests




     modified as described at about two hour intervals during the cycle




     on the night of July 22, 1980.
Scott Environmental Technology Inc.

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 SET 1957  05  1280
                                                   Page 6-10
                                 FIGURE 6-5
    Glass
Stack
       Stack
       Flow
                      Empty
              100 ml
              Propylene
              Carbonate
                                 — Teflon Sampling Line
                                              Magnehelic Gauge
                            30 liter
                           Tedlar Bag
                                                Tygon Tubing

                                                Personnel
                                                 Sampling
                                                 Pump
                                                    •Leak-proof
                                                     Barrel
                                  Tank
Scott
Environmental
Technology
Inc.
MODIFIED METHOD 110 SAMPLING TRAIN WITH PROPYLENE
CARBONATE KNOCKOUT TRAP

-------
     SET 1957 05 1280                                            Page 6-11






     6.5  DENVER FLOAT UNITS






               The Denver float  unit  presented  a  complex problem to  the use




     of a tracer gas  for  quantifying  the  unit's benzene  mass  emissions.




     First,  there are 4 separate Denver float tanks,  of  which 3  were




     normally in use  during  these tests.   The particular tank which  was out




     of service varied from  day  to day.   Second,  the  naphthalene melt pit




     was immediately  adjacent  to the  Denver  float tanks  on one of the




     sides that was physically accessible for downwind sampling.   While the




     emission rate from the melt pit  was  low, compared to the Denver float




     tanks,  some "hot spot" points contributed  to  the downwind  samples.




     For example,  the point at which  the  Denver float overflow trough




     serving Units 1  and  2 empties its  contents into  the melt pit was




     shown to be a "hot spot"  for benzene in subsequent  grab  samples.




     Figure 6-6 shows the processes and flow directions  for the  entire




     naphthalene handling operation.  Figure 6-7  shows specifically  the




     Denver float units and  the  positions of the  samplers for the Denver




     unit tests.




               The sampling strategy  used was believed to be  the best




     means of arriving at reasonably  accurate emission rates  without unduly




     elaborate and costly sampling procedures.  The simultaneous  use of a




     different tracer gas at each tank  and tests  utilizing different




     tracer gas release configurations  would probably have resulted  in better




     confidence in the emission  rates during a  particular test period.




     However,  the emission rate  varies  from  day to day due to variations in
Scott Environmental Technology Inc.

-------
T -I ITl

P ft .;'
 O ')
 o J
   c
   C
                          /fi*
                                                a i.
                           Mecr
                                                                                          HOT
                                                              *\ .
                                                              lMi
                                                             TAWK
                                                                                                                M
                                                                                                                O

-------
 SET 1957 05 1280
                                                  Page 6-13
                                 FIGURE 6-7
             ^  2^1     Walkway
            21'
       ©
Downwind
Samplers
       Unit
        //I
                  !
                  6'
                  !
Unit
 #2
Unit
 #3
Unit
 /M
                         Melt Pit
                                                                 Upwind
                                                                 Sampler
                                                            Underflow to
                                                            Hot Well
                                                     To Drainage
                                                       —  ^ tank
                                                      (During melt)
                                                              To Drainage Tank
                                                               Wind
                                                             Direction
Scott
Environmental
Technology
Inc.
   DENVER FLOTATION UNITS

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     SET  1957  05  1280                                            Page  6-14






     both process  and  ambient  conditions.  Thus,  it was not  cost effective




     to perform very elaborate test procedures.




              The approach used  in the Denver float unit  tests was  to measure




     the  emissions from a  single  tank.  The  tracer gas was dispersed onto




     the  surface  of this tank  with the gas discharge probe located along  the




     center  longitudinal point; there will be contributions  of benzene from




     the  other two Denver  tanks then in use.  The relative contribution from




     the  second tank was estimated by releasing  the tracer onto the  surface




     of the  second tank in a test immediately following the  first tank test




     without changing  the  position of the samplers.  The relative contribu-




     tion of the  two tanks to  each sampling  location is proportional to the




     relative  amounts  of tracer found at that location.  There are  two




     assumptions  inherent  to this conclusion.  First,  the  benzene emission




     rates  from the two tanks  are equal.  This should  be true because  the




     temperature,  feed material and size were the same for the two  tanks.




     Second, the  diffusion patterns were the same in the two tests.  This




     was  demonstrated  by comparing the benzene concentrations in each




     sampler for  the two tests.




              The sampler locations for Test 1  are shown  in Figure  6-7.




     The  isobutane tracer  concentrations from the two  tests  were normalized




     for  differences in isobutane release rate and differences in dispersion.




     The  normalized values were then used to calculate the fraction of the




     benzene due  to emissions  from Tank 1.   The  contribution from Tank 3




     was  not determined.   Because of the additional spacing  between Tanks




     2 and  3,  the contribution ratio of Tank 3 to Tank 2 would be less than
Scott Environmental Technology Inc.

-------
     SET 1957 05 1280                                            Page 6-15






     that of Tank 2 to  Tank 1.   It is  believed that Tank 3 contributed




     less than 5% of the total  found in the samples.   The calculations




     shown in Appendix  A assume a negligible contribution from Tank 3.




     The upwind background from distant sources was also assumed to be




     negligible.  The trace benzene concentrations  found in the upwind




     sampler were primarily due to the Denver unit  tank emissions swirling




     during wind shifts.  No source was immediately upwind of the Denver




     unit, and grab samples verified the absence of benzene in the back-




     ground air mass.




               In Tests 2 and 3,  the test procedure was the same as in




     Test 1.  However,  during Tests 2  and 3,  Tank 2 was out of. service and




     thus did not contribute to the benzene found.   In Tests 2-2 and 3-1




     the tracer gas should have been dispersed over Tank 3 rather than




     Tank 2 which was out of service.   Unfortunately,  this was not recog-




     nized .because this newly developed procedure had  not been used before




     under these circumstances.  Tests 2-2 and 3-1  serve as replicates for




     the benzene concentrations found  in Tests 2-1  and 3-2, respectively.




               All of the benzene found in Tests 2  and 3 is attributable to




     Tank 1, since Tank 2 had no emissions, and it  is  assumed that the




     Tank 3 contribution to the samplers was negligible as in Test 1.
Scott Environmental Technology Inc.

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     SET 1957 05 1280                                           Page  6-16






     6.6  NAPHTHALENE MELT PIT






               The naphthalene  melt  pit  is  diagrammed  in Figure  6-8.   The




     melt pit is 24 feet long,  6  feet wide  and  approximately  8 feet below




     grade.   Generally there is one  melt cycle  per  day at  the beginning of




     the first shift.  During the melting operation, which lasts approxi-




     mately  one hour or until all the naphthalene is melted,  massive




     emissions of steam and naphthalene  are released from  the melt pit.




     These emissions were sufficiently large that small variations in  wind




     speed and direction would  not interfere with plume dispersion and the




     collection of representative samples.




               The sampling strategy was to position samplers downwind from




     the melting process at a distance that would prevent  samplers from




     becoming clogged with naphthalene.   Three  samplers were  placed approxi-




     mately  10 feet from the edge of the melt pit and  were 5  feet apart, an




     upwind  sampler was also positioned  approximately  10 feet from the




     source.  At these sampling locations it was assumed that there was no




     contribution from the Denver float  units because  the  mass and velocity




     of the  plume rising from the melt pit  would essentially  block emissions




     from that source from reaching  the  sampling locations.   The gas dis-




     persion bar was positioned on the 'grating  which covered  the melt  pit




     approximately 5 feet above the  surface of  the  naphthalene slurry. It




     is preferable to disperse  the tracer at the liquid level of the source




     but in  this case proper safety  procedures  precluded that arrangement.
Scott Environmental Techndosyinc

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 SET 1957 05 1280
                                                  Page 6-17
                                FIGURE  6-8
          •
          2'
          •I,
              Walkway
                D e
     ^\'
            //I
                    n v
            e r   Flo
t a t i
on   U n :. t si
                                #3
                          Tracer  Gas Dispersion Bar
                                     Melt Pit
                                  •24'
                                  ©
                             Downwind Samplers
                                                 Wind
                                                 Direction
                                                                     \
Scott
Environmental
Technology
Inc.
NAPHTHALENE MELT PIT

-------
    SET 1957 05 1280                                            Page 6-18



              The sampling strategy used was believed to be the best means

    of arriving at reasonably accurate emission rates without unduly

    elaborate and costly sampling procedures.  The simultaneous use of a
                                                                      «
    different tracer gas at the melt pit and on the Denver float units

    and tests utilizing different tracer gas release configurations would

    probably have resulted in better confidence in the emission rates

    during a particular test period.  However, the emission rate varies

    from day to day due to variations in both process and ambient  conditions.

    This, it was not cost effective to perform very elaborate test procedures.

              Between Runs 1 and 2 of Test  2, the dry gas meter was dropped

    and a leak developed at the rotameter at the exit of the gas meter.

    This was not detected until after Run 2.  As a result, a portion of  the

    tracer gas was released to the air near Sampler 2 instead of through

    the dispersion probe.  Thus, the benzene emission results for  Samplers

    1 and 3 are somewhat high and that for  Sampler 2 is too low.   In

    addition, the leak was after the dry gas meter, so the metered release

    rate of isobutane was not the rate at which isobutane left the dis-

    persion probe.  For these reasons, Test 2, Run 2 was not valid.  The

    results were included in Table 3-6 for  comparison of the benzene concen-

    trations measured, which are valid.

              Four tests were run on consecutive days.  During the first

    three tests, the wind  was from the S to SW and the sampler location

    was as shown in Figure 6-8.  During Test 4, the wind direction was

    from  the north.  For this reason sampler positioning for this  test was
Scott Environmental Technology Inc.

-------
     SET 1957 05 1280                                            Page 6-19






     different than for the first three tests.  The samplers were positioned




     two feet from the melt pit between the melt pit and the Denver units




     and approximately five feet from the dispersion bar.




               After Test 3, a test was performed to measure the emissions




     present at the sampling locations when a melt cycle was not in progress.




     The tracer apparatus and samplers were set up as they were for Tests




     1, 2 and 3 on the melt pit.  During this test the wind was light but




     steady over the Denver units.  The benzene found in these samples




     could come from the filling melt pit,  the feed troughs and from the




     Denver units.  It was believed that the results of this test could be




     helpful in interpreting the data obtained at the same locations during




     the melt cycle.
Scott Environmental Technology Inc

-------
                                                               Page 7-1
 SET 1957  05 1280
                      7.0  LABORATORY SAMPLE ANALYSIS


          Two types of liquid samples were collected:  process liquids, and


sar.ple line and water trap catches and washes.   All liquid samples were


stored in amber glass bottles and returned to Scott's Plumsteadville laboratory


for analysis.


7.1  SAMPLE PREPARATION


          Depending upon the complexity of the sample, one of the following


sample preparation procedures was followed prior to the "purge and trap"


procedure and analysis.


          Samples Containing Immiscible Liquid  Phases


          Using a clinical centrifuge (International Equipment Company,


Massachusetts) immiscible liquid phases were separated and each phase was


analyzed separately for benzene.


          Samples Containing Solid and Immiscible Liquid Phases


          Samples containing solids of higher density than the liquid phase


were separated by centrifuge or by simple decantation of the liquid.  The


different phases in the liquid fraction were then further separated by


centrifuging.  Solid and liquid phases were analyzed separately.


          Samples Containing Finely Crystalline Solid Suspension


          In analyzing these samples the stoppered sample jars were shaken


for at least half an hour for homogenizing the solution.  The uniform


distribution of suspended fine crystalline solid particles was tested by


determining the percentage of dry solid in several aliquots of the homoge-


nized mixture.  A weighed amount of the mixture was analyzed for benzene.
Scotc Environmental Technology Inc

-------
                                                                   7_2
 SET 1957 05 1280
          Sampling System Washings




          All washings were clear solutions having only one liquid phase.




The total weight of the liquid phase was determined using a. balance correct




to ±0.1 g.  The total weight of each washing w£S more than 25 grams, so an




error of 0.1 g in weighing the mass will contribute an. error of only 0.4%




to the final analytical data.  A weighed aliquot of the washing was analyzed




for benzene by following the "purge and trap" and analysis procedures out-




lined in the following sections, and using this analysis data the weight




of benzene present in the total mass of washing was calculated.




7.2  PURGE AND TRAP PROCEDURE FOR EXTRACTION OF BENZENE FROM LIQUID PHASE




     TO GASEOUS PHASE




          An accurately weighed quantity of the sample to be analyzed was




diluted with 20-25 ol of propylena carbonate in a specially designed glass




purging apparatus which was kept immersed in a thermostatted water bath




maintained at 78°C.  Benzene free nitrogen gas was bubbled through the




propylene carbonate solution in the purging apparatus at the rate of




0.2 - 0.3 liters/minute, and collected in leak free Tedlar bags.  Under




these experimental conditions, 1 1/2 - 2 hours were sufficient to purge




off all the benzene from the liquid phase to the gaseous phase.  The total




volume of nitrogen gas used to purge the sample was accurately measured




by a calibrated dry gas meter.  A diagram of the purge and trap set-up is




shown in Figure 7-1.




