&EPA
United States
Environmental Protection
Agency
                 Office of Air Quality
                 Planning and Standards
                 RTF, NC 27711
EMB Report 87-IWW-2
NOVEMBER 1988
Air
INDUSTRIAL WASTEWATER
STEAM STRIPPER
PERFORMANCE
EMISSION TEST REPORT
RHONE-POULENC AG COMPANY
INSTITUTE, WEST VIRGINIA
 SUMMARY REPORT

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                FINAL REPORT

       METHOD DEVELOPMENT AND TESTING
    FROM INDUSTRIAL WASTEWATER FACILITIES

     RHONE-POULENC AGRICULTURAL CHEMICALS
           INSTITUTE,  WEST VIRGINIA
            ESED PROJECT  NO.  84/11
           CONTRACT NO. 68-02-4337
            WORK ASSIGNMENT NO.  10
           TRC PROJECT NO. 4683-E81
                 Prepared by:

     James E.  Canora,  Principal  Scientist
     TRC ENVIRONMENTAL CONSULTANTS, INC.
          800 CONNECTICUT BOULEVARD
           EAST HARTFORD, CT  06108
                Prepared for:

     U.S.  ENVIRONMENTAL PROTECTION AGENCY
 EMISSION STANDARDS AND ENGINEERING DIVISION
         EMISSION MEASUREMENT BRANCH
RESEARCH TRIANGLE PARK, NORTH CAROLINA  27711
                December 1988

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                               TABLE OF CONTENTS
SECTION

  1.0             INTRODUCTION  	
      1.1           Program Objectives  	
      1.2           Site Description  	
      1.3           Measurement Program 	

  2.0             SUMMARY OF RESULTS AND CONCLUSIONS  	
      2.1           Steam Stripper Performance  	
      2.2           Method Development  	

  3.0             PROCESS DESCRIPTION AND OPERATION 	

  4.0             SAMPLING LOCATIONS  	

  5.0             SAMPLING AND ANALYTICAL METHODS 	 ,
      5.1           Sampling Equipment/Procedures 	 ,
      5.2           Analytical Methods  	
          5.2.1       Purgeable Organic Compounds (EPA Method 624)
          5.2.2       Extractable Organic Compounds (EPA Method 625)
          5.2.3       Total Organic Carbon (TOC) and Purgeable
                        Organic Carbon (POC) (EPA Method 415.2) .  .

  6.0             DETAILED RESULTS  	
      6.1           Steam Stripper Performance Evaluation 	
      6.2           Total Organic Carbon and Purgeable Organic
                      Carbon Analyses 	

  7.0             QUALITY ASSURANCE AND QUALITY CONTROL 	
      7.1           Data Validation 	
          7.1.1       Accuracy  	
          7.1.2       Precision 	
      7.2           Calibration Procedures and Frequency  	
      7.3           Sample Custody  	
          7.3.1       Chain-of-Custody Form 	
          7.3.2       Chain-of-Custody Tape 	
          7.3.3       Shipping of Samples 	
      7.4           Deviations from the Test Plan 	

APPENDICES

    A             TEST PLAN

    B             DESCRIPTIONS OF ANALYTICAL METHODS

    C             DATA TABLES

    D             ANALYTICAL DATA SHEETS

    E             CHAIN-OF-CUSTODY FORMS
PAGE

   1
   1
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   2

   4
   4
   5
  10

  14
  14
  14
  16
  16

  19

  21
  21

  24

  26
  26
  26
  28
  31
  31
  31
  31
  33
  33
                                      -11-

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                               LIST OF FIGURES

FIGURE                                                                     PAGE

  1       STEAM STRIPPER SYSTEM AT RHONE-POULENC AGRICULTURAL
            COMPANY 	          7
  2       STEAM STRIPPER SAMPLING LOCATIONS AT RHONE-POULENC
            AGRICULTURAL COMPANY  	         12

  3       SCHEMATIC OF HEAT EXCHANGER SAMPLING SYSTEM 	         15

  4       CHAIN-OF-CUSTODY FORM	         32



                                LIST OF TABLES

TABLE                                                                      PAGE

  4-1     STEAM STRIPPER SAMPLING MATRIX  	         13

  5-1     PURGEABLE ORGANIC COMPOUNDS 	         17

  5-2     EXTRACTABLE ORGANIC COMPOUNDS 	         18

  6.1-1   RPAC STEAM STRIPPER BULK STREAM FLOWRATES 	         22

  6.1-2   RPAC STEAM STRIPPER AVERAGE COMPONENT STREAM
            CHARACTERIZATION  	         23

  6.2-1   COMPARISON OF TOC AND TOTAL PURGEABLE EXTRACTABLE
            CONCENTRATIONS  	         25

  7-1     WATER MATRIX SPIKE/MATRIX SPIKE DUPLICATE RECOVERY  ....         30
                                     -111-

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1.0 INTRODUCTION

    The  Environmental  Protection  Agency is  currently  developing background

information on  volatile  organic (VO) emissions from industrial wastewater and

control  techniques for  reducing these  emissions.   The  Emission Measurement

Branch  (EMB) of EPA's  Office of Air Quality Planning and Standards  (OAQPS)  is

evaluating  sampling and analytical  methods   for  measuring  the  VO  emission

potential of a  waste to support this program.  In addition,  EMB  is  evaluating

steam strippers  as a control technology.  The  information may ultimately aid

in  the  development  of  an  air  emission standard  or  a  Control   Technique

Guideline (CTG) document.

    Field  sampling and  analytical programs  are  to  be  conducted at  several

organic  chemical,  plastic and  synthetic fiber (OCPSF)  facilities  which use

steam   strippers  for  wastewater   treatment.    Sampling  was   conducted   at

Rhone-Poulenc  Agricultural  Chemicals  (RPAC)  in  Institute,  West   Virginia,

during  the  week of  September 14, 1987.  TRC Environmental  Consultants,  Inc.

(TRC)  performed  sampling   and  analytical   tasks,   and  Radian Corporation

monitored  the  process  operation.   Subsequently,  TRC  provided Radian  with

analytical  results and  Radian  applied  these  data  to  an evaluation  of  the

process.



1.1 Program Objectives

    There were three primary objectives for the testing performed at  RPAC:


    1.0  Investigation of the cost effectiveness  of controlling  volatile
         organic   (VO)   emissions   from wastewater   streams  at  OCPSF
         facilities with steam strippers.

