EMBReport88CEPI3
 Neshap Screening Method
          Chromium

    Emission Test Report
Roll Technology Corporation
 Greenville, South Carolina
     U. S. ENVIRONMENTAL PROTECTION AGENCY
          Office of Air and Radiation
      Office of Air Quality Planning and Standards
     Research Triangle Park, North Carolina 27711

             AUGUST 1983

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       EPA Contract No. 68-02-4346
            Work Assignment 4
            December 8, 1988
              Final Report
    Determination of the Efficiency of a
        Four-Stage Mist Eliminator
             Candidate Plant
       ROLL Technology Corporation
        Greenville, South Carolina
              Prepared for

   U.S. Environmental Protection Agency
      Emissions Measurement Branch
Research Triangle Park, North Carolina 27711
               Prepared by
          PEER Consultants, P.C.
        4134 Linden Ave., Suite 202
           Dayton, Ohio 45432

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                                 CONTENTS

SECTION                                                              PAGE

  1.0  INTRODUCTION	    1-1
  2.0  PROCESS OPERATION ..... 	    2-1
       PROCESS DESCRIPTION 	    2-1
       AIR POLLUTION CONTROL 	    2-2
       PROCESS CONDITIONS DURING TESTING 	    2-5
  3.0  SUMMARY OF RESULTS	    3-1
         INTRODUCTION  	    3-1
         HEXAVALENT CHROMIUM EMISSION RESULTS  	    3-1
           Inlet to the Moisture Extractor	    3-3
           Inlet to the M1st Eliminator	    3-7
           Outlet from the Mist Eliminator	    3-8
           Plating Tank Solutions  	   3-11
         MOISTURE EXTRACTOR RINSE  	   3-11
         MIST ELIMINATOR RINSE 	   3-11
  4.0  SAMPLING LOCATIONS AND TEST METHODS	    4-1
         PLATING TANK EMISSIONS  	    4-1
           Location of Measurement Sites 	    4-1
           Test Methods  	    4-5
         EMISSION SAMPLE ANALYSIS  	    4-7
  5.0  QUALITY ASSURANCE 	    5-1
         INTRODUCTION  	    5-1
         FIELD QUALITY ASSURANCE PROCEDURES  	    5-1
           Sample Blanks 	    5-1
           Duplicate Samples 	    5-2
           Standards	    5-2
           Chain of Custody	    5-2
           Sample Transfer 	    5-4
         SAMPLING TRAIN COMPONENTS 	    5-4
         VERIFICATION OF CALCULATIONS   	    5-4
           Emission Calculations 	    5-4
           Chromium Concentration Calculations 	    5-4

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                                 FIGURES

Number                                                               Page

 1-1     Location of sample sites	     1-2
 2-1     Schematic of control  device system  	     2-3
 2-2     Cross section of mist eliminator	     2-4
 2-3     Overlapping-type blade design for
           chevron-blade mist eliminators  	     2-6
                                  TABLES

                                                                     Page

 2-1     Average Operating Parameters During
           Each Mass Emission Test Run	     2-8
 2-2     Total Current Supplied to Tank No.  6
           During Each Mass Emission Test Run	     2-8
 3-1     Schedule of Activities  	     3-2
 3-2     Summary of Flue Gas Conditions	     3-4
 3-3A    Summary of Sample Volumes, Analytical  Results and
           Emission Rates for the Moisture Extractor Inlet .  .  .  .     3-5
 3-3B    Summary of Screening Method Results at Moisture
           Extractor Inlet 	     3-5
 3-4     Summary of Sample Volumes, Analytical  Results and
           Emission Rates for the Mist Eliminator Inlet  	     3-9
 3-5A    Summary of Sample Volumes, Analytical  Results and
           Emission Rates for the Mist Eliminator Outlet 	    3-10
 3-5B    Summary of Screening Method Results at Mist
           Eliminator Outlet 	    3-10
 3-6     Summary of Cr+6 Removal Efficiencies  	    3-12
 3-7     Summary of Plating Solution and Rinseate Analytical
         Results	    3-12

 4-1   Sample Traverse Point Locations for Moisture Extractor
         Inlet and Mist Eliminator Outlet  . .	     4-3
 4-2   Sample Traverse Point Locations Mist Eliminator Inlet .  .  .     4-4

 5-1   Summary of Analytical Results for QA/QC Samples and
         Blanks	     5-3
                                   IV

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                               SECTION 1.0
                               INTRODUCTION

      During the week of August 8, 1988, an emission measurement program
was conducted at ROLL Technology Corporation in Greenville,  South
Carolina.  Primary purpose of this program was to collect data to
determine the efficiency of a four-stage horizontal-flow mist
eliminator.  Based on this determination, it may be necessary to develop
a regulatory alternative based on this type of system.

      The principal reason for selecting ROLL Technology was that the
plant had recently installed a new fume control system.  This new mist
eliminator system combines both single chevron blade and the mesh pad
configuration into one unit.  (ROLL had participated in this EPA test
program in the past when the EPA tested the packed-bed scrubber/mist
eliminator on another plating tank.)  The capture and control system
servicing Tank No. 6 consists of a double-sided down-draft hood ducted to
a moisture extractor followed by a mist eliminator unit containing two
sets of overlapping-type blades followed by two mesh pads.  Hexavalent
chromium emissions were measured at three locations along the duct.
These locations are identified in Figure 1-1 as:  (1) IA - inlet to the
moisture extractor, (2) IB - inlet to the mist eliminator, and
(3) 0-outlet from the mist eliminator.  Figure 1-1 is a schematic showing
the sample locations.  The emission samples were collected using the
Modified Method 13B (MM13B) sample train and the EPA Screening Method.
These methods will be discussed in Section 4.0.  The samples were analyzed
for Cr+6 concentration using the diphenylcarbazide colorimetric method.
This method will also be discussed later in Section 4.0.
                                   1-1

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  Outlet
    (O)
                96"
                  \
                         Mist
                      Eliminator
                                             75-
    Flow
En let
(IB)
_J
\\\\\\\\\\\\\\\\\\ \
                                  Mist Elimlnator
                                   Rinse Return
                                        Line
                                 Moisture Extractor
                                     Drian Line
Roof —7

rt-
                                Moisture
                                Extractor
                                                            108"
                                                            Inlet
                                                              (IA)
                                   Tank No.  6
             C  "
                D
               Figure 1-1.  Location of sample  sites.