          Propylene carbonate was found to be an ideal diluting solvent




for the extraction of benzene from all types of liquid samples containing




viscous tar, pitch, light and heavy oil and insoluble particulates .  It




was chosen for its high boiling point, low density, and good, solvating




capacity.





Scott Environmental Technolosy Inc

-------
                                                                                            T.
                                                                                            pa
                                                                                            03
                                                                                            rai
FIGURE 7-1   PURGE AND TRAP METHOD  EQUIPMENT SET-UP

-------
SET 1957 05 1280                                               PaRe 7"4








7.3  GAS ClIROMATOGRAPH




          A Ferkin-Elmer 900 gas chromatograph was used for the analysis




of the purge bags.  A 10 ft. by 1/8 inch stainless steel column packed with




20% SP-2100/0.1% Carbowax 1500 on 80/120 mesh Supelcoport was used for the




analysis.  This column gave complete resolution of the benzene peak from




other components present in the purge bags.   The 'peak height' method was




utilized to calculate the concentration of benzene in the purge bags




analyzed.  The Perkin-Elmer 900 used for analysis 'was not equipped with




a backflushing unit.  Gas chromatograph conditions were as follows:




          GC column temperature:  70°C isothermal




          Detector temperature:  190°C




          5 ml loop at a temperature of 120°C




          Carrier gas flow rate:  30 cc/min He




          Hydrogen flow rate:  45 cc/min




          Oxygen flow rate:  400 cc/min




          Detector:  Flame lonization Detector (FID)




          In addition to benzene, the purge bags contained other volatile




hydrocarbons present in the liquid samples such as toluene and naphthalene.




Because this chromatograph was not equipped  with a backflush, it was




necessary to elute all heavy organics from the column by heating the column




to 150°C after every two injections for one hour with the carrier gas on.




After cooling the column to 70°C the absence of any organic in the column




which might overlap the benzene peak ir. the next analysis was checked.  When




the column was found to be satisfactorily clean, the next analysis was




continued under the conditions previously described.
Scott Environmental Technciosy

-------
SET  1957 05  1280             '•                                 Pa"e 8~1
                8.0  QUALITY CONTROL AND QUALITY ASSURANCE





          The following sections will address quality control and quality




assurance procedures for th«: field analysis of benzene in air samples and




the laboratory analysis of process liquids.





8.1  FIELD ANALYSIS PROCEDURES




          All samples were analyzed in duplicate and as a rule peak heights




were reproduced to within 5%.  For some very high concentration samples




(percent range) it was necessary to make dilutions for analysis.  When this




was done a fresh dilution was prepared for each injection and peak heights




were reproduced to within 10%.  To verify that the system was retaining no




benzene, frequent injections of the standard and nitrogen were made.  In all




cases the result was satisfactory.




          The Tedlar bags that were reused for sampling were flushed three




times with nitrogen and allowed to sit overnight after being filled  to




approximately three quarters of their capacity.  They were analyzed  for




benzene content the following day.  The background concentrations of the




bags were recorded and varied from 0 to 10 ppm benzene.  Care was taken to




use sample bags whose background concentration was very low compared to the




expected concentration of the source.




          The accuracy and linearity of the gas chromatographic techniques




used in this program were tested through the use of EPA Audit Samples.  Two




standards, a 122.5 ppm and 6.11 ppm benzene were used to analyze the audit




cylinders.
Scott Environmental Technology Inc.

-------
 SET 1957  05  1280
8.2  PROCEDURES FOR ANALYSIS OF PROCESS LIQUIDS




          Scott's benzene standards,  checked against EPA Audit Standards,




were used as reference standards throughout this prcgram.  The accuracy and




linearity of the gas chroma tographic  technique for benzene analysis was        ;




tested through the use of EPA Audit Standards which were available to Scott.




Gas chroma tographic analysis of the samples and .standard were performed




under identical conditions to assure  the accuracy of the analytical data




generated.




          Each batch of propylene carbonate which was used as the diluting




solvent in the purge and trap technique was analyzed for benzene content by




subjecting 25 ml of propylene carbonate to the purge and trap procedure




followed by gas chroma tographic analysis of the trapped gas under identical




conditions as described in Section 5.2.  All batches of analytical grade




propylene carbonate were found to be  free from benzene.




          Every day before the analysis of samples the. purging apparatus and




trapping bags were tested for absence of benzene.  Whenever the whole system




was found to be free from benzene to  the lowest detectable limit of the




instrument, the samples were analyzed using the purging apparatus and the




trapping gas sampling bags.




          Generally an accurately weighed mass of each sample was subjected




to purge and trap procedure only once and the trapped gas sample was repeat-




edly analyzed by GC until the analytical data of consecutive GC analyses varied




by ±0.5% or less.
Scott Envfrcnrr^ntcMTv^hrclcKy fnc

-------
                                                                Page 8-3
 SET 1957 05 1280
          For randon.lv- selected samples,  the whole analytical procedure was


repeated with a different weighed, mass of the source sample to. check the


validity and accuracy of the analytical methodology.  The analytical data


for different runs were found 'not to vary by more than 5%.


          By purging the sample with nitrogen under the experimental con-


ditions as utilized by Scott, the recovery of benzene from the sample was


quantitative and this has been verified by analyzing a standard benzene


solution in propylene carbonate containing tar and pitch.
 Scott Environmental Technology Inc

-------
                                                        Page A-l
                                  APPENDIX A




                             SAMPLE CALCULATIONS
Scott Environmental TechrsclcKjy Inc

-------
                                                             Page A-2
                                APPENDIX A



                            SAMPLE CALCULATIONS





1.  Tracer Gas Calculations



    Example:  Naphthalene melt pit, Test 1, Run 1



    Concentration of Benzene:  11.48 ppm



    Isobutane release rate:  1.16 Ib/hr




    Calculation of mass to mass ratios:



          Benzene   11.48 ppm x 78 g/mole = 895.44



          Isobutane  0.713 ppm x 58 g/mole = 41.35





              £ x 1.16 Ib/hr = 25.12 Ib/hr benzene
2.  Flow Rate at Standard Conditions (saturated at 68°F, 29.92 inches Hg)



    Example:  Naphthalene drying tank,  Run 1



    A.   Correction for temperature and  pressure:


                                                   528°R
          Flow Rate (STP) = Flow Rate (source) =
                                                 T(°F) + 460      29 92



                                          COQ      OQ C

          Flow Rate (STP)  = 1150 cfm x 2Q9 + 46Q x -g^- = 895




    B.   Correction for moisture



          Imp ing er and water trap catch volume:   76cc



          Tedlar bag volume(gas sample):  0.474  ft3 = 13.42 1



          Gaseous volume of collected water, standard conditions:



          _,      1 gm   1 mole   24.15 1   1 m  ._ .
          76 cc x — °— x -r-r - x - - - = 101.97 1
                   cc    18 gm     mole
Scott Environmental Technology Inc.

-------
                                                             Page A-3
          Percent moisture:



             101.97
          101.97 + 13.42
                          =  83.4 %
          Flow Rate corrected for moisture:



          Flow Rate (dry) = Flow Rate (STP) x (100 - % Moisture) /100



                          = 895 x (100 - 88.4)/100



                          = 104 cfm



          Flow Rate (saturated at 68°F)  = Flow Rate (dry) x 1.025



                                        = 104 cfm x 1.025



                                        = 106 cfm







3.  Correcting Benzene Concentration for Benzene Found in Water Trap Catch



    Example:  Naphthalene dyring tank, Run 1



    Mg benzene in catch:  1.42 mg



    Tedlar bag volume (gas sample): 0.474 ft3 = 13.42 1



    Measured benzene concentration:  135.96 ppm




    A.  Mg benzene in collected gas sample:




          135.96   ,, /0 -   78 g   1 mole    , QQ
                 x 13.42 1 x — -f- x 0/ . , , = 5.89 mg
                             mole   24.15 1
    B.  Total mass of benzene (air + liquid)



          5.89 + 1.42 = 7.31 mg
    C.   Corrected benzene concentration:


       . --__.     1 mole   24.15 1     106     n,Q ,.
       0.00731 g x -=^	 x	 x    .     = 168.60 ppm
               °   78 e      mole     13.42 1
Scott Environmental Technotosy Inc

-------
                                                            Page A-4
4.  Calculation of Benzene Mass Emission Rate



    Example:  Naphthalene drying tank, Run 1



    Flow Rate (standard conditions) = 106 cfm



    Benzene concentration = 168.60 ppm




          .^ft3   28.32 1   ,_min   168.60   78 g   1 mole     1  Ib       . .„ ,  ,,
          106—r- x	r— x 60r-— x 	2— x —r6- x ..  . g . x  -7-=-.	  =  0.22 Ig/hr
             mm     £t3       hr     ±QO     mole   24.15 1    454 g
Scott Environmental Technolosy Inc

-------
                                                      Page B-l
                                APPENDIX B




                             FIELD DATA SHEETS
Scott Environmental Technology Inc.

-------
                                        Page B-2
                         SCOTT ENVIRONMENTAL TECHNOLOGY,  INC.
     PROJECT 1922
     PLANT;
                             METHOD 110 DATA SHEET
                                         DATE:
PROCESS ; (Loo/f'>\
     PROCESS NOTES:
                  £
                                              AMBIENT TEMPERATURE:
                                              BAROMETRIC PRESSURE:
                                              TEDLAR BAG NUMBER:
       TIME
             STACK TEMP
                                   GAS VELOCITY
                                                       PUMP FLOWRATE
          0
Z
3
4
                                   TOO
                           P
                               (-OOC
                                                                     5-7-75-
                                   1^00
         (0
                                    & 00
                                                   ^  6?
 II
/o
 1
 7
(3
1C,
(7
%H
                                                      A  
-------
                                    Page B-3
                      SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
. PROJECT 1922
PLANT:
                             METHOD 110 DATA SHEET
                »t
                          ?? gf/t fc/t
                                         DATE:
PROCESS ; dCQ//'jt
PROCESS NOTES:
                .g  df^.ir

               .  I O 4- T~.
                                         AMBIENT TEMPERATURE:^
                                         BAROMETRIC PRESSURE:_
                                         TEDLAR BAG NUMBER:
                 F
    TIME
             STACK TEMP
                              GAS VELOCITY
PUMP  FLOWRATE
                                       -A An1
        f
                                 (00(9
                                  19,00
       10
      IQ
                 155"
                                 ^00
                                  105-0
                                      oo
      Zo
                                  fl
                                                   L.5~
                                                     '•
      34-
                                  5 DO
                                                     -*t
                                  ^/oo
                1T5"
                                      60
                                                 / . 5"
                IS
      4(3
              C
                 pS/Vvs-rI >

-------
                                      Page B-4
                        SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
                                                             3
    PROJECT 1922
    PLANT;
               METHOD 110 DATA SHEET
                           DATE:
    PROCESS-: Ceoft'MT f QtD e
    PROCESS NOTES:
                           AMBIENT TEMPERATURE:^
                           BAROMETRIC PRESSURE:
pu^
                \3
                           TEDLAR BAG NUMBER:    /
       TIME
STACK TEMP
. GAS VELOCITY
PUMP FLOWRATE
                         F

                                                     iS
4
                     1 0 0
                                    /OO 0
                                     /. fT
          /O
                                     f.-T
                   /QQ  H/m/
                                            m in
          4
                   400
                                                       S'
                      3
                    [06~0
         ID
                       00
1
                                            ^

        n
                      CO
                     i-r
                    2.^0
                                                     c . 5-
                                                     /.5
        3
                    300
                                                       . 5T"
                                                      1. 5
                                                       1,5
                                                          r
 n
                                                        .5"
    qu
                       1. S

-------
                                        Page B-5

                           PROJECT  1906  BENZENE/BaP PRESURVEY



                                SAMPLE   DATA
Plant 6 1

jft.Sf ^

tfkU Ufa

Process Coo (t\&ibwvr do/rC
Q

Date 7//O/56?
•
•
Sample No.
CT MlO^
ill 1
Time Sampled
IS;?
0
Sample Type:  Liquid     Air



Sample Temperature     $) 6
                                                    ,•  ,
                                                    kef
                                                              L)
Ambient Temperature
                         / /   /
Description of Sampling Location:
                                          /)
                                                             ~~ftJL#J\.
                                            en ue r.
Sample No.   C "T"   nfflU e II   cA
Sample Type:  Liquid    Air
                                           Time  Sampled
                                                            /Q • T ^
Sample Temperature
Ambient Temperature
                          U & r^
                              r
Description of Sampling Location:
Description of Sampling Location:
                                                   1 d  UJ-e //     f I
                                               C 0     UJ-e
      Scott Environmental Techix^osy Irx.
                                                                                 n/(J^f
                                                                              '  <>tr?7(__

Sample No . C Cx3 I 6u
Sample Type: /'Liquid
Sample Temperature
Ambient Temperature
€((
Air
^7
' N C7\ Time Sampled \J-I^
)
2. 'F
6 *F

