United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EMB Report 85-CHM-10
December 1985
Air
Neshap Screening
Study
Chromium

Emission Test
Report
C. S. Ohm
Manufacturing
Company
Sterling Heights, Ml

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             EMISSION TEST REPORT
       C. S. OHM MANUFACTURING COMPANY
          STERLING HEIGHTS, MICHIGAN
                  ESED 85/02

                EMB 85-CHM-10
                      by

       Entropy Environmentalists,
            Post Office Box 12291
Research Triangle Park, North Carolina  27709
           Contract No. 68-02-3852
     Work Assignments No. 18, 21, and 23
                  PN:  3023
               EPA Task Manager
                  Dan Bivins
    U. S. ENVIRONMENTAL PROTECTION AGENCY
         EMISSION MEASUREMENT BRANCH
 EMISSION STANDARDS AND ENGINEERING DIVISION
RESEARCH TRIANGLE PARK, NORTH CAROLINA  27711
                 January 1986

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                                    CONTENTS

                                                                          Page

Figures                                                                    iv

Tables                                                                      v

1.0  INTRODUCTION                                                          1-1

2.0  PROCESS OPERATION                                                     2-1

     2.1  Process Description                                              2-1
     2.2  Air Pollution Control                                            2-3
     2.3  Process Conditions During Testing                                2-4

3.0  SUMMARY OF  RESULTS                                                    3-1

     3.1  Particulate Matter, Hexavalent Chromium and Total Chrcmiun       3-3
          3.1.1  Scrubber Inlet  (EPA Method 5)                             3-3
          3.1.2  Scrubber Inlet  (Impinger Train)                           3-7
          3.1.3  Scrubber Outlet                                           3-8
     3.2  Emissions in Units of Process Rate and Control Equipment
           Collection Efficiency                                           3-9
          3.2.1  Emissions in Units of Process Rate                        3-9
          3.2.2  Control Equipment Collection Efficiency                   3-11
     3.3  Summary of Analytical Results for Hexavalent and
             Total Chromium                                                3-11

4.0  SAMPLING LOCATIONS AND TEST METHODS                                   4-1

     4.1  Scrubber Inlet (Sampling Location A)                             4-1
     4.2  Scrubber Outlet (Sampling Location B)                            4-5
     4.3  Velocity and Gas Temperature                                     4-5
     4.4  Molecular Weight                                                 4-7
     4.5  Particulate Matter                                               4-7
     4.6  Impinger Collection Efficiency                                   4-8
     4.7  Hexavalent Chrcmiun Content                                      4-8
     4.8  Total  Chromiun Content                                           4-9

5.0  QUALITY ASSURANCE                                                     5-1
                                         11

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                              CONTENTS (Continued)
APPENDICES
     A   TEST RESULTS AND EXAMPLE CALCULATIONS                             A-1
         Particulate, Hexavalent Chrcmiun and Total Chrcmiun               A-3
         Example Particulate Test Calculations                             A-15
         Total Chromiun Analysis Calculation                               A-28
         Explanation of Total Chromiun Analysis Calculation Table          A-29

     B   FIELD AND ANALYTICAL DATA                                         B-1
         Particulate Matter                                                B-3
         Total Particulate Analysis                                        B-21
         Hexavalent Chromiun Analysis                                      B-27
         Total Chromiun Analysis                                           B-31

     C   SAMPLING AND ANALYTICAL PROCEDURES                                C-1
         Determination of Total Particulate Emissions                      C-3
         Determination of Hexavalent Chromiun Emissions                    C-8
         Determination of Total Chromium Content                           C-15

     D   CALIBRATION AND QUALITY ASSURANCE DATA                            D-1

     E   MRI PROCESS DATA                                                  E-1
         Source Sampling Program - Process Data Sheets                     E-3
         Current Usage Calculations                                        E-6

     F   TEST PARTICIPANTS AND OBSERVERS                                   F-1

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                                    FIGURES

Number                                                                    Page

2-1  Sequence of tanks on the decorative plating line at C. S. Ohm
       Manufacturing Company                                               2-2

4-1  Diagram of decorative chromiun plating line and emissions
       control system at C. S. Ohm Manufacturing Company                   4-2

4-2  Scrubber Inlet (Sampling Location A)                                  4-4

4-3  Scrubber Outlet (Sampling Location B)                                 4-6
                                       iv

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                                     TABLES

Number                                                                   Page

2.1  Total Current Supplied to Tank During Source Tests                    2-5

3.1  Testing Schedule for C. S. Ohm                                        3-2

3.2  Summary of Flue Gas Conditions                                        3-4

3.3  Summary of Particulate, Hexavalent Chromium, and Total
       Chromiun Emissions                                                  3-6

3.4  Summary of Emission Rates in Units of Process Rate and
       Efficiency                                                          3-10

3.5  Summary of Analytical Results for Hexavalent and Total
       Chromiun                                                            3-12

3.6  Summary of Analytical Results for Hexavalent and Total
       Chromiun Quality Assurance Samples                                  3-14

4.1  Sampling Plan for C. S. Ohm                                           4-3

5.1  Field Equipment Calibration                                           5-2

5.2  Audit Report Chromiun Analysis                                        5-4
                                       v

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                               1.0  INTRODUCTION



    During the week of June 17-21, 1985,  Entropy Environmentalists,  Inc.

conducted an emission measurement program at C.  S.  Ohm Manufacturing Company's

chromium plating plant located in Sterling Heights, Michigan.   The purpose of

this program was to provide data for a screening study to determine the

quantity and form of chromium emissions associated with decorative chromium

plating.

    Comprehensive testing was conducted on a decorative chromiun plating tank

whose emissions are controlled by a packed-bed wet scrubber.   This fume

scrubber controlling emissions from the decorative chromiun plating tank at the

plant was selected for source testing for the following reasons:
         The plating tank appears to be typical of other automated
         decorative plating tanks in the chromiun plating industry,  based
         on operating parameters such as temperature, current, voltage,
         and plating time.  The automatic hoist is programmed to change
         the rack in the chromiun plating tank every 4.5 minutes.
         Electrolysis occurs in this tank for 1.5 minutes during each
         cycle, or 33 percent of the time.  A demisting agent called
         MSP-1, manufactured by Harshaw Chemicals, is used in the tank to
         suppress misting.  The use of demisting agents is common practice
         for decorative platers.

        The emissions capture system is highly efficient in directing
        fuses from the plating tank to the control device.  The tank is
        equipped with a push-pull ventilation system that draws 16,000
        scfm across a total tank surface area of 90 ft .  (Included in
        this area is a storage tank used to concentrate chromic acid
        solutions from the rinse tank and the fune scrubber.  No
        electrolysis occurs in this tank.)

