STANDARDS PACKAGE
FOR
HAZARDOUS AI R POLLUTANTS
OFFICE OF AIR AND HfflER PROGRWS
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\
j UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SUBJECT: Regulations for the Control of Three Hazardous Pollutants:
Asbestos, Beryllium, and Mercury - BRIEFING MEMO .
FROM: Assistant Administrator for Air and Water Programs
TO: The Administrator
THRU: AX
•^
The major sections of this memorandum are: DESCRIPTION OF ACTION
(recommendation for action by Administrator), STATUTORY BASIS (actions
required by the Act compared .with actions taken), SELECTION OF POLLUTANTS
(some of the consideration which led to listing asbestos, beryllium, and
mercury -as hazardous air pollutants), ASBESTOS (complete discussion of
relevant issues and alternatives) BERYLLIUM, MERCURY AND GENERAL PROVISIONS
(as for asbestos), RESOURCE AND COST ANALYSIS (estimated manpower and
economic impact of recommended standards), and RECOMMENDATION. There are
two enclosures with this memorandum: (1) a table (Tab A) comparing the
standards proposed on December 7, 1971 with those now recommended
for promulgation, and (2) a copy of the recommended standards (Tab B)
in the format for publication in the Federal Register.
DESCRIPTION OF ACTION
Promulgation of regulations is recommended for the control of
three hazardous pollutants: asbestos, beryllium, and mercury.
STATUTORY BASIS :
Section 112 of the Clean Air Act requires the Administrator to
establish national emission standards for hazardous air pollutants. !
A hazardous air pollutant is defined as "...an air pollutant to which
no ambient air quality standard is applicable and which in the '
judgment of the Administrator may cause, or contribute to, an increase
in mortality or an increase in serious irreversible, or incapacitating
reversible, illness." Section 112 defines three steps to be followed
in the establishment of emission standards for such pollutants. The
required steps and the actions taken pertinent to these requirements
follow:
1. Paragraph (b)(l)(A) requires that the Administrator publish
a list of those hazardous air pollutants for which he intends to
establish emission standards. Publication of the initial list was
required within 90 days after the date of enactment of the Clean Air
Amendments of 1970. In response to this requirement, an initial
list containing asbestos, beryllium, and mercury was published in
the Federal Register of March 31, 1971.
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2. Paragraph (b)(l)(B) requires that, within 180 days after
an air pollutant is included in a published list, the Administrator
publish proposed regulations establishing emission standards for
such pollutant together with a notice of public hearing within
thirty days. Pursuant to this requirement, proposed regulations
for the control of emissions of asbestos, beryllium, and mercury
were published in the Federal Register of December 7, 1971 (about
10 weeks after the statutory deadline), and public hearings were
held in New York City on January 18, 1972 and in Los Angeles on
February 15 and 16, 1972. In addition, an office to which comments
by mail could be addressed was included in the Federal Register.
3. Paragraph (b)(l)(B) further requires that, within 180 days
after the publication of a proposed emission standard, the Administrator
prescribe an emission standard, unless he has found, on the basis of
Information presented at public hearings, that the pollutant clearly
1s not a hazardous air pollutant. The statutory deadline for the
prescribing of standards was June 4, 1972. On September 27, .1972., ... .;.
the Health Research Group of Washington filed notice, under
Section 304 of the. Act, of its intention to force the completion
of rule-making, and after the 60 days' required notice expires on
November 26, 1972, they may file suit. Regulations are attached
which prescribe standards for all three poflutants for which
standards were proposed. . '.".'•'••
SELECTION OF POLLUTANTS . '
There were eleven toxic substances appraised as candidates for
the first list of hazardous air pollutants: asbestos, arsenic,
beryllium, cadmium, chromium, lead, mercury, nickel, polychlorinated
biphenyls, polycyclic organic matter, and vanadium. Major selection
criteria included (1) the severity of the associated human diseases,
(2) the length of time between exposure and disease, with the longer
periods considered especially dangerous, (3) the portion of the total
human intake relatable to air-borne substances, and (4) the linkage
between sources of emissions and reported cases of diseases attributed
to the pollutant. Consultations were held with federal agencies,
advisory committees, and other experts. All consulted groups
recommended that the initiaT list be limited to asbestos, beryllium, and
mercury. In addition, a National Academy of Sciences study concluded
that control of asbestos be undertaken as quickly as possible, and the
HEW report, "Hazards of Mercury," concluded that it is urgent to use all
possible means to reduce exposure to mercury immediately.