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      PEER Consultants, P.C., located In Dayton, Ohio was responsible for
developing the test protocol, conducting the field test,  on-site analysis
of sample.s and the preparation of draft and final  reports.   PEER was
supported by its subcontractor, Pacific Environmental Services,  Inc.
located in Cincinnati, Ohio.  Midwest Research Institute, located in
Raleigh, North Carolina, was responsible for monitoring the process
operation, and the EPA conducted Screening Method testing and monitored
the implementation of the test protocol.
                                   1-3

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                               SECTION 2.0
                            PROCESS OPERATION

2.1   PROCESS DESCRIPTION

      Roll Technology, Inc., is a job specializing in precision finishing
and refinishing of industrial rolls.  Operations performed at this
facility include hard chromium plating, sulfamate nickel  plating,
machining, grinding, and mirror finishing.  The plant plates rolls that
are used primarily in the paper manufacturing, roofing,  laminating,  and
coating industries.

      There are seven hard chromium plating tanks at this facility.   On
the average, the tanks are charged for a total of 20 hours per day.
Approximately 4 hours per day are required for the change-over of rolls.
During a change-over, the roll that has been plated is raised out of the
plating tank, rinsed with water from a hose, and transferred to the
grinding area.  Then, the roll to be plated is cleaned with an abrasive
cleaner and lowered into the plating solution.  Typical  plating times
range from 12 to 36 hours per roll.  Rolls that require longer plating
times typically are plated overnight, and rolls that require shorter
plating times are plated during the day when personnel are available to
perform the change-over.

      Tank No. 6 was tested during this source test program.  Tank No. 6
is 3.65 m (12.0 ft) long, 0.91 m (3.0 ft) wide, and 2.9 m (9.6 ft) deep
and holds approximately 9,270 liters (2,450 gallons) of plating
solution.  The plating solution contains chromic acid in a  concentration
of 250 grams per liter (g/2.) (33 ounces per gallon) of
                                   2-1

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water.  Sulfuric acid is used as a catalyst at a bath concentration of
2.5 g/fi. (0.033 oz/gal).  The temperature of the plating solution is
maintained between 57° and 60eC (135° and 140°F).   Tank No.  6 is used to
plate small industrial rolls, aircraft engine pistons, and rotary pumps.
A manual hoist transfers parts in and out of the plating tank.   In
addition, the plating tank is equipped with a timer which allows plating
operations to be completed during evenings and weekends when no personnel
are available to turn off the rectifier.  The typical current and voltage
applied to Tank No. 6 is 8,000 amperes and 12 volts.

      Tank No. 6 is typical of other hard chromium plating tanks used in
the electroplating industry, based on operating parameters such as
current, voltage, plating time, temperature, and chromic acid
concentration.  Although the composition of the plating solutions remains
constant, the operating voltage and current vary with each roll that is
plated.

2.2  AIR POLLUTION CONTROL

      The capture and control system on Tank No. 6 consists of a
double-sided lateral hood ducted to a moisture extractor followed by a
mist eliminator unit containing two sets of overlapping-type blades and
two mesh pads.  Figure 2-1 presents a schematic of the capture and
control system on Tank No. 6.  The fan used in the ventilation system is
rated at  255 cubic meters per minute (9,000 cubic feet per minute).

      The four stage mist eliminator unit was fabricated and installed by
KCH Services, Inc., in June  1988.  This unit replaced the scrubber that
was formerly used to control chromic acid mist from the plating tank.
Figure  2-2 presents a cross-sectional view of the mist eliminator unit.
This unit has a design airflow rate of 280 m3/min (10,000 ft3/min)
and a design pressure drop of 0.62 kilopascal (2.5 inches of water
column) at a velocity of 140 meters per minute (450 feet per minute).
The blade section consists of two sets of overlapping-type blades.
                                   2-2

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                                                                          t. HOT CLOUIUm MO F4H MUStW TO If OF .
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                                                                                     ou. msnif armcm
                                                                          — mSHfe AFKNOT [tHHJSl HOOD
                            LIB VAT I ON  VIEV
                   Figure  2-1.    Schematic of  control  device  system.
                                                 2-3

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          MESH-PAD HIST ELIMINATION SECTION
                                               54*0
              DOUBLE BAFRE SECTION
Figure 2-2.   Cross section of mist  eliminator.
                    2-4

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Catchments are located along the overlapping edges  of the blades  and  act
as collection troughs that provide a central location for droplet
collection and facilitate gravitational  drainage of the droplets  Into a
collection sump.  Figure 2-3 presents a schematic of this type blade
design.  Two sets of spray nozzles (three nozzles per set) are located
prior to each set of blades and are activated periodically to wash down
the blades.  The wash down water is drained to a holding tank and
recirculated to the plating tank to replace plating solution evaporation
losses.  The mesh pad section consists of two mesh pads in series.  The
mesh pads are manufactured by Kimre, Incorporated.   Each mesh pad is
about 1.4 m (4.5 ft) high, 1.45 m (4.75 ft) wide, and 0.15 m (0.5 ft)
deep.  Each pad consists of eight layers of mesh.  Each layer consists of
interlocked polypropylene filaments.  Each filament is 0.094 cm (0.037 m)
in diameter.  The first two layers of each pad have a void space of 97
percent, and the remaining six layers have a void space of 94 percent.

      The 22-inch diameter moisture extractor is located in the ductwork
near the ceiling of the plating shop.  Because moisture extractors are
designed for the removal of large droplets that also would be collected
in the first stage of the mist eliminator unit, the overall performance
measured during testing would be equal to the average performance of the
mist eliminator unit used alone.
      During testing, the airflow rate at the outlet of the mist
eliminator averaged 195 m3/min (6,880 ft3/min) and the pressure
drop was measured at 0.84 kPa (3.4 in. of water column).