        The emissions control device used at C. S. Ohm is typical of
        control devices in use at other decorative plating facilities.
        Most decorative plating facilities use impingement-type mist
        eliminators or packed-bed fune- scrubbers to control chromic acid
        emissions.  Emission data from testing at the outlet of the Viron
        wet packed-bed fune scrubber at this facility will represent
        emissions controlled by a typical fune scrubber.

                                    1-1

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    Particulate concentrations and mass emission rates were measured at




the scrubber inlet and outlet using U. S. Environmental Protection Agency




(EPA) Reference Method 5.*  Total chromium concentrations and hexavalent




chromium concentrations were measured at the same locations by further




analysis of the Method 5 samples using the alternate sample preparation




and analytical procedures as described in Appendix C.  Flue gas flow




rates, temperature, moisture content, and composition  [oxygen (02)/ carbon




dioxide (CC^)/ and carbon monoxide (CO)] were measured in conjunction with




the particulate tests.  In addition, an impinger train was run concurrent with




the Method 5 train at the scrubber inlet to determine  impinger collection




efficiency for total and hexavalent chromium.  And for approximately 8 1/2




hours on the second day of testing, a special high volume, constant rate,




single point sampling run was conducted at the scrubber inlet using a Method 5




train.




     Ms. Barbara Duletsky [Midwest Research Institute  (MRI)] monitored process




operation throughout the test period.  Mr. Dan Bivins  (EPA Task Manager) of the




Emission Measurement Branch (EMB) and Mr. Al Vervaert  of the Industrial Studies




Branch (ISB) observed the test program.  Mr. Robert Waters, Plating Plant




Manager served as the contact for C. S. Ohm Manufacturing.




     This report is organized into several sections addressing various aspects




of the testing program.  Immediately following this introduction is the




"Process Operation" section which includes a description of the process and




control device tested.  Following this  is the "Summary of Results" section




which presents table summaries of the test data and discusses these results.




The  next section, "Sampling Locations and Test Methods" describes and
*40 CFR 60, Appendix A,  Reference Method 5, July  1,  1980.




                                       1-2

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illustrates the sampling locations for emissions testing and then explains the




sampling strategies used.  The final section, "Quality Assurance," notes the




procedures used to ensure the integrity of the sampling program.  The




Appendices present the complete Test Results and Example Calculations (Appendix




A); Field and Analytical Data (Appendix B);  Sampling and Analytical Procedures




(Appendix C); Calibration Data (Appendix D); MRI Process Data (Appendix E)j  and




Test Participants and observers (Appendix F).
                                      1-3

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2.0  PROCESS OPERATION
2.1  PROCESS DESCRIPTION
     The C. S. Ohm Manufacturing Company manufactures bumpers for use in
the automotive industry.  The company has a captive plating shop that
performs decorative nickel-chromium plating of the bumpers.  The plat-ing
plant operates 24 hours per day, 6 days per week, 52 weeks per year, with
the exception of Wednesday mornings from midnight to-6:00 a.m., when the
operation ceases for maintenance purposes.
     The decorative plating line consists of 36 tanks that contain various
plating and cleaning solutions.  The sequence of tanks is shown in
Figure 2-1.  The line is serviced by an automatically controlled hoist
that transfers each rack of bumpers through the various tanks in the
plating line.
     The chromium plating segment of the line is comprised of one plating
tank, one evaporation tank, and three rinse tanks.  Emissions from the
chromium plating tank were measured during this source test program.  The
tank measures 3.0 meters (m) (10 feet [ft]) in length, 1.4 m (4.5 ft) in
width, 2.4 m (8 ft) in depth, and holds 10,600 liters (i) (2,800 gallons)
of plating solution.  The solution contains chromic acid in a
concentration of 330 to 340 grams per liter (gA) (44 to 46 ounces per
gallon [oz/gal]).  This is in the range of 220 to 370 g/i (30 to
50 oz/gal) typically used by decorative chromium platers.  Sulfuric acid
is used in the solution as a catalyst in a concentration of 1.0 to 1.2 g/2,
(0.14 to 0.16 oz/gal).  The proper concentration of constituents is
maintained by adding chromic acid and sulfuric acid every other day, and
by adding make-up solution from the evaporation tank on alternate days.
The total chromic acid consumption at C. S. Ohm is about 8,200 kilograms
(18,000 pounds) per year.
     Typically, a rack remains in the chromium plating tank for 4 minutes
and 20 seconds.  The normal operating temperature of the tank is between
46° and 63°C (115° and 145°F).  The electrodes are charged by a single
transformer/rectifier set that automatically controls the operating
voltage and current.  During a typical plating cycle, the tank operates at
2.5 volts (V) and 1,500 amperes (A) for 15 seconds to activate the
nickel-plated surfaces.  Then, the voltage increases to 12.4 V and the
                                    2-1

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  Tank
sequence                     Description

   1                         Soap tank
   2                         Power spray
   3                         Electro-cleaner No. 1
   4                         Electro-cleaner No. 2
   5                         Water rinse

   6                         Water rinse
   7                         Anodic etch (contains H2)
                             Anodic etch (contains H2)
   8                         Rinse
   9                         Rinse

  10                         Rinse
  11                         Electro-cleaner No. 3
  12                         Rinse
  13                         Muriatic acid
  14                         Rinse

  15                         Nickel strike
  16                         Dull nickel plate
                             Dull nickel plate
                             Dull nickel plate
                             Dull nickel plate

                             Dull nickel plate
                             Dull nickel plate
                             Dull nickel plate
                             Dull nickel plate
  17                         Bright nickel plate

                             Bright nickel plate
  18                         Micro-porous (MP) nickel plate
  19                         Nickel reclaim
  20                         Rinse
  21                         Activator chrome

                             Chromium plate (evaporation tank)
  22                         Chromium plate
  23                         Chromic acid reclaim
  24                         Rinse
  25                         Rinse

  26                         Hot water rinse
       Figure 2-1.  Sequence of tanks on the decorative plating line
                     at C. S. Ohm Manufacturing Company
                                    2-2