FROM PROPOSAL TO PROMULGATION
• A table is attached (Tab A) which compares the standards proposed in the
December 7, 1971 Federal Register with the standards now recommended
for promulgation.The rationale for each change is presented later
1n this memorandum, under the pertinent pollutant heading.
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One hundred and two contributors submitted comments on the
proposed standards. The three largest groups represented were
industry (54 contributors), state and local air pollution control
agencies (20), and environmentalists (13). The major issues
concerning the promulgation of these standards are discussed in
this memorandum.
Control technology reports for the three pollutants will be
issued at the time the standards are promulgated.
ASBESTOS
The two major issues concern!ng~~the asbestos standard are:
Is asbestos hazardous within the meaning of Section 112? If so,
to what extent must asbestos emissions be controlled to provide an
ample margin of safety for protection of public health?
Issue 1:
Is asbestos a hazardous air pollutant within the meaning of
Section 112?
Discussion:
The health effects data which led to listing asbestos under
Section 112(b)(l)(A) are briefly summarized herein.
The effects of asbestos minerals on human health include
nonmalignant changes—such as pulmonary and pleura! fibrosis--
and several types of malignancy, notably of the lung, pleura,
and peritoneum. Nearly all the positive evidence of association
between asbestos and human disease has come from occupational
groups, but several studies do implicate non-occupational
asbestos exposure in the development of diffuse mesothelioma.
The identified risks of occupational exposure to asbestos
include the development of asbestosis (asbestotic pneumoconiosis) and
a higher-than-expected incidence of bronchogenic cancer.
Direct and indirect evidence that persons other than
those working directly with asbestos minerals are being exposed
to asbestos exists. For example, asbestos fibers can be identified
in the lungs of persons not occupationally exposed. In a few
geographic areas, pathologic changes regarded as representing a
reaction to asbestos, e.g. pleura! calcification, have been found
in populations with no history of occupational exposure.
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The only studies that appear to implicate asbestos in the
development of malignancies in persons not occupationally exposed
are those involving diffuse mesothelioma, a malignant tumor.
Many mesotheliomas reported in South Africa have been attributed to
nonoccupational household and neighborhood exposures in an asbestos
producing area. Among 76 patients with mesothelioma diagnosed
1n London Hospital from 1917 to 1964, 31 (40.8%) had occupational
exposures to asbestos, 9 (11.8%) had a relative who worked with
asbestos, 11 (14.5%) had neither of those backgrounds but had
lived within a half-mile of an asbestos factory, and 25 (32.9%)
had no known contacts. Similar results were found in a study of
42 mesotheliomas reported in Pennsylvania.
It 1s not now possible to specify with reasonable accuracy an
ambient standard for asbestos. The needed definition of the dose-
/ response relationship is not available. Research and analysis in
this area have been hampered severely by two factors: (1) the effects
of breathing in asbestos do not usually become evident until long
after the exposure--a 30-year latent period is not uncommon." Exposure
histories can only be roughly estimated, and (2) until recently, there
were no reliable techniques for measuring ambient concentrations of
asbestos; therefore, the concentrations to which the public might be
exposed remained unknown. There is, however, evidence to suggest that
a dose-response relationship exists. The incidence of associated
jj--,--c j.'_^_-'-i .. _ __.. • ____.,.i._ ru,,._. fv.~.~ ,!.:,.„-4.
uidcaacS u mini loucs aS CA^UAUI c GuVl roruuciiirj Cuuuyc i i um KIIC.V.W-
.occupational, to indirect-occupational, to family and neighborhood.
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In order to remove asbestos from the hazardous list, the
Administrator would have to determine that asbestos is clearly
not hazardous on the basis of information presented during the
public hearings on proposed standards. No such information was
presented.
Option A: . .
Determine that the available data support the decision that
asbestos is a hazardous air pollutant.
Pro: •
1. Asbestos has been proven to endanger health in occupational
environments where concentrations are high.
2. Both EPA and HEW health experts agree that asbestos should
be considered a hazardous air pollutant.
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Con:
1. There may be a minimum concentration below which asbestos
Is not hazardous, although this is not known.
Option B:
Determine that the available data clearly indicates that asbestos
1s not a hazardous air pollutant.