    2.0  Evaluation  of steam stripper  efficiency on a compound-specific
         basis using EPA methods for the analysis of wastewater.

    3.0  Evaluation of EMB  test methods (e.g., air purge and trap,  steam
         distillation, heated headspace) by  comparison with  approved EPA
         methods.   As  of this  date, this  objective has  not  been met for

                                      -1-

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         the RPAC program.   Samples were collected for method evaluation,
         but were  not analyzed  because desired EMB  conditions  have not
         been established.
1.2 Site Description

    Rhone-Poulenc Agricultural  Chemicals (RPAC)  is an  agricultural chemical

manufacturing facility.  The  process  wastewater is treated by steam stripping

to  remove  organics  prior  to  the wastewater  treatment  plant.    The   steam

stripper is in operation 24 hours per  day.



1.3 Measurement Program

    The measurement or  sampling program was conducted by TRC over  a three  day

period  from September  15-17,  1987.   The  objectives  of  the  study  at RPAC

required simultaneous sampling  of  the stripper feed, tails,  and  overhead waste

streams.   During that  time,  the  steam  stripper  feed,  tails,   and  overhead

streams  were sampled   and  analyzed  for volatile and  semi-volatile  organic

compounds  using  modified EPA Methods 624  and 625.   Additional samples were

taken for  total  organic carbon  (TOG), purgeable organic carbon  (POC),  and  EPA

method development analysis.

    Concurrent with  the wastewater  sampling.  Radian  monitored the  following

process parameters:
    Base liquid level
    Column pressure differential
    Overhead flow
    Feed flow
    Tails flow
    Jet decanter liquid level
    Condensate pot liquid level
    Steam stripper water level
    Steam stripper temperature
    Steam stripper head pressure
                                      -2-

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    Critical to  the stripper evaluation  were  the liquid flow measurements of




the stripper feed,  overhead and tails.   The  feed and  overhead were  equipped




with  calibrated  orifices,  and  the  flows could  be  monitored  in the  control




room.   The  stripper  tails was  not equipped  for monitoring  and  required  a




periodic flow  measurement implemented by  diverting  the flow into a  55-gallon




drum and timing the fill rate.
                                      -3-

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2.0 SUMMARY OF RESULTS AND CONCLUSIONS

2.1 Steam Stripper Performance

    Steam  stripper  performance was  evaluated  on a compound-specific basis as

well  as  an overall  basis.  The efficiency evaluation was made  using flow and

concentration  data   to  perform  material  balances.   The  average   removal

efficiencies for the compounds detected are listed below:


                 Compound                      VOC Removal  (%)

         Benzene                                    99.62
         Toluene                                    98.94
         Ethylbenzene                               99.44
         Isophorone                                 96.02
         Naphthalene                                99.66
         5-Ethyl-l,2-Methylpyridine                 84.54
         1,2,3,4-Tetrahydronaphthalene              98.33
         Acetophenone                               97.91
         2-Methyl-l,3-Cyclopentanedione             98.29

                                   Total VOC        92.25


The   overall   efficiency   was  calculated   based   on   the   flow   weighted

concentrations of each  compound in the inlet and outlet streams.   The sampling

and analytical methods  employed in  the compound-specific  stripper  efficiency

determination were conducted  in accordance with EPA Methods 624  and 625. The

analytical  procedures  were  judged  to  be  valid  according  to  the  quality

assurance measures as described in Section 7.1.  Although no standard protocol

exists for  sampling wastewater streams, sampling was conducted  in such  a way

as  to  minimize  evaporative  VO  losses  and  assure  representativeness.  All

samples were collected  from pump outlets where the waste  streams should have

been  sufficiently  mixed,  minimizing  the  potential for  stratification and

non-representative sampling.   Heat exchangers  were  employed  to cool  samples

under  20°C prior  to contact with  air.   Flowrates  were  also monitored with

calibrated  orifices  at  the  feed and  overhead and with the timed  fill of  a

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55-gallon drum from the  tails  stream.   These flow measurements are assumed  to



be accurate although orifice calibration data has not been provided.








2.2 Method Development



    Samples were  collected for method development purposes, but analyses  have



not been performed.   The  decision to hold  this portion of  the  program was



based  on  incomplete  results  from  laboratory  evaluations  presently being



conducted on synthetic wastes.
                                      -5-

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3.0 PROCESS DESCRIPTION AND OPERATION




    The  primary source of  wastewater  during production is the jet collection




system.  A steam jet  system  is used  to  pull vacuum on  the  process refining




stills  and the  reactor  recovery stills.   This steam picks up organics during




operation  of  the vacuum jet system.   The  condensed steam containing organics




is  collected  in various   jet  collection pots  and pumped to a  central  jet




collection pot  which is shown in Figure 1.   Other wastewater streams feeding




the  central  jet collection  pot  include the scrubber  decant  pot, periodic




reactor  washes   (once  per  month),  and  wastewater overflow from the  jet




collection pot.  Process  wastewater  from  the central jet collection  pot  is




pumped  to  the   decanter  tank.   Additionally, the reactor  recovery wash-up




header which is used twice a year feeds into the decanter  tank.




    The decanter tank, which is 15,000 gallons in capacity, is used  to recover




organics  picked  up  by the  jet  collection  system.   The recovered organics




overflow  to  a  collection  tank and  are  recycled  to the  process.   The  water




layer  is  drawn off  the  side  of the  decanter tank and  pumped  to the  steam




stripper.  The  temperature of  the water normally  ranges between  55  -  60°C.




Any sludge that enters the decanter settles  to the bottom of the tank and is




removed as necessary, using a bottom suction line.




    The steam stripper system is shown in Figure  1.  The purpose  of the  steam




stripper is to  remove volatile organic compounds  (VOC's) from the  wastewater




generated  by  the process.  At  least one  of the VOC's  removed by  the  stripper




is  not  biodegradable  in   the  biotreatment  basin  which is  located  at  the




facility  wastewater  treatment  plant.   The  stripper column  is  60 inches  in




diameter and  contains 14 Glitsch valve trays.  The trays are spaced one foot




apart.  A  water-cooled condenser is installed in the top head of the column to




condense  the overheads stream.   Nitrogen  is  used to   maintain  the  column




pressure at  5  pounds  per  square inch (psig).  A  control valve  vents pressure




                                      -6-

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   From
   WLSS	
Condensale
   Pol
                                   Jel Collection Pols
                                          A.	