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current Increases to 12,000 to 16,000 A for 90 seconds, during which
chromium is deposited on the activated surfaces.  This 90-second period is
called "electrolysis."  The current required during electrolysis is
dependent on the surface area being plated and is automatically adjusted
for each new rack of bumpers.
2.2  AIR POLLUTION CONTROL
     A fume suppressant called "MSP-1" is used in the chromium plating
tank to inhibit the release of gases generated during electrolysis.  The
suppressant is manufactured by Harshaw Chemical Company.  It contains a
fluorocarbon that decreases the surface tension of the plating solution,
thus, decreasing the generation of mist.  There are no test data available
showing the emission reduction achieved by using this fume suppressant,
although it is used commonly in the electroplating industry to preclude
misting.
     The chromium plating tank and evaporation tank are equipped with a
push-pull ventilation system.  Air jets on one end of the tanks push mist
across the plating solution to a 1.2-m-high (4-foot-high) hood on the
other end.  An induced draft fan driven by a 20-horsepower motor draws
emissions away from the tanks to the control device.
     The control device is a wet, double-packed-bed scrubber manufactured
by Viron International (Model HSDP-2000).  The scrubber is designed to
treat about 7.6 cubic meters per second (m?/s) (16,765 standard cubic feet
per minute [scfm]) of plating tank exhaust gases.  Chromic acid is removed
from the gas stream by impacting on two 30-cm-deep (12-inch-deep) beds of
filter media that are continuously sprayed with scrubbing liquid.  The
spent liquid drains into a remote holding tank from which it is
recirculated through the scrubber.  The holding tank is emptied once every
2 or 3 days and refilled with fresh water.  The holding tank has an
estimated volume of 500 i (132 gal) and pumps about 91 a/min (24 gal/min)
of liquid to the scrubber.
     The scrubber also contains a mist eliminator stage for the final
removal of liquid droplets from the gas.stream.  This stage consists of a
"Chevron-type" arrangement of baffles that change the direction of gas
                                    2-3

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flow several times.  The entire scrubbing unit has a design removal
efficiency of 99 percent for chromic acid.
2.3  PROCESS CONDITIONS DURING TESTING
     The process was operating normally during the source test program.
Process operating parameters such as temperature, voltage, and current
were monitored during each test run and are recorded on the process data
sheets in Appendix E.  No operating parameters were monitored for the
scrubber; however, there were no indications of any malfunction in the
system during the testing.
     Normal operating conditions allowed all three test runs to be
performed without interruption.  A scheduled 10-minute break in operation
occurred each day at 10:30 a.m., but this was not considered cause to
suspend testing because it was of short duration.  Inlet and outlet
testing were performed simultaneously.
     The total current supplied to the tank during each test run is
calculated in terms of ampere-seconds and included in Appendix E.  A
summary of the total current values is presented in terms of
ampere-seconds and ampere-hours in Table 2-1.
                                    2-4

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      TABLE 2-1.  TOTAL CURRENT SUPPLIED TO TANK DURING SOURCE TESTS


                                                        Total current,
             Total current, ampere-seconds          	ampere-hours	
Test No.       Inlet              Outlet             Inlet          Outlet
            90,000,000          83,900,000          25,000          23,300


            79,590,000          73,740,000          22,100          20,500


            94,620,000          84,350,000          26,300          23,400
                                    2-5

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                            3.0  SUMMARY OF RESULTS







    Particulate matter (EPA Method 5)  tests were conducted at the  inlet  and  the




outlet of the packed-bed wet scrubber controlling the decorative chrcmiun




plating tank.  Because the emissions were chromic acid fumes, "impinger  train"




tests were run at the scrubber inlet to evaluate the use of Method 5  for sample




collection.  An additional run using the Method 5 train was conducted at a high




sampling rate (HV) for eight hours at a single point.  The data is presented




for the high volume run but not discussed since the  other tests were




quantifiable and conducted isokinetically at all points.  Table 3.1 summarizes




the testing schedule for this testing program.




    In brief, from the results of the Method 5 testing, the uncontrolled




emissions from the tank averaged 0.035 pounds per hour of particulate matter,




0.000017 pounds per hour of hexavalent chromium, and 0.000065 pounds  per hour




of total chromium.  Based on the Method 5 results, the controlled  emissions




averaged 0.024 pounds per hour of particulate matter, 0.000016 pounds per hour




of hexavalent chrcmiun, and 0.000095 pounds per hour of total chromium.  Also




based on the Method 5 results, the collection efficiency of the wet scrubber




appeared to be low, however, this is inconclusive due to questionable data




quality as indicated by the methods evaluation comparison with the impinger




train.  The impinger train samples were not analyzed for particulate  matter.




The collection efficiency of the impinger train indicated that essentially all




the chromium was collected by the impingers and the impinger train results for




hexavalent chromium at 0.00011 pounds per hour averaged about seven times




greater than those from the Method 5 train.
                                      3-1

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                                    TABLE  3.1.   TESTING  SCHEDULE FOR C.  S. OHM
Date
(1985)
6A8
6/19
6/20
Sample Type
Participate
Participate
Participate (HV)**
P articulate
Scr
Run
No.
2
5
SR
8
Libber Inlet
Test Time
24 h clock
1004-1529
0838-1404
1419-2247
0855-1420
Scrubber Inlet
(Implnger Train)*
Run
No.
1
4
7
Test Time
24 h clock
1005-1530
0839-1405
0856-1421
Scrubber Outlet
Run
No.
3
6
9
Test Time
24 h clock
1003-1505
0837-1336
0855-1350
U)
I
         *Runs 1, 4, and 7  utilized an Implnger train.
        **Spec1al high volume, constant rate,  single  point,  run  (SR).

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    In the following sections, the results  addressed above and additional




results are presented and discussed in detail according to the emission  type




and sampling location.  The computer printouts of the emission calculations




can be found in Appendix A.  The original field data sheets and the  analytical




data are located in Appendix B.








3.1  PAKTICULATE MATTER, HEXAVALENT CHROMIUM, AND TOTAL CHROMIUM




    Particulate matter tests (EPA Method 5) along with the determination of the




associated flue gas flow rates were conducted at both the scrubber inlet and




outlet; impinger train method evaluation tests were conducted at the scrubber




inlet.  The particulate matter samples were initally analyzed using  gravi-




metric techniques to determine the mass of particulate matter.  Then the




samples were further analyzed for hexavalent and total chrcmiun.   The impinger




train samples were analyzed for hexavalent and total chromium only.   Complete




descriptions of each sampling location and the sampling and analytical




procedures are given in Chapter 4 (and Appendix C).








3.1.1  Scrubber Inlet (EPA Method 5)
    The results for the scrubber inlet (EPA Method 5) represent the




uncontrolled emissions from the plating tank as measured by EPA Method 5.   The




circular vertical inlet duct was traversed with both an EPA Method 5  sampling




train and an impinger train.  The results from these two trains should be




compared for methods evaluation purposes as a check on the ability of the  EPA




Method 5 sample train to collect chromic acid fines.