Pro:
1. In its comments on the proposed standards, the asbestos
Industry argued that asbestos has not been proven to be hazardous
1n the concentrations present in ambient air.
Con:
l.; Industry spokesmen provided no factual information to support
the argument that asbestos is not hazardous in ambient air.
2. No new data were submitted either at the public hearings or
during the comment period, that would indicate that asbestos is
clearly not hazardous in the ambient'air.
3. An environmental group would very likely take legal action
against"EPA.
Recommendation:
We recommend that asbestos be judged a hazardous air pollutant
within the meaning of Section 112. EPA may be sued no matter which
option is selected because of the lack of quantitative data supporting
either position; however, the arguments and information that show
asbestos is hazardous are more defensible than those which would
clearly show it is not hazardous.
Issue 2;
To what extent must as'bestos be controlled to provide an ample
margin of safety? .
Discussion:
The decision on this issue must be based solely on judgment.
There are no quantitative data available which can be used to establish
the concentration of asbestos which will not endanger public health.
A good guideline for a decision is a conclusion by the National Academy
of Science in their 1971 report on asbestos which states:
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"Asbestos is too important in our technology and economy for its
essential use to be stopped. But because of the known serious
effects of uncontrolled inhalation of asbestos minerals in industry
and uncertanity as to the shape and character of the dose-response
curve in man, it would be highly imprudent to permit additional
contamination of the public environment with asbestos. Continued
use at minimal risk to the public requires that the major sources of
man-made asbestos emissions into the atmosphere be defined and controlled."
At this time very little information exists which accurately
defines the mass or number of fibers of asbestos emitted by sources
of asbestos. Some engineering estimates of the emissions have
been made on the basis of extremely limited data pertaining to
production rates, approximate collection efficiences of existing
control equipment, and operating conditions of stationary sources
which involve the use or manufacture of asbestos products. The
major source categories which emit asbestos are considered to be
mining, milling, manufacture and use of asbestos containing .products,
and demolition of buildings containing asbestos. Based on the asbestos
emissions from all stationary sources except demolition, it is estimated
that mining and milling contribute 85 percent, manufacture of
asbestos products 10 percent, and use of asbestos containing
products 5 percent. No estimate is available on demolition
emissions.
There are very limited data available which define the ambient
concentrations of asbestos to which the general public is exposed.
Until recently, there were no acceptable methods for measuring
asbestos in low concentrations as are found in ambient air. EPA
recently analyzed approximately 400 samples which were collected
1n urban and nonurban parts of the country. The results of these
samples ranged from 0.01 nanograms per cubic meter at a rural
background site to 110 nanograms per cubic meter at Dayton, Ohio.
These samples were analyzed using a recently developed method
which costs approximately $225 per sample to analyze. There are
no health effects data available related to this method.
In general, control technology exists for most source
categories of asbestos emissions. In the mining of asbestos,
control technology exists for drilling operations. Control
technology exists for most operations carried out in the milling
or basic processing of asbestos ores and from operations involving
the manufacture-of asbestos-containing products. The control
techniques most commonly applied is filters, scrubbers, and good
housekeeping practices. A control technique applicable to some
end uses of asbestos-containing products is the substitution of
another material for asbestos.
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Option A:
Require no control of asbestos emissions.
Pro: - •:.-.-
1. There would be no economic impact on industry.
• •:• Con: . •• •...• ... . .--•.••.•-. '-..-..•-• -*] . .;. ' •••
1. It would be very difficult to justify no control action
1f asbestos is considered hazardous.
2. An environmental group would very likely take legal action
against EPA. . .. -
Option B:
Require a reasonable degree of control on the basis of technical
and economic parameters. - :
Pro:
1. There would be a reduction in asbestos emissions,, which
*ioulxl have some benefit to public health. -
2. This would tend to satisfy both industrial and environmental
groups.
3. There would not be an extreme impact on the economy.
Con:
1. The Act does not explicitly provide for taking economic and
technical parameters into consideration under Section 112.
2. This level may not fully protect public health.
Option C: .
Require total control of asbestos emissions and ban its future
use.
Pro:
1. This would protect public health to the maximum extent
possible.
Con:
1. There are no health effects data to support such an extreme action.
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8 .-".". ~~. ~:v~" ;•".*". .T; ;:.:..""