2.3  PROCESS CONDITIONS DURING TESTING

      Mass emission tests were conducted at the following locations:
(1) the inlet of the moisture extractor, (2) between the moisture
extractor and mist eliminator unit, and (3) the outlet of the mist
eliminator unit to characterize the performance of the control devices
independently and in series.
                                   2-5

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                                OVERLAPPING
                                BLADES SERVE AS
                                CATCHMENTS
MIST-LADEN
GAS STREAM
CONTROLLED
GAS STREAM
                     DROPLETS TO COLLECTION SUMP
  Figure 2-3.  Overlapping-type blade design for chevron-blade mist
                            eliminators.
                               2-6

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      Process parameters recorded during each test run were the plating
solution temperature, operating voltage, and operating current.  Process
data sheets documenting the process paramenters monitored during testing
are presented in Appendix A.  Data on the average operating parameters
recorded for each test run are presented in Table 2-1.  The process  was
operating normally during emission testing.  The plating tank was plating
two industrial rolls during each source test.  The two rolls were
identical in size.  Each roll measured 69 cm (27 in.)  long with a
diameter of 41 cm (16 in.).  The total current supplied to the tanks
during each test run was calculated in terms of ampere-hours and is
reported in Appendix A.  A summary of the total current values is
presented in Table 2-2.

      Grab samples from the plating tank were taken during each test run
to determine the chromic acid concentration of the plating solution
during emission testing.  The mist eliminator was washed down with clean
water at the beginning of each day, and grab samples of the mist
eliminator washdown water were collected.  The chromic acid
concentrations of the grab samples are reported in Section 3 of this
report.

      Test run No. 1 was 3 hours in duration and two subsequent runs were
2 hours in duration.  Each test run was interrupted 10 to 15 minutes to
change test ports.  Test run No. 1 was interrupted for 14 minutes due to
a power loss to the meter boxes.  However, no other process interruptions
occurred during the test runs.
                                   2-7

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TABLE 2-1.   AVERAGE OPERATING PARAMETERS DURING EACH MASS
            EMISSION TEST RUN



Run No.
1
2
3

Operating
current,
amperes
4,800
5,200
5,200

Operating
voltage,
volts
6.8
7.0
7.3
Temperature
of plating
solution,
°C (°F)
54 (130)
54 (130)
54 (130)
TABLE 2-2.  TOTAL CURRENT SUPPLIED TO TANK NO. 6 DURING
            EACH MASS EMISSION TEST RUN
     Run No.
Test time, h
Total current,
 ampere-hours
       1
       2
       3
    3.0
    2.0
    2.0
   14,400
   10,400
   10,400
                                 2-8

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                               SECTION 3.0
                            SUMMARY OF RESULTS

INTRODUCTION

      Modified Method 13B (MM13B) samples and the Screening Methods (SM)
Samples were collected In triplicate at each sample location.   All  of the
emission samples were analyzed on site for Cr+6 concentrations using
the procedures outlined in "Draft Method-Determination of Hexavalent
Chromium in Dry Particulate Emissions from Stationary Sources".  This
analytical method is presented in Appendix D.

      In addition to the emission samples, grab samples of the plating
bath were composited during each MM13B run and analyzed using the same
procedures as for the emission samples.  Prior to beginning the test
program, the moisture extractor and the mist eliminator units were rinsed
with freshwater.  Following the daily test program, these two units were
rinsed again and samples of the rinseate were collected in a polyethylene
sample bottle.  These samples were also analyzed for Cr+6
concentrations.  Table 3-1 presents a schedule of the activities during
the test program,  the results from the aforementioned analysis are
presented in the remainder of this section.

HEXAVALENT CHROMIUM EMISSION RESULTS

      Emission samples were collected isokinetically using a method 13B
sample train that had been modified by removing the glass fiber filter
and placing 100 ma of 0.1N NaOH in each of the first two impingers.
The impinger solutions were recovered into tared polyethylene sample
bottles and the total volume of the recovered samples was determined
                                   3-1

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TABLE 3-1.   SCHEDULE OF ACTIVITIES
Date
(1988)
8/9
8/9
8/9
8/9
8/9
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/11
8/11
Sample
Type
MM13B
SM
SM
SM
SM
Plating Sol.
Moist. Ext. Rinse
Mist Elim. Rinse
MM13B
SM
SM
SM
SM
Plating Sol.
MM13B
SM
SM
SM
SM
Plating Sol.
Moist. Ext. Rinse
Mist Elim. Rinse

Run No. Test Time
IA-1, IB-1, 0-1 192 min.
1A series
IB series
11A thru 14H
15E thru 18H
1
1
1
IA-2, IB-2, 0-2 120 min.
2A series
2B series
21A thru 24D
25E thru 28H
2
IA-3, IB-3, 0-3 120 min.
3A series
3B series
31A thru 34D
35E thru 38H
3
2 and 3
2 and 3
Parameter
Measured
Cr+6
Cr+6
Cr*6
Cr+6
Cr+6
Cr+6
Cr+6
Cr+6
Cr+6
Cr+6
Cr+6
Cr*6
Cr+6
Cr+6
Cr+6
Cr+6
Cr+6
Cr+6
Cr+6
Cr+6
Cr+6
Cr+6
              3-2

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gravimetrlcally.  Following recovery of the samples,  an  alipuot-of the
solution was analyzed for Cr+6.   The following subsections  present
the flue gas data and analytical  results for each sample location.

Inlet to the Moisture Extractor

Modified Method 13B—
      A summary of the flue gas conditions at this location are  presented
in Table 3-2.  The volumetric flowrates were consistent  and averaged  171
dry standard cubic meters per minute (dscmm), (6041  dry  standard cubic
feet per minute, (dscfm).  The flue gas temperature  averaged 34°C (93°F)
and the moisture content averaged 2.52 percent.   The flue gas was
essentially ambient air and was assigned a dry molecular weight  of 28.95
Ib/lb mole.  The isokinetic sampling rates were within the allowable
limitations for these sample runs.