    Flue Gas Conditions and Isokinetic Sampling Rate - A sunmary of the flue




gas conditions at the scrubber inlet (EPA Method 5 and impinger train)  and the




scrubber outlet (EPA Method 5 train) is presented in Table 3.2.  The volunetric
                                      3-3

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                                             TABLE 3.2.  SIM WRY OF FLUE GAS CONDITIONS
Run
No.
Date
(1985)
Test Time
24 h clock
Volumetric Flow Rate
Actual8
acmh
x 106
acfh
x 106
Standard"
dscmh
xlO6
dscfh
x 106
Stack
Temperature
°C
°F
Malsture
°2
co2
CO
Isoklnetlc
                                                Scrubber  Inlet  (Implnger Train)
1
4
7
6/18
6/19
6/20
1005-1530
0839-1 405
0856-1421
Average
0.0216
0.0215
0.0216
0.0216
0.764
0.759
0.764
0.762
0.0203
0.0204
0.0204
0.0204
0.717
0.719
0.719
0.718
25
24
26
25
77
76
79
77
1.0
1.0
1.0
1.0
20.9
20.9
20.9
20.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
98.7
98.6
98.4

                                                   Scrubber  Inlet  (Method 5)
2
5
8
6/18
6/19
6/20
1004-1529
0838-1404
0855-1420
Average
0.0206
0. 0200
0.0212
0.0206
0.728
0.705
0.748
0.727
0.0194
0.0188
0.0199
0.0194
0.685
0.664
0.703
0.684
25
25
26
25
77
77
79
78
0.8
1.3
1.2
1.1
20.9
20.9
20.9
20.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
97.6
100.6
99.2

                                                  Scrubber  Inlet - Special Run
SR
6/19
1419-2247
0.0197
0.695
0.0187
0.660
26
79
0.2
20.9
0.0
0.0
79.8
                                                        Scrubber Outlet
3
6
9
6/18
6/19
6/20
1003-1505
0837-1336
0855-1 350
Average
0.0222
0.0221
0.0222
0.0222
0.785
0.780
0.783
0.783
0.0212
0.0211
0.0211
0.0211
0.749
0.747
0.744
0.747
20
20
22
21
68
68
72
69
1.4
1.7
1.8
1.6
20.9
20.9
20.9
20.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
94.2
94.6
94.5

Volumetric flow rate In actual  cubic meters  per  hour  (acmh)  and  actual cubic feet per hour (acfh) at stack conditions.
Volumetric flow rate In dry standard cubic meters per hour  (dscmh)  and dry standard cubic feet per hour (dscfh).

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flow rates for the inlet Method 5  tests  were fairly consistent  and averaged




20,600 actual cubic meters per hour (727,000 actual cubic  feet  per hour).




    The flue gas temperature averaged 25°C (78°F),  with  a  moisture content




of 1.1 percent.  The oxygen, carbon dioxide, and carbon  monoxide  content was




that of air at 20.9, 0.0, and 0.0  percent, respectively.   The volunetric flow




rate at standard conditions averaged 19,400 dry standard cubic  meters per hour




(684,000 dry standard cubic feet per hour).  Standard conditions  are 20°C




(68°F), 760 mm Hg (29.92 in. Hg),  and dry.  The isokinetic sampling rate was




within the allowable range for all three sample runs.




    Particulate Emissions - The particulate emissions  from the  plating  tank




(see Table 3.3) were variable.  The particulate emissions  for the inlet runs




averaged 0.82 milligrams per dry standard cubic meter (0.00036  grains per dry




standard cubic foot) and 0.016 kilograms per hour (0.035 pounds per hour).  The




variability was likely due to sampling and analytical  error in  measuring the




extremely low pollutant concentrations.




    Hexavalent Chromium Emissions - The hexavalent chromium emissions for each




test run (see Table 3.3) were also variable with the corresponding particulate




run.  They averaged 95, 2150, and 633 milligrams of hexavalent  chromiuu per




gram of particulate emissions for runs 2,  5, and 8, respectively.  The




hexavalent chromium emissions for the inlet tests averaged J3.39 x 10




milligrams per dry standard cubic meter (0.17 x 10~  grains per dry standard




cubic foot) and 7 x 10   kilograms per hour (17 x 10  pounds per hour).




    Total Chromium Emissions - The total chromiuu emissions for each test run




(see Table 3.3) were variable with respect to the corresponding particulate run




and averaged 423, 8290, and 2429 milligrams of total chromium per gram  of
                                     3-5

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                                  TABLE 3.3.  SUMMARY OF PARTICULATE,  HEXAVALENT CHROMIUM,  AND TOTAL OROMIUM  EMISSIONS
Run
No.
Date
(1985)
Partlcul ate
concentration
mg/dscm
gr/dscf
mass emissions
kg/h
Ib/h
Hex av a lent Chromium
concentration
mg/dscm
x 10~3
gr/dscf
x 10~3
mass emissions
kg/h
x 10"-5
Ib/h
x 10~3
Total Chromium
concentration
mg/dscm
x JO"3
gr/dscf
x IO"3
mass emissions
kg/h
x IO"3
Ib/h
x 10~3
                                                             Scrubber Inlet (Implnger Train)
1
4
7
6/18
6/19
6/20
Average




(not anal



/zed)







2.35
2.02
3.14
2.50
0.00103
0. 00088
0.00137
0.00109
0.048
0.041
0.064
0.051
0.10
0.09
0.14
0.11
12.13
6.83
13.40
10.8
0.0053
0.0030
0.0059
0.0047
0.246
0.139
0.273
0.22
0.543
0.306
0.602
0.48
Scrubber Inlet (Method 5)
2
5
8
6/18
6/19
6/20
en
Average
1.27
0.20
0.98
0.82
0.00056
0. 00009
0. 00043
0.00036
0.025
0.004
0.020
0.016
0.054
0.008
0.043
0.035
0.12
0.43
0.62
0.39
0. 00005
0.00019
0.00027
0.00017
0.002
0.008
0.012
0.007
0.005
0.018
0.027
0.017
0.537
1.658
2.380
1.52
0. 00023
0.00072
0.00104
0.0007
0.010
0.031
0.047
0.029
0. 023
0.069
0.104
0.065
Scrubber Inlet (Special Run)
SR
6/19
0.226
0.00010
0.004
0.009
0.36
0.00016
0.007
0.015
0.91
0. 0004
0.017
0.038
SR
6/19
0.226
0.00010
0.004
0.009
0.36
0.00016
0.007
0.015
0.91
0. 0004
0.017
0.038
Scrubber Outlet
3
6
9
6/18
6/19
6/20
Average
*
0.524
»
0.524
*
0.00023
*
0.00023
*
0.011
*
0.011
»
0.024
»
0.024
0.27
0.34
0.41
0.34
0.00012
0.00015
0.00018
0.00015
0.006
0.007
0.009
0.007
0.013
0.016
0.019
0.016
2.406
1.826
1.899
2.04
0.00105
0.00080
0.00083
0. 0009
0.051
0.039
0.040
0.043
0.112
0.085
0.088
0.095
*Partlculate catch was not quantifiable.

-------
particulate.  The total chromium emissions  averaged  1.52 x  10   milligrams




per dry standard cubic meter (0.7  x  10    grams  per dry standard cubic foot)




and 0.029 x 10   kilograms per hour  (0.065  x  10  pounds per hour).