Reactor
Washes






^T^ "T""

"^te^f


^^^



Scrubber
Decani
Pot
^»^_ ^^^




      Recycle
        lo
      Process


Organics
H,0


ca
7
/
^ 	 S "j ^
                                                            Process
                                                           Waslewaler
                                                            Decanter
                                                                                          o "'" ^T.
                                                                                         -{XI	»
                                                                               Steam
 Water Layer
Steam Stripper
   (WLSS)
                                                                                                                       N, -IX]	i-tlj-/
                                                                                                                               WLSS
                                                                                                                             Condensale
                                                                                                                                Pol
                                                                                                                        To Jel
                                                                                                                     Collection Pot
                                                         -Plant Sewer
                                           To Waslewaler
                                          Treatment Plant
                        Figure 1.   Steam stripper system  at Rhone-Poulenc Agricultural  Company.

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from  the column  when the  column pressure  exceeds 5  psig.   The column  is



equipped with a condensate pot for collection of the condensed overhead.



    Feed from the decanter tank passes  through  a heat  exchanger and is heated



to ~110°C by  the  stripper tails stream.  On startup, additional heating of the



feed is supplied by a preheater, heated with  75 psig steam.   The feed rate to



the stripper  is controlled by the level  in the decanter tank.   The feed rate



normally operates within  a  range  of  8,000 to 14,000 Ibs/hr.  The feed stream



leaving  the decanter  tank is  a  single  phase  wastewater  stream; an organic



layer  is  present only when  there is  a  process  upset.   The  stripper cannot



process a stream with an organic layer.



    Design of the column  provides  for  use  of  75  psig  steam.   However, waste



steam is supplied to the  sparger at  25 psig under normal operation.  The steam



flowrate is controlled by the column pressure  differential  which ranges from



30-40 inches.  Additional heating  in the column may be provided by steam coils



submerged below the liquid level at the bottom of the column.  These coils  are



only  used  during  cold  weather.    The  overheads  stream  flowrate   normally



operates at about 1,000-2,000  Ibs/hr and is controlled to maintain a  constant



level  in  the condensate  collection  pot.  The  condensed overheads are pumped



from the  condensate  pot  to  the   jet  collection  pot  which overflows to  the



central jet  collection pot.   As  previously discussed,  the water and  organics



in the central jet collection pot are pumped to the  decanter tank for  recovery



of the organics.



    The column tails  stream  is pumped  through  an  exchanger to heat  the  feed



stream.  The  flowrate of the tails  stream is  controlled to maintain  constant



liquid level in the bottom of the column.  The  temperature of the tails  stream



leaving  the column  ranges  from 95-100°C.   The stream  is  cooled in  the  heat



exchanger  before being   discharged  to the  process  sewer  at  75-80°C.   The
                                      -8-

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tails  stream is  combined with  other  wastewater  in  the  process  sewer and



collected in a  sump which is located on-site at  the process unit.   Wastewater



from the sump  is  pumped to a decanter  before the process  wastewater flows  to



the facility sewer system and on to the wastewater treatment plant.
                                      -9-

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4.0 SAMPLING LOCATIONS

    The  RPAC  stripper  wastewater  treatment  system   is  monitored  by  plant

personnel  for  flow,  temperature,  pressure,  and tank  liquid  level   in  the

control  room.   The following parameters  were  measured and  recorded from the

control room by Radian personnel throughout the sampling program:


    Base liquid level
    Column pressure differential
    Overhead flow
    Feed flow
    Jet decanter liquid level
    Condensate pot liquid level
    Steam stripper water level
    Steam stripper temperature
    Steam stripper head pressure


In order to  accurately  determine the stripper performance, the feed and tails

stream flowrates  were monitored.  RPAC  measured both  the feed  and  overhead

flowrates using  calibrated orifices and  pressure transducers.  These devices

were recalibrated by RPAC prior to the  beginning of the sampling program.  The

feed  and overhead lines  are  equipped  with  0.920  and  0.413 inch orifices,

respectively.  Each  line was also  outfitted with pressure  taps  on  the  pump

inlets  and  outlets   to  provide  additional flow measurements based  on  pump

output versus  pressure  curves.   TRC measured  and  recorded  pressure  data  at

hourly  intervals  but the accuracy  of  the method was inadequate and results

were  discarded.   The tail or stripper bottom  line  was  not  equipped with  a

calibrated  orifice.   Flow was  measured  at  hourly   intervals  by  loading  a

55-gallon drum with  the  tails  stream,   recording  time  on  a stopwatch,  and

volumetrically measuring the stream collected.

    Sampling taps were located  at the  feed, tails, and overhead  pump  outlets.

Sampling  locations  for  required  pressure  measurements  and  liquid  sample
                                     -10-

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collection  are  indicated  in  Figure 2.   Wastewater samples  were collected at




hourly  intervals  six  times   daily  according  to the  matrix  presented in




Table 4-1.




    In addition to feed,  tails and overhead flowrates, steam  flowrate at  the




stripper was estimated  based  on a mass  balance for water in  the  stripper.   The




steam flowrate is normally not monitored at RPAC.
                                      -11-

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                                    Jet Collection Pols
                                    	A.	
    From
    WLSS 	
 Condcnsale
I     Pol
K-*
to
I

Reactor

Washes








Sr*11




~^^^i


r-^"





"^^


^^




Scrubber
Decant
Pol
^^•^ *~^^



       Recycle
         to
       Process
                                                          Organtcs
H,O
                                                             Process
                                                            Wastowater
                                                             Decanter
                                                           Plant Sewer
                                                                              FEED
                                                                            SAMPLES)       H,?^£
                                                                                        —{3d	»
                                                                                                        Water Layer
                                                                                                       Steam Stripper
                                                                                                          (WLSS)
                                                                                                                        To Jet
                                                                                                                     Collection Pot
                                            To Wastewater
                                           Treatment Plant
                          Figure 2.   Steam stripper  sampling locations at  Rhone-Poulenc Agricultural Company.

