United States
       Environmental Protection
       Agency
        Office of Air Quality
        Planning and Standards
        RTP, NCZ7711
EMB Report 89-CEP-16
MAY 1989
       Air
EPA
CHROMIUM
ELECTROPLATERS
TEST REPORT
       FUSION, INCORPORATED
       HOUSTON
       TEXAS

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        EPA Contract No.  68-02-4346
             Work Assignment 5
             September 25, 1989
Determination of the Performance Level of a
         Single Packed-Bed Scrubber
              Candidate Plant
                Fusion, Inc.
               Houston, Texas
                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
  2.0     Process Description  	     4
  3.0     Summary of Results	    15
  4.0     Sampling Locations and Test Methods	    25
  5.0     Quality Assurance  	    31

APPENDICES
  A       Process Data Sheets and Ampere-Hour Calculations ....   A-l
  B       Field Data Sheets	   B-l
  C       Draft Method for Chromium Analysis 	   C-l
  D       Chain of Custody Sheets	   D-l
  E       Equipment Calibration Data  	   E-l
  F       Project Participants and Activity Log   	   F-l
  G       Datachem Quality Control Plan   	   G-l
  H       Calculation Checks   	   H-l

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                                 FIGURES
Figures                                                              Page
  1-1  Location of sample points  	     2
  2-1  Side view of capture and control  system
          at Fusion, Inc., Houston,  Texas 	     6
  2-2  Detailed schematic of a Duall horizontal-flow,
          single packed-bed scrubber  	     7
  2-3  Side view of capture and control  system
          at Fusion, Inc., Houston,  Texas   	     9
  4-1  Duct area calculations	    26

                                  TABLES
Table                                                                Page
 2-1  Average Scrubber Operating Parameters Monitored
            During Each Mass Emission Test Run	    11
 2-2  Averages of Operating Parameters Monitored During
            Each Mass Emission Test Run	    13
 2-3  Total Ampere-Hours Supplied to Plating Tank
            During Each Mass Emission Test Run	    14
 3-1  Schedule of Activities  	    16
 3-2  Summary of Flue Gas Conditions	    18
 3-3  Summary of Sample Volumes, Analytical Results
            and Emission Rates for the Scrubber Inlet 	    20
 3-4  Summary of Sample Volumes, Analytical Results and
            Emission Rates for the Scrubber Outlet  	    21
 3-5  Summary of Cr+6 Removal Efficiencies  	       23

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                                 TABLES
                              (continued)

3-6  Summary of Plating Solution Analytical Results  	   24

3-7  Summary of Plating Solution & Rlnseate
           Analytical Results  	   24

4-1  Sample Traverse Point Locations for the Scrubber
         Inlet and Outlet	   27

5-1  Summary of Analytical Results for QA/QC Samples
           And Blanks	   33

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                               SECTION 1.0
                               INTRODUCTION

     During the week of May 17-24, 1989, an emission measurement program
was conducted at the Fusion, Inc. plant in Houston,  Texas.   The purpose
of this program was to collect data to determine the efficiency of the
single packed bed scrubber, operating with an overhead washdown system
running under three separate conditions.  The conditions tested were:
without the washdown; the washdown system operating  periodically; and
with the washdown system operating constantly.

     The primary reason for selecting Fusion, Inc. was that the plant  was
willing to allow EPA to modify the scrubber by adding an overhead weir
system to determine if the flooding action provided  by the  weir improves
scrubber performance.  The capture and control system on the plating tank
consists of a double-sided draft hood ducted to the  scrubber.   In order
to assess the control efficiency of the system, hexavalent  chromium
(Cr+6) and total chromium emissions were measured at two locations
along the duct.  These locations are identified in Figure 1-1  as:
(1) inlet to the single packed-bed scrubber and (2)  outlet  from the
single packed-bed scrubber.

     The emission samples were collected using the Modified Method 13B
(MM13B) sample train.  This method 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 in Section 4.0.

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                                                      Outlet from the single
                                                      packed-bed scrubber
                                                      29.69" Dia.
 Double-sided lateral hood
30.0'x3.5'x4.0' plating tank
                                                         15.8"
                              wall
                                Inlet to the single
                                packed-bed scrubber
                                30.05"Eq. Dia.
                                                         63.2"
76"
                                       19"
                                                Dual!
                                                Single
                                              Packed-Bed

                                               Scrubber
                                    Fan
               Figure 1-1.  Location of Sample Points

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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 samples 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 EPA personnel conducted Screening  Method testing and
monitored the implementation of the test protocol.
                                    3

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                               SECTION 2.0
                            PROCESS OPERATION
2.1  PROCESS OPERATION
    Fusion, Inc.  In Houston, Texas, is a job shop that specializes  in
hard chromium electroplating of crankshafts.  The plating shop consists
of five hard chromium plating tanks that are operated 24 hours per  day,
7 days per week,  and 52 weeks per year.