3.1.2  Scrubber Inlet (Impinger Train)




    The results for the scrubber inlet  (impinger  train) represent the




uncontrolled emissions from the plating tank  as measured by the impinger




train.  The Method 5 and impinger train sampling  were conducted simultaneously




in the vertical circular duct prior  to  the  packed bed scrubber.  The impinger




train tests wree conducted to evaluate  the  use  of the Method 5 train for the




reference method collection of the chromic  acid fumes for the chromium plating




industry.  The results of the Method 5  and  impinger  train testing should be




comparable.




    Flue Gas Conditions and Isokinetic  Sampling Rate - A summary of the flue




gas conditions at the scrubber inlet (impinger  train) is presented in




Table 3.2.  The volumetric flow rate results  for  both the Method 5 train and




impinger train were within standard  measurement error of each other.  The




isokinetic sampling rate was within  the allowable range for all three impinger




train sample runs.




    Particulate Emissions - The collected samples were not  analyzed for




particulate emissions since all of the  impinger contents would have had to be




taken to dryness.  Also, it would have  made the analysis for hexavalent and




total chromium more difficult in the sample preparation phase.




    Hexavalent Chromium Emissions -  The hexavalent chromium emissions were




fairly consistent averaging 2.5 x 10   milligrams per dry standard cubic



               —6                                               —6
meter (1.1 x 10   grains per dry standard cubic foot) and 51 x 10




kilograms per hour (110 x 10   pounds per hour).  This was  about seven times




greater than the hexavalent chromium emissions  measured by  the EPA Method 5




train.  The reason for the extremely poor agreement  is not  known.
                                    3-7

-------
    Total Chromium Emissions - The total chromium  emissions  averaged  10.8 x




10~  milligrams per dry standard cubic meter (4.7 x 10    grains  per dry




standard cubic foot) and 0.22 x 10~  kilograms  per hour (0.48 x  10   pounds




per hour).  This was about eight times greater  than the total chromium




emissions measured by the EPA Method 5 train.   This is  in agreement with  the




comparison of the hexavalent chromium results between the two sampling trains.
3.1.3  Scrubber Outlet




    The scrubber outlet represents the controlled emissions  from  the chrcmiun




plating tank as measured by EPA Method 5?  no impinger train  tests were




conducted at the scrubber outlet.  A four-inch filter and larger  than normal




size nozzle were used in an effort to collect the maximun sample  volvme under




isokinetic sampling conditions.




    Flue Gas Conditions and Isokinetic Sampling Rate - A sunmary  of  flue gas




conditions at the scrubber outlet is presented in Table 3.2.   The volunetric




flow rates for the three outlet runs were very consistent.   The outlet




volunetric flow rate averaged 22,200 actual cubic meters per hour (783,000




actual cubic feet per hour) with a flue gas temperature of 21°C (69°F) and




a moisture content of 1.6 percent.  The oxygen, carbon dioxide, and  carbon




monoxide concentrations were that of ambient air at 20.9, 0.0,  and 0.0 percent,




respectively.  The volunetric flow rate at standard conditions averaged 21,100




dry standard cubic meters per hour (747,000 dry standard cubic feet  per hour).




Standard conditions are 20°C (68°F), 760 mm Hg (29.92 in. Hg),  and dry.




    The isokinetic sampling rates were well within the allowable  range for  all




runs.




    Particulate Emissions - The particulate emissions exiting from the control




equipment to the atmosphere were not quantifiable (see Table 3.3) for two of




the three runs.  For the one run which had quantifiable results,  the particulate
                                   3-8

-------
emissions averaged 0.5 milligrams per dry standard cubic meter (0.0002 grains

per dry standard cubic foot) and 0.01 kilograms per hour (0.02 pounds per

hour).  The other two runs had negative sample weights.  Method 5  was intended

to accurately measure pollutant concentrations at these low levels.

    Hexavalent Chromium Emissions - The hexavalent chromium emissions for each

test run were fairly consistent and averaged 0.34 x 10"^ milligrams  per dry

standard cubic meter (0.15 x 10"  grains per dry standard cubic feet) and

7x10   kilograms per hour  (16 x 10   pounds per hour).  These results

were similar in magnitude to the Method 5 uncontrolled results.

    Total Chromium Emissions - The total chromium emissions were fairly

consistent and averaged 2.04 x 10~3 milligrams per dry standard cubic meter

(0.9 x 10~5 grams per dry standard cubic foot) and 0.043 x 10~  kilograms

per hour (0.095 x 10"  pounds per hour).  These results were greater than the

controlled emissions as measured by the EPA Method 5 train.
3.2  EMISSIONS IN UNITS OF PROCESS RATE AND CONTROL EQUIPMENT COLLECTION
     EFFICIENCY

    The emission rates in units of process rate are given in terms of

milligrams of emissions per hour per square foot of tank surface area,  and in

units of milligrams of emissions per amperage input to the plating operation.

To determine the collection efficiency of the scrubber, the milligrams  per hour

per square foot (uncontrolled emissions and controlled emissions)  were  used for

the calculations.

3.2.1  Emissions in Units of Process Rate

    Two process parameters were used to determine the emissions in terms of

units of the process rate as shown in Table 3.4.  The first was milligrams of

emissions per amperage input to the plating operation.  The second was

milligrams of emissions per hour per square foot of tank surface area.   The

surface area of the tank was 45 ft  for all tests.
                                3-9

-------
                                       TABLE 3.4.   SUMMARY OF EMISSION RATES  IN  UNITS OF PROCESS RATE AND EFFICIENCY
Run
Nos.
Process Rate
current sup-
pi led to tank
1 n amps/hr
Uncontrolled Emissions
part leu 1 ate
ing/amp
mg/hr
ft2
hexavalent
chromium
mg/amp
mg/hr
ft2
total
chromium
mg/amp
mg/hr
ft2
Controlled Emissions
partlcul ate
mg/amp
mg/hr
ft2
hexavalent
chromium
mg/amp
mg/hr
ft2
total
chromium
mg/amp
mg/hr
ft2
Collection Efficiency**
part icul ate
%
hexavalent
chromium
%
total
chromium
%
                                                                   Scrubber  Inlet  (Implnger Train)
1
4
7
25,000
22.100
26,300
Average
not
analyzed


not
analyzed


0.0019
0.0019
0.0024
0.0021
1.07
0.91
1.42
1.13
0.0098
0. 0063
0.0104
0. 0088
5.46
3.09
6.07
4.87

N/A



N/A



N/A



N/A



N/A



N/A



N/A



N/A



N/A


                                                                      Scrubber  Inlet (Method 5)
D
2
5
8
25,000
22,100
26,300
Average
0.0010
0.0002
0.0008
0.0007
556
89
444
363
0. 00008
0. 00036
0.00046
0. 00030
0.04
0.18
0.27
0.16
0.0004
0.0014
0.0018
0.0012
0.22
0.69
1.04
0.65

N/A



N/A



N/A



N/A



N/A



N/A



N/A



N/A



N/A


                                                                     Scrubber Outlet (Method 5)
3
6
9
23,300
20, 500
23,400
Average

N/A



N/A



N/A



N/A



N/A



N/A


no val
0.00054
no val
0.00054
no val
244
no val
244
0.00026
0.00034
0.00038
0.00033
0.13
0.16
0.20
0.16
0.0022
0.0019
0.0017
0.0019
1.13
0.87
0.89
0.96
no val
	
no val
32.8***
— — —
11.1
25.9
0***
	
	
14.4
	 »**
  •Emission rate In units of milligrams of emissions per  hour  per  square  foot of tank surface using a tank surface of 45 ft  for all  tests.
 **Alr pollution control efficiency calculations  are based on  uncontrolled and controlled emissions In units of mg/hr/ft .
•••Calculated based on averages of uncontrolled and controlled emissions.