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                                   TABLE 4-1




                        STEAM STRIPPER SAMPLING MATRIX




                     RHONE-POULENC AGRICULTURAL CHEMICALS




                             September 15-17,  1987
Date
9/15





9/16


9/17





Total
Feed
Method
Time Development
10:30
11:30 X
12:30
13:30*
14:30
15:40
14:00
15:00*
15:30
08:50
10:00
11:00
12:00
13:00
14:00
Number of Samples
(excluding duplicates) 2
and Tails
EPA
624/625

X

X

X
X
X
X

X

X

X

18

TOC/POC
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

30
Overheads
EPA
624/625 TOC/POC

X

X X


X X
X X


X X

X X



6 5
*  Collected replicate samples for RPAC internal analyses
                                     -13-

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5.0 SAMPLING AND ANALYTICAL METHODS




    All  sampling and  analysis  procedures used in  the field study  are fully




described in the Test Plan submitted to the EPA on September  11,  1987 which is




in  Appendix A.   A  brief overview  is  included in  this section along  with a




diagram of  the  heat exchanger used  for sampling.   All sample  containers and




sampling equipment were  precleaned and decontaminated  as described in the Test




Plan.  Sample identification and preservation procedures for collected  samples




were  also   adhered  to   during   the   field  program.   Any   deviations  or




modifications to the procedures and methods described in the  Test  Plan are




summarized in Section 7.0, Quality Assurance  and Quality Control.








5.1 Sampling Equipment/Procedures




    Samples  taken  at RPAC were collected from taps which were located at the




pipeline walls.  The  tap was reduced to a 1/4 inch tube  to  minimize aeration




of the  sample and subsequent VO loss.   The  sampling valves  were opened slowly




to prevent accidental exposure to wastes.  The waste stream was cooled  using  a




heat  exchanger   as  depicted in Figure 3.  The  heat exchanger  consisted of  a




6-foot by 0.25 inch stainless steel coil submerged  in an ice bath which cooled




the liquid waste sample prior to containerization.




    The system was purged prior to sampling.  The flowrate  through  the system




was lowered  during  sampling to help reduce  the  sample  temperature  prior to air




contact.  The  wastewater  temperature  was monitored  with a thermocouple  and




maintained below 20°C.








5.2 Analytical Methods



    This section provides a brief review of the analytical methods utilized in




the  project.   The  detailed description of  these  methods  is  included  in




Appendix B.



                                     -14-

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PROCESS LINE
          VALVE
                    P"     REDUCER (I" TUBE FITTING)




                              i" TEFLON OR STAINLESS STEEL COIL
                              ICE BATH
                                       SAMPLE CONTAINER
Figure
                Heat Exchanger Sampling  System
                            -15-

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    5.2.1  Purgeable Organic Compounds  (EPA Method 624)



    This  method was  designed  to  determine  volatile  organic  materials  in



wastewater.  It was designed  to be  used to meet the monitoring requirements of



the National Pollutants Discharge Elimination System  (NPDES).  The method was



designed   to  determine   31   volatile   organic   priority   pollutants   (see



Table 5-1).  However,  other  volatile  organic compounds  could  be determined



with a  similar  degree  of  accuracy and precision.   The method involves  a purge



and trap gas chromatographic/mass spectrophotometer  (GC/MS).



    An  inert gas  (Helium)  was  bubbled at a rate of  40 ml/min  through a 5 ml



aqueous sample  contained in a specially designed purging  chamber at 30°C.  The



purgeable  organic  compounds  were transferred from the  aqueous  phase  to the



vapor phase. The vapor phase was passed through  a three-material  sorbent  trap



(SP-1000, silica gel,  and Tenax GC) where the purgeables were trapped. After



purging  was completed, the trap  was  heated to  80°C  and  backflushed  with



nitrogen gas to desorb the purgeable onto a gas chromatographic  column packed



with 60/80 mesh Carbopack B/1% SP-1000.  The  sample  passed through the  column,



which was temperature  programmed to gradually increase at the rate of  8°C per



minute from 30°C to 220 °C, and held at 220°C for 15 minutes.   The components



of  the  sample  were   separated  and  detected   by  the  mass   spectrometer.



Components  (either  one of  the  31 priority  pollutants or  other  than  the  31



listed  compounds)  were identified  by  the mass spectra and quantified  through



the use of  the nearest  internal  standards.   The  system  used  was  Hewlett



Packard Model 5985.








    5.2.2  Extractable Organic Compounds (EPA Method 625)



    This is  a  gas chromatographic/mass  spectrometer  (GC/MS)  method applicable



to  the  determination  of  the  43  base  neutral  extractables   and   11  acid



extractable  components   of  the   priority   pollutants   (see   Table 5-2).   A



                                     -16-

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          TABLE 5-1

 PURGEABLE ORGANIC COMPOUNDS
Chloromethane
Brornomethane
Vinyl Chloride
Chloroethane
Methylene Chloride
1,1-Dichloroethene
1,1-Dichloroethane
Trans-l,2-Dichloroethene
Chloroform
1,2-Dichloroethane
Trichlorofluoromethane
1,1,1-Trichloroethane
Bromodichloromethane
Carbon tetrachloride
1,2-Dichloropropane
Trans-1,3-Dichloropropene
Trichloroethene
Dibromochloromethane
Benzene
1,1,2-Trichloroethane
cis-1,3-Dichloropropene
Brornoform
2-Chloroethyl vinyl ether
Tetrachloroethene
1,1,2,2-Tetrachloroethane
Toluene
Chlorobenzene
Ethylbenzene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
             -17-

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                               TABLE 5-2

                     EXTRACTABLE ORGANIC  COMPOUNDS
Base Neutral Compounds;

     Acenaphthene
     Ac enaphthy1ene
     Anthracene
     Benzo(a)anthracene
     Benzo(a)pyrene
     Benzo(b)fluoranthene
     Benzo(k)fluoranthene
     Benzo(g,h,i)perylene
     bis (2-Chloroethoxy) methane
     bis (2-Chloroethyl) ether
     bis (2-Chloroisopropyl) ether
     bis (2-Ethylhexyl) phthalate
     4-Brornophenyl phenyl ether
     Butyl benzyl phthalate
     2-Chloronaphthalene
     4-Chlorophenyl phenyl ether
     Chrysene
     Dibenzo (a,h) anthracene
     1,2-Dichlorobenzene
     1,3-Dichlorobenzene
     1,4-Dichlorobenzene
     3,3-Dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
Di-N-butyl phthalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-N-octyl phthalate
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadi ene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno (1,2,3) pyrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitroso-di-N-propylamine
N-Nitrosodiphenylamine
Phenanthrene
Pyrene
1,2,4-Trichlorobenzene
Acid Compounds;