      Prior to sampling, it was decided that the first MM13B should be
run at 8 minutes per point for a total sample time of 192 minutes.  This
sample time ensured the collection of a detectable concentration of
Cr"1"6.  Following the analysis of the sample, it was  determined that
the sample time per point could be reduced to 5 minutes  for a total
sample time of 120 minutes.  The uncontrolled emissions  for each MM13B
were consistent and averaged 3.073 milligrams per dry standard cubic
meter (mg/dscm).  A summary of the MM13B sample volumes, analytical
results and emission rates for this location is presented in Table 3-3A.

Screening Method—

      A summary of the sample volumes, analytical results and emission
rates for the Screening Methods conducted at this location is presented
in Table 3-3B.
                                   3-3

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TABLE 3-2.   SUMMARY OF FLUE GAS CONDITIONS
Run No.
IA-1
IB-1
0-1
IA-2
IB-2
0-2
IA-3
IB-3
0-3
Date
8/9/88
8/9/88
8/9/88
8/10/88
8/10/88
8/10/88
8/10/88
8/10/88
8/10/88
Volumetric Flowrate
ds cm/mi n dscf/min
177 6.248
167
178
166
176
171
170
168
176
5,906
6,279
5,868
6.207
6,053
6.006
5.918
6.229
Temperature
8C °F
34
36
37
32
34
36
35
37
37
93
97
98
90
93
96
95
99
99
% Moisture
2.32
2.50
2.43
2.62
2.80
3.04
2.62
2.59
2.50
% Isokinetic
96.1 .
101.9
96.7
98.3
98.6
97.1
96.2
99.2
94.4
                  3-4

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                 TABLE  3-3A.   SUMMARY OF SAMPLE VOLUMES, ANALYTICAL RESULTS AND
                              EMISSION RATES FOR THE MOISTURE EXTRACTOR INLET

Run No.
IA-1
IA-2
IA-3
Vol ume
dscm
6.482
3.891
3.897
Metered
dscf
228.891
137.395
137.602
Total Mass
Cr+6. ma
18.3771
12.9125
11.9374
Concentration
*ma/dscm
2.835
3.319
3.064
ar/dscf
0.0012
0.0015
0.0013
Emission Rates
kq/hr
0.030
0.033
-0.031
Ib/hr
0.066
0.073
0.069
                           TABLE  3-3B.  SUMMARY OF SCREENING METHOD RESULTS AT
                                       MOISTURE EXTRACTOR INLET

Screening Methods
1-A-l
l-A-2
1-A-3
1-A-4
l-B-1
l-B-2
l-B-3
1-B-4
2-A-l
2-A-2
2-A-3
2-A-4
2-B-l
2-B-2
2-B-3
2-B-4
3-A-l
3-A-2
3-A-3
3-A-4
3-B-l
3-B-2
3-B-3
3-B-4
Vol ume
Samol ed
8.856
8.390
8.754
7.509
8.856
8.390
8.754
7.509
8.698
8.241
8.599
7.375
8.698
8.241
8.599
7.375
8.922
8.453
8.819
7.564
8.922
8.453
8.819
7.564
Stack
DSCFM
6245
6245
6245
6245
6245
6245
6245
6245
5873
5873
5873
5873
5873
5873
5873
5873
6006
6006
6006
6006
6006
6006
6006
6006
Screen
Ma/m3
0.3935
1.331
0.5337
2.114
1.745
1.870
2.127
1.438
2.520
3.144
3.213
4.937
2.063
2.404
2.377
4.293
1.381
1.377
1.880
2.001
1.864
1.815
5.999
5.831

"MM13B Ma/m3
2.84
2.84
2.84
2.84
2.84
2.84
2.84
2.84
3.32
3.32
3.32
3.32
3.32
3.32
3.32
3.32
3.07
3.07
3.07
3.07
3.07
3.07
3.07
3.07

* of MM13B
13.86
46.87
18.79
74.44
61.44
65.85
74.89
50.63
75.90
94.67
96.77
148.70
62.14
72.41
71.60
129.31
44.98
44.85
61.24
65.18
60.72
59.10
195.41
189.93
* Slight discrepancy due to difference in ejaculation  procedure
                                             3-5

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      Sample volumes for the, screening method were controlled  by critical
orifices made from hypodermic needles.  The needles were checked for  flow
rates in the lab by using a wet test meter in series with each needle.
Numbers obtained in the lab were used to determine sample volumes in  the
field by applying the ideal gas law.  Unfortunately, the ideal  gas law  is
not the correct way to determine sample volumes when using hypodermic
needles as critical orfices.

      When components are assembled as they are in the screening train,
the ideal gas law will not give satisfactory volumes.  As air  goes
through the system and reaches the hypodermic needle, it is cooled.   This
changes the diameter of the orfice (hypodermic needle) and the cooler
temperature may also change the speed of sound.  The upstream  and
downstream pressures also influence the volume, and the simple
calculations of the ideal gas law do not give precise volumes.  In order
to keep the screening method simple, samples volumes should be determined
empirically at the site.

      The ideal gas law was used to determine sample volumes at the Roll
Technology sites, and was adjusted for temperature differences for the
speed of sound.  While this seemed like a logical approach at  the time,
the volumes are not correct and the true volumes will probably never be
known.  The data, however, are still useful.  The same error was applied
to all samples, so at least the samples give some indication as to the
precision of the technique.  The reproducibility of the data,  especially
at the outlet is encouraging.