-------
3.2.2  Control Equipment Collection Efficiency




    The collection efficiency of the packed-bed scrubber (see  Table  3.4) was




extremely low based on the EPA Method 5  results.   The control  equipnent




collection efficiency was 32.8 percent for particulate and was zero  percent for




hexavalent chromium.  The measured emissions for total chrcmiun were greater




after the scrubber than prior to the scrubber.  The validity of the  results are




questionable based on the methods evaluation tests and should  not be used  as an




accurate indication of collection efficiency.








3.3  SUMMARY OF ANALYTICAL RESULTS FOR HEXATALENT AND TOTAL CHROMIUM




    The summary of analytical results for the hexavalent chromium and total




chromium analyses of samples collected is presented in Table 3.5.  The




analytical data sheets are contained in Appendix B.  The results shown in  Table




3.5 for hexavalent and total chromium are the results obtained using the EPA




tentative method for "Determination of Hexavalent Chromium Emissions from




Stationary Sources" and the "EPA Protocol for Emissions Sampling for Both




Hexavalent and Total Chromium"  (see Appendix C).  When, for total chrcmiun




analysis, the table indicates that the sample "residue" was analyzed, then the




values presented for total chrcmiun content are a sun of (1) the hexavalent




chromium in the sample filtrate from the extraction of the sample and (2)  the




chromium in the residue from the extraction as measured by Neutron Activation




Analysis.  When the table indicates that the "total" sample was analyzed,  then




the values presented for total chromium content are from the direct  analysis of




the total sample for total chromium by Neutron Activation Analysis.   A table




showing the total chromium calculations for each sample can be found at the end




of Appendix A of this report.




    The collection efficiency of hexavalent chromium by the impinger train is




believed to be greater than 99%.  The efficiency was determined by analyzing




the impinger contents separately as shown in Table 3.5.




                                   3-11

-------
                                       TABLE 3.5  SUMM/RY OF ANALYTICAL RESULTS FCR  HEXAVALENT AND TOTAL CWOMIUM
Run
No.
Sample
Type
Sample
No.
Analyzed
Amount of
Samp 1 e
Analyzed
Hexavalent Chromium
Results
yg
Concentration
pg/g
Amount of
Samp 1 e
Analyzed
Total Chromium
Results
yg
Concentration
yg/g or yg/ml
                                                             Scrubber Inlet (Implnger Train)
I
1
1
4
4
4
7
7
7
1st Implnger Contents
2nd Implnger Contents
3rd Implnger Contents
1st Implnger Contents
2nd Implnger Contents
3rd Implnger Contents
1st Implnger Contents
2nd Implnger Contents
3rd Implnger Contents
C-255
C-256
C-257
C-258
C-259
C-260
C-261
C-262
C-263
Total
Total
Total
Total
Total
Total
Total
Total
Total
15.6
< 0.2
< 0.2
13.2
< 0.2
0.2
19.4
0.7
0.7









.(.
15.6 yg total

.)•
13.4 yg total

4.
20.8 yg total

Half
Half
Half
Half
Half
Half
Half
Half
Half
77.38*]
2.56»>
2.26*)



71.70*]
8.84* J
10.36*)
t
80.5 yg total

f
45.4 yg total

t
88.9 yg total

                                                     Scrubber Inlet (Method 5 and High Volume Train)
2
2
5
5
8
8
SR
SR
Part leu late Front Half
Implnger Contents
Part leu late Front Half
Implnger Contents
Part leu late Front Half
Implnger Contents
Partlculate Front Half
Implnger Contents
C-241
C-249
C-242
C-250
C-243
C-251
C-244
C-267
8.3 mg
Total
1 .3 mg
Total
6. 7 mg
Total
3.7 mg
Total
0.8
< 0.2
2.8
< 0.2
4.2
< 0.2
5.9
< 0.2
96
negl Iglble
2150
neg 1 Iglble
627
neg 1 1 g I b 1 e
1590
negl Iglble
Residue
Half
Residue
Half
Residue
Half
Residue
Half
2.5
1.0
9.4
1.4
16.2
	
14.9
— —
301.2
	
7230.8
	
2417.9
— — —
4027.0
__*._
                                                                     Scrubber Outlet
3
3
6
6
9
9
Partlculate Front Half
Implnger Contents
Part I cu late Front Half
Implnger Contents
Partlculate Front Half
Implnger Contents
C-245
C-252
C-246
C-253
C-247
C-254
»*
Total
4. 1 mg
Total
**
Total
2.1
< 0.2
2.7
< 0.2
3.2
< 0.2
*»
neg 1 Iglble
659
negl Iglble
**
neg 1 Iglble
Residue
Half
Residue
Half
Residue
Half
18.8
	
14.3
	
14.8
*_ — —
	
	
3487.8
— — — —
	
— — — —
                                                           Scrubber Water Discharge (liquids)

Scrubber H,0
C-265
~
—
5.09 yg/ml
1.0 ml
12.7
12.7 y g/ml
Blank Samples


Partlculate Fl Iter
Distilled H20 w/Acetone
C-248
C-264
—
—
1.1
—

< 0.2 yg/ml
Residue
1.0 ml
6.7
2.0
	
2.0 yg/ml
*Not blank corrected.  **Partlculate catch was  not  quantifiable.
 The concentration In terms of yg/g could not be calculated  since the mass collected by the Implngers was not determined;  the value represents
 the total weight of chromium collected In all  three Implngers.

-------
    Both the quantity of the particulate and the hexavalent chromium analyzed




were extremely low and, under these circumstances, both sets of analytical




results are subject to greater analytical error.




    Quality assurance audit samples were analyzed for both the hexavalent and




total chromium methods.  As shown in Table 3.6, no bias was present and the




results are considered acceptable.