     4-Chloro-3-Methylphenol
     2-Chlorophenol
     2,4-Dichlorophenol
     2,4-Dimethylphenol
     4,6-Dinitro-2-methylphenol
     2,4-Dinitrophenol
     2-Nitrophenol
     4-Nitrophenol
     Pentachlorophenol
     Phenol
     2,4-6-Trichlorophenol
                                  -18-

-------
one-liter  sample  was  serially  extracted  with methylene  chloride  at  a pH

greater than 11, and again at a pH less than 2 using a separatory funnel.  The

methylene chloride extract was  dried to a volume of  1 ml,  and analyzed by gas

chromatographic/mass spectrometer.   Both  the  listed  compounds  and unlisted

components  were  identified  through  mass  spectra  comparison and  quantified

through  internal  standard  response  factors.  The system  used  was  Hewlett

Packard  Model  5990  with Mass  Spectrometric Detector.  The  column was  fused

silica coated with DB-5  (Supelco,  Bellefonte Park 0,  PA) and  operated  between

50°C and 300°C with an increasing rate of 10°C per minute.



    5.2.3  Total Organic Carbon  (TOG)  and Purgeable Organic Carbon  (POC)  (EPA
           Method 415.2)

    The method  converts organic carbon to  carbon  dioxide and then methane.

The methane was  measured by  a flame ionization  analyzer (O.I. Corp.  Model

700).   The  instrument  was designed for  a two-step  operation to  distinguish

between purgeable and non-purgeable organic carbon.

    A sample was combined with 1 ml of acidified persulfate reagent  and placed

in a sparger.   The sample was purged with helium which transfers inorganic CC>2

and purgeable  organics to a C02 scrubber.   The C02 was removed  with at  least

99.9%  efficiency with  a 2.5-minute purge.   The  purgeable organics proceeded

through a  reduction system  where  the  gas  stream was joined  by hydrogen and

passed over a nickel catalyst which converted  the  purgeable  organic carbon to

methane.    The   methane  was  measured  by  a  flame  ionization detector.   The

detector signal  was  integrated  and displayed as the concentration of purgeable

organic carbon.

    The  sample  was  then transferred  to  a quartz ultraviolet  reaction coil

where  the  nonpurgeable organics  were  subjected  to   intense  ultraviolet

illumination  in   the   presence  of  the  acidified  persulfate  reagent.  The


                                     -19-

-------
nonpurgeables were converted to C02  and transferred to a second  sparger where



a  helium purge  transferred  the C(>2  to  the reduction  system  and  into  the



detector.  The signal was integrated,  added to the  purgeable organic  carbon



value, and displayed as the concentration of total  organic carbon.
                                      -20-

-------
6.0 DETAILED RESULTS



6.1 Steam Stripper Performance Evaluation



    Flowrate data  were gathered during  testing  for the  streams  entering and



leaving  the steam stripper.   Using  these  data  and the  concentration data



discussed  in  Section 3.0  [of  the Radian  report],  material balances were



performed  to  evaluate the removal  performance obtained  by the steam stripper



for individual pollutants and overall volatile organics (VO).



    Flowrates for  the  feed and overheads streams were monitored during testing



using measurements provided by calibrated orifices.  In addition, the flowrate



of the tails was  periodically measured by diverting this  stream to  a  55-gallon



drum  and  recording  the  increase  in volume  per  unit  time.   The  volumetric



flowrates  of  the  feed,  tails,  and overhead streams  measured during testing



were converted to mass flowrates and are presented  in Table 6.1-1.



    Using  concentration data  obtained  from periodic sampling and  the  flowrates



measured at  the time  of  each sample,  mass  loadings  were  computed  for  each



pollutant  in the  feed, tails, and overhead streams.  These results, along with



calculated percent removals,  are  presented in Appendix C (Tables  C-l through



C-6).  It  should  be  noted that tails flowrates were not  measured at  each time



a  sample was  taken.   Therefore,  tails  flowrates were  estimated for  these



sample times  based  on the  feed flowrate and  the  average  measured ratio  of



tails to feed flow of 1.7.



    The  computed   loadings for the  feed, tails,  and overheads  streams  were



averaged for  the   three days  of testing.  The  average concentration of  each



pollutant  was   also  computed for  the  three  days of testing.    The  average



loadings and concentrations are presented in  Table 6.1-2.   Also shown in Table



6.1-2  are  the  average percent  removals for each pollutant.  These removals



were estimated  based  on  the  average loadings  in  the  feed and tails streams.
                                     -21-

-------
                                  TABLE 6.1-1

                   RPAC STEAM STRIPPER BULK STREAM FLOWRATES
        Date
Time
 Feed
 Rate
(kg/hr)
Overheads
  Rate
 (kg/hr)
 Tails
 Rate
(kg/hr)
       9/15/87a
       9/16/87b
       9/17/87b
11:15
12:15
14:15
15:15
16:15

14:00
14:30
15:00
15:30
16:00
 9:
 9:
                         30
                      10:30
                      11:00
                      11:30
                      12:30
                      13:30
                      14:30
 2,077
 2,168
 2,043
 2,043
 2,168

 1,771

 1,771

 1,771
 1,771
 1,771

 1,445
 1,445
 1,351
  1,615
  1,623
  1,652
  1,670
  1,668

  1,373

  1,426

  1,435
  1,267
  1,283

  1,298
  1,289
  1,283
 3,448
 3,599
 3,391
 3,391
 3,599
 3,004

 2,921


 2,394


 2,442



 2,512
a Tails  rate values  for this  day were calculated  from an average  tails-to-
feed  (T/F)  ratio  of 1.66.  This was  the average  ratio  obtained for  T/F from
measurements  taken  on  9/16/87 and  9/17/87.   Reliable  measurements for  the
tails rate were not  obtained  on 9/15/87.  Tails rates for  9/15/87  listed here
are the calculated values.

b On  this day, the tails rate was determined by measuring the  liquid level
increase  in  the drum per unit  time.   The  tails rate  was calculated  from  the
following expression:   Tails  rate = (ird2p/4) x  (level  increase  per unit time)
where d = inside  diameter of the  drum = 22.5 inches.  Feed and overhead rates
were not recorded at these times.
                                      -22-