2. Asbestos exists in the earth's crust and is present in
many products currently in use which will result in some
emissions.
3. Suitable substitutes for asbestos do not exist for many
of the uses of products such as brake bands, clutch flanges,
heat resistent protective clothing, and asbestos cement pipe.
4. Enforcing such a requirement would be a major problem.
Recommendation: - -
It is recommended that Option B be selected. Since some judgment
must be made as to what control is required to provide an ample margin
of safety to protect public health, a requirement based on reasonableness
could be supported more easily than either of the two extreme positions.
Issue 3:
How many categories of manufacturing sources should be covered
by the standard? . ;
Discussion:
This issue has surfaced repeatedly since the standard was
proposed. The OEGC has argued that the proposed standard applies
to a large number of insignificant sources and the wording of the
standard was vague and difficult to understand. They felt that
significant time and manpower would be devoted to enforcement actions
which would produce no significant health benefit.
1 The problem of defining the number of sources to be considered
1s the same as that discussed previously'under the issue on ample
margin of safety. The decision must be made on judgment alone.
As a result of the work done preparing the control technology document
for asbestos, some experience is available to make a judgement as
to which industries are "major" sources of asbestos emissions.
Revising the standard to include a list of manufacturing sources
covered by the standard rather than those exempted from the standard
will make the standard clearer and easier to understand. If
additional information comes available which indicates additional
sources should be covered, the standard could be revised.
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Option A:
Promulgate the standard to cover all manufacturing'ope'ratioihs
and exempt those known to have insignificant asbestos emissions.
Pro:
1. Those sources for which no information is available would
be covered. _ ..•••.-."..
2. Environmental groups would be more satisfied with this option.
'Con: ' . • ••- - .•'••'";.'.•'.'.'•'. •
1. The actual sources to be covered is vague.
2. Many insignificant sources would be covered.
3. Industry would not be as satisfied with thfs" option." ~'~
Option B: . .
Promulgate the standard to cover a specified list of - •- -
manufacturing sources known to have significant asbestos emissions. -
Pro: — ,
1. The standard is clear and easy to understand.
2. There is no question about which sources are covered.
3. The economic impact would be less. :
4. It seems to be consistent with the National Academy of
Sciences recommendation.
Con:
1. Some significant sources of asbestos may be emitted from
coverage. .
2. Some environmental groups will feel more sources should
be covered..
Recommendation:
Option B is recommended.
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Issue 4;
Should the standard incorporate a numerical emission limit?
Discussion:
It is not clear that the Act requires a standard to contain an
emission limit rather than an equipment specification. To develop
a sound numerical emission limit based on stack tests and good
control technology as is done with new source performance standards
would take two to three years; it would take this long to develop an
acceptable stack test method and sample the various sources of I
asbestos emissions. To develop a sound numerical emission limit
based on an ambient guideline, as was done with beryllium and mercury
could take twenty to thirty years; this is the lag time between
asbestos exposure and the resulting health effects. Any numerical
emission limit set at this time would be based on a guess as to what
ambient concentrations would be safe and the corresponding emissions
which would meet the guideline. It could not be supported by any
factual quantitative information and would make such a standard
extremely vulnerable to legal attack. Since there is no reliable
method to measure asbestos emissions at this time, it would not be
possible to determine compliance with a numerical limit.
The proposed standard contained several types of requirements:
no visible emissions; equipment specifications; and prohibition
of certain practices. Although the no visible emission requirement
1s not a numerical emission limit,"it is an emission limit and
should satisfy the intent of the Act. An approach to avoiding an
equipment specification is to require no visible emissions and
allow the use of the desired equipment as a means of complying. There
does not appear to be another approach to prohibiting certain practices
for certain sources.
The legislative package on the Clean Air Act for the next session
of Congress will include proposals to clarify the authority under
Section 112 to set equipment and good practice type standards and to
distinguish between classes and categories of sources. We interpret
the Act as already providing this authority; however, clarification
would be helpful.
Option A:
Promulgate a standard which specifies a numerical emission limit.
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Pro:
1. It would satisfy the requirements of the Act.
2. It would be consistent with the mercury and beryllium standards.
Con:
1. There are no data available to establish such a limit.
2. Without a sound basis, such a limit would be subject to
legal attack.
3. There is no reliable source test method at this time.
4. Without supporting data, it would not be possible to predict"
what control equipment would be necessary to comply.