      The screening method tests run at Saint Clair Shores gave values
equivalent to about 70% of the values measured by the MM13B tests, and
this was without the use of a filter in the screening trains.   The
addition of a filter was expected to increase the yield at the Roll
Technology test, however, such was not the case.  There are some possible
explanations for this result.
                                   3-6

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First, sampling was done at a single location during both tests.
Although the flow through the ducts was fairly uniform,  this  does  not
necessarily mean that the distribution of chromic acid 1s uniform
throughout the stack gas.  Thus the concentration sampled could be high,
low, or average, but still 1s probably biased in one (unknown)
direction.  Another biasing characteristic could be the  sample  volumes
used 1n the calculations.  Calculations performed on a smaller  than
actual volume will bias the results high; calculations performed on a
larger than actual volume will bias the results lower.

      While the results from the screening method were somewhat
disappointing, the next test will incorporate stack traverses into the  SM
sampling.  It is hoped that the next phase of the test will  provide
results that more closely agree with the MM 13B trains.

Inlet to the Mist Eliminator

      After completion of the cyclonic flow check at this location it was
determined that special sampling procedures would need to be
implemented.  The discussion of those sampling procedures will  be
presented in Section 4.0 of this report.

Modified Method 13B—
      A summary of the flue gas conditions at this location is  presented
in Table 3-2.  The volumetric flowrates were consistent and averaged
170 dry standard cubic meters per minute (dscmm), (6010 dry standard
cubic feet per minute, (dscfm).  The flue gas temperature averaged 36°C
(96°F) and the moisture content averaged 2.63 percent.  The flue gas was
essentially ambient air and was assigned a dry molecular weight of
28.95 Ib/lb mole.  The isokinetic sampling rates were within the
allowable limitations for these sample runs.

      In order to meet the requirements of the cyclonic flow sampling
procedure employed, the sampling times at each traverse point were
adjusted.  Sampling times ranged from 5 minutes, 28 seconds to  11
                                   3-7

-------
minutes, 55 seconds, based on a nominal  sampling time of 8 minutes  per
point, a total sampling time of 187 minutes,  40 seconds was attained.
This sample time ensured the collection  of a  detectable concentration  of
Cr+6.  Following analysis of the sample  it was determined that the
nominal sampling time could be reduced to 5 minutes per point which
corresponded to actual sampling times ranging from 3 minutes, 31  seconds
to 5 minutes, 27 seconds, for a total sampling time of 117 minutes,
11 seconds.  The emissions for each MM13B run were consistent and
averaged 0.436 milligrams per dry standard cubic meter (mg/dscm).  A
summary of the MM13B sample volumes, analytical results and emission
rates for this location is presented in  Table 3-4.

Outlet from the Mist Eliminator

Modified Method 138—
      A summary of the flue gas conditions at this location is presented
in Table 3-2.  The volumetric flowrates  were  consistent and averaged
175 dry standard cubic meters per minute (dscmm), (6187 dry standard
cubic feet per minute, (dscfm).  The flue gas temperature averaged  37°C
(98°F) and the moisture content averaged 2.66 percent.  The flue gas was
essentially ambient air and was assigned a dry molecular weight of
28.95 Ib/lb mole.  The isokinetic sampling rates were within the
allowable limitations for these sample runs.

      Prior to sampling it was decided that the first MM13B should   be
run at 8 minutes per point for a total sample time of 192 minutes.   This
increased sample time ensured the collection of a detectable
concentration of Cr+6.  Following the analysis of the sample, it was
determined that the sample time per point could be reduced to 5 minutes
for a total sample time of 120 minutes.   The uncontrolled emissions for
each MM13B were consistent and averaged 0.0409 milligrams per dry
standard cubic meter (mg/dscm).  A summary of the MM13B sample volumes,
analytical results and emission rates for this location is presented in
Table 3-5A and screening method results  are presented in Table 3-5B.
                                   3-8

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TABLE 3-4.  SUMMARY OF SAMPLE VOLUMES, ANALYTICAL RESULTS AND
           EMISSION RATES FOR THE  MIST ELIMINATOR INLET
Run No.
IB-1
IB-2
IB-3
Vol ume
dscm
4
3
2
.740
.041
.919
Metered
dscf
167
107
103
.357
.397
.069
Total Mass
Cr+6. ma
1
1
1
.644
.610
.257
Concentration
mq/dscm qr/dscf
0.347 0.00015
0.529
0.431
0
0
.00023
.00019
Emission
ka/hr
0.0035
0.0056
0.0043
Rates
Ib/hr
0.0076
0.0123
0.0095
                            3-9

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                    TABLE 3-5A.  SUMMARY OF SAMPLE VOLUMES,  ANALYTICAL RESULTS AND
                                 EMISSION RATES FOR THE MIST ELIMINATOR OUTLET
Volume Metered Total Mass Concentration
Run No.
0-1
0-2
0-3.



Screenina Methods
1-1 -A
1-2-B
1-3-C
1-4-D
1-5-E
1-6-F
1-7-G
1-8-H
2-1 -A
2-2-8
2-3-C
2-4-0
2-5-E
2-6-F
2-7-G
2-8-H
3-1 -A
3-2-B
3-3-C
3-4-D
3-5-E
3-6-F
3-7-G
3-8-H
dscm
6.298
3.810
3.811
TABLE

Vol ume
Samol ed
10.306
14.751
14.665
15.181
10.306
14.751
14.665
15.181
10.449
14.954
14.867
15.391
10.449
14.954
14.867
15.391
10.697
15.310
15.220
15.756
10.695
15.310
15.220
15.756
dscf
222.371
134.539
134.555
Cr+6. ma *ma/dscm
0.189 0.030
0.165 0.043
0.180 0.047
3-5B. SUMMARY OF SCREENING METHOD
MIST
Stack
DSCFM
6279
6279
6279
6279
6279
6279
6279
6279
6051
6051
6051
6051
6051
6051
6051
6051
6218
6218
6218
6218
6218
6218
6218
6218
ELIMINATOR OUTLET
Screen
ar/dscf
0.00001
0.00002
0.00002
RESULTS AT


mq/m3 *MM13B mq/m3
0.01984
0.01740
0.01979
0.01866
0.01096
0.01815
0.01780
0.01584
0.02193
0.01925
0.02126
0.02203
0.01910
0.02000
0.02252
0.02317
0.01898
0.01845
0.01947
0.02017
0.01700
0.01785
0.01680
0.01952
0.0305
0.0305
0.0305
0.0305
0.0305
0.0305
0.0305
0.0305
0.0442
0.0442
0.0442
0.0442
0.0442
0.0442
0.0442
0.0442
0.0481
0.0481
0.0481
0.0481
0.0481
0.0481
0.0481
0.0481
Emission
ka/hr
0.0003
0.0004
0.0005
THE