-------
PROJECT NUMBER
                                     IEST  NUMBER
 PLANT
                     SfcW
 DATE   7/lofVQ
                                                       Page  B-6
                                                                  DRY f.!CLECULAil WEIGHT DETERMINATION   OY
                                                                  SAMPLING Ti.VE (24-hr CLOCK)	
                                                                  SAMPLING LOCATION	
  fAHPLING LOCATION  G?o/'/ui
                                                                   SftiY.PLE TYPE (BAG, INTEGRATED. CONTINUOUS).
                                                                   ANALYTICAL KETHOO	
                                                                   AMBIENT TEMPERATURE	•
SAMPLE TYPE

llUN  NUMBER 	

OPERATORS    CG-
                            1 10
                   /
                        T\fiJ   £~ G-
  AMBIENT  TEMPERATURE

  ftROMETER
YRITE ANALYSIS

        2      —
 co2
          FIEU) DATA

           MOISTURE
      Meter Heading



     Meter Reading 	
  aiaetric Pressure



ieter Temp.  In	

          Out
otameter Setting
acer Volume Final
  er Volume Initial
   Volume
perator
  :OMMENTS
                   	J
">^v^ RUN
i CAS ^^^.^
COZ
0 J'.IET IS ACTUAL Oj
KE*o:::3 sinus ACTUAL
CO; RtJO.'.'IQ
CO,:iir:s*cruALCO
RttMc .visus ;.CTUAL
0; KCAOItlQ
'IjIMiTiSIM MIKUS
ACTUAL CO RUC;»O

ACTUAL
ar.\'."(t;





NET





ACTUAL
PfATOO




t
NET





ACTUAL
SE;,o:;n;





NET




>VtR,\CE
ntr
vctu:,:E




                                     TRAVERSE POINT LOCATION & VELOCITY DATA
                                                                          BY
POINT
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
. 32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
A-FRACTION
OF I.D.
3- /
G,.~7
][.'S
I7.T
3.^,0
?>5:i-
t^/.V
"75". 6
T)^! 3
o ?..3

-------
                                      Page B-7
                      SCOTT ENVIRONMENTAL TECHNOLOGY,  INC.
PROJECT 1922
PLANT:
    PROCESS :  Ik r p e £. a
    PROCESS NOTES:
       10*"
                                   METHOD 110 DATA SHEET
                                                DATE:
                                b d fof -
            AMBIENT TEMPERATURE:_
            BAROMETRIC PRESSURE:_
            TEDLAR BAG NUMBER:
                                                                     . S3
   TIME
                  STACK TEMP
GAS VELOCITY
PUMP FLOWRATE
0
                7o °
                    V.
                                                                                         /f
                                    f o  -rf«i/>
                                                                Apfrvy
                                          f/M/'/i
    30
                                                                             70/.

-------
PROJECT 1922
PLANT:
                       Page B-8
        SCOTT ENVIRONMENTAL TECHNOLOGY, INC.

                 METHOD 110 DATA  SHEET
                             DATE:
                                6
PROCESS;
PROCESS NOTES:
           AMBIENT TEMPERATURE:_ ~
           BAROMETRIC'PRESSURE:_
           TEDLAR BAG NUMBER:
                                                   "I . 5"3
   TIME
STACK TEMP
GAS VELOCITY
PUMP FLOWRATE
     0
     5"
                   -f-^e-
                                          f -e
     /O
 70,4
               I/.. 3 °C
                                                           5- 7?
                                                  /, /:
     3C?
                            VOIP
                                           etc
                                                       co

-------
                                     Page B-9
                      SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
PROJECT 1922
PLANT;
PROCESS ;"fcvtjeCan'fc
PROCESS  NOTES:
                               METHOD 110 DATA SHEET
                                           DATE:
                           - V
            AMBIENT TEMPERATURE:
            BAROMETRIC PRESSURE;
            TEDLAR BAG NUMBER:   3
   TIME
             STACK TEMP
GAS VELOCITY
PUMP FLOWRATE
      D
      s
     10
                                  ^00
     10
                                                            p
       o
                                 50(9
                             veto
                                      /Ait?
                                                             ivw\(>  to//grf£f(

-------
                                        Page B-10
                           PROJECT 1906 BENZENE/BaP PRESURVEY
Plant
                                SAMPLE   DATA
Process    ojr
                                            Toj
                                                                       Date
Sample No.
             TD   i
       Time Sampled
Sample Type:   Liquid     Air
Sample Temperature
                        T) ^
                                                         o
                                                          r-   c/
Ambient 'Temperature
Description of Sampling Location:
                                                                        Q
                                                                                    f>
Sample No.
               rp
      Time Sampled
Sample Type: \Liquid )   Air
Sample Temperature
                      8" a
Ambient Temperature
Description of Sampling Location:
                                                                    I
                                                        LC>TJ3
                                                                 -t~ C t
                                                      (T
                                                                            Q
Sample No.
                                          Time Sampled
Sample Type:  Liquid    Air
Sample Temperature
Ambient Temperature
Description of Sampling Location:
      Scott Environmental Technology Inc.

-------
                                              Page B-ll
                              SCOTT ENVIRONMENTAL TECHNOLOGY,  INC.
       PROJECT 1922
       PLANT;
                          METHOD 110 DATA SHEET,.
                                       DATE:
       PROCESS: T5 y- j ggq/vt'e r-^S" (?cx //g rs/
                              0
       PROCESS NOTES:
                   -3'
                                       AMBIENT TEMPERATURE: ~
                                       BAROMETRIC PRESSURE:
                                       TEDLAR BAG NUMBER:
          TIME
        STACK TEMP
GAS VELOCITY
PUMP FLOWRATE
 10 '
0
                                         ^00
                                         if U>v \~    uA
                                                       letk.OL
                                   ¥-
!c-
fO
                          o
               ff cd
            SLO
           as
           1)0

-------
                                     Page B-12
                      SCOTT  ENVIRONMENTAL TECHNOLOGY, INC.
PROJECT  1922
PLANT:
                              METHOD 110 DATA SHEET
                                           DATE:
PROCESS;
                         '^5
PROCESS NOTES:
    \t>" ID
           AMBIENT TEMPERATURE:  ~ 95" V-
           BAROMETRIC PRESSURE;   c
           TEDLAR BAG NUMBER:
                                                              4-
   TIME
             STACK TEMP
GAS VELOCITY
PUMP FLOWRATE
      0
                                S~l O  C f
      0
               •73
     /r
               13  "C
                                       ft-/*,;^.
                                                              39
                                ^•70
    to
                                                     /?
                                                    x
                                                     r
                                 q -7 
-------
Plant
                                        Page B-13

                           PROJECT 1906 BENZENE/BaP PRESURVEY



                                SAMPLE   DATA
Process
                                                                       Date
         .    /  Q   <3
Sample No



Sample Type:  (Liquid )    Air



Sample Temperature    /   7 C/
       Time
                                                Sampled     « '->  i T'>
                                                            Issuer
                                                               I
                                                                    >y £$d k r
Ambient Temperature  ^ I o
Description of Sampling Location:
Sample No.
                           t,
      Time Sampled
             /^
Sample Type:  (Liquid    Air
Sample Temperature
Ambient Temperature
Description of Sampling Location:
Sample No.
Sample Type:   Liquid    Air
Sample Temperature
Ambient Temperature
Description of Sampling Location:



      Scott Environmental Technology !nc
                                          Time Sampled

-------
PROJECT 1922
PLANT;
                Page B-14




SCOTT ENVIRONMENTAL TECHNOLOGY, INC.






         METHOD 110 DATA SHEET
                      DATE:
PROCESS: L^M-oi'l (WdecTSeT we n't" AMBIENT TEMPERATURE:
PROCESS NOTES: BAROMETRIC PRESSURE: 2.*? .S~l
£, " 3lO vevft" TEDLAR BAG NUMBER: ^

TIME
IC'.lC" ^
5"
10
f£
SO
3^
30















1





STACK TEMP

GAS VELOCITY t PUMP FLOWRATE
//O
130 -(+/Wv(>
(3n
130
lao
132)
|^O














-



•*.


j*\ i f fiit f*^
) // xi A **> V 1- ^i
2 £#Zz_
l'^ j^n^ ^ ^/^^
\& JlLy^ (c^&l
,3 ,0 JLpL^ 6^ &&
2s) 6 ^ 9K
.-%/ f / /^ ^ '^j











•










-------
                                      Page B-14
                       SCOTT  ENVIRONMENTAL TECHNOLOGY, INC..
PROJECT 1922
PLANT;
     g-fee/
                  METHOD  110 DATA SHEET
                                   -\trt\     DATE:
PROCESS :
PROCESS NOTES:
                              AMBIENT TEMPERATURE:
                              BAROMETRIC PRESSURE:
                              TEDLAR BAG NUMBER:
   TIME
STACK TEMP
                                GAS VELOCITY
PUMP FLOWRATE
        0
            F
                                                     3
                 57 6*
       5
                     SlO
                                   CO
     as

-------
PROJECT 1922
PLANT;
                        i'age rs-j.5
         SCOTT  ENVIRONMENTAL TECHNOLOGY,  INC.

                 METHOD 110 DATA SHEET
                                                                                 3
                              DATE
                :    7/11
PROCESS;
PROCESS NOTES:
                              AMBIENT TEMPERATURE:	
                              BAROMETRIC PRESSURE:	£
                              TEDLAR BAG NUMBER :__"7_
   TIME
STACK TEMP
GAS VELOCITY
            PUMP  FLOWRATE
       o
      loH'F
  //O
**?/!
                                  /oo
      10
                      3D
                                   30
                    ib
                     US"
                       a
                                    3(9

-------
                                      Page B-16
                       SCOTT ENVIRONMENTAL TECHNOLOGY,  INC.
PROJECT 1922
PLANT;
PROCESS:
PROCESS NOTES:
                                METHOD  110  DATA SHEET
                                             DATE:
                                                             12.
                                            AMBIENT TEMPERATURE:_
                                            BAROMETRIC PRESSURED
                                            TEDLAR BAG NUMBER:
                                                                          f-
   TIME
              STACK TEMP
                                 GAS VELOCITY
PUMP FLOWRATE
                                                                       .  (o7
-------
PROJECT 1922
PLANT:
                        Page B-17
         SCOTT ENVIRONMENTAL TECHNOLOGY, INC.

                 METHOD 110 DATA SHEET
                              .DATE:
                                                             ?f~
PROCESS;
PROCESS NOTES:
                              AMBIENT TEMPERATURE
                              BAROMETRIC PRESSURE
                              TEDLAR BAG NUMBER:
   TIME
       C
STACK TEMP
GAS VELOCITY
                        5%  fnKi
    10
                                                      '5
                   iol
                                                             -*_y

-------
                                         Page B-17
PLANT;   iH  ."•'•'	
PROCESS;  t\'ciu^t('£. ]r t'ig  '(\^! T<\ ^U
PROCESS NOTES :  ,-, ,
   TIME
        0
                GA
                                     -7 •' "' *~> .' '">• /
                             ;V,TE:_._  LLL^LL':.^
                             /ii-iBiE:.";. :-;-;Fr:- .:".;i-:..:._
                             BARCMLVUIC ?EE^SUi;. '.:
                               )I>.R BAG NUMBER:   /
/;c_ :£:...„
                                                                                f-
       fT
T7
       ID
                                              /o ,  7?o
     l-o
                                                           i-
              79 'C.
                                           i  j 6     r-'
       $
       to
                                         (n£> • Vp
      ze
                                                                                  o
                                                                 3, X9/ Pi-

-------
PROJECT i&2^..
                        Page B-18

            '\


         SCOTT  ENVIRONMENTAL TECHNOLOGY, INC.






                 •METHOD liO D±iTA oluLEIT
                                            DATE:
                                                      4 ,
PROCESS ;
tf
\
     * i »   <:i ^  /
                            VVQ •
PROCESS NOTES:
 AMBIENT TEMPERATURE:
.-  i


 «BAJWMETRIC PRESSURED



 HDLAR .BAG NUMBER:
   TIME
STACK TEMP
                     GAS^VELOCITY
                                                      PUMP FLOWRATE
£•13   0

       0.

    10
                   6*60
      ft
   7/  e c
     /o
                                                 
-------
                                      Page  B-19
                       iiCOT-" ?f UO:;ME;--.T;J. 'rj .OOLOGY,  INC.
PROJECT 192?
                         110
PLAMTJ
                               DATE:
PROCESS:
PROCESS NOTES:
                               AMBIENT TEMPERATURE:.
                               BAROMETRIC PRESSURE:,
                                      BAG NUMBER:
   TINE
STACK TEMP .
GAS VELOCITY
PUMP ..fLOWRATE
     /o
        c
     30
                                                    no
                                 ct
     JTo
                                          0
                                        ~^0&f

                            /yfU

-------
                                      Page B-20
                      SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
                                                                                       7
PROJECT 1922
PLANT ;
                               METHOD 110 DATA SHEET
                                            DATE:
                     •Ui-
PROCESS:
PROCESS NOTES:  <,-)•£ a ii^ cn &
^—.                \/  o / /_/
                                            AMBIENT TEMPERATURE:_
                                            BAROMETRIC PRESSURED
                                            TEDLAR BAG NUMBER:
   TIME
              STACK TEMP
GAS VELOCITY
PUMP FLO',>/RATE
       n
      /o
                                           Sax
         .
                                0  \A<\(  ;
                                A . ^ Hn l*» llw
                                        K.,v
                                                    		  x   / ^'^
                                                   s—7T  ~y i f   / L » • •> -&
                                                   f 0 ,  51 ^Iki^^S
                                                 n e J
f^g-f 9.
                                                   l
                                                                          j  in
                                  
-------
PROJECT 1922
PLANT:  &
PROCESS; ftJnftV^
PROCESS  NOTES:
                                     Page B-21
                      SCOTT ENVIRONMENTAL TECHNOLOGY,  INC.