    There is some sample analysis variability due to the small amount of




hexavalent chromium present.  However, the average values for the runs are




believed to be fairly accurate.
                                     3-13

-------
TABLE 3.6.  SUMM/WY OF ANALYTICAL RESULTS FCR HEXAVALENT AND TOTAL OROMIUM QUALITY ASSLRANCE  SAffLES

Run
No.

Sample
Type

Sample
No.

True
Value
Hexavalent Chromium
Results
Ug/ml
%
Dev.
Total Chromium
Results
P9
%
Dev.
Quality Assurance Samples
--
—
—
— —
Qual Ity Assurance
Qual Ity Assurance
Qual Ity Assurance
Qual Ity Assurance
C-266
OA-16
OA-17
QA-18
50 ug/ml Cr*6
50 ug Cr
100 ug Cr
150 yg Cr
52.4
	
	
— — —
+4.8
	
	
—— — —
	
45.69
96.49
146.4
	
-8.6
-3.5
-2.4

-------
                    4.0  SAMPLING LOCATIONS AND TEST METHODS








    This section describes the sampling locations and test methods used to




characterize emissions from the decorative chromium plating tank at C.  S.  Ohm




Manufacturing Company in Sterling, Michigan.  Two sampling locations were  used




in the emission testing program.  At each sampling location (one at the




scrubber inlet and one at the scrubber outlet), emissions testing was conducted




for participate matter, total chromium content, and hexavalent chrcmiun




content.  Sampling for chrcmiun and an impinger collection efficiency




determination was also conducted at the scrubber inlet using an impinger




train.  One special high volune, constant flow rate, single point sampling run




was conducted at the inlet, also.  The relative positions and the type of




testing conducted at each location are shown in the simplified process flow




diagram (see Figure 4-1) and accompanying Table 4.1.  The subsections which




follow further describe each sampling location and applicable test methods.









4.1  SCRUBBER INLET (SAMPLING LOCATION A)




    Particulate matter, hexavalent chromiun, and total chrcmiun were measured




at the inlet to the packed-bed scrubber controlling emissions from the




decorative chromiun plating tank as shown in Figure 4-2.   Two sampling ports




were installed 90° apart in the vertical circular duct (32 inches in




diameter).  These ports were located 26 inches (0.81 duct diameters) upstream




of a bend in the duct to the scrubber and 168 inches (5.25 duct diameters)




downstream from another bend.
                                      4-1

-------
                    16,000 SCFM
                    TO ATMOSPHERE
                       VIRON
                       WET
                       BED
             SCRUBBING
             LIQUID
            HOLDING
            TANK
 / x' X x< //


32-IN. DIAMETER
RIGID PVC DUCT
                                                    PUSH-PULL
                                                      VENTILATION


X-— •"" '



-«< —
Ni
PLATINC






RINSE







RINSE



. «.




|
i - i

DILUTE
Cr03
. »

CK)/
PLATING






RINSE



^»v

Figure 4-1.Diagram of decorative chromium plating line and emissions
           control system at C. S. Ohm Manufacturing Company.
                                  4-2

-------
                       TABLE 4.1.   SAMPLING  PLAN  FOR  C.  S.  QW
Sample Type
Sampl ing
Locations
     Number
   of Samples
 Methods
Particulate matter
Hexavalent chromium
Total chromium
Chromium (Impinger
efficiency)
  A, B


  A, B




  A, B
    3 (M5)
1 (M5 HV. at A)

    3 (M5)
1 (M5 HV, at A)
    3 (M5)
1 (M5 HV, at A)
EPA Method 5 or
EPA Method 5 High Volume

EPA Method 5 or
EPA Method 5 High Volume
using Tentative EPA
Method for Hexavalent Chromium

EPA Method 5 or
EPA Method 5 High Volume
using EPA Protocol for
Total Chromium

Impinger Train using
Tentative EPA Method for
Hexavalent Chromium and EPA
Protocol for Total Chromium
                                         4-3

-------
TRAVERSE POINTS

  2  AXES
  8  POINTS/AX IS
 16  TOTAL POINTS
                                         32"DIA.
                        SECTION L-L
                 TO
              SCRUBBER
   ROOF  LINE	]8]
                  f
                                  B
                                     26"
                              t
                                     168"
                                        FROM
                                       PROCESS
                        ELEVATION VIEW
 FIGURE  4-2.   SCRUBBER INLET  (SAMPLING  LOCATION A)
                    4-4

-------
    For the Method 5 testing,  (used for particulate matter,  hexavalent




chromiun, and total chromiun determinations)  and the impinger train  testing, a




total of 16 points, as per Method 1,  were sampled.   Each of  the  16 points was




sampled for 20 minutes for a total of 320 minutes of sampling per run.   Each of




three Method 5 and three impinger train runs  were conducted  to coincide  with




the sampling at the scrubber outlet location.








4.2  SCRUBBER OUTLET STACK (SAMPLING LOCATION B)




    Particulate matter, hexavalent chromiun,  and total chromium  were measured




at the scrubber outlet as shown in Figure 4-3.   Four sampling ports  were




installed along the shorter side of the 26 1/2 by 34 3/4 inch vertical




rectangular stack.  The ports were located about 8  inches (0.025duct diameters)




upstream from the stack exit and 32 1/4 inches (1.07 duct diameters)  downstream




from the fan.  Because of the close proximity of the flow disturbance (stack




exit) downstream of the ports, this location did not meet EPA Method 1 sampling




requirements; a planned stack extension was refused by EPA for reasons of




excessive additional cost.




    For the EPA Method 5 sampling (used for particulate matter,  hexavalent




chroraiua, and total chromiun determinations), a total of 24  points,  6 per axis,




were sampled.  Each point was sampled for 12 minutes for a total sampling time




of 288 minutes.








4.3  VELOCITY AND GAS TEMPERATURE




    A type S pitot tube and an inclined draft gauge manometer or two




differential pressure gauges in-parallel were used to measure the gas velocity




pressure ( p).  Velocity pressures were measured at each sampling point  across
                                      4-5

-------
              34.75"
< 	 26.5" 	 >
. i
1
i
i
	 1
• i
•-•I
• i
- - -i
. i
	 1
i
i
A
. i
i
i
~ ~ r
• i
— r-
• i
— u
. i
_ — L
I
I
B
SECTION
. t
1
i
i
~T
• 1
- I-
• 1
--!•
. 1
_ J.
1
1
c
R-
. -
*
• •••
•
- —
•
_ _
,



D
R
                          TRAVERSE  POINTS

                             4  AXES
                             6  POINTS/AX IS
                            24  TOTAL POINTS
     k-26.5"
1
k— 34.75"—>j
3"
[
.25"
t
k

6"
A B C D
t
I.D.
FAN


R

FROM Z
SCRUBBER ,


FIGURE 4-3.  SCRUBBER  OUTLET (SAMPLING LOCATION B)
                     4-6

-------
the duct to deteimine an average value according to the procedures outlined in




Method 2 of the Federal Register.*  The temperature at each sampling point was




measured using a thermocouple and digital readout.