Rates
Ib/hr
0.0007
0.0010
0.0011



* of MM13B
65.05
57.05
64.89
61.18
35.93
59.51
58.36
51.93
49.62
43.55
48.10
49.84
43.21
45.25
50.95
52.42
39.46
38.36
40.48
41.93
35.34
37.11
34.93
40.58
























* Slight discrapency  due  to  difference in calculation procedure.
                                             3-10

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      The Cr+s removal efficiencies for the system were consistent
and averaged 98.6X.  A summary of removal efficiencies for the system is
presented in Table 3-6.

PLATING TANK SOLUTIONS

      During each MM13B run, grab samples of the plating bath solution
were collected and composited.  The samples were analyzed for Cr"1"6
concentration.  The results from these analyses are presented in
Table 3-7.

MOISTURE EXTRACTOR RINSE

      Prior to the start of sampling program the moisture extractor was
rinsed with fresh water.  The moisture extractor was rinsed daily and a
sample of the rinseate was collected and analyzed for Cr"1"6
concentrations.  The result of these analyses were presented in Table 3-7.

MIST ELIMINATOR RINSE

      Prior to the start of the sampling program the mist eliminator was
rinsed with fresh water.  The mist eliminator was rinsed daily and a
sample of the rinseate was collected and analyzed for Cr+6
concentrations.  The result of these analyses were presented in Table 3-7,
                                   3-11

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TABLE 3-6.  SUMMARY OF Cr+6 REMOVAL EFFICIENCIES
Run No.
IA-1
0-1
IA-2
0-2
IA-3
0-3
Average
Cr+« Emission Rate Ib/hr
0.0664
0.0007
0.0729
0.0010
0.0689
0.0011

Or*6 Removal Efficiency
98.9%
98.6%
98.4%
98.6%
  TABLE 3-7.  SUMMARY OF PLATING SOLUTION AND
              RINSEATE ANALYTICAL RESULTS
    Run No.            Cr+6 Concentration,

  Plating Solution
       IA-1                             145,872
       IA-2                             115,385
       IA-3                             119,308

  Moisture Extractor Rinseate
     8/10/88                              3,046
     8/11/88                              6,551

  Mist Eliminator Rinseate
     8/10/88                                461
     8/11/88                                620
                      3-12

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                               SECTION 4.0
                   SAMPLING LOCATIONS AND TEST METHODS

PLATING TANK EMISSIONS

Location of Measurement Sites

      EPA Reference Method 1  "Sample and Velocity Traverse for Stationary
Sources" was used to select representative measurement  sites.   The
measurement site at the moisture extractor was located  in a 21.5 inch ID
circular vertical duct.  Two 3-inch ID holes were cut in the duct at
90 degrees from each other.  The measurement site was 53 inches
(2.5 stack diameters) downstream from the nearest flow disturbance (bath)
and 55 inches (2.6 stack diameters) upstream from any flow disturbance
(90° bend).

      The measurement site for the mist eliminator inlet was located in a
21.5 inch ID circular horizontal duct.  The measurement site was located
50 inches (2.3 stack diameters) downstream from any flow disturbance
(90° bend) and 20 inches (1.2 stack diameters) upstream from the mist
eliminator.

      The measurement site for the outlet of the mist eliminator was
located in a 21.5 inch ID circular vertical duct.  The measurement site
was located 75 inches (3.5 stack diameters) downstream from the mist
eliminator outlet and 20 inches (0.9 stack diameters) upstream from the
atmosphere.

      According to EPA Method 1 criteria, each site required 24 sample
traverse points, 12 along each diameter.  With the EPA Task Manager's
                                   4-1

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approval, the point closest to the port was not sampled because the high
static pressure at that point might result in erroneous measurements.
Thus it was decided instead to sample point #2 twice.   The point closest
to the bottom of the duct at the inlet to the mist eliminator was not
sampled in order to prevent contamination of the sample due to the
presence of liquid accumulated on the duct wall.  The  EPA Task Manager
was consulted and approved this change.  Table 4-1 and 4-2 show the
traverse points used.

      Prior to sampling, verification of the absence of cyclonic flow  at
each sample traverse point was assessed based on procedures described  in
EPA Reference Method 1.  In this method the face openings of the Type-S
pitot tube are aligned perpendicular to the duct cross-sectional plane,
designated "0-degree reference."  Null (zero) pitot readings obtained  at
0-degree reference indicate an acceptable flow condition at a given
point.  If the point reading were not zero at 0-degree reference, the
pitot was rotated until a null reading was obtained.  The value of the
rotation angle (yaw) was recorded for each point and averaged across the
duct.  Method 1 criteria stipulate that average angular rotations greater
than 20 degrees indicate cyclonic (nonaxial) flow conditions in the
duct.  The average of the angular rotation for the moisture extractor
inlet was 3 degrees, and the average angular rotation  at the mist
eliminator outlet was 8 degrees.  Both of these sites  indicated
acceptable flow patterns so that extraction of representative samples
from these sites was performed using normal sampling procedures.  The
average of the angular rotation at the mist eliminator inlet was
24 degrees indicating the presence of cyclonic flow, by exceeding the
20 degree limit allowed by Method 1.  With the approval of the EPA Task
Manager it was decided that the alignment approach for sampling in
cyclonic flow be used.