Option B:
Promulgate a standard which includes provisions on visible
emissions and prohibition of certain practices. .
Pro: > .
1. The emissions would b? co?rtrol1»ti with technically feasible
technology.
2. _ There would be no question as to what is required to comply.
3. Enforcement would be simpler since no source test would be
required.
4. Indications are that industry accepts this approach.
1 Con:
1. The prohibition of certain practices does not meet the
requirements of the Act.
* .
Recommendation: '
Option B is recommended. , .
Issue 5;
Should the standard include provisions for demolition operations?
Discussion: ;
\
\ '
The propose^standard prohibited visible emissions of asbestos
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12 . • : . •.
-. * - -* —-.* — •—.-.-. _ *- _ .-»j —. .. „ . ^ -» —»._« _ ._..
particulate matter resulting from the repair or demolition of buildings
or structures. The EPA Office of Enforcement and the City of
Philadelphia commented on this standard and indicated, that
technology is not available to achieve the proposed standard. ----- ---•
After considering these comments, a tentative decision was made to
exclude any provisions on demolition from the standard. Draft copies
.of background documents were obtained by environmental groups.
Letters were received criticising this action from the Baltimore
County Health Department (November 6, 1972) and the Center for
Science in the Public Interest (November 9, 1972). Jack Anderson
recently published a column also criticising EPA for deleting
demolition provisions. •'•..; .
OAWP restudied the issue of demolition and examined other .
options besides the one proposed on visible emissions. These options
were evaluated with OEGC in regard to their effectiveness, and resources
required to enforce. State and local agency regulations on demolition
were also studied.
/ .
The limited number of State and local agency regulations in effect
require certain "standards of good practice" and do not include
emission limits. The regulations are generally enforced by the air
pollution control agency with cooperation from the building department
which is responsible for demolition in general. .....
It is estimated that the nu-bsr of iu 11 dings, derailIstied ir, the
U.S. per year ranges from 20,000 for buildings classified as >
commercial arid public or larger, to 137,000 for buildings classified
as residential or larger. Since this is a potential enforcement
problem, several enforcement options were considered. It could be
argued that every building demolished, is a new source and requires
the Administrator's approval before demolition can begin. To avoid
this problem, OAWP and OEGC agreed that these would be considered
existing sources; this allows the use of a registration rather than
a permit type system. Under the registration system, the person
responsible for the demolition would have to notify the Administrator
before beginning demolition but approval by the Administrator would
not be required. This would require a minimal amount of enforcement
resources.
* . • - •
Option A:
Promulgate a standard with no provisions on demolition.
- Proi™ . _'.^.;.'",.,./_';..„. .;.VX-.- .t'lir.!- .'.J...•.."„• '"._•''
1. No completely effective control method is available.
2. The provisions on spraying asbestos will eliminate new
buildings from being a problem in the future.
3. .No known cases of non-occupational effects from asbestos
have been related to demolition operations.
:\ : ' . •
:. v • :
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4. Significant EPA resources will be required to enforce a
standard requiring controls on demolition. .
5. No effective method for monitoring compliance is known.
Con:
1. Because an ample margin of safety cannot be quantitatively
defined for asbestos, it is risky not to regulate demolition.
2. Demolition is a problem in densely populated areas.
3. Buildings being demolished now contain large quantities of
asbestos for fireproofing and thermal insulation; therefore,
demolition may be a significant source of asbestos emissions.
Option B:
Promulgate a standard based on ambient'air quality'monitoring.""
Pro: :
1. Provides some margin of safety te protect public health
If the standard could be based on health effects data.
2. An .ambient standard is closer to an emission standard in
monitoring fugitive dust, as defined in Section 112 of the Act,
than specifying a code of practice in demolition.
Con:
1. Enforcement will be expensive because it will take at least
four monitoring devices to obtain an adequate sample for each
demolition site.
2. Establishing a safe ambient air quality level will be
difficult considering there are no data relating ambient air
levels of asbestos to effects on public health. If the standard
1s based on the best code of practice in demolition, there are
no data to indicate what the levels of asbestos would be.
3. Varying wind conditions will make it extremely difficult to
locate the .monitors to accurately measure background asbestos
concentrations and the asbestos concentrations resulting from a
building being demolished.
4. A violation of the standard will not be determined until
after the fact.