    The plating tank (No. 1) tested during this source test program is
9.1 m (30 ft) long, 1.1 m (3.5 ft) wide, and 1.2 m (4.0 ft) deep,  and
holds approximately 10,410 liters (JO (2,750 gallons [gal]) of plating
solution.  The plating tank is equipped with a single rectifier rated  at
15 volts (V) and 8000 amperes (A).  The tank contains a conventional  hard
chromium plating solution consisting of 240 grams per liter (g/1)  (32
ounces per gallon [oz/gal]) of chromic acid and 2.4 g/fi- (0.32 oz/gal)
of sulfuric acid.  The plating solution is maintained at 54°C (130°F).

    The only portions of the crankshafts that are plated are the cams.
The crankshafts contained from 5 to 15 cams.  Semicircular-shaped  anodes
are positioned over each cam on the crankshaft.  The crankshaft is them
lowered by hoist into the plating tank.  The anodes are connected  to the
electrical circuit, and the current and voltage are applied stepwise
until the current density reaches 3100 A per square meter (2 A per square
inch).  During plating, each crankshaft is rotated continuously in the
tank to ensure that an even plate thickness is applied over the entire
surface area of each cam.  Typically, two to three crankshafts are plated
simultaneously over a 24-hr period at a current loading of 3000 to 4000
amperes.

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2.2 AIR POLLUTION CONTROL

    The capture and control system on the plating tank consists of a
double-sided draft hood that is vented to a horizontal-flow single
packed-bed scrubber.  Figure 2-1 presents a schematic of the capture and
control system on the plating tank.

    The scrubber was manufactured by Duall, Industries, Inc.,  (Model
No. F-101) and installed in 1988.  Figure 2-2 presents a detailed
schematic of the scrubber.  The design gas flow rate to the scrubber is
450 cubic meters per minute (m3/min) (16,000 cubic feet per minute
[fta/m1n]).  The scrubbing water flow rate is approximately 180
liters per minute (48 gallons per minute).  The design pressure drop
across the scrubber is 0.5 kilopascal (kPa) (2.0 inches of water column
[in.w.c.]).

    Hlthin the scrubber system, the velocity of the gas stream is  reduced
to approximately 143 meters per minute (440 feet per minute),  and  the gas
stream 1s humidified by a spray of water.  Water is sprayed
countercurrent to the flow of the gas stream through 10 spray nozzles.
The saturated gas stream then passes through a packed bed of
polypropylene, spherical-type mass packing.  The packed bed 1s
approximately 2.0 m (6.4 ft) high, 1.9 m (6.2 ft) wide, and 0.30 m
(1.0 ft) deep.  Entrained mist and water droplets impinge on the packing
and drain into a sump.  Behind the packed bed is a two-stage mist
elimination section that removes entrained water droplets.  The first
stage allows large droplets to settle by gravity to the bottom of the
scrubber.  The second stage contains a series of vertically-mounted
chevron blades that change the direction of the gas flow four times at
30° angles, which causes any entrained droplets to impinge on the
blades.  The mist eliminator is not washed down.

    The scrubber water drains into a sump in the bottom of the scrubber
and is recirculated by a pump.  A level indicator (sight gauge) is used
to monitor the water level in the sump, which holds approximately 450 ft

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 fan
   Dual!
   single
packed-bed
  scrubber
                                  wall





















double-sided lateral hood

30.0'x3.5'x4.0' plating tank






Figure 2-1.  Side view of capture and control system at Fusion, Inc., Houston, Texas.

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             Water
             Spray
             Section
                              Packed
                              Bed
Mist-Laden
Gas Stream
            Inspection Door
Mist
Eliminator
Section
                                                           Reclrculatlon
                                                           Pump
           Controlled
           Gas Stream
    Figure 2-2.  Detailed schematic of  a  Duall horizontal-flow,  single packed-bed scrubber.

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(120 gal) of water.  Once a week, the water in the sump is  drained  into a
5680 2, (1500 gal) holding tank and the sump is recharged with fresh
water.  During testing, the chromic acid concentration of the water
samples taken from the sump averaged 0.08 g/2, (0.01  oz/gal) through
test run No. 3  After the scrubber was thoroughly cleaned by draining the
sump and washing down the inside walls, packing media, and  mist
elimination section, the chromic acid concentration of the  sump water
averaged 4.9 g/fi. (0.65 oz/gal) for the next three runs.  Although the
plating tank is operated 24 hours per day, the recirculation system on
the scrubber is turned off from 11:30 p.m. to 7:30 a.m.  During this
time, there are no plant employees on site.  The company is concerned
that if the pump or water line broke there would be no one  on site  to
detect the break and prevent a significant spill.