      In the alignment method, the sampling rate must  be based on the
total velocity at each sampling point in order to maintain isokinetic
                                   4-2

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TABLE 4-1.   SAMPLE TRAVERSE POINT LOCATIONS FOR MOISTURE
            EXTRACTOR INLET AND MIST ELIMINATOR OUTLET
Traverse
Point
No.
1
2
3
4
5
6
7
8
9
10
11
12
Location
Moisture Extractor Mist
Inlet
0.5a
1.44
2.54
3.81
5.38
7.65
13.85
16.13
17.69
18.96
20.06
21.00a

Eliminator
Outlet
0.5a
1.44
2.54
3.81
5.38
7.65
13.85
16.13
17.69
18.96
20.06
21.00a
a Relocated to the minimum distance from the inside
  stack wall.
                            4-3

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      TABLE 4-2.   SAMPLE TRAVERSE POINT LOCATIONS-MIST  ELIMINATOR  INLET
Traverse
Point
No.
1
2
3
4
5
6
7
8
9
10
11
12
Traverse
0.5a
1.44
2.54
3.81
5.38
7.65
13.85
16.13
17.69
18.96
20.06
21.00a
Anale of
Vertical (degrees)
C40
C45
C40
C30
C20
C5
CIS
CC25
CC20
CC15
CC15
CC20
Flow Deviation
Horizontal (degrees)
C20
C20
C15
CIS
CIS
C21
C18
CC 3
CC18
CC44
CC50
CC40
a Relocated to the minimum distance from the inside stack wall.
 C - Clockwise
CC - Counter Clockwise
                                     4-4

-------
sampling conditions.   Since the angle between the flow direction  and
stack axis varies across the stack,  the sampling velocity is  not  weighted
proportionally to the axial, velocity component.  Proportional  sampling
requirements can be satisfied by adjusting the sampling time  for  each
sampling point such that the volume  of sample collected at each point is
related by a constant to the axial velocity component at each point.
Thus,
                    *2 = *1 C°S *
          where
                    t  - nominal sampling time per point
                    t  o actual sampling time per point
                     * = angle between flow direction and stack axis

      The nominal sampling time per point should be of sufficient
duration to ensure collection of sufficient sample volume to  provide
accurate mass concentration measurements since the application of the
above weighting procedure will reduce the actual sampling time.

      When sampling to determine a mass emission rate, the volumetric
flow rate is determined as:
TS
PeMe
N
I ( i
&P\ COS $i>
                                           N

      If negative velocities are encountered at particular sampling
points, then no sampling should be conducted at those points and the
measured negative axial volume flow rate should be subtracted from the
measured positive axial volume flow rate.

Test Methods

      Velocity and static pressures, moisture content, and temperature
were measured prior to sampling, in order to define sampling rates and
                                   4-5

-------
nozzle sizes as described 1n the EPA Reference Methods  1,  2  and  4.   The
stack gas molecular weight was not determined by procedures  outlined In
EPA Method 3.  Alternatively, the molecular weight was  assigned  the  value
of 29.0 Ib/lb mole, as stated 1n the EPA Method 2, paragraph 3.6.

      An EPA MM13B sample train was used to collect the Cr*6 samples.
The sample train consisted of a 316 stainless steel button-hook  design
nozzle, an unheated Pyrex glass-lined probe, and a series  of four
impingers.  The first, third and fourth impingers were  Greenburg-Smith
design, modified by replacing the tip with a 1/2-in. inside  diameter
glass tube extending to 1/2-in. from the bottom of the  flask.  The second
impinger was a Greenburg-Smith Impinger with the standard  tip.   The  first
and second impingers contained lOOmfi, of 0.1N NaOH.  The third impinger
was empty and the fourth impinger contained approximately  200 grams  of
silica gel.  On Run IA2, 182 and 0-2, an additional silica-gel  filled
impinger was added to the sampling train.  The balance  of  the sampling
system consisted of a vacuum pump, dry gas meter, calibrated orifice and
related temperature and pressure indicating apparatus to determine dry
gas sample volume, stack gas temperature, volumetric flow  rate and
isokinetic sampling rates.  During sampling, stack gas  temperature and
the gas temperature exiting the last Impinger were monitored with
calibrated thermocouples.

      The sampling time was varied from 8 minutes per point  (192 minute
total sample time) to 5 minutes per point (120 minute total  sample time)
since the concentration of Cr+6 was such that good analytical results
could be obtained using the shorter time.  The sampling times calculated
for the alignment approach varied from 5.63 to 8.75  minutes per point,
for an eight minute nominal sampling time and 3.52 to 5.46 minutes for a
five minute nominal sampling time.

      The impingers were weighed before and after each  test  to determine
the moisture content of the flue gas stream.  The contents of the
                                   4-6

-------
1mp1ngers were placed 1n a tared polyethylene container.   All  connecting
glassware, the nozzle and probe were rinsed with 0.1  N NaOH and combined
with the impinger solution in the polyethylene sample bottle.   In
recovering, the mist eliminator outlet samples the probe  and nozzle rinse
were separated from the impinger catch in an effort to concentrate the
Cr*6 in a smaller sample volume.  The liquid level was marked on each
sample bottle and each bottle was marked indicating the run number and
bottle contents.  Appropriate blank solutions were collected.

      The polyethylene containers were all tared before their use and
weighed after the collection of the sample.  The volume of each solution
was determined by multiplying the specific gravity of the solution times
the net weight of the solution.  Each sample, including blanks, was
analyzed for Cr+6 concentration using analytical methodology recently
developed by the EPA.

EMISSION SAMPLE ANALYSIS

      The MM13B samples, the Screening Methods samples, the plating
solution and the emission control unit rinses were analyzed for Cr+6
concentration.  The analyses were conducted on site in the plant's
analytical laboratory.  Immediately following the sample recovery, the
samples were submitted to the analyst and the analyses and the
calculations were performed the same day.  The analytical results were
performed on the Hewlett Packard 41CV computer that was set up in the
on-site computer center.  The calculations were also performed by the EPA
Task Manager.