-------
LO
I
                                                                           TABLE  6.1-2

                                                  RPAC STEAM STRIPPER  AVERAGE  COMPONENT  STREAM CHARACTERIZATION
Feed
Tails
Overheads
Flow Weighted Flow Weighted Flow Weighted VOC
Flowa Concentration" Flow Concentration*- Flow Concentration*' Removal6
Component
Benzene
Toluene
Ethyl Benzene
Isophorone
Naphthalene
5-Ethyl-l ,2-Methylpyridine
1 ,2,3,4-Tetrahydronaphthalene
Acetophenone
2-Methyl-l ,3-Cyclopentanedione
Total VO
Water
Total
(kg/hr)
9.26E-03
1.96E-03
2.66E-03
1.91E-03
2.20E-02
1.76E-01
1.40E-01
1.81E-02
2.21E-02
3.95E-01
1,828.61
1,831
(ppmw)
5.06E+00
1.07E+00
1.46E+00
1.04E+00
1.20E+01
9.64E+01
7.67E+01
9.91E+00
1.21E+01
2.29E+01


(kg/hr)
3.45E-05
2.07E-05
1.49E-05
7.58E-05
7.58E-05
2.73E-02
2.35E-03
3.79E-04
3.79E-04
3.06E-02
2,972.13
2,973
(ppmw)
1.19E-02
6.98E-03
5.00E-03
2.55E-02
2.55E-02
9.18E+00
7.89E-01
1.27E-01
1.27E-01
7.90E-02


(kg/hr)
7.45E-03
1.27E-03
1.33E-03
2.36E-03
1.39E-02
1.90E-01
9.16E-02
2.90E-02
1.77E-02
3.55E-01
1,436.94
1,437
(ppmw)
5.18E-00
8.85E-01
9.25E-01
1.64E-00
9.65E+00
1.32E+02
6.38E+01
2.02E+01
1.23E+01
3.12E+01


(V.)
99.62
98.94
99.44
96.02
99.66
84.54
98.33
97.91
98.29
92.25


Feed-to-
Closure Steam
Error Ratio
(%) (F/S)
19.14
34.09
49.57
-27.93
36.62
-23.38
33.04
-61.71
18.42


0.70
        a  The  flow is  calculated  by averaging the  individual  compound  flows  presented  in  Tables C-5  through C-10 in Appendix C.
          calculated by averaging the six  total  flows  presented  in  Tables  C-5  through  C-10  in Appendix C.
        b  The  feed pollutant flow weighted concentration  =  feed  pollutant  flow/total flow x  106,
          i.e..  for benzene, 9.26 x 10~3 kg/hr / 1,831  kg/hr  x  106  = 5.06  ppmw.
        c  The  tails pollutant flow weighted concentration = tails pollutant  flow/total  flow  x 106,
                                                                                                                        The total flow is also
          i .e.,
        for benzene, 3.54 x 10~5 kg/hr / 2.973 kg/hr x 106 = 1.19 x 10~2
                                                                                 ppmw.
          The overheads  pollutant  flow weighted  concentration  =  overheads  pollutant  flow/total  flow x  10°,
                for benzene,  7.45  x  10~3  kg/hr / 1,437  kg/hr x 106  =  5.18  ppmw.
           .e.
e VOC removal = (feed pollutant flow - tails pollutant flow) / feed pollutant flow x 100,
  i.e., for benzene, 9.26 x 10~3 kg/hr - 3.45 x 10~5 kg/hr / 9.26 x 10~3 kg/hr x 100 = 99.62%.
f Closure error (1.) = (feed pollutant flow - (tails pollutant flow + overheads pollutant flow))  / feed  pollutant  flow x  100,
        for benzene, 9.26 x 10~3 kg/hr - (3.45 x 10~5 kg/hr + 7.45 x 10~3 kg/hr) / 9.26 x  10~3  kg/hr x  100  -  19.14%.
          i.e.

-------
The  loadings  in the  overhead streams were  not  used due to the difficulty  in




obtaining a representative sample.




    This overall  VO  removal  was  determined by  summing  the average  pollutant




loadings in  the feed and tails  streams and  comparing the  difference.  The




average VO removal during the test was 92.25 percent.








6.2 Total Organic Carbon and Purqeable Organic  Carbon Analyses




    Theoretically,  the results from the TOC  (total  organic carbon)  analyses




and the sum of the extractable and purgeable  analyses  (Methods  624 and  625)




should be  equal  if identical units are used for reporting  the  analyses and all




the organic material  can  be  detected using Methods  624  and 625.   Table 6.2-1




shows  that TOC values  were  often lower  than  the  sum of  the  624 and 625




values.  This  difference  can  be  attributable  to  the relative uncertainty  of




results from  methods  624 and 625.  The  TOC results may be lower than normal




due to incomplete combustion of the larger molecular weight compounds.




    Purgeable organic carbon (POC) analyses were not conclusive as all samples




analyzed showed levels below the  method  detection  limit.   In  comparison  with




Method 624 analyses,  the  POC method should have  shown  concentrations slightly




above the limits of detection.
                                      -24-

-------
                                                     TABLE 6.2-1

                           COMPARISON OP TOG AND TOTAL PURGEABLE EXTRACTABLE CONCENTRATIONS
                                 Feed Concentrations
                                  (ug of carbon/1)
                                Tails Concentrations
                                 (ug of carbon/1)
                              Overhead Concentrations
                                 {ug of carbon/1)
                                                       9/15/87

TOC
Total Purgeable
and Extractable8

ho
i
TOC
Time: 11:30
6,475
20,979

Time: 14:00
3,506
13:30
7,202
18,324

15:00
4,334
15:40 11:30
6,110 21
18,975 <71
9/16/87
15:30 14:00
4,615 226
15:30 15:40
19 20
<32 <31

15:00 15:30
215 38
13:30
9,964
26,099

14:00 15:00
6,684 5,614
Total Purgeable
  and Extractable*
23,020  21,053  20,296
<82
<82
<82
 9,665
9,033
                                                       9/17/87
                       Time:    10:0012:00   14:00
                                10:00   12:00   14:00
                                 10:00
                                    12:00
TOC
Total Purgeable
  and Extractable8
   298   3,007   3,047
 44.3    46.0    48.1
14,360  15,250  14,910
<48
<82
<82
                         5,358
11,471
                            6,128
9,026
Individual concentrations of compounds determined by EPA Method 624 and 625 are shown in Tables C-l through C-3.
a Total  Purgeable  and Extractable  = E  (Concentration in ug  of Compound)(Weight  of  Carbon)(#  of Carbons)/(MW of
  Compound)
Tentatively identified compounds  were not included in the total concentrations.   Concentrations determined by TOC
and POC are shown in Table C-4 in Appendix C.