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Option C:
Include "standards of good practice" in the standard.
Pro:
1. Will result in reducing emissions to the greatest amount
practicable.
2. Enforceable with minimum amount of expense.
•*
3. Control practice regulations have been used by States for
control of fugitive dust from demolition. I
4. Control practice regulations appear to be a reasonable
approach to the problem.
Con:
1. Resources must be spent to familiarize personnel with the
good and bad practices of demolition.
2. May not provide ample margin of safety to protect public
health.
3. Must establish a permit or registration system to
effectively enforce the standard.
Recommendation:
Option C is recommended.
BERYLLIUM
The two major issues concerning the beryllium standard are: Is
beryllium hazardous within the meaning of Section 112: If so, to what
extent must beryllium emission be controlled to provide an ample margin
of safety for protection of public health:
Issue 1:
Is beryllium a hazardous air pollutant within the meaning of Section
112?
Discussion:
The health effects data which led to listing beryllium under Section
112(b)(l)(A) are briefly summarized herein.
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Beryllium and many of its compounds are among the most •• . . -
toxic and hazardous of the nonradioactive substances.in industrial
use. The proven effects of airborne beryllium materials on human
health include both acute and chronic lethal inhalation-effects,:
and skin and conjunctional effects.
The first beryllium disease to be recognized was an acute
Inflammatory reaction in the respiratory tract. Beryllium has
also been implicated as a cause of acute pneumonitis. The acute
form of beryllium disease has been observed, with a single reported
exception, only in persons with occupational beryllium exposures.
The chronic form of beryllium disease, which has been
observed in individuals who have never been employed in the
beryllium industry, has a long latency period which renders
difficult the establishment of dose-response relationships.
The Beryllium Registry - a record of all reported cases of
beryllium disease - now contains 822 cases. Of these Registry
cases, 64 resulted from exposure during machining operations
(37 from machining the pure metal, 27 from machining copper-- —
alloys whose maximum beryllium content was 4%). The chronic
disease has also been associated with foundry operations where
4% beryllium - copper (BeCu) alloy was melted and diluted to
2% BeCu alloy. Furthermore, there are 60»cases on file resulting.'
from non-occupational exposures: approximately half of 4^iese-.
-have been fatal. . . _ ". "
Beryllium 'induced cancers have been demonstrated in laboratory
animals (monkeys, rabbits, guinea pigs, hamsters, and rats).
Insufficient data are available to incriminate beryllium as a
human carcinogen, but there is no mechanism for the total elimination
of beryllium body burdens. The resulting potential for a long
residence time may entrance the opportunity for cancer induction
In humans. .
Statements presented at the public hearings and in written
comments did not challenge the conclusion that beryllium can in
specific circumstances be a hazardous air pollutant or that non-
occupational cases of beryllium disease have resulted from the
Inhalation of beryllium. It was argued, however, that non-
occupational beryl!iosis has to date been associated only with
emissions from beryllium extraction plants and that potential
emissions from numerous other beryllium emission sources have not
been shown to endanger the public health. Furthermore, it was
argued that since the AEC had once enforced an ambient beryllium
standard for extraction plants, it would not be necessary to
regulate beryllium emissions under Section 112.
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Option A:
Determine that the available data support the decision
that beryllium is a hazardous air pollutant.
Pro:
1. No one questions the conclusion that exposure to
quite low concentrations of beryllium is hazardous.
2. Although the AEC once regulated beryllium from
extraction plants, it no longer does so.
3. Comments on the proposed standards do not provide
a factual basis for a determination that beryllium is
clearly not a hazardous pollutant.
Con:
1. The data base on beryllium emission sources is not
sufficiently complete to define whether federal regulations
are necessary to protect the public health with an ample
margin of safety.
Option B:
Determine,that the available data clearly indicates that
beryllium is not a hazardous air pollutant.
Pro: > -
1. Even though there is no question that beryllium can be
a hazardous air pollutant, testimony presented at the
public hearings indicates that berylliosis has been eliminated
as a community disease.
Con:
1. Existing beryllium emission control practices are subject
to change, and Federal "regulations are needed to ensure that
berylliosis does not again become a community problem.
Recommendation:
• _ ,
Option A is the recommended action.
Issue 2:
What degree of control is necessary to provide an ample
margin of safety to protect the public health?