    Prior to emissions testing, the scrubber was retrofitted with an
overhead weir so that the scrubber could be operated with and without
periodic washdown of the scrubber packing with fresh water.  The scrubber
was also moved back approximately 1.5 m (5.0 ft) and a section of duct
was inserted between the plating tank exhaust plenum and the inlet  of the
scrubber to accommodate inlet testing.  A stack was also added to the fan
to accommodate outlet testing.  Figure 2-3 presents a schematic of  the
capture and control system on the plating tank after modifications.
Duall Industries, Inc., the manufacturer of the scrubber, performed the
modifications on the ventilation system and scrubber in addition to
inspecting the scrubber to ensure proper operation.

2.3  PROCESS CONDITIONS DURING TESTING

    The primary purpose of this source test was to determine if the
periodic flooding action provided by the scrubber overhead  weir system
could significantly improve the scrubber performance.  Therefore, eight
mass emissions tests runs were conducted at the inlet and outlet of the
scrubber at each of the following three conditions:   (1) the scrubber
recirculation system was in operation and any required makeup water was

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 fan
    Dual!
/ single
 packed-bed
   scrubber
                                           wall
                                                 double-sided lateral  hood   '
                                                30.0'x3.5'x4.0' plating tank
Figure 2-3.   Side view of capture and control system at Fusion, Inc., Houston, Texas,

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supplied by a hose through one of the scrubber's inspection  doors;  and
(2) the scrubber recirculation system was in operation and  all  required
makeup water was supplied through a pipe that extended out  about 10 to
13 centimeters (4 to 5 inches) over the top of the packed bed.   Two
subsequent test runs were conducted at the inlet and outlet  of  the
scrubber with the scrubber recirculation system in operation and a
continuous flow of fresh water supplied through the overhead weir at a
rate of 7.6 i/min (2.0 gal/min).

    Prior to test runs No. 1 and 3, the sump in the bottom  of the
scrubber was drained to the holding tank and the sump was recharged with
fresK water supplied by a hose through one of the scrubber's inspection
doors.  During test runs 1 through 3, makeup water required  by the
scrubber to replace evaporation losses was added through the inspection
doors with a water hose.  Prior to test run No. 4, the scrubber was
inspected and found to contain a heavy buildup of chromic acid resulting
from the overnight shutdown of the recirculation system. Therefore, the
scrubber was thoroughly cleaned by draining the sump and washing down the
inside walls, packing media, and mist elimination section with a
pressurized water hose.  During test runs 4 through 6., makeup water
required by the scrubber to replace evaporation losses was  supplied
through the pipe located over the top of the packed-bed.  Prior to test
run No. 7, the scrubber was cleaned again.  During test run Nos. 7  and 8,
makeup water was added continuously over the top of the packed bed
through the overhead weir at a flow rate of 7.6 Jl/m1n (2.0  gal/min).

    The scrubber parameters monitored during testing were  the pressure
drop across the scrubber, the frequency and, 1f possible,  the amount of
makeup water added, the chromic acid concentration of the  scrubber  water,
and when applicable, the overhead water flow rate.  The actual  inlet gas
flow rate to the scrubber during testing averaged 575 m3/min
(20,350 ft3/min), and the monitored pressure drop was close to the
design pressure drop of 0.5 kPa (2.0 in. w.c.).  The average scrubber
parameters monitored during each test run are presented in  Table 2-1.
                                    10

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    TABLE 2-1.  AVERAGE SCRUBBER OPERATING PARAMETERS MONITORED DURING
                       EACH MASS EMISSION  TEST RUN
Test run No.
  Frequency
  of water
 replacement,
    No.  of
times per run
  Amount of
 makeup water
added, i (gal)
Pressure drop, kPa
    (in. w.c.)
No washdown

  1                   6
  2                   4
  3                   4

Periodic washdown

  4                   4
  5                   5
  6                   4

Continuous washdown

  7                   c
  8                   c
                             a
                             a
                             a
                      260  (70)5
                     380 (100)J
                      260  (70)D
                   1,590  (420)5
                    980  (260)°
                        0.45 (1.8)
                        0.45 (1.8)
                        0.45 (1.8)
                        0.55 (2.2)
                        0.55 (2.2)
                        0.55 (2.2)
                        0.55 (2.2)
                        0.55 (2.2)
Makeup water was supplied by a garden hose and, therefore, the amount of
.water added was not measured.
 Makeup water was added through a flow meter.  The quantities of water
 provided are based on the amount of time required to fill  the sump and
 the flow rate measured through the flow meter.
JjFresh water was added continuously at a rate of 2 gallons  per minute.
 Based on the total amount of time to collect a complete emission sample
 and a continuous fresh water flow rate of 2.0 gallons per  minute.
                                  11

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Grab samples of the scrubber water were taken from the sump at  the end of
each test run.  The chromic acid concentration of the scrubber  water
samples is reported in Section 3 of this report.