                               METHOD 110 DATA SHEET
                                            DATE:
                        Af
                           ^, f&>
                                "
            AMBIENT  TEMPERATURE:
                                            BAROMETRIC PRESSURE:
                                            TEDLAR  BAG NUMBER:  \J?
   TIME
              STACK TEMP
GAS VELOCirf
                                                      PUMP FLOWRATE
                                     -1GO./00 r
       0
     (T
     20
                              j£/'/2 - Itol.Zoo
                                 0
                                    9 i  M ?

-------
                                     Page B-22
  <3

3
     6
             l/'C  -
              -H
             -     /.-:•"
                   4
                         I r-. .A
                        <>i *
' J -".

-------
                                     Page B-23
                      SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
PROJECT 1922
PLANT;
PROCESS t  OgwtV
PROCESS  NOTES:
                             TRACER GAS DATA SHEET
                     /-fofKWim  Pfl
                                           DATE:
                                           WIND SPEED;
                                                                  u-a.-u a.
    I f na
Sampler  Number
Distance from Source
Sampling Rate
Pump Numbers
Tedlar bag numbers
Start Time
Stop Time.
                                           WIND DIRECTION:
                     incL .  IVl" n€ & )-€$-/•    AMBIENT TEMPERATURE:   7^ 5~.
                     <{
                       C IA,
                                           BAROMETRIC PRESSURE;
                              fttfr
                             /O  tp
                          !3
                                          (0
                                        ir.T.1
                                        ir.s^f
                                                       3
                                                                 c fc u'
                                                                       UPWIND
                                                                      1T
ISOBUTANE RELEASJ::: Gas Temperature
  TIME
        o
        3
       G
       70
      9.0
      30
                METERED VOLUME
                     -7
                     -74.
                      7S". 5^77
                              7o
                      76. /
                       "76,  -7^0
                      77.  3
                                           Gas
                                       C\r^.
                                                 TIME
METERED VOLUME

-------
                                    Page B-24
                     SCOTT ENVIRONMENTAL TECHNOLOGY,  INC.
                                                                 I     £(,A)
PROJECT 1922
                            TRACER GAS DATA SHEET
PLANT: J5£ThU/\fi,m D'^J/ ) V €//
JdJ^ju^ DATE: ' / [Q 1 6^
PROCESS: JP(\\tfir HocJ- Unf-\-
PROCESS NOTES:
Sampler Number
Distance from Source
Sampling Rate
Pump Numbers
Tedlar bag numbers
Start Time
Stop Time
WIOT SPEED:
WIND DIRECTION:
AMBIENT TEMPERATUI
BAROMETRIC PRESSUI
DOWNWIND
(
ID fr.
Id
£>
14
a o?
£fk



13V31I
£
(^ fr
IV.tpl^
3
S3
I a: of
Q; 31




IE: S~ &C Cf
IE: '21\5"5~
e^'V

3
/-5v -Pf-
|0 ^/v
3
34
1 ~> A?
/#•
J°.-tpk
^
39s.
fc:/o
ll^o
ISOBUTANE RELEAS:.'.:  Gas Temperature
  TIME
         0
        /•o
         G
       an
       3 c
               METERED VOLUME
                        .  3 )
                    $1  . 447
                   ff L
                     3 . o  i  a
                        .. / 3
                    ^•3.100
                        *  o.
                                          Gas
TIME
                                      f>w
METERED VOLUME

-------
                       SCOTT  ENVIRONMENTAL TECHNOLOGY, INC.
PROJECT 1922
PLANT;
PROCESS ;
PROCESS NOTES:
                 F(
                  oa
 Sampler  Number
 Distance from Source
 Sampling Rate
 Pump Numbers
 Tedlar bag numbers
- Start Time
 Stop Time
                              TRACER GAS DATA SHEET
                                             DATE:
                                                              o
WIND SPEED:
                                             WIND DIRECTION:
                               A  i
                             /HIT  1
                                             AMBIENT TEMPERATURE:,
                                             BAROMETRIC PRESSURE:
                                    DOI^WIND
                                                         3
                                                                          UPWIND
                                                                           4*
                                                                       /o:. 30
ISOBUTANE RELEAS;::  Gas Temperature
  TIME
10 '.-So     0
          4-
          lo
         12.
         f?
        lo
                 METERED VOLL"1E
                       •fo-7.
                                             Gas
                         I D°l*
                            .1/0
                        do.
                       hQ.r 14  .ft'
                     •  lUfl^
                                                  TIME
                         METERED VOLUME '

-------
PROJECT 1922
PLANT;
PROCESS:
PROCESS NOTES:
Sampler Number
Distance from Source
Sampling Rate
Pump Numbers
Tedlar bag numbers
Start Time.
Stop Time
                                      Page B-26
                       SCOTT ENVIRONMENTAL TECHNOLOGY,  INC.
                             TRACER GAS DATA SHEET
                                            DATE:
                                            WIND SPEED theses
                        rf-
                                             AMBIENT  TEMPERATURE:,
                                             BAROMETRIC  PRESSURE:
                                     DOWNWIND
                                 o
                            G
                           10
                         I/:
=!?
  3

                                      /      WIND DIRECTION:  frvp^ffy  S<9
                                       /I   AMBIENT TEMPERATURE:    ^KO
                                                                         UPWIND
                              (3
ISOBUTANE RELEAS:::  Gas Temperature
  TIME
 U'.ll
          0
          (o
          IZ
         1C?
                METERED VOLUME
         1)0
                       1  4.
                       IK.
                       //IT.330   .
                                             Gas
          :IME
METERED VOLUME

-------
PROJECT 1922
                                      Page B-27
                       SCOTT  ENVIRONMENTAL TECHNOLOGY,  INC.
TRACER GAS DATA SHEET
PLANT: SeVMC-Vvevw ^>\





-2-
-^
->
3
IfT








3


3
/G






UPWIND
^



/7

•
ISOBUTANE RELEAS:-'.:  Gas Temperature
  TIMEfMETERED VOLUME
         /o
         ^^
                     0,
                             So
                                             Gas
                                                  TB1E
                                        METERED VOLUME

-------
 PROJECT 1922
 PLANT ;
                                     Page B-28
                      SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
                             TRACER GAS DATA SHEET
                                           DATE:
                                                               -TEsr 3
 PROCESS : Denver  F(oa4-
                                           WIND SPEED:
 PROCESS NOTES:
                                           WIND DIRECTION;  Most"//
                                           AMBIENT TEMPERATURE :
                                           BAROMETRIC PRESSURE:
                                                                      ff $"
 Sampler Number
 Distance from Source
 Sampling Rate
 Pump Numbers
 Tedlar bag numbers
.Start Time
 Stop Time
                                    DOWNWIND
                            lo
                                             2-
                                         11
                                                                       UPWIND
ISOBUTANE RELEAS": Gas Temperature
  TIME
           o
          10
          Zo
          Z.G
          is
          50
                METERED VOLUME
                                            Gas
TIME
METERED VOLUME
                         , ^ o.  /3^74
                        /HOT/

-------
                                      Page B-29
                         PROJECT 1906 BENZENE/BaP PRESURVEY
 Plant
su,
'roc ess
Date
f,
Sketch of  Process;
 Include dimensions and flow directions.
Process Description;
     Scott EnvironmentaJ Technolosylnc

-------
                                        Page B-30
                          PROJECT  1906  BENZENE/BaP PRESURVEY
Plant
Date    7
                                                                              /f/ffr
Sketch of Process:
 Include dimensions and flow directions.
Process Description:
      Scott Environmental Technolosy lr>c.

-------
                                        Page B-31
                          PROJECT 1906 BENZENE/BaP PRESURVEY
Plant
              Process
                                                      f 6//t/Y"     Date  7 7/57

Sketch of Process;
 Include dimensions and flow directions.
Process Description;
;<**)
                                  4"

      Scott Environmental Technology Inc

-------
Plant
                                        Page B-32
                           PROJECT 1906 BENZENE/BaP  PRESURVEY

                            	— s AM PL E  - D A-T-A •
                                    Process
Sample No.
                                           Time Sampled
Sample Type: / Liquid/    Air
Sample Temperature
Ambient Temperature
Description of Sampling Location:
Sample No. /fcywgf
                                    ^
Date
Sample Type: ( LiquidJ   Air

Sample Temperature 	^ (#  C
Ambient Temperature
Description of Sampling Location:
                                          Time Sampled
Sample No.
Sample Type: \Liquid)   Air
Sample Temperature
Ambient Temperature
                                     u-
                                          Time Sampled
Description of Sampling Location:
      Scott Environmented Technology Inc


-------
                                       Page B-33
                       SCOTT ENVIRONMENTAL TECHNOLOGY,  INC.
PROJECT 1922
                              TRACER GAS DATA SHEET
PLANT ;   f f k if . U IK
                            fe/A. /£ /t
                                           DATE:
PROCESS :
                                             WIND SPEED:
PROCESS NOTES:
         SUv+eJ?    T'S~0*«~
                                             WIND DIRECTION:
                                             AMBIENT TEMPERATURE•:
                                             BAROMETRIC PRESSURE:
Sampler Number
Distance from Source
Sampling Rate
Pump Numbers
Tedlar bag numbers
Start Time
Stop Time
                                     DOWNWIND
                               10
                              Id
                         f.o*
£.0k
                                           10
                                          //}
                                          3
                                           10
                                          (0
                                                        3
                                                       ti'OO
                                                                          UPWIND
ISOBUTANE RELEASE:  Gas Temperature
TIME
         13
         (0
        ^^
METERED VOLUME
                        .  o-rs"
                        .  3
                                             Gas
                                                   TIME
                                                C a h
                                                   k
                                                    loo/C.S
                                                , t v
                                                d
                                              foo
                                                              fn
                                                                      METERED VOLUME
                                                          fv/7l/
                                                             i/m
                                                              Lover "ft?  i/h^n V
                                                                         f
                                                                             iT
                                        r .(23

-------
                                     Page B-34
                      SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
PROJECT 1922
            TRACER GAS DATA SHEET
PLANT: \9 ^mV^Vxi/K 3*&\. .^ &MObJMUv^ •
PROCESS: $Vanl\\t*CLl<£h.C. KK^ r
PROCESS NOTES: <* . /•>£
5* If ?K *£: 5>£>
Sampler Number
Distance from Source
Sampling Rate
Pump Numbers
Tedlar bag numbers
Start Time
Stop Time
• DATE: / / \0 / iSU
- WIND SPEED:
WIND DIRECTION:
AMBIENT TEMPERATURE:
. BAROMETRIC PRESSURE:

DOWNWIND


(0 (4
to toL
Lf
13






1^
Uf4
• 10
3
34


Jpk






^
(o 4-4
/o JtoL

6U

•i



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UPWIND
4
Cf-f-
jo J^pL
I
3


ISOBUTANE RELEASE:  Gas Temperature
  TIME
        lo
         i
        zz
        30
METERED VOLUME
                    . 000
   "Tt,.
                   Q-7.
                      7. 3 K
                           Gas PrpggiiT-o
TIME
                                            •ffto
      _£'
                                                 -
METERED VOLUME
           F
                                                               ft
                                                                   ^~

                                                             *f
                                                                            - A

-------
                                       Page B-35
                       SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
PROJECT 1922
                              TRACER GAS DATA SHEET
PLANT;
DATE:
                                                      7
PROCESS;
                              
                                32.f/3
                              /  - 9
                              13:?,
                               1 3s: o to
                                             Gas
      TIME
                                                        -.0
                                                         7.
                                                         -
                                                          ;f
                                                        .-.
METERED VOLUME

-------
                                      Page B-36
                       SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
                                                                          5
PROJECT 1922
PLANT :
                             TRACER GAS DATA SHEET
                   S/T I f ;
DATE:
                                                            o
PROCESS ;
                     rfl£(-f
WIND SPEED;  Van*R.bl
PROCESS NOTES:
                                            WIND DIRECTION:
                                            AMBIENT TEMPERATURE :
                                            BAROMETRIC PRESSURE:
                                                                     , S)
 Sampler Number
 Distance from Source
 Sampling Rate
 Pump Numbers
 Tedlar bag numbers
• Start Time
 Stop Time
         \p\ AJ O
                                    DOWNWIND
                             10
                           1-
ISOBUTANE RELEASE:  Gas Temperature
  TIME
         10
         It
         IS*
        zz
        so
                METERED VOLUME    4H- '
                       iS~~7.  4,3-0
                        5-7 .
                                                  10
                                                           72.7
                                                     3.10^/30,