4.4  MOLECULAR WEIGHT




    Flue gas composition was essentially that of the ambient air drawn in from




above the plating tank.  Therefore, the dry molecular weight and composition of




air was used.









4.5  PAKTICULATE MATTER




    Method 5, as described in the Federal Register,* was used to measure




particulate grain loading at locations A and B.  All tests (except the special




high voluue run) were conducted isokinetically by traversing the




cross-sectional area of the stack and regulating the sample flow rate relative




to the flue gas flow rate as measured by the pitot tube attached to the sample




probe.  A sampling train consisting of a heated, glass-lined probe, 79 mm




(3 inch) [or 102 mm  (4 inch) for the high volune run]  diameter Teflon filter




(Schleicher & Schuell), and a series of Greenburg-Smith impingers was employed




for each test.  An acetone rinse and a water rinse of the nozzle, probe, and




filter holder portions of the sample train were made at the end of each test.




The particulate caught on the filter media was dried at room temperature, the




combined acetone and water rinse was taken to dryness in an oven; both were




desiccated to a constant weight, and weighed on an analytical balance.  Total




filterable particulate matter was determined by adding these three values.  See




Appendix C for detailed sampling procedures.
                                      4-7

-------
4.6  IMPINGER COLLECTION EFFICIENCY




    A sample train similar to that used for EPA Methods 1-5  was  used to measure




the impinger collection efficiency at the scrubber inlet.  The train did not




contain any filter, instead a filter bypass was inserted in  the  line and three




Greenburg-Smith impingers each containing 100 ml of distilled water were used




to collect the emissions.  The impinger train tests were run simultaneously




with the Method 5 tests and were conducted isokinetically by traversing the




cross-sectional area of the stack and regulating the sample  flow rate relative




to the flue gas flow rate as measured by the pitot tube attached to the sample




probe.  The contents of each impinger were recovered separately  at the end of




each test.  Each impinger was rinsed first with acetone and  then with water;




these rinses were then added to the corresponding impinger contents.  The probe




and filter bypass were also rinsed with both acetone and water and these rinses




were added to the first impinger contents.  The contents and rinses from each




impinger were concentrated and analyzed for hexavalent and total chromiun




content.








4.7  HEXAVALENT CHROMIUM CONTENT




    Hexavalent chromium content was determined utilizing procedures described




in the tentative EPA Method "Determination of Hexavalent Chromium Emissions




from Stationary Sources" (see Appendix C).  The Method 5 filter  catches




collected and weighed for each Method 5 run and the. impinger train impinger




catches were taken and analyzed for hexavalent chroraiun content  using this




method.  It was also used to determine the hexavalent chromiun content in the




first impinger for representative Method 5 runs.
* 40 CFR 60, Appendix A, Reference Methods 2,  3,  and 5,  July 1,  1980.
                                      4-8

-------
4.8  TOTAL CHROMIUM CONTENT




    Total chromium content was determined using procedures  described in the




"EMB Prototcol for Sample Preparation and Emission Calculation of  Field Samples




for Total Chromium" in combination with Neutron Activation  Analysis  (NAA)  (see




Appendix C).  Samples collected during Method 5 and impinger train runs and




first submitted for analysis for hexavalent chromiun were then analyzed for




total chromiun using this method.
                                      4-9

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                             5.0  QUALITY ASSURANCE


    Because the end product of testing is to produce representative emission

results, quality assurance is one of the main facets of stack sampling.

Quality assurance guidelines provide the detailed procedures and actions

necessary for defining and producing acceptable data.  Two such docunents were

used in this test program to ensure the collection of acceptable data and to

provide a definition of unacceptable data.  These docunents are:  the EPA

Quality Assurance Handbook Volune III, EPA-600/4-77-027 and Entropy's "Quality

Assurance Program Plan" which has been approved by the U.  S. EPA, EMB.

    Relative to this test program, the following steps were taken to ensure

that the testing and analytical procedures produce quality data.


     •   Calibration of field sampling equipment.  (Appendix D describes
         calibration guidelines in more detail.)

     •   Checks of train configuration and on calculations.

     •   On-site quality assurance checks such as sampling train, pitot
         tube, and Orsat line leak checks, and quality assurance checks of
         all test equipment prior to use.

     •   Use of designated analytical equipment and sampling reagents.

     Table 5-1 summarizes the on-site audit data sheets for the sampling

equipment used for particulate testing at each sampling location, including

deviation limits.  In addition to the pre- and post-test calibration audits, a

field audit was performed on the meter boxes used for sampling.  Entropy used

the procedures described in the December 14, 1983 Federal Register (48FR55670).

In addition, the analytical balance used for filter weighing was audited with

Class "S" weights.  Appendix D includes the audit run data sheets for each dry

gas meter used for particulate testing and audit data sheets for the other

sampling equipment.


                                      5-1

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TABLE 5.1.  FIELD EQUIPMENT CALIBRATION
Equipment
Reference
Al lowable
Error
Actual
Error
Within
Al lowable
Limits
Scrubber Inlet
Meter box (N-5)
Meter box thermometer
Trip balance
Analytical balance
Wet test meter
ASTM-3F at ambient
temperature
IOLM standard weight
Cl ass "S" standard
weight
Y + 0.03Y
5°F
0.5 grams
0.1 mg
-KK025
+1«F
0.1 gram
0.02 mg
v^
Y
-]/

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    Audit solutions prepared by the EPA were used to check the analytical




procedures of the laboratories conducting the hexavalent and total chromium




analyses.  Table 5-2 presents the results of these analytical audits.   The




audit tests show that the analytical techniques were good.




    The sampling equipment, reagents, and analytical procedures for this test




series were in compliance with all necessary guidelines set forth for accurate




test results as described in Volune III of the Quality Assurance Handbook.
                                      5-3

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                 TABLE  5.2.   AUDIT  REPORT  CHROMIUM ANALYSIS
Plant
:    C-S.
Task No.:   3£>Z-
Date sample:
Sample anal;
Reviewed by

Sample
Number
O266
QA-U,
QA-I7-
GJA-/S




3 received: //
fzed by: fC_<
'Tc^c^ £"^

ug/ml
Cr*6 or Cr
£OW/*L
si ^ ^^
/^/i^ ^*"
i /




2- / 6 5~~ Dat
r
lS«- Dat

Source of
Sample
Q4D
A/£^
tf6s
rt&$




:e analyzed: //
/
:e of review:

Audit
Value
57?. 4-
-^r.6f
f^.f^
/^.f




files'



Relative
error, %
^^.6^
-3-C- %
-3,5-^0
- ^.f %




                                      5-4

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