    The process was operating normally during the test.  Process
operating parameters such as voltage, current, and plating solution
temperature were monitored and recorded during each test run.   Also
recorded were the number and approximate size of the crankshafts in the
plating tank during each test run.  Averages for the operating  parameters
recorded are presented in Table 2-2.  The total amount of current
supplied to the plating tank during each test run was calculated in terms
of ampere-hours based on the duration of sampling at the inlet  and outlet
test locations.  Information on the total ampere-hours supplied to the
plating tank during each test run is presented in Table 2-3.  Data sheets
documenting the process parameters that were recorded during each test
run and the ampere-hour calculations are presented in Appendix  A.

    Grab samples of the plating solution were taken at the beginning,
middle, and end of each test run to determine the chromic acid
concentration of the solution during testing.  The chromic acid
concentration of the composite samples is reported in Section 3.0 of this
report.

    Test Runs 1 through 6 and test run 8 were each 2 hours in duration.
Test run No. 7 was 3.2 hours in duration.  Each test run was interrupted
for 10 to 25 minutes to change test ports.  Test run No. 1 was
interrupted for approximately 3 hours because of an electrical  problem in
the plating line, which resulted from a current overload.  Test run No. 2
was interrupted for 8 minutes because of a problem with maintaining the
isokinetic sampling rate at the outlet test location.
                                    12

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    TABLE 2-3.  TOTAL AMPERE-HOURS SUPPLIED TO PLATING TANK
              DURING  EACH MASS EMISSIONS TEST  RUN

Test Run No.
1
2
3
4
5
6
7
8

Test
time, hours
2
2
2
2
2
2
3.2
2
Total
current, ampei
Inlet
5,500
6,000
4,600
7,200
7,200
7,400
10,000
5,600

'•e-hoursa
Outlet
5,400
6,000
4,600
7,100
7,200
7,400
10,000
5,600
aNumbers were rounded to the nearest 100.
                           13

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         TABLE 2-2.  AVERAGES OF OPERATING PARAMETERS
         MONITORED  DURING EACH  MASS EMISSION   TEST RUN
Run No.
1
2
3
4
5
6
7
8
Operating
voltage, volts
5.5
5.8
6.0
5.6
5.6
5.6
6.6
6.2
Operating
current, amperes a
2,600
3,000
2,300
3,600
3,600
3,700
3,100
2,800
Operating
bath
temp., °F
127
127
127
127
127
128
126
127
aRounded to nearest 100.
                           14

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                               SECTION 3.0
                            SUMMARY OF RESULTS
INTRODUCTION
    Eight Modified Method 13B (MM13B) samples were collected at each
sample location.  All of-the emission samples were analyzed on site for
Cr+6 concentrations using the procedures outlined in the method
entitled "Draft Method - Determination of Hexavalent Chromium in Dry
Particulate Emissions from Stationary Sources."  Upon completion of the
test program, two emission samples from each location were analyzed for
total chromium concentrations using the procedure outlined in EPA
Method 218.1.  These analytical methods are presented in Appendix D.

    Testing was carried out under three separate conditions.  Under the
first condition (Condition 1), three tests were run when the scrubber's
overhead washdown system was not in operation.  For the second condition
(Condition 2), the scrubber was cleaned and the overhead washdown system
was in operation periodically; this condition was also tested for three
runs.  Under the final condition (Condition 3), the overhead washdown
system was operating continuously; testing under this condition was only
carried out for two runs.