      The analytical method entitled "Draft Method - Determination of
Hexavalent Chromium in Dry Particulate Emissions from Stationary Sources"
was used as a "guideline" in conducting the analyses.  This method is
currently under development by the EPA and is presented in Appendix D.
                                   4-7

-------
      There were several variations between the Draft Method and the
Analytical Method that was performed In the field.  They are described as
follows:

      1.  The collected samples were not digested in an alkaline
          solution.  Aliquots of the recovered samples were pipeted
          directly from the sample bottle and prepared as 1n paragraph
          5.7.1 of the Draft Method.

      2.  The pH of the sample aliquot was monitored with a pH meter
          while adjusting the pH of the aliquot to 2 ± .5.

      3.  The spectrophotometer was calibrated with standards containing
          2 mi, 5 ml, 7 mft, 10 ml, 15 mfi, and 20 mfi, of the
          5 jig/mft, working standard.  The spectrophotometer
          calibration factor, K , was calculated as follows:
         Aj. + 2.5A2 + 3.5A3 + 5A4 + 7.5A5 + 10A6
Kc - 10 	
              222222
            AI + A2 + A3 + A4 + A5 + A6
    4.  The value of this calibration factor was calculated using a computer
        program that was developed by the EPA Task Manager for the HP41
        calculator.
                                   4-8

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                               SECTION 5.0
                            QUALITY ASSURANCE
INTRODUCTION
      The goal of the quality assurance activities for this  project is  to
ensure, to the highest degree possible, the accuracy of data collected.
The procedures contained in the "Quality Assurance Handbook  for Air
Pollution Measurement Systems," Volume III, "Stationary Source Specific
Methods," EPA-600/4-77-027B served as the basis for performance of all
testing and related work activities that were undertaken in  this testing
program.  In addition to the quality assurance measure guidelines
presented above, specific quality assurance activities were  conducted for
several of the individual testing activities, as performed;  these are
presented in the paragraphs that follow.

FIELD QUALITY ASSURANCE PROCEDURES

      In order to assure a high level of quality control while sampling
to allow the comparison of data from these two methods, a field quality
assurance program was followed during the test program.  Methods used to
obtain the required level of quality assurance are itemized  below.

Sample Blanks

Reagent Blanks—
      The 0.1N NaOH absorbing solution was transported to the field in
its "as-purchased" container.  When in the field, the 0.1N NaOH was
transferred to a polyethylene wash bottle.  From the wash bottle, the
NaOH solution was used for sample train preparation and recovery.  A
                                   5-1

-------
blank sample was collected from the solution In the  wash  bottle.   This
sample was given to the on-site laboratory personnel  with the  emission
samples, and analyzed in the same manner.   Results of the blank  analyses
are presented in Table 5-1.

H 0 Blanks—
      A distilled water blank was obtained from the  wash  bottles and
analyzed in the same manner as the emission samples.

Duplicate Samples

      One sample for every 10 samples analyzed was a duplicate,  e.g.,  if
24 samples were analyzed, 3 duplicate samples would  be analyzed.   The
analytical results for the duplicated samples are presented in Table 5-1.

Standards

      Daily, throughout the analysis of the samples,  standards were set
up as a spot check of the spectrophotometer calibration.   The  results  of
these checks are presented in Table 5-1.

Chain of Custody

      In an effort to maintain the integrity of all  samples taken at  the
test facility, a chain of custody procedure was followed.  A copy of  the
"Chain-of-Custody" data sheets is included in Appendix E.  These sheets
include the sample identification, date of sample recovery, name of
person who performs the recovery, place of recovery  as well as the name
of the responsible person from the analytical group  who is taking custody
of the samples.  Once the samples were placed in custody of the
analytical group, that group provided for safe storage and maintenance of
records sufficient to maintain sample integrity.
                                   5-2

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  TABLE 5-1.   SUMMARY OF ANALYTICAL RESULTS FOR QA/QC SAMPLES AND BLANKS
Sample No.
10 pg/mQ.
10 jig/mi
75 yig/mfi,
l-A-2
50 yg/mfi.
10 jig/mi
25 pg/mfi,
I-A-2
75 pg/mfi.
3-B-4
3-B-3
50 jig/ml
Plating Sol.
Run 2
Blanks
H2°
0.1N NaOH
Date (1988)
8/9
8/9
8/9
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/10
8/29

8/29

8/9
8/10
Tvoe of Sample
Duplicate Standard Total pa Cr*6
X 10.04
X 10.14
X 74.73
X 344.04
X 53.19
X 10.70
X 26.57
X 12915.53
X 77.28
X 1295.45
X 1565.31
X 47.10

X 114,430 Jig/ml

0.00
0.392



"(316.21)



"(12,001.58)

"(1248.93)
"(1498.24)


«(n5,385ng/mfi,)



* Original  value aginst which duplicate  is  to  be  compared
                                       5-3

-------
Sample Transfer

      All MM13B samples collected during testing remained in the custody of
PEER Consultants, P.C.  All Screening Methods samples were returned to the
EPA after analysis.  All samples were secured in the mobile laboratory while
in the field.

SAMPLING TRAIN COMPONENTS

      The equipment used in this test program, including nozzles, pi tot
tubes, dry gas meters, orifices, and thermocouples were uniquely identified
and were calibrated in accordance with calibration procedures specified in
the applicable EPA Reference Method prior to, and at the completion of the
testing program.  The calibration sheets are presented in Appendix F.

VERIFICATION OF CALCULATIONS

Emission Calculations

      Dry gas volumes, percent moisture of the stack gas, gas flow rates,
and Cr+6 emission rates were calculated using a Hewlett Packard 41CV
programmable calculator.  The programs used can be found in the document:
"Source Test Calculation and Check Programs for Hewlett Packard 41
Calculators" (EPA-340/1-85-018).  The results were checked and verified by
the contractor task manager.

Chromium Concentration Calculations

      All absorbance data for blanks, standards, samples and QA/QC samples
were documented in a notebook.  The percent absorbance was calculated from
the percent transmittance and subsequent calculations were carried out as
described in the draft method for hexavalent chromium analysis.
                                   5-4

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