-------
                                   B-37
                     SCOTT ENVIRONMENTAL TECHNOLOGY, INC.
PROJECT 1922
            TRACER GAS DATA SHEET
PLANT: &>;Uvtd\AM<\ SWj? . • DATE: ~? f {$ \ £0
PROCESS: Aj^h^ffAfinL VW&(jC
PROCESS NOTES:
PtlNVtrvvirte. (,2- 3 (
Sampler Number
Distance from Source
Sampling Rate
Pump Numbers
Tedlar bag numbers
Start Time
Stop Time
WIND SPEED: ^ ^ £ ,cA^M
WIND DIRECTION: A/
T-^
AMBIENT TEMPERATURE:
BAROMETRIC PRESSURE:

DOWNWIND
[
<] ft
- /o j0/?A

?
^^G
•
i
H
$:30

7^
i 2 ^f-
/n J^P/A

_L^ , 1^
"'7'. 3fc j^:so



^,
3 -fi-
. fo *pL

n ^y
73(o S\3o


UPWIND
it
Z5 ft-
.-lOApL
.
2^ 2~?-
'7--5fo ^N3C>
k
ISOEUTANE RELEASE: Gas Temperature
  TIME
         0
         In
        20
        30
METERED VOLUME


           I-77J
                          1T7.
                           17^.0,3
                                 S
           7*7
                          Gas
TIME
     / D
                                                   IZ
                                   w
                                                         u
METERED VOLUME
                                                  /S2./00

-------
PROJECT 1922
                                       Page B-38  .
                       •SCOTT ENVIRONMENTAL TECHNOLOGY.,  INC,
                              •;TRACER .GAS-DATA SHEET
                                             DATE;
.PROCESS: DdJS&
PRCESS .NOTES-:-,
                                                              .
                                   pi-J'.  :  .WIND  SPEED;''., /ffr/L'f'
                                      .
                                              WIND. -DIRECTION: 5
                                             AMBIENT  TEMPERATURE:_
                                           . ; BAROMETRIC  PRESSURE: :.
 Sampler  Number
 Distance .from Source
 Samp.iing Rate  • •  .   ;
 Pump  Numbers
 Tedlar .bag numbers
.Start.Time : .;.. '•'  '.' ...'•
 Stop .Time      .    ••   •
                                     DOWNWIND .
                                                          /r
ISOBUTANE-. RELEASTi:: . Gas Temperature
  TIME
          6-
          #.
         -.I.Q
         -11.
                  METERED VOLUME .'
              :i3f. •.-.•
_ly • ££	4'*>Q
Tip  I•• y  IT:
                                              Gas
                           TIME .
                                                          to
                                                          a-
                                               ..
                                                                           .UPWIND
METERED VOLUME
                                                                      •[ "70/70.0 '..
                                                                           >
-------
PROJECT 1922
                           Page B-39
             SCOTT ENVIRONMENTAL TECHNOLOGY,  INC.
                   TRACER GAS DATA SHEET
                                                             VOIP
PLANT: '3c*Kid>.vi Steel , FHUlfeken~ • DATE: • 7//W'?<9
PROCESS: '"VfU'gv" uvoi t" - n£JlU~ - will
PROCESS NOTES:
' 	 i — •;—
Btf-CK'H'Cx-'n J -v-c i'' w\
UVu »KvS ^ h"Ylts?- ^H-iX
Sampler Number
Distance from Source
Sampling Rate
Pump Numbers
Tedlar bag numbers
Start Time
Stop Time
WIND SPEED:
WIND DIRECTION: ^> - S W '
 >
AMBIENT TEMPERATURE: ^ ^ ° p '
BAROMETRIC PRESSURE: '1 ^ , 5^7"

DOWNWIND


-^'^ (-+-
10 'U'k-
(D
H-
[0\2S


1


."2-
^ff
—S

/«/ li
I *y * '— *-^ , -J
i


' 3 •
^Pf


1^
/O'.iS


\c\
\\.of


UPWIND
£j-
loC-f-

?
 0
 10
30
                   141,3-70
                             3.3/9
                                 Gas
                                      TIME
                                                  :0
                                          •'If
                                            0
                                           /0/
                                                 3c
                                                               METERED -VOLUME
                                                                   7, ^5"
                                                        is-/,

-------
                                       Page B-40
                         PROJECT 1906 BENZENE/BaP PRESURVEY
 Plant
gc-VKUk
Process 'we i
Date
Sketch of Process;
 Include dimensions and flow directions.
Process Description;
      Scott Environmental Techndogy Inc

-------
                                                      Page C-l
                               APPENDIX C




                         LABORATORY DATA SHEETS
Scott Environmental "technology Inc

-------
    Project No,
                                         CHROMA*
                              Date
                                            ANALYSIS LOG
                                 Analyst_
Time
Sample Identification
               "     '
        (A
                      ..«-
                      .
               \\ ' - -   -X
              /->       ll:   /
              o-     /
-------
I
s

g
                                                                 ANALYSIS LOG
Project No,
  Date
   Analyst_
         Time
        Sample Identification
   Peak

Height/Area
                                                               Concentration

                                                                  Factor
Concentration
Comments
                                                  (1- C-
                 ,,/ O -i  t"\
                 (f   >AvV

                                                                                      riA WVV
                                                                                                                        .
                                                                                                                     trc
                                                                                                                         U"
                                                                                                                           OQ

                                                                                                                           (B
                                                                                                                           x

                                                                                                                           n


                                                                                                                           CO

-------
Project No.
                                   CHROMATOGRAPHIC ANALYSIS LOG
Date
    \s.-
Analyst
v '6
Time
i

'







Sample Identification
\
' /> 7 J" O* \ / 1 ( 1 \ i: 'V- *. J i ,-- - , , { ; i
f -^ — i«^_ , •'«.. -'^-- \_
C ' •"• '•*-
\i> \e)-'^ ^ t O
•VI a', ^.-..^''t-"^
(^uwlU.J" '.'''. "f^
( ** • / ^X
•'^\ ( t — __i;. j. M J


'
-------
•X1
                                                  CHROMATOGRAPHIC  ANALYSIS LOG V
Project No,
Date
? "(\  - '>.
                                  Analyst
         Time
        Sample Identification
   Peak
Height/Area
    Concentration
       Factor
                             Concentration
Comments
                      V
                                 .^_»- yf'
                      ' < -J.-- '-<-••' ^
                         /cv'b
                                                 6-6 b
                                                 06 6'
                                                                   . ^6 -X
                                                                 /•TV
                                                                                                      .&- -.

-------
1
                                                  CHROMATOGRAPHIC ANALYSIS LOG  -'\rtl\X:. I
              Project No,
  Date
7 ' /(.  \c
Analyst
                                                                                                   -
         Time
                      Sample Identification
   Peak

Height/Area
                                                                Concentration

                                                                   Factor
                    Concentration
                    Comments
v<


*
       •}  H.X
                      c~" v      - *-       '    -ff"

                      V '.^c-r— - — '— -v.  -  \T\ '- — ->  3


                              x^"       '  <1
                      V  /Ay  (e-y /o.^VA/
                                                   /O
                                                  •c
                                                  / -5"


                                                  / ^
                                                                                                 (kt,,..<.f^,Xi

                                                                                                    AX-I- - -^
                                                                                                                    A
                                                                                                                    - —
                                                                                                                             tu
                                                                                                                             OQ
                                                                                                                             n>

                                                                                                                             o

                                                                                                                             o\

-------
                                          CHROMATOGRAPHIC  ANALYSIS LOG VS . v;. i'.s 0'. (;.  ^  "~V~f V i  \,
Project No,    !'"'-'';-^
                                            Date
                                                                Analyst
Time
Sample Identification
   Peak
Height/Area
Concentration
   Factor
                                                                     Concentration
Comments
         ..7.7. -vv>— •      TE^'
             (,"/
                                            • o ,
                                           0/6
                                                                           / 'j %'j" - •
                                                                             i O>>

-------
CHKUMATUUKAi'tUU ANALI5IS LUU ,-./ ,". •! ,j • ( . • (' '* '
Project No, I'-W'A Date " / ' 1 1 ''->> Analyst "X V> ^-/ .

Time |
'<- '/.'Ov.-

->:X









Sample Identification
c^fr-^TM
/" ,v
-^-_ •*-' ( '•'•
^ " T" V~~ \ '^
\ ^ .,,'• •-'--- --• -.( \ (C'(/Jf '*-*
I ^
^ ..v .-.-.,^- \,j...
-. ^_ ^
V'- v%^ * •— ^-y-A
/.-.-^ C .)..-,;% '«
'' J
'M^
Peak
Height/Area
->/- -3 '

' 9- ^ T
' '-V C
_ '"'
r^5C-Y3

'-/. ^>
•~~)

..-,- . .-j^ A'v
Concentration
Factor
• ,.x-/.
•
•
. -j
-------
    Project No.
                                         CHROMATOGRAPHIC ANALYSIS LOG
                               Date
                                  Analyst
Time
Sample Identification
   Peak
Height/Area
Concentration
   Factor
Concentration
                                                                                                Comments
        /CCC X
         ^ V,    O Jl
               /3s-1  -  ^'



        /*  -i    '  ' I*'!
        .1-  •"    'j  11 •{
        'ccc v  - ^ Si-
                            (I  Q >5l:/«

                           2r& t~'f
               ^j,.9.^
                                                                                           r 25 v;


-------
I
                                                 CHROMATOGRAPHIC ANALYSIS LOG
             Project No,
  Date
                                                                - >rc-
                   Analyst    y \S
         Time
                     Sample Identification
   Peak
Height/Area
Concentration
   Factor
                                                                              Concentration
                                                                                                     Comments
3
I
*<
?
                    T-   r~f'.  0
                    /,*>-=••—•--> — > _;-"_>.'v

                    T-;v  £:'
                                                  VK
                                                  /S
                                                                  oft

-------
Project No,
                                    CHROMATOGRAPHIC  ANALYSIS  LOG
Date
Analyst	j
Time '
i






Sample Identification
- . fv\,-3i '"'
^£y^:£^
:wZ Z
33 *t - 
. C^/XIO
Peak
Height/Area


v

^9


Concentration
Factor

'
V/3
x^
,y(.( f

•
Concentration


V//.5,




Comments


/ / /57o ^ _^



• '^"

-------
I
f
Project No,
                                                  CHROMATOGRAPHIC ANALYSIS LOG
  Date
                   Analyst_
         Time
        Sample  Identification
   Peak
Height/Area
Concentration
   Factor
Concentration
                                                                                                         Comments
                 ft j&'
                         ./-A isr v

                              ^
                        /-J. 'rA
                                                           .
                                                           '/-• j
                                                           7<; >
                                                           70
                                                                   /•(*(
                                                                   .'^'5  c^^_
                                       *
                                                    3
                                                                                  I "3

-------
                            CHROMATOGRAPHIC ANALYSIS LOG
                                             S .-"CiUtO.: —. ^.--
                                                                                    » ]>
Project No,
                                          Date
                                      '?-/'•/ %<•"""
                                 Analyst
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   Peak
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                                                  Concentration
                                                     Factor
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                                                                                              Comments

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                                                 CHROMATOGRAPHIC ANALYSIS LOG
  Date
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                                                                  Factor
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-------
Project No.      / 'M-^
                                       CHROMATOGRAPHIC ANALYSIS LOG
                                         Date
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-------
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                                               CHROMATOGRAPHIC ANALYSIS LOG
                             Date
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   Peak
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   Factor
                                                                         Concentration
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-------
                                         CHROMATOGRAPHIC ANALYSIS LOG

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                              Date
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                                                                                  Comments
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                                  Date
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                                                  ANALYSIS  LOG
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-------
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                             Date
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   Peak
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                                                                                          Conunents
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                             Date
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                            Date - !.  "7 ~
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                                   CHROMATOGRAPHIC ANALYSIS LOG
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                                          CHROMATOGRAPHIC ANALYSIS LOG
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                              Date
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                                    CHROMATOGRAPHIC ANALYSIS LOG
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                              Date
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                                 Date
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  Date
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                                         CHROMATOGRAPHIC ANALYSIS LOG
    Project No.
                              Date     "? -
                                  Analyst    t"^v
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   Factor
                                                                       Concentration
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                                           CHROMATOGRAPHIC ANALYSIS LOG
                              Date
                                 Analyst_
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                                                         Concentration
                                                            Factor
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                                        CHROMATOGRAPHIC ANALYSIS LOG
                               Date
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                                                                                              Comments
           ,
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-------
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                                        Date
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                                 Date
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                                                                                             Comments
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                               Date     / ' d'--• *~  V  
-------
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                                        CHROMATOGRAPHIC  ANALYSIS LOG
                              Date
                                 Analyst
Time
Sample Identification
   Peak
Height/Area
Concentration
   Factor
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                                                                                             Comments


-------
    Project  No,_
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                                  Date
                                Analyst
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-------
    Project  No.
                                       CHROMATOGRAPHIC ANALYSIS LOG
                             Pate
                                Analyst
Time
Sample Identification
   Peak
Height/Area
Concentration
   Factor
Concentration
                                                                                          Comments
               °V  7
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-------
                                  APPENDIX D



                       TRACER GAS METHOD DEVELOPMENT
Scott Environmental Technology Inc.