    In addition to the emission samples, grab samples of the plating bath
were composited during each MM13B run and analyzed using the same
colorimetric procedures used for the emission samples.  Table 3-1
presents a schedule of the activities during the test program.  The
results from the sampling program are presented in the remainder of this
section.
                                    15

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TABLE 3-1.   SCHEDULE OF ACTIVITIES
Date
(1989)
5/19/89
5/19/89
5/19/89
5/19/89
5/19/89
5/19/89
5/19/89
5/19/89
5/20/89
5/20/89
5/20/89
5/20/89
5/21/89
5/21/89
5/21/89
5/21/89
5/21/89
5/21/89
5/21/89
5/21/89
5/21/89
5/21/89
5/21/89
5/21/89
5/23/89
5/23/89
5/23/89
5/23/89
5/23/89
5/23/89
5/23/89
5/23/89
Sample
Tvoe
MM13B
SM
Plating Sol.
Scrubber Rinse
MM13B
SM
Plating Sol .
Scrubber Rinse
MM13B
SM
Plating Sol.
Scrubber Rinse
MM13B
SM
Plating Sol.
Scrubber Rinse
MM13B
SM
Plating Sol.
Scrubber Rinse
MM13B
SM
Plating Sol.
Scrubber Rinse
MM13B
SM
Plating Sol .
Scrubber Rinse
MM13B
SM
Plating Sol.
Scrubber Rinse

Run
1-1
1-1
1
1
1-2
2-1
2
2
1-3
3-1
3
3
1-4
4-1
4
4
1-5
5-1
5
5
1-6
6-1
6
6
1-7
7-1
7
7
1-8
8-1
8
8
Test Time
No. (Minutes)
, 0-1 120
, i-o


, 0-2 120
, 2-0


, 0-3 120
, 3-0


. 0-4 120
. 4-0


, 0-5 120
, 5-0


. 0-6 120
, 6-0


, 0-7 192
. 7-0


, 0-8 120
, 8-0


Parameter
Measured
Cr"
Cr"
Cr"
Cr"
Cr", Total
Cr", Total
Cr"
Cr"
Cr"
Cr"
Cr"
Cr"
Cr"
Cr"
Cr"
Cr"
Cr", Total
Cr", Total
Cr"
Cr*6
Cr"
Cr"
Cr"
Cr"
Cr"
Cr*6
Cr"
Cr"
Cr"
Cr"
Cr*6
Cr"






Cr.
Cr










Cr
Cr














           16

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

Scrubber Inlet

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
541 dry standard cubic meters per minute (dscmm) [19,100 dry standard
cubic feet per minute, (dscfm)].  The flue gas temperature averaged  31°C
(88°F) and the moisture content averaged 2.41 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 MM13B runs should be run
at 5 minutes per point for a total sample time of 120 minutes.  This
sample time was chosen to ensure the collection of a detectable
concentration of Cr+6.  To ensure collection of a detectable sample
during Run 7, testing was carried out at 8 minutes per point for a total
sample time of 192 minutes.  Following the analyses of the sample, it was
determined that the subsequent  sample time per point could be reduced to
5 minutes.  The uncontrolled emissions as measured in each MM13B run were
consistent and averaged 0.697 mg/dscm (0.00030 gr/dscf).  It should be
noted that results for 1-1 came out significantly lower than the other
                                    17

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TABLE 3-2.   SUMMARY OF  FLUE GAS CONDITIONS
Run No.
Condition
1-1
0-1
1-2
0-2
1-3
0-3
Condition
1-4
0-4
1-5
0-5
1-6
0-6
Condition
1-7
0-7
1-8
0-8
Volumetric
Date ds cm/mi n
_1 - No Washdown
5/19/89
5/19/89
5/19/89
5/19/89
5/20/89
5/20/89
2. - Periodic
5/21/89
5/21/89
5/21/89
5/21/89
5/21/89
5/21/89
542
500
537
507
537
504
Washdown
546
510
543
499
536
503
Flowrate
dscf/min
19,140
17,670
18.940
17,880
18,960
17,800

19,290
18.000
19.160
17,610
18.910
17.730
Temperature
°C °F

29
28
28
28
31
29

31
27
34
29
31
28

85
83
83
82
88
84

87
81
93
84
88
82
X Moisture

2.44
2.68
2.39
3.01
2.67
2.88

2.31
2.52
2.31
2.86
2.52
3.06
% Isokinetic
108.4
104.0
108.2
102.0
107.0
101.8

104.9
101.8
104.4
101.6
104.7
102.1
_3_ - Continuous Washdown
5/2*3/89
5/23/89
5/23/89
5/23/89
548
504
540
508
19,330
17,780
19,080
17,930
31
28
33
28
88
82
91
82
2.33
2.87
2.30
2.86
105.0
98.00
105.1
97.4
                    18

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seven runs.  Noticeable discoloration of the sample could  be  seen  and  may
have been caused by accidental contact with the duct wall.  Due  to this
probable contamination the results of Run 1-1  were not used in any
calculations.  A summary of the MM13B sample volumes, analytical  results
and emission rates by test condition for this  location are presented  in
Table 3-3.