-------
7.0 QUALITY ASSURANCE AND QUALITY CONTROL

    The overall QA  goal  was to determine steam stripper  efficiency within +5

percent.   As stated  in the  test plan,  because of  the  orders  of magnitude

difference   between  stripper   feed   and   tails   pollutant   concentrations,

measurement  uncertainties  have  little impact on  overall accuracy.  Standard

deviation(s)  of  the  mean  (z)  was  calculated  for   each  pollutant   removal

efficiency based  on six measurements  (only five measurements  for the Method

625 compounds) and is reported in the table below.   The mean VOC  removal  rates

were  calculated on  an arithmetic basis  rather  than  the flow weighted  basis

used in Section 2.1.

Compound                                         X               S
benzene                                        99.68           0.25
toluene                                        98.96           0.37
ethyl benzene                                  99.41           0.17
isophorone                                     94.70           3.82
naphthalene                                    99.63           0.23
s-ethyl-l,2-methylpyridine                     89.12          14.20
1,2,3,4 tetrahydronaphthalene                  98.73           2.10
acetophenone                                   96.48           2.90
2-methyl-l,3-cyclopentanedione                 97.41           1.51


All standard deviations were  less  than 5% with the exception  of 5-ethyl-l,2-

methylpyridine.  Based on standard  deviation,  the  primary QA  goal was met  on

each compound  except  the pyridine.   Analytical QA  procedures were required and

results are outlined in the following subsections.



7.1 Data Validation

    Data were validated by reviewing quality control sample  analytical  results

and comparing them  with pre-determined  criteria.   The  following discussions

present the validation results and the criteria.



    7.1.1  Accuracy

    To determine the accuracy of any analytical method,  an  assumption  must be

made that  appropriate  sampling techniques have been employed to  provide for a

                                     -26-

-------
representative sample.   Assuming  a representative sample  has  been collected,

the  analytical  accuracy is  defined  as  the degree  of agreement  between an

accepted reference value and the true  value.

    A  laboratory  sample spiking  program was  conducted  on  the  samples to

determine the  accuracy  of measurement methods  for  volatile and  semi-volatile

organic compounds.  Four samples  were spiked.   Only two samples were  spiked at

correct concentration ranges.  The other  two spiked samples had to be  diluted

before the  final analysis;  therefore, the spike concentrations were too low to

be properly quantified.  The analytical  results  of  the two correctly  spiked

samples are  listed in Table 7-1.   As  indicated  in this table, the matrix spike

percent recovery (%R) was calculated as follows:
                                _
                         %R = -=r- x 100
    where:
       X = Analytical result from the spiked sample
       T = Analytical result from the unspiked sample
       K = Known value of the spike
      %R = Percent recovery = {% Accuracy)
    The calculated matrix spike percent recovery (%R) is listed below:

                                                             %R
                                                        #1        »2

         1,1-Dichloroethene                             70%       82%
         Trichloroethene                                92%       86%
         Chlorobenzene                                  94%       96%
         Toluene                                        96%       98%
         Benzene                                        94%       88%
                                            Average     89%       90%
    These matrix spike percent  recovery  values are within the range  of  60% to

145%,  i.e.,  the  acceptable  range  determined  in the  test plan  for volatile

organic analysis {Method 624).

    The  matrix spike  percent  recovery  values  for the  semi-volatile organic

compounds are:

                                      -27-

-------
                                                     	%R	
                                                       #1        t2

         1,2,4-Trichlorobenzene                        80%       79%
         Acenaphthene                                  81%       84%
         2,4-Dinitrotoluene                            38%       65%
         Pyrene                                        115%      112%
         N-Nitroso-Di-n-Propylamine                    91%       89%
         1,4-Dichlorobenzene                           63%       62%
         Pentachlorophenol                             67%       78%
         Phenol                                        85%       77%
         2-Chlorophenol                                91%       89%
         4-Chloro-3-Methylphenol                       76%       78%
         4-Nitrophenol                                 76%       82%
                                           Average      79%       81%
    These matrix spike percent recovery values  are  within the acceptable range

for  the   semi-volatile   organic   compounds  analysis   noted  in  Table 6  of

Appendix A  of  Method  625.   In  conclusion,   results  from  both analytical

measurement methods are accurate.

    There were no  matrix  spikes performed for the total  organic carbon  (TOC)

or purgeable  organic carbon  (POC)  analyses.   No  accuracy  information can be

derived from  this  project  for the total  organic  carbon (TOC)  and  purgeable

organic carbon (POC).
    7.1.2  Precision

    Precision  is  the  measure  of  the mutual  agreement  between  individual

measurements of  the  same property.   Precision  is best  expressed in terms  of

Standard Deviation or  Relative Percent Deviation (RPD) and is inferred through

the use of duplicate samples.  RPD for each component was  calculated using the

following equation:
    where:

     RPD = Relative Percent Deviation
       A = Replicate Value 1
       B = Replicate Value 2
       2 = Number of Duplicates
                                      -28-

-------
    The   relative   percent  deviation  (RPD)   calculated  for  volatile  and

semi-volatile organic compounds is also listed in Table 7-1.   Among the 16 RPD

calculated,  two  were determined visually to be  outliers  (1,1,-Dichloroethene,

and  2,4-Dinitrotoluene).   The  mean and  standard deviation  of the  RPD were

calculated and are shown below:
    Volatile Organic Compound (624):
       With outlier                                       6.80      5.72
       Without outlier                                    4.50      2.89

    Semi-Volatile Organic Compound (625):
       With outlier                                       9.27     14.81
       Without outlier                                    5.00      4.55
    The  precision  of  total  organic  compound  (TOC)  and  purgeable  organic

compound  (POC)  measurement  methods  was  determined  by  analyzing  duplicate

results.   For total  organic compounds  three  sets  of  duplicate  results  are

available:


                                      #1              #2           RPD
    RPAC ST-1                       19.0 mg/L        18.0 mg/L     2.1%
    RPAC ST-12                      38.0 rog/L        38.0 mg/L       0%
    RPAC SO-16                   6,128.0 mg/L     5,697.0 mg/L     3.6%


Since only limited RPD  data were available,  no further  statistical  analysis

was performed.