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                                                             Page D-l




                  ;•' .             APPENDIX D       .




                      TRACER GAS METHOD DEVELOPMENT




  D.I Tracer Gas  Selection




             The  initial consideration when using  the  tracer gas method




  is  the  choice of a  suitable gas.  There are several criteria used  in




  the selection:   First, the tracer gas must not  be present  in the atmos-




  phere at  the sampling location.  Second, the  tracer gas must be separable




  from other components in the background at the  sampling location and




  quantifiable on  the same GC column without interfering  with the elution




  of  the  compound(s)  of primary interest.  The  tracer gas should also be




  readily available,  transportable, economically  feasible, and safe  for




  the given usage  situation.




             For  the determination of benzene  emissions at  secondary by-




  products  plants, isobutane is the recommended tracer  gas.  The second




  choice  for a tracer gas is a halogenated hydrocarbon.  At  secondary by-




  products  plants  the hydrocarbons in the background atmosphere are  almost




  exclusively emissions from the coking operation and neither isobutane




  nor halogenated  hydrocarbons are present to any significant degree.




  Isobutane was chosen over a halogenated hydrocarbon on the basis of




  chromatographic  elution characteristics.  Isobutane elutes well before




  the benzene peak thus eliminating any interference when using a tempera-




  ture program for the chromatographic analysis.




             The  separation of isobutane from  mixtures containing concen-




  trations  of hydrocarbons typical of secondary by-products  plants was




  verified  by spiking samples collected at different sources in a secondary




  by-products plant with various concentrations of  isobutane and performing











Scott Environmental Technology Inc.

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                                                            Page D-2




 a temperature program of chromatographic analysis to achieve the desired




 degree of separation.  In all cases the desired separation was achieved.




 D-2  Dispersion Apparatus




            The apparatus for the dispersion of tracer consists of a




 cylinder of the tracer gas connected to a dry gas meter, a rotameter and a




 dispersion tube.  All necessary connecting lines are Teflon.




            Two different dispersion tube configurations were tested, both




 were constructed  from 1/4" O.D. stainless steel tubing.  The first tube




 tested was 8* long with the tracer source connected to one end of the tube.




 The tube contained holes every 19" which were progressively larger moving




 away from the gas source.  The hole size ranged from 0.062" to 0.031".




 The second tube was 8' long in two 4' sections which are connected via a




 T-joint to each other and to the tracer gas source.  This dispersion tube




 has 0.041" holes  every 19" and the ends are capped.
                                                      L/W5"
                     <— D?N 6AS METER.
             Of  the  two  types of dispersion  tubes  tested  the  latter  described




 was more efficient  for  the  dispersion  of  the  tracer.  This judgement  was  made




 by visual inspection of the holes  in each tube while  isobutane was  flowing at
Scott Environmental Techndosy Inc

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                                                             Page D-3






  0.1 CFM.  At this rate isobutane can be seen as it leaves the dispersion




  tube and differences in the relative volume leaving each hole are visually




  discernible.  The first configuration had all gas coming out of the first




  2 holes, whereas the second configuration had uniform emissions from each




  orifice.



             Benzene was also released in two ways; by evaporation and




  a heated bubbler.  Both methods proved adequate for experimental determina-




  tions.  When evaporation was used to release benzene, a stainless steel




  pan 16" x 24" x 1/2" was employed to contain the benzene.  During an




  experimental determination benzene was added to the pan in 50 cc aliquots




  at intervals frequent enough to maintain a constant surface area of benzene.




  This was done in order to keep the emission of benzene at a constant rate.




  However, this evaporation method proved unsatisfactory on days when the wind




  speed exceeded 15-20 MPH due to the changing evaporation rate resulting




  from gusting wind.  A more steady emission of benzene was achieved by



  using a heated bubbler.  The bubbler system consisted of a 500 cc




  impinger of the Greenburg-Smith design wrapped with a heat tape.  The




  impinger was kept at a constant temperature below the boiling point of




  benzene.  A rubber diaphragm pump was used to push atmospheric air through




  a bubbler.  Flow was regulated with a rotameter.
Scott Environmental Technology Inc.

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                                                       Page   D-4




              It   was  necessary to  add  more  benzene during an experimental




  run,  because the emission  rate drops  substantially if the benzene level




  drops too  low in the impinger.  The  frequency of  addition and the quantity




  of benzene per  addition  are  dependent on the  emission rate being used.




  For our determinations it  was necessary to add 50 cc of benzene at intervals




  of approximately 10  minutes.




  D-3  Experimental Determinations




              An  experiment  consists of the  release of a known amount of




  isobutane  and benzene simultaneously.  Samples are collected along a 30




  arc,  25 feet downwind from the source of the  emissions.
                                   10'
              Initially samples  were grab samples collected in clean one




  liter glass gas flasks.   Later samples were integrated over a 1/2 hour




  period and collected in  clean  10-liter Tedlar bags via Emission Measure-




  ments Air Quality Sampler with a flow rate of 10 LPH.




              In initial determinations, portions of actual presurvey




  samples containing 62% benzene were released in an effort to simulate
Scott Environmental Technology Inc.

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                                                              Page  D-5




  the type  of  sample which would be encountered  in  the  field.  Various  amounts




  of the  sample mixture  from 0.20  to  10 cc were  released and samples were




  collected downwind in  1-liter gas flasks.  When these samples were analyzed




  the amount of benzene  detected was  very small, approximately 20 ppb.   From




  this it was  apparent that it would  be necessary, to release significantly




  more benzene in order  to produce the necessary concentration at the




  sampling  location so that quantative mass  to mass ratios  could be calculated.




              Because of the necessity of releasing more benzene and avoiding




  the foul  odor which the high concentration benzene field  samples  possessed,




  it was  decided that pure benzene be used for all  subsequent  determinations.




              For the next series  of  experiments evaporation as previously




  described was used to  release benzene.  This series of experiments produced




  results accurate to within 10% of the theoretical mass to mass ratios




  with a  minimum benzene emission  of  0.54 Ib/hr  for the series.  These




  experiments  were performed on days  when the wind  speed was light  (5 - 10




  MPH) and  the wind direction was  steady (See Table D-l).




              The next experiment  was designed to test  the  variations which




  might be  introduced when the wind speed and direction were less than  favorable.




  On the  day selected the wind speed  was 20-25 MPH  and  the  direction was 180




  variable  due to a changing weather  system.  The rate  of evaporation of the




  benzene was  noticeably affected  by  the conditions as  were the dispersion




  patterns  of  the emissions.  Erratic results were  produced by the  meteorological




  stress  on key experimental variables.  Calculated mass to mass ratios differed




  from the  theoretical value from  15% to as  much as 56%, demonstrating  the




  effect  of high and variable winds on the technique.   In order to  reduce




  stress  on the experiment the benzene bubbler as described was used to provide
Scott Environmental T^ndogy

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                                                             Page D-6






  a  steady source of benzene emission at a rate that would be independent




  of meteorological conditions.  On the day chosen to use the bubbler system.




  the wind speed was 15-20 MPH and the direction was steady.  Favorable re-




  sults were obtained despite the relatively strong wind demonstrating that  the




  tracer technique is valid in winds up to 20 MPH depending on the sampling




  location (see Table D-l).




  D-4  Summary                                            !




             When using the tracer gas method it is necessary to verify




  that the tracer gas is detectable at the sampling location of choice




  as the method is somewhat dependent upon meteorological conditions.




  The method works best when the wind speed is light to moderate, 5-15 MPH,




  and the wind direction is steady.  When the wind speed exceeds approximately




  20 MPH or if there is no wind and/or the wind direction is too variable,




  dispersion patterns condusive to accurate sampling are disturbed and




  quantitative mass to mass relationships are difficult to establish.




  The upper limit of stress with respect to meteorological conditions can




  be examined by the spread of mass to mass ratios for each individual




  sample for a given sampling run.  If the calculated ratios are inconsistent




  or the deviation between each calculated ratio and their mean is greater




  than 20%, it would be necessary to seek an explanation based on process




  variations or meteorological conditions or to void the sampling run and




  possibly suspend sampling until conditons are more favorable.




  D-5  Field Sampling Strategy




             The program for a sampling run will generally involve  the




  collection of triplicate downwind samples and a single point upwind sample.




  Actual sampler locations will be determined by the gas chromatograph on










Scott Environmental Technology Inc.

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                                                              Page D-7






  site.  Grab samples will be collected in glass flasks and analyzed to




  determine the benzene concentration in the vicinity of the source to be




  tested.  This information will be correlated with wind speed and direction




  to choose the exact sampler locations.  In the ideal case downwind




  samplers  will be equidistant from the source and along approximately a




  30° arc.




              Two sets of samples will be integrated over separate one-




  half hour periods and together constitute a single test.  Samples




  will be collected by Environmental Measurements AQS II sampling system




  into clean 10-liter Tedlar bags.  Tedlar bags to be reused for sampling




  will be flushed three times with nitrogen and allowed to sit overnight




  three quarters full.  Prior to their next use each will be analyzed for




  benzene content.




              The tracer gas dispersion apparatus will be positioned over




  the source to be tested as near as possible to the actual emissions.




  Ideally the dispersion tube or support member will span the source of the




  emissions at its center.
Scott Environmental Technology Inc.

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                                                TABLE  D-l




                                           EXPERIMENTAL DATA



Release      Benzene

Rate         Release                    Wind     Wind       Theoretical  /ic,   4>/icA

g/min        Method     Sample Type     Speed    Direction    T/ic,       #1     #2     //3 "*   Average
41 - Benzene


ic, - Isobutane


* No benzene, only Isobutane detected.
i ° 5226   Evaporation  Grab         0-5 MPH      Steady        0.005      *NO    NO     NO      ---

  4




d> fl QQ1
*   a ,,   Evaporation  Grab         0-5 MPH      Steady        0.120      *NO    NO     NO      ---
ic, o.e.1






t 4*75ifi   Evaporation  Grab         0-5 MPH      Steady        o'.59        0.64   0.64   0.65    0.645

1C4 ''-1"




* 9.40

ic,  6.38  Evaporation  Integrated   5-10 MPH     Steady        1.47        1.57   1.43   ---     1.50







t 10ii5^o  Evaporation  Integrated   20-25 MPH    Variable      0.80        1.29   1.82   0.94    1.35
ic . x j • j y






ic9 8°25   Bubbler      Integrated   15-20 MPH    Steady        1.14        1.40   1.93   1.02    1.18







iC6'3<3 48  Bubbler      Integrated   0-5 MPH      Steady        0.91        0.97   0.96   0.96    0.96








J 6*J8/Q   Bubbler      Integrated   0-5 MPH      Steady        1.00        0.91   0.86   0.89    0.89
1C f V • ^O
                                                                                                               t)

                                                                                                               oo

-------
                                 APPENDIX E




                             FIELD AUDIT REPORT
Scott Environmental Technology Inc.

-------
                                                                 Page E-I
                              FIELD.AUDIT REPORT
PART A - To be filled out  by organization supply unit cylinders  (RTI)

     1.  Organization supplying*audit sample(s) and shipping  address
                            •                                      —
          Research Triangle  'institute, Post Office Box. 12194, Research Triangle Park,-NC
        .                .          ._     __
     2.  Audit supervisor, organization, and phone number  (EMB Technical
        . Manager)          „.«,.«.                                          •
                       Dan  Bivens, EPA
      3."   Shipping instructions '- Name, 'Address, Attention
        *
           Scott Environmental technology      	'
           Post Office Box"D-11
           PTurnsteadviHe, PA  18949	'ATTN:  Bob Denyszyn'
                                                 t
      4.   Guaranteed  arrival date  for cylinders      6/10/80
      5.   Planned shipping date for cylinders	6/10/80
      &.  Details on audit cylinders for  last analysis  •
                                .  .         '      Low Cone.    High Cone.
          a.  Date .of. last analysis               5/30/80-      5/30/80
          b.  Cylinder number                     B-1372      'B"921
          c.  Cylinder, pressure,. PSI                1750         1500
          d.  Audit gas(es)/balarice, gas    vv    Benzene/N?   Benzene/N?
          e.  Audit gasCes)  ppm                ""7.93          154.4  .
          f.  Cylinder construction               Steel         Steel

-------
PART B - To be filled out by audit supervisor

     1.  Organic chemical manufacturing process  Cofcc
     2.  Location of audit
                                                                Page E-2
     3.  Name of individual audit and organization
     4.  Audit results
a.  Cylinder number

b.  Cylinder pressure before
    audit, psi

c.  Cylinder pressure after
    audit, psi

d.  Audit date and measured
    concentration, ppm

                   Date

    'Analysis #1    ?'/ v/jC-
       '     .    «™^^^^^^^^^^^^^^^^™—

    •Analysis £2    77 *y'j C<

    Analysis #3 _£
                              7 '
e.  RTI concentration, ppm
    (Part A, 6d)
                                               Low Cone.   High Cone.

                                               CH3TZ,
                                                 7't-"/
                                                             I4CO
                                                          "   /3'f.Z/
                                                    (l-

-------
f.  Audit accuracy*                .                    Pase E~3
    Analysis £1                    -  '.'%.'*-      -/
    Analysis ?2                    ~'$
•   .Analysis S3           •       •  — Z//        -/3,06

' \ *Percent accura^ ^Measured' Concern tone. 'x 1QQ    =-' ' .
g.  Problems detected (if an.>?    S^/7  "''s  Wr  x.-v.> •.•>/>;/.'