Scrubber Outlet

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
504 dry standard cubic meters per minute (dscmm) [(17,800  dry standard
cubic feet per minute, (dscfm)].  The flue gas temperature averaged 28°C
(83°F) and the moisture content averaged 2.84 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 testing should be run at
5 minutes per point for a total sample time of 120 minutes.   This  sample
time ensured the collection of a detectable concentration  of  Cr*6.
As with the inlet samples, testing during run 7 was done at 8 minutes  per
point to assure a detectable sample.  Following the analysis  of  the
sample, it was determined that the sample time per point could be  reduced
to 5 minutes as was done for the inlet samples.  When the  scrubber was
operating without the overhead washdown system in use (Condition 1) the
emissions were consistent and averaged 0.0392 mg/dscm (0.000017  gr/dscf);
furthermore, emissions were consistent and averaged 0.0230 mg/dscm
(0.000010 gr/dscf) when the overhead washdown system was used
periodically (Condition 2), and 0.0214 mg/dscm (0.000010 gr/dscf)  with
the overhead washdown in constant use (Condition 3).  Outlet  emissions
over the course of all eight test runs averaged 0.0287 mg/dscm
(0.000012 gr/dscf).  A summary of the MM13B sample volumes,  analytical
results and emission rates broken down by condition for this  location is
presented in Table 3-4.
                                     19

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TABLE 3-3.  SUMMARY OF SAMPLE VOLUMES. ANALYTICAL RESULTS AND
            EMISSION RATES FOR THE SCRUBBER  INLET
Volume
Stack Metered
Run No. dscfm dscf
Condition 1
1-1 19,140 162.729
1-2 18,940 160.691
1-3 18,960 159.143
Condition 2
1-4 19,290 158.581
1-5 19,150 156.719
1-6 18,910 155.491
Condition 3
1-7 19.330 254.682
1-8 19.080 157.312
Total Mass Concentration Emission Rates
Cr+6. ma ma/dscm ar/dscf kq/hr Ib/hr

1.3794 0.299 0.00013 0.00097 0.0215
2.9411 0.646 0.00028 0.0208 0.0458
3.5306 0.783 0.00034 0.0252 0.0557

3.8189 0.850 0.00037 0.0279 0.0614
2.5549 0.576 0.00025 0.0187 0.0413
2.5477 0.580 0.00025 0.0186 0.0410

5.4262 0.752 0.00033 0.0247 0.0545
3.0854 0.693 0.00030 0.0225 0.0495
                                20

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                   TABLE 3-4.   SUMMARY OF SAMPLE VOLUMES,  ANALYTICAL  RESULTS AND
                               EMISSION RATES FOR THE SCRUBBER  OUTLET
            Stack
Run No.      dscfm

Condition 1

0-1        17.670

0-2        17,880

0-3        17.800

Condition 2

0-4        18,000

0-5        17,610

0-6        17,730

Condition 3

0-7        17,780

0-8        17,930
 Volume
Metered
  dscf
141.229

140.140

139.366



140.892

137.619

139.263



214.324

134.313
Total Mass
 Cr+6. mq
 0.14996

 0.15495

 0.16240



 0.10248

 0.08409

 0.08582



 0.13798

 0.07656
  Concentration
mq/dscm   gr/dscf
Emission Rates
 kq/hr   Ib/hr
 0.0375    0.000016    0.00113  0.00248

 0.0390    0.000017    0.00119  0.00261

 0.0412    0.000018    0.00124  0.00274



 0.0257    0.000011    0.00078  0.00173

 0.0216    0.000009    0.00065  0.00142

 0.0218    0.000010    0.00066  0.00145



 0.0227    0.000010    0.00069  0.00151

 0.0201    0.000009    0.00061  0.00135
                                              21

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    The Cr"1"6 removal efficiencies for the scrubber without washdown
averaged 94.71 (based on emission rates) and 94.4% (based on
concentration).  When periodic washdown was in use, efficiency averaged
96.8% (emission rates) and 96.5% (concentration).  Constant washdown
produced efficiencies averaging 97.3% (emission rates) and 97.1%
(concentration).  A summary of removal efficiencies for the system is
presented in Table 3-5.

TOTAL CHROMIUM ANALYSIS

    Upon returning from Houston the samples from Run 2 and Run 5 were
submitted for total chromium analysis.  Based on the concentration
determined from these analyses, the total Cr removal efficiencies for
these runs were:  91.3% for Run 2 and 92.6% for Run 5.  The results from
the total chrome analysis are presented in Table 3-6.  The analyses were
performed by Datachem Inc. in Cincinnati, Ohio.  Their quality.control
plan is presented in Appendix G.