    For purgeable  organic compounds,  there  are also  three sets  of duplicate

data available:


                                                     #1        #2
    RPAC ST-1                                       <0.1      <0.1
    RPAC ST-12                                      <1.0      <1.0
    RPAC SO-16                                      <1.0      <1.0
                                      -29-

-------
                                                              TABLE 7-1



                                          WATER MATRIX SPIKE/MATRIX SPIKE DUPLICATE RECOVERY
I
OJ
o


Cone.
Allowable
QC Limits*
Spike Added Sample
Sample No.
RPACST-4




Compound
1 , 1-Dichloroethene
Trichloroethene
Chlorobenzene
Toluene
Benzene
(pg/L)
50
50
50
50
50
Result
ND
ND
ND
ND
ND
Cone.
MS
35
46
47
48
47
%
Recovery
70
92
94
96
94
Cone.
MSD
41
43
48
49
44
%
Recovery
82
86
96
98
88
Cone.
RPD
16*
7
2
2
7

RPD
14
14
13
13
11

Recovery
61-145
71-120
75-130
76-125
76-127
        *  Asterisked values are outside QC limits:


           RPD:  VOAs 	1  out of 	5 ; outside QC limits
RECOVERY:  VOAs 	0  out of  10 ;  outside QC limits

-------
No  meaningful  data  analysis  can be performed  because all  results  are lower



than the detectable limits.







7-2 Calibration Procedures and Frequency



    All analytical instruments, including the GC/MS, TOG and POC systems, were



calibrated  in  accordance with the  procedures  listed  in the  test  plan,  and



following the guidelines of the referenced EPA methodology.







7.3 Sample Custody



    The purpose of using chain-of-custody procedures at RPAC was to ensure the



integrity of  the sample  from  the time of  collection through data  reporting.



Custody records  trace each sample  from  collection through all  transfers  of



custody  from  shipment  to  arrival  at the  analytical  laboratory.    Internal



laboratory  records  then document the  custody  of  each sample  throughout the



analysis  and its  final  disposition.  Use of  chain-of-custody procedures are



described in the sections that follow.







    7.3.1  Chain-of-Custody Form



    A  chain-of-custody form   (Figure 4}  accompanied   each  group of  samples



collected for  laboratory  analysis.   One person was responsible for maintaining



the samples at any given time.  Upon shipment of the samples to  the  analytical



laboratory, both  the  person relinquishing  the  sample  and  the  person receiving



the  samples for  the  shipper  signed and  dated  the  chain-of-custody  form.



Responsibility  for the  samples  then  passed  on  to  the  receiver.   Copies  of




chain-of-custody forms are in Appendix E.







    7.3.2  Chain-of-Custody Tape



    Chain-of-custody tape was used to detect unauthorized tampering  of samples



prior to and during shipment.  The tape contained the  following information:




                                     -31-

-------
              Environmental
              Consultants, Inc.
CHAIN OF CUSTODY FORM
N2
PROJECT NO.:
SAMPLERS (SIGNATURE):
PROJECT NAME:

SAMPLE NO.*













DATE













TIME













*SOURCE Teat Pit So»l...(TP)
CODES: Ground Water. ..(GW)
RELINQUISHED BY (SIGNATURE).


RELINQUISHED BY (SIGNATURE).


RELINQUISHED BY (SIGNATURF1:


DATE/TIME:


DATE/TIME:


DATE/TIME:


COMP













GRAB













NO.
OF
CON-
TAINERS













/













// f/


























/













ay «/ REMARKS













Boring Hole Soil. ..IBM) Surface So!l...(SS) Waate...(W)
Surface Water. ..(SW) Sediment ...( SD) Waate Water...
RECEIVED BY (SIGNATURE).
RECEIVED BY (SIGNATURE):
RECEIVED FOR LABORATORY BY
(SIGNATURE):
RELINQUISHED BY (SIGNATURE):


RELINQUISHED BY (SIGNATURE):

DATE/TIME:
1
Distribution Original accompanies shipment, copy to coordinator field files

REMARKS:
DATE/TIME:
1
DATE/TIME:





























(WW)
RECEIVED BY (SIGNATURE):
RECEIVED BY (SIGNATURE!

NJ
I
                              Figure 4 - Sample  Chain of Custody Form

-------
    •  Project Name/Number



    •  Date



    •  Signature



    •  Printed Name






The person who  had possession of the samples filled out  the  tape and placed it



on  the sample  cooler at  times  the  samples  were  not  in  view,   and during



shipment  to  the analytical  laboratory.   The tape  was  attached in such a way



that it was necessary to tear it in order to open the cooler.








    7.3.3  Shipping of Samples



    The samples were delivered to  the  laboratory for analysis within 24 to 48



hours  after  sampling.   They were accompanied  by the chain-of-custody record



and delivered to  the  person in the laboratory  authorized  to receive  samples.



All material  was  transported as  required  in  49 CFR Subpart  B Section  172,



which  lists   and  classifies   those   materials  which   the  Department  of



Transportation has  designated  as hazardous for purposes  of transportation.  It



also   details   the   requirements   for   shipping,   marking,   labeling  and



transportation of these materials.



    Upon receipt of the samples, the laboratory inspected  the chain-of-custody



seal   for   signs   of   tampering,   reconciled   the   information   on  the



chain-of-custody  form  with  the  sample  label,   and   inspected   the  sample



container for leakage.








7.4 Deviations from the Test Plan



    Some  deviations  in  the test  plan  procedures  were  implemented  in  the




program.   These are listed as follows:
                                      -33-

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    •  Due to process delays on September  14  there were fewer numbers of
       TOC/POC samples collected.

    •  Graduated  cylinder  measurements  of  phase   separation  in  the
       stripper overheads  was not  conducted.

    •  Temperatures of wastewater  samples  at the  heat exchanger outlets
       were less than 20°C,  not 4°C as required  by  the test  plan.

    •  Documentation of flow orifice calibrations were not obtained.

    •  Did not  preserve EPA 624  samples  with  I^SO^ to a  pH of  < 2 as
       stated in the test  plan.


  These deviations  did not  have  significant  effects  on program  goals.   The

higher  temperatures  encountered  on the  sampling  heat  exchanger outlets  may

have contributed to some increase  in VO losses.
                                      -34-

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