-------
-JOT
 FROM:'.
                                                       Page E-4
                SCOTT ENVIRONMENTAL TECHNOLOGY, INC.

                     Plumsteadville, Pennsylvania 18949
                   INTERDEPARTMENTAL MEMORANDUM




                        	        DATE.     TuLy   \g
                                     SUBJECT:.
                         HU;j
         CM ( t/
                                                              t/~
             ^ j> c S~£LJJ -V-
                                 ..JLV   £0^ *?•
U ' VbW' 2  ff^



    Vy^-     ± i'l
                                                             V\
 ("0 --r
                                                         —-—7 /  / - • .. ^
                                                         ^/': :.--•

-------
                                                      Page F-l
                                  APPENDIX,F




                              PROJECT PARTICIPANTS
Scott Environmental Technology Inc.

-------
SET 1957 01 1080









                                APPENDIX F




                           PROJECT PARTICIPANTS




          The following people participated in some phase of the sampling




program at Bethlehem Steel.






From Scott Environmental Technology, Inc.:




     Tom Bernstiel, Chemist




     Jack Carney, Chemist




     P. K. Chattopadhyay, Chemist




     Dan FitzGerald, Manager, Eastern Operations




     Kevin Gordon, Technician




     Carolyn Graham, Chemical Engineer




     Scott Henderson, Environmental Scientist




     Lou Reckner, Vice President & General Manager




     Joe Wilson, Senior Technician






From Research .Triangle Institute:




     Ralph Roberson




     Dave Marsland






From U. S. Environmental Protection Agency




     Lee Beck




     Dan Bivins
Scott Environmental Technology Inc.

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                                                         Page G-l
                                 APPENDIX G




                               EPA METHOD 110
Scott Environmental Technology Inc.

-------
                                                           Page G-2
                   Federal Roaster /  Vol. 45. No. 77  / Friday,  April  18.  1080  / Prcnosed Rules
                                                                             2RS77
   (f) All con'iri1.:*'.'! monitoring systr-ms
 used in accordante-with this section are
 to complete a minimum of one cyrii; of
 operation (sampling.-analyzing, and data
 recording] fur each successive 15-minute
 period.
   (y) Owners or operators of all
 continuous monitoring systems installed
 in accordance with this subpart shall
 check the zero and span drift at least
 once daily in accordance with ihe
 method prescribed by the manufacturer
 of such systems unless the manufacturer
 of such systems recommends
 adjustments at shorter intervals, in
 which case such recommendations shall
 be followed. The daily span check is to
 be conducted with reference gas
 containing a concentration of benzene
 determined to be equivalent to the
 emission limit for that source based on
 the emission tests required by § 61.94.
   (h) The calibration is to be done with
 either—
  (1) A calibration mixture prepared
 from the liquids and gases specified in
 Section 5.2.1 and 5.2.2 of Test Method
 110 and in accordance with Section 7.1
 of Test Method  110: or
  (2) A calibration gas cylinder
 standard containing the appropriate
 concentration of benzene. The gas
 composition of the calibration gas
 cylinder standard is to have been
 certified by the  manufacturer. The
 manufacturer must have mcorr.mended a
 maximum shelf iifo ."or each  cylinder so
 g-is standards vail no: be used if their
 concentration has chanced greater than
 ±5 percent from the certified value. The
 data of gas cylinder preparation.
 certified benzene concentration, and
 r(.comn;oncled maximum shell life must
 have been affixed to the cylinder  before
 shipment from the manufacturer la the
 buyer. If a gas ch.-ornatogr^.ph is used as
 the continuous monitoring system, these
gas mixtures may be used directly to
piepare a chrorr.atograph calibration
 curve as described in Section 7.2 of Test
Method 110 for certification of cylinder
 standards and for establishment and
 verification of calibration standards.
  (ij After receipt and consideration of
 written application, the Administrator
 may approve use of an alternative or
equivalent continuous monitoring
system, alternative monitoring
procedures, or alternative monitoring
requirements.
(Sec. 114. Clean Air Act as amended [42
U.S.C. 7414|)

§ 61.9S  Recordkeeping requirements.
  (a) The owner or operator  of each
source to which this subpart applies
shall maintain daily records  of the
monitoring information specified in
I 61.95[a).
   (b) Records arc to b.2 retained at the
 source and made available for
 inspection by the Administrator for a
 minimum of 2 years.
 (Sec. 114. Clean Air Act as amended [42
 U.S.C. 7414))

 Appendix B—Test Methods

 Method 110. Determination of Benzene From
 Stationary Sources
 Performance of this method should not be
   attempted by persons unfamiliar with  the
   operation of a gas chronmtoqraph. nor by
   those who are unfarr.ilar with source
   sampling, because k.-.owledse beyond the
   scop* of this presentation is required. Care
   must be exercised to prevent exposure of
   sampling personnel to benzene, a
   carcinogen.

 /.  Applicability and Prinicple
   1.1 Applicability. This method applies to
 the measurement of benzene in stack gases
 from processes as specified in the
 regulations. The method does not remove
 benzene contained in particulate matter.
   1.2 Principle. An integrated bng sample of
 stack gas containing benzene and other
 organics is subjected to gas chromatographic
 (CC) analysis, using a flame ionization
 detector (FID).

 2.  Range and Sensitivity
  The range of this method is 0.1 to 70 ppm.
 The upper limit may be extended by
 extending the calibration range or by diluting
 the sample.

 3.  Interferences
  Thi; chromatn.araph columns ar.J the
 coiTL-spon:::.-^ cpuru:ir.5 pjraniat'.rs herein
 •Jcs^ribad normal':;' pro\ids an adequate
 resolution of benzene: however, resolution
 interferences may be encountered on some
 sources. Therefore, the chromatograph
 operator sh:i!l select the column and
 operating parameters  best  suited to his
 particular analysis croblem. subject to the
 approval of the Adrrir.istrutor. Approval is
 automatic provided i.-.si! the tester produces
 confirming data throuoh an adequate
 supplemental analytical technique, such as
 analysis with a different column or GC/mass
 spectroicopy. and hus the data available fur
 review by the Administrator.

 •}.  Apparatus
  4.1  Sampling (see Figure 110-1). The.
 sampling train consists of the following
 components:
  4.1.1   Probe. Stainless steel. Pyrex * glass.
 or Teflon tubing (as stack temperature
 permits), equipped with a glass wool plug to
 remove paniculate matter.
  4.1.2   Sample Lines. Teflon, 6.4 mm oursiJe
 diameter, of sufficient lenvjih  to connect
 prol:e to bag. Use a new unused piece for
 each series of bag samples that constitutes an
emission test and discard upon completion of
 the test.
  4.1.3  Quick Connects. Stainless stoel,
male (2) and female (2). with ball uhscks (one
 p.->ir without) !iicn!o
-------
2GG73
                              Page  G-3
Fcder.il Register / Vol. 45. No. 77 / Friday, April 10, 1980 / Proposed Rules
                STACK WALL
   FILTER
(GLASS WOOL)
X
f
*==)=.-----..•
I

s
PROBE
/
^----.-- = z
1
/
                                                TEFLON
                                              SAMPLE LINE
                                                                  VACUUM LINE
                          QUICK
                        CONNECTS
                         FEMALE
                        TEDLAR OR
                       ALUMINIZED
                        MYLAR BAG
                                                                          NEEDLE
                                                                          VALVE
                                                               FLOW METER

                                                             CHARCOAL TUBE

                                                                     \
                                                                                 PUMP
                                                         RIGID LEAK-PROOF
                                                            CONTAINER
             Figure 110-1.  Integrated-bag sampling train. (Mention of trade names or specific products
                         does not constitute endorsement by the Environmental Protection Agency.)
BILUNQ CODE 6560-01-C

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                                                                Page  G-4

                    Federal  Register /  Vol. 45.  Nn.  77  / Friday. April 18, .1980. /  Proposed  Rules
                                                                                 26679
   4.3.2  Chrorr.atographic Columns. Columns
 as listed below. Th>' analyst rrviy use other
 columns provided that the precision and
 accuracy of the analysts of benzene
 standards are not impaired  and he has
 avdil.ible foe review information cnm'irming
 that there is adequate resolution of the
 benzene prak. (Adequate resolution is
 defined as an area overlap of not more than
 10 percent of the benzene peak by an
 interferent peak. Calculation of area overlap
 is explained in Appendix E. Supplement A:
 "Determination of Adequate
 Chromatographic Peak Resolution.")
   4.3.2.1 Column A: Benzene in the Presence
 of Aliphatics. Stainless steel, 2.44 m by 3.2
 tr.m. containing 10 percent 1.2.3-tris (2-
 cyanoetho.xy) propane (TCEP) on 80/100
 Chromosorb P AW.
   4.3.2.2 Column B: Benzene With
 Separation of the Isomers of Xylene.
 Stainless steel. 1.83 m by 3.2 mm. containing 5
 percent SP 1.200/1.75 percent Bentone 34 on
 100/120 Suplecoport.
   4.3.3  Flow Meters (2). Rotameter type. 100
 mi/min capacity.
   4.3.4  Gas Regulators. For required gas
 cylinders.  •
   4.3.5  Thermometer. Accurate to 1° C. to
 measure temperature of heated sample loop
 at time of sample injection.
   4.3.6  Barometer. Accurate to 5 mmHg, to
 measure atmospheric pressure around gas
 chromatograph during sample analysis.
   4.3.7  Pump. Leak-free, with minimum of
 100 mL/min capacity.
   4.3.8  Recorder. Strip chart type, optionally
 equipped with either disc or electronic
 integrator.
   4.3.9  Planimeter. Optional, in place of disc
 or electronic integrator, on recorder, to
 measure chromatograph peak arsas.
   4.4 Calibration. Sections 4.4.2 through
 4.4.5 are for the optional procedure in Section
 / .1.
  4.4.1  Tubing. Teflon, 6.4 mm outside
 diaiTiuter, separate pieces marked for each
 calibration consentration.
  4.4.2  TeJlar or Aluminized Mylar Bags. 50
L capacity, with valve: separate bag marked
for each calibration concentration.
  4.4.3  Syringes. 1.0 nL  and 10 /iL. gas tight;
individually calibrated to dispense liquid
benzene.
  4.4.4  Dry Gas Meter, With Temperature
and Pressure Gauges. Accurate  to :r2
percent, to meter nitrogen in preparation of
standard gas mixtures, calibrated at the fiotv
rate used lo prepare standards.
  4.4.5  Midget Itr.pinger/Hot Plate
Assembly. To vaporize benzene.

5.  Reagents
  Use only reagents that  are of
chromatographic grade.
  5.1  Analysis. The following are needed
for analysis:
  5.1.1  Helium or Nitrogen. Zero grade, for
chromatograph carrier gas.
  5.1.2  Hydrogen. Zero grade.
  5.1.3  Oxygen or Air. Zero grade, as
required by the detector.
  5.2  Calibration.  Use one of the following
options: either 1.2.1 and 5.2.2. or 5.2.3.
  5.2.1  LV:'.ze:ii;. 03 Mol Percent Pure.
Certified l;y the- manufacturer to contain a
 minimum of 99 Mol percent benzene; for use
 in the preparation of standard gas mixtures
 as described in Section 7.1.
   5.2.2  Nitrogen. Zero grade, for preparation
 of standard gas mixtures as described in
 Section 7.1.
   5.2.3  Cylinder Standards (3). Gas mixture
 standards (50.10. and 5 ppm benzene in
 nitrogen cylinders). The tester may use
 cylinder standards to directly prepare a
 chromatograph calibration curve as
 described in Section 7.2.2, if the following
 conditions are  met: (a) The manufacturer
 certifies the gas composition with an
 accuracy of ±3 percent or better (see Section
 5.2.3.1). (b) The manufacturer recommends a
 maximum shelf life over which the gas
 concentration does not change by greater
 than ±5 percent from the  certified value, (c)
 The manufacturer affixes  the date of gas
 cylinder preparation, certified benzene
 concentration, and recommended maximum
 shelf life to the cylinder before shipment to
 the buyer.
  5.2.3.1  Cylinder Standards Certification.
 The manufacturer shall certify the
 concentration of benzene in nitrogen in each
 cylinder by (a)  directly analyzing each
 cylinder and (b) calibrating his analytical
 procedure on the day of cylinder analysis. To
 calibrate his analytical procedure, the
 manufacturer shall use. as a minimum, a
 three-point calibration curve. It is
 recommended that the manufacturer maintain
 (l).a high-concentratio.i calibration standard
 (between 50 and 100 ppm) to prepare his
 calibration curve by an appropriate dilution
 technique: and (2) a low-concentration
 calibration standard (between  5 and 10 ppm)
 to verify the dilution technique used. U' the
 difference between the apparent
 concentration read from the calibration curve
 and the true concentration assigned  to the
 low-concentration standard exceeds 5
 pcrctr.l of the true eonccntratior., ;he
 manufacturer shall determine the source of
 error and correct it, then repeat the three-
 point calibration.
  5.2.3.2  Verification of Manufacturer's
 Calibration Standards. Before using, the
 manufacturer shall verify each  calibration
 standard by (a) compiling it to gas mixtures
 prepared (with 99 Mol percent benzene) in
 accordance with the procedure described in
 Section 7.1 or by (b) having it analyzed by the
 National Bureau of Standards. The agreement
 between the initially determined
 concentration value and the verification
 concentration value must be within ±5
 percent. The manufacturer must reverify all
 calibration standards on a time interval
 consistent with  the shelf life of the cylinder
 standards sold.
  5.2.4  Audit Cylinder Standards (2). Gas
 mixture standards with concentrations
 known only to the person supervising the
 analysis of samples. The audit cylinder
 standards shall  be identically prepared as
 those in Section 5.2.3 (benzene i:i nitrogen
 cylinders). The concentrations of the audit
 cylinder should  be: one lov.'-cr;ncentration
cylinder in the rar.ge of-5 to £0 ppm benzene
 and one hi.",h-concen:ratioa cylinder  in the
range of 100 to DUO ppm benzene. When
 available, the tester may obtain audit
cylinders by contacting: U.S. Eruironme.ital
 Protection Agency, Environmental Monitoring
 und Support Laboratory. Quality Assurance
 Branch (MD -77). research Trian.qle Park.
 North Carolina 27711. If audit cylinders are
 not available at the Environmental Protection
 Agency, the tester must secure un alternative
 source.