PLATING TANK SOLUTIONS

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

SCRUBBER RINSE

    Prior to the start of the sampling program, and between conditions,
the scrubber was cleaned with fresh water.  After every test run, a
sample of the scrubber rinseate was collected and analyzed for Cr+s
concentrations.  The results of these analyses are presented in Table 3-7.
                                    22

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                          TABLE  3-5.  SUMMARY OF Cr+6 REMOVAL EFFICIENCIES
Emission Rate Cr+6 Removal
Rgn Np. Ib/hr Cr+6 Efficiency %
Condition 1
*I-1
0-1
1-2
0-2
1-3
0-3
Average Condition
Condition 2
1-4
0-4
1-5
0-5
1-6
0-6
Average Condition
Condition 3
1-7
0-7
1-8
0-8
Average Condition

0.0215
0.00248 88.4
0.0458
0.00261 94.3
0.0557
0.00274 95.1
1 94.7

0.0614
0.00173 97.2
0.0413
0.00142 96.6
0.0410
0.00145 96.5
2 96.8

0.0545
0.00151 97.2
0.0495
0.00135 97.3
3 97.3
Concentration
mq/m3 C_r+6
0.2996
0.0375
0.646
0.0390
0.783
0.0412


0.850
0.0257
0.576
0.0216
0.580
0.0217


0.752
0.0227
0.693
0.0201

Cr*6 Removal
Efficiency %

87.5

94.0

94.7
94.4


97.0

96.3

96.3
96.5


97.0

97.1
97.1
* - This run is not included in the average  due  to  possible contamination of sample 1-1
                                             23

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TABLE 3-6.  TOTAL CHROMIUM DATA FUSION,  INC. HOUSTON, TEXAS
Run No. Vmstd
1-2 160.691
0-2 140.140
1-5 156.719
0-5 137.619
TABLE
Qstd Total Cr mass
dscfm mq
18,940 3.59
17.880 0.27
19.160 3.25
17,610 0.21
3-7. SUMMARY OF PLATING
Concentration Emission Rate
mq/m3 qr/dscf kq/hr Ib/hr
0.789 0.00034 0.0254
0.0680 0.000029 0.00207
0.732 0.00032 0.0238
0.0539 0.000024 0.00161
SOLUTION & RINSEATE
0.0560
0.00456
0.0525
0.00355

ANALYTICAL RESULTS
Run No.
Plating Solution
Run 1
Run 2
Run 3
Run 4
Run 5
Run 6
Run 7
Run 8
Scrubber Rinse
Run 1
Run 2
Run 3
Run 4
Run 5
Run 6
Run 7
Run 8
Cr*6 Concentration,
mq/2-

115.039
115,981
117,569
115,981
116,297
115,353
114,416
114.105

14.7
14.1
91.91
1995
2709
29.07
119.5
64.7
Cr03 Concentration

33.0
33.3
33.7
33.3
33.3
33.1
32.8
32.7

0.00422
0.00404
0.0264
0.572
0.777
0.00834
0.0343
0.0186


















                         24

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                               SECTION 4.0
                   SAMPLING LOCATIONS AND TEST METHODS

EMISSION SAMPLES

Location of Measurement Sites

    EPA Reference Method 1 "Sample and Velocity Traverses  for Stationary
Sources" was used to select representative measurement  sites.  The inlet
measurement site was located in a horizontal  duct that  was slightly
out-of-round (30.375 in. vertical diameter and 29.5 in. horizontal
diameter). The diameter of 30.05 inches was determined  by  procedures
shown in Figure 4-1.  The site was located 76 inches (2.5  duct diameters)
downstream from the nearest downstream flow disturbance (plating tank)
and 19 Inches (0.6 duct diameters) from the nearest upstream flow
disturbance (scrubber).  According to EPA Method 1  criteria, this
location required 24 sample traverse points,  12 along each of two
perpendicular diameters (30.375 and 29.5 inches).  Table 4-1 shows the
traverse point locations.

    The outlet measurement site was located in a 29.69  in. ID circular
vertical stack, 63.2 Inches (2.1 stack diameters) downstream of the
nearest flow disturbance (ID fan) and approximately 15.8 inches
(0.53 stack diameters) upstream of the nearest flow disturbance
(atmosphere).  According to EPA Method 1 criteria,  this location required
24 sample traverse points, 12 along each of two perpendicular diameters.
Table 4-1 also shows these traverse point locations.