 6.  Procedure
   6.1  Sampling. Assemble the sample train
 as shown in Figure 110-1. Perform a bag leak
 check according to Section 7.3.2. Join the
 quick connects as illustrated, and determine
 that all connections between the  bag and the
 probe are tight. Place the end of the probe at
 the centroid of the stack, and start the pump
 with the needle valve adjusted to yield a flow
 that will more than half fill the bag in the
 specified sample period. After allowing
 sufficient time to purge the line several times,
 connect the vacuum line to the bag and
 evacuate the bag until the rotametcr indicates
 no flow. At all times, direct the gas exiting
 the rotameter away from sampling personnel.
 At the end of the snmple period, shut off the
 pump, disconnect the sample line from  the
 bag. and disconnect the vacuum line from the
 bag container. Protect the bag container from
 sunlight.
   6.2  Sample Storage. Keep the sample bags
 out of direct sunlight. Perform the analysis
 within 4 days of sample collection.
   C.3  Sample Recovery. With a new piece of
 Teflon tubing identified for that bag, connect
 a bag inlet valve to the gas chromatograph
 sample valve. Switch the valve to receive gas
 from the bag through the sample loop.
 ArrAnge the equipment so the sample gas
 pnsscs from the sample valve to a 100-rr.L/
 min rotameter wita flow cor.troi valve
 followed by a charcoal tube and a 1-in.
 pressure gauge. The tester may maintain the
 sample flow either by a vacuum pump or
 container pressurization if the collection bag
 ruir.uir.s '.n the ri^id container. Afler sar.iple
 loop purging is ceased, always allow the
 pressure gauge to return lo zero before
 activating the gas sampling valve.
   6.4  Analysis. Set the column temperature
 to 80° C (1761 F) for column A or 75" C (107°
 F) for column B, and the detector temperature
 to 225' C (-337° F). When optimum hydrogen
 and oxygen flow rates  have been  determined,
 verify and maintain these flow rates during
 all chromatograph operations.  Using zero
 helium or nitrogen as the carrier gas,
 establish a flow rate in the range consistent
.with the manufacturer's requirements for
 satisfactory detector operation. A flow rate of
 approximately 20 mL/min  should produce
 adequate separations. Observe the base line
 periodically and determine lhat the noise
 level has stabilized  and that base-line drift
 has ceased. Purge the sample loop for 30 s.ec
 at the rate of 100 mL/min, then activate the
 sample valve. Record the injection time (the
 position of  the pen on the chart at the time of
 sample injection), the sample number, the
 sample loop temperature, the column
 temperature, carrier gas flow rate, chart
 speed, and  the attenuator setting. From the
 chart, note  the peak having the retention time
 corresponding to benzene, as determined in
 Section 7.2.1. Measure the benzene peak area.
 Am, by use  of a disc integrator, electronic
integrator, or a planimetcr. Record Am and

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                                                  Page G-5

                 Federal Register  / Vol. 45. N'o. 77 / Friday. April 18, 1980  / Proposed Rules
                                                                     SYRINGE
         DRY GAS METER
                                                  TEDLAR BAG
                                                   CAPACITY
                                                   50 LITERS
                       Figure 110-2.  Preparation of bsnzene standards (optional).
26681
BIUING CODE 6560-01-C

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                                                            Page  G-6


         	Federal  Register /  Vol. 45.  No.  77 /  Friday.  April  18,  1900 /'Proposed Rules


 the rrlnnticn lir.ie. Rcpniil the injpr.tion at
 least two times or us\'i\ two consecutive
 values for thi; totnl area of (lie benzene peak
 do not vary more than 5 percent. Use the
 average value of Iiie.sc two total areas to
 compute the bag cun.-.entration.
   6.5  Determination of Bag Water Vapor
 Content. Measure (he ambient temperature
 and barometric pressure near the bag. From a                     '
 water saturation vapor pressure table,
 determine and record ihe water vapor
 content of the bag as a decimal figure.
 (Assume the relative humidity to be 100
 percent unless a lesser value is known.)

 7,  Preparation of Standard Cos Mixtures.
 Calibration, and Quality Assurance
   7.1  Preparation of Benzene Standard Gas
 Mixtures. (Optional procedure—delete if
 cylinder standards are vised.) Assemble the
 apparatus-shown in Figure 110-2. Evacuate a
 50-L Tedlar or aluminizud Mylar bag that has
 passed a leak checi; (described in Section
 7.3.2) and meter in about 50 L of nitrogen.
 Measure the barometric pressure, the relative
 pressure at the dry «as meter, and the                                                          •
 temperature at the dry gas meter. While the
 bag is filling, use the lO.uL syringe to inject
 lOfiL of 99+ percent benzene through the
 septum on top of the impingcr. This gives a
 concentration of approximately SO ppm of
 benzene. In a like manner, use the other
 syringe to prepare dilutions having
 approximately 10 ppm and 5 ppm benzene
 concentrations. To calculate the specific
 concentrations, refer to  Section 8.1. These gas
 mixture standards may  be used for 7 days
 from She dale o!' preparation, after which  time
 preparation of ne-.v g;is mixtures is required.
 (Caution: If the new i;us mixture standard is a*
 lower concentration than the previous gas                                       .         .      .
 mixture standard, contamination may be  a
 problem when a bag is reused.)
  7.2  Calibration.
  7.2.7.  Dttermination of Benzene Retention
Timp. (This section can  be performed
 simultaneously with Section 7.2.2.) Establish
 chromato^raph conditions identical with
 those in Section 6.4, above. Determine proper
attenuator position.  Flush the sampling loop
with zero helium or nitrogen and activate the
sample valve. Record the injection time, the
sample loop temperature, the column
temperature, the carrier gas flow rate, the
chart speed, and the attenuator setting.
Record peaks and detector responses that
occur in the absence of benzene. Maintain
conditions,  with the equipment plumbing
arranged identically to Section G.3. and flush
the sample  loop for 30 sec at the rate of 100
mL/min with one of the benzene calibration.
mixtures. Then activate the sample valve.
Record the injection time. Select  the peak
that corresponds to benzene. Measure the
distance on the chart from the injection time
to the time at which the peak maximum
occurs. This distance divided by  the chart
speed is defined as the benzene peak
retention time. Since it is quite likely that
there will be other organics present in the
sample, it is very important that positive
identification of the benzene peak be made.

BILLINO CODE (SW-01-M

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26632
                                                           Page G-7  .

                   Federal Register  /  Vol.  45,  No.  77 /  Friii;;y. April 18.  1930  / Proposed Rules
Question.
 • 7.2.2  Prrjpar.'itinn of Chromatocraph
Calibration C;:rvo. Mnkr. a pas
chromatopraphic nmasiircnont of each
standard gas n;i.\!ure (described in Sf:ction
5.2.3 or 7.1.1) usi.-.j: conditions identical with
those  listed in Sections G.3 and 6.4. Flush the
sampling loop for 30 sec at the rate of ml./
min with one of the standard gas mixtures
and activate the sampe valve. Record Cc. the
concentration of benzine injected, the
attenuator se'.tui;:. chart speed, peak area,  •
Siimpie loop temperature, column
temperature, carrier gas flow rate, and
retention lime. Record [he laboratory
pressure. Calculate Af, the peak area
multiplied by the attenuator setting. Repeat
until two consecutive injection areas are
within 5 percent, then plot the average of
those two values versus Cc. When the other
standard gas mixtures have been similarly
analyzed and plotted, draw a  straight line
through the points derived by the least
squares method. Perform calibration daily, or
before and 
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                    i-\:dr;r;il Register / Vol. 45, No, 77  / Fridiv. A">ri! 18. In30  / Proposed Rule1?
                                                                                                                       26683
Th?

1

2

3.

4.



S.
 7.

 3.

 9.
^.C:-K
<* « J b-2,  '
                         dt =
                                                  dx
    following calculation steps are  required:*
     2c.
               tc/2;2 In 2
           .j.f
             V25 J
»   x_
e " Z  dx
6.   Q(x2) .
                     - Q(x2)
     Percentage overlap  =  AQ  x  100
     A    =    Ths area  of  the  sample peak of interest determined by  elec-
               tronic  integration,  or by the formula A  = "c^c-
          -    The area  of  the  contaminant peak, determined  in  the  same
               «iar,~er as  A  .
                           a
      b   =    The distance  on the chromHographic chart that separates  the

               isaxima of  the two  peaks.
     H    =    The oeak height of the sample compound of interest.  neasurPd
               fro;!  thff average value of the oase!in* to the maximum  of  the
               curve.
     t_   -    The width  of  the sample peak of interest at  1/2 of peak
               height.
     l    -    The wi'jth  of  the contaminant peak at 1/2 of  peak  height.
     (i    =    The standard  deviation of the sample compound of  interest
               elution curve.
     u    =    The standard  deviation of tne contaminant eluticn curve.
    Q(<  ) =    fho inteyra!  of the normal distribution function  from  x^  to
               infinity.
    Q!*.>) =    Tne integral  of the normal distribution function  fron  x.  to
               infini ty.
               The  overlap integral.
               The  area overlap fraction.
   1r. judging thn sui!;ibi!i!y of a!ti:rr.a'h:c ci'mditions. one can
 •'Riploy the area overlap as the resolution
 pnr.-imotrr with a specific maximum
 •permissible value.
   The use of Gaussian functions to describe
 khi'uiii.itoijriiphic elution curves is
 widespread. However, some elution curves
 are hiphly Hsymmelric. In those cases where
 thf! sample p«ak is followed by a
 contaiminant that has a lisi'dini; ed^n that
 risus sharply but the curve then tails off. it
 may be possible to define an effective width
 for tj as "twice the distance from the leading
 edge to a perpendicular lino through the
 rnaxim of the contaminant curve, measured
 along a perpendicular bisection of  that  line."

 Supplement B—Procedure for Field Auditing
 CC Analysis
   Responsibilities of audit supervisor and
 analyst at the source sampling site include
 the follow-in":
   A. Check that audit  cylinders are stored in
 a safe location both before and after the audit
 to prevent vandalism of same.
   B. At the beginning and conclusion of the
 audit, record each cylinder number and
 cylinder pressure. Never analyze an audit
 cylinder when the pressure drops below 200
 psi.
   C. During the audit,  ths amlyst is to
 perform a minimum of two consecutive
 analyses of each audit cylinder gas. The audit
 must bo conducted to coincide with the
 analysis of so;ir;:o tost sarnuies. Normally, it
 will he conducted irririicdin:::!y ufter the CC
 calibration and prior to tha i^mplii analyses.
   D. At the end of.auriit analyses, tho audit
 supervisor requests the calculated
 concentrations from ihc analvst and then
 compares the rosuits with the actual audit
 concentrations. If nach :nons:ired
 concentration agrees with the respective
 act'.nl concentration within ±10 perront, he
 thon dirccis the analyst to begin the analysis
*of source samples. Audit sut.-pm'sor ji:d2ment
 and/or supervisory policy dutermine course
 of action with agreement is not within ±10
 percent. VVhnre a consis'^nt bias in excass of
 10 percent is found,  it rruy be possible to
 proceed with Ihe sample analyses,  with a
 corrective factor to be applied to the results
 at u later tinip. However, every attempt
 should be made to locate the causi; of" this
 discrepancy, as it may be misleading. The
 audit supervisor is to record er?ch cylinder
 number, cylindor pressure (at the end of the
 nuilit). and all calculated concuntrations. The
 individual buin;; audiiRd niiist not unu'erany
 circumstance be  tald the actual audit
 concentrations until the calculated
 concentrations have been submitted to  the
 audit supervisor.
 BILLING CODE 6560-01-M
    ri;;t instances, Q(<;) is very small and  may  be  neglected.

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