    Prior to sampling, the absence of cyclonic flow at  each sample
traverse point was verified based on procedures described  in EPA
Reference Method 1.  In this method, the face openings  of  the Type-S
                                    25

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to
                                  .875"
                                      A=3.14(14.75)2 +(29.5)(0.875)
                                      A= 708.96in
                                            708.96
                                             3.14
                                      R=15.026"




                                      0=30.05"
                Figure 4-1.  Duct Area Calculation

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TABLE 4-1.  SAMPLE TRAVERSE POINT LOCATIONS FOR THE
            PACKED-BED SCRUBBER INLET AND OUTLET
Traverse
Point
No.
1
2
3
4
5
6
7
8
9
10
11
12
Scrubber
Horizontal
1.0
2.0
3.5
5.2
7.4
10.5
19.0
22.1
24.3
26.0
27.5
28.5
Location (inches)
Inlet
Vertical
1.0
2.0
3.6
5.4
7.6
10.8
19.6
22.8
25.0
26.8
28.3
29.375
Scrubber
Outlet
1.0
2.0
3.5
5.3
7.4
10.6
19.1
22.3
24.4
26.2
27.7
28.7
                            27

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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 was 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.  However, both of these sites indicated acceptable  flow patterns so
that extraction of representative samples from these sites was performed
using appropriate sampling procedures.

Test Methods

      Velocity and static pressures, moisture content, and temperature
were measured prior to sampling in order to define sampling rates and
nozzle sizes as described in the EPA Reference Methods 1, 2 and 4.-

      An EPA MM13B sample train was used to collect the Cr+s
samples.  The sample train consisted of a 316 stainless steel button-hook
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 100 mft, of 0.1N NaOH.  The third impinger
was empty and the fourth impinger contained approximately 200 grams  of
silica gel.  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.
                                    28

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      The sampling time was initially set at 5 minutes per point
(120 minute total sample time) and increased to 8 minutes per point
(192 minute total sample time) to assure the concentration of Cr+6
was such that good analytical results could be obtained.

      The impingers were weighed before and after each test to determine
the moisture content of the flue gas stream.  All connecting glassware,
the nozzle and probe were rinsed with 0.1N NaOH and combined with the
impinger solution into a tared polyethylene sample bottle.  The total
volume of the sample was determined gravimetrically.  The liquid level
was marked on each sample bottle and each bottle was marked indicating
the run number and bottle contents.
      Following the recovery of the samples, all samples, including
blanks, were analyzed for Cr+6 concentration using the analytical
methodology developed by the EPA.

EMISSION SAMPLE ANALYSIS

      The MM13B samples and the plating solution were analyzed for
Cr+6 concentration.  The analyses were conducted on site in the EPA
Mobile Laboratory.  Immediately following the sample recovery, the
samples were submitted to the analyst and the analyses and calculations
were performed the same day.  The reported results were calculated on the
Hewlett Packard 41CV computer.  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 Cr+6analyses.  This
method is currently under development by the EPA and is presented in
Appendix C.
                                    29

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      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 in 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 ± 0.5.

      3. The spectrophotometer was calibrated with standards containing
         2 ma, 5 mft, 7 mi, 10 m&, 15 mfl. and 20 mil of the
         5 jig/mi working standard.  The spectrophotometer calibration
         factor, K , was calculated as follows:
                       2.5A2 + 3.5A3 + 5A4 + 7.5Ag + 10Afi
         <
          c             A; * A; * A; * < + A; * A;
    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.

    The total chromium analyses were performed by Datachem Laboratories in
Cincinnati, Ohio.  The method used was EPA Method 218.  This method is
presented in Appendix C, and the results are given in Appendix G.
                                    30

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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.  These are presented in the paragraphs that
follow.

FIELD QUALITY ASSURANCE PROCEDURES

    To assure a high level of quality control while sampling in order 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.
                                    31

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A 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.

H20 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.   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.  The "Chain of Custody" record  sheets are
presented in Appendix D.

Sample Transfer

      All MM13B samples collected during testing remained  in the custody
of PEER personnel and were secured in the mobile laboratory while in the
field.
                                    32

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          TABLE 5-1.   SUMMARY OF ANALYTICAL  RESULTS FOR QA/QC SAMPLES AND BLANKS
Sample No.
75 g/100 mfl-
0-2
50 jig/mfl,
75 Jig/100 mfl,
50 Jig/100 mi
75 Jig/100 mft,
Blanks
0.1N NaOH
Date (1989)
5/21
5/21
5/21
5/21
5/22
5/22

5/21
Tvoe of Samole
Duolicate Standard Total JIQ Cr+6
X 74.6
X 161.99 "154.95
X 49.7
X 73.6
X 50.2
X 74.1

0.00
* Original values against which data are to be compared.
                                          33

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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 PEER Task Manager.

Chromium Concentration Calculations

      All absorbance data for blanks, standards, samples and QA/QC samples
were documented in a notebook.  The Cr+6 content and total mass of
Cr+6 collected were calculated using a program developed by the EPA Task
Manager for the HP41CV programmable calculator.
                                    34

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