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Discussion:
The need for control of beryllium extraction pi ants -has been -
generally accepted before the AEC control program was initiated
in 1949. Other known sources of beryllium emissions include:
beryllium metal and beryllium alloy machine shops, beryllium alloy
foundries, beryllium ceramic manufacturing plants, combustion
of beryllium-containing propel! ants or wastes, and coal combustion.
Although coal contains 1 to 2 ppm beryllium, it is unlikely that
coal -fired power plants would generate beryllium emissions which
could endanger the public health.
In our judgment, the AEC ambient guideline of 0.01 ug/m for
a thirty-day average has proved itself adequate to protect public
health. This guideline is the basis for the emission limit of )
10 grams of beryllium per 24-hour period, which diffusion modelling
Indicates to be the emission rate sufficient to prevent concentrations
1n excess of 0.01 vg/nr. The diffusion model assumed ground-level
emissions vented from a single stack. Ground-level emissions are ------
characteristic of machine shops, foundries, and ceramic plants,
but not of extraction plants. Extraction plants with a history of
compliance with the AEC ambient guideline were allowed exemption
from the 10 gram per day emission limit ip favor of directly . -
monitored compliance with the ambient guideline. -Most -extraction ____
plants have already structured their facilities in .configurations
which disperse emissions, enabling them to meet the arabtent guide-
line but making it difficult if not impossible for them to meet the
10 gram per day emission limit.
In 1966, the Committee on Toxicology, National Academy of Sciences,
at the request of the Public Health Service, prepared a report on
"Air Quality Criteria for Beryllium and its Compounds." They concluded
that the 0.01 pg/m^ level has been effective in controlling chronic
beryllium disease. They also noted that the level may be overly
conservative. Examination of the ambient data around the extraction
plants indicates this may be true, because at least one extraction
plant has caused ambient concentrations above the 0.01 ug/nr level
without causing non-occupational cases of berylliosis. This would
Indicate that the 0.01 yg/m.3 level has an ample margin of safety.
The AEC ambient guideline provides sufficient protection against
chronic berylliosis. However, certain activities may generate
short-term beryllium concentrations which could cause acute
berylliosis. Thus, a short-term limit for combustion of beryllium-
containing wastes and for uncontrolled firing of beryllium
propellents was proposed. The short-term limit was not controversial
and very few comments were received concerning it.
-------
Option A:
Set a uniform long-term beryllium emission limit of-10. grams
per day, independent of the nature of the source category.
Pro:
1. The form of the resulting emission limit satisfies the
letter of Section 112 in specifying a single "national
emission standard which does not distinguish among types,
sizes, and classes of sources."
.2. The elimination of the ambient sampling option to all
sources removes potential questions of discrimination in
favor of the plants permitted this option and of the option
not directly representing an emission limit as required by ~
Section 112.
Con: . - .-^-:_--.--
1. Existing beryllium extraction plants can not, within the
framework of any reasonably acceptable economic penalty,
comply with the emission limit. > . . .....".
2. Although very largp uncontrolled coal-fired power plants
may emit more than 10 grams per day of beryllium, the emissions
are dispersed from tall stacks which prevents the ambient
guideline of 0.01 yg/nr from being violated.
Option B:
Exempt from the standard all sources of beryllium which, with
uncontrolled emissions, would not exceed the ambient guideline;
require all other sources to meet the 10 grams per day emission
limit.
Pro:
1. The advantages of .Option A are preserved.
2. Coal-fired power plants would be exempt from coverage
greatly reducing both enforcement burdens and opposition
to the standard.
Con:
1. Existing beryllium extraction plants would still be
required to go to a great deal of unnecessary expense.
Option C:
Exempt from the standard those uncontrolled beryllium sources
which would not cause the ambient guideline to be exceeded. In
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19
addition, exempt from the standard those existing sources which
have at least three years of data to demonstrate that they can
comply with the ambient guideline. Require all other sources
to meet the 10 grams per day emission limit.
Pro:
1. This type of standard would properly impact on only those
sources which are judged to be capable of endangering the
public health. Consequently, unnecessary source reports
and enforcement monitoring of sources which can not
reasonably be expected to exceed the ambient guideline
would be eliminated.
• .^. 2. The use of an ambient compliance option, under the
stated conditions, does not compromise protection of
.the public health.
Con; .
1. The ambient sampling option does not directly qualify as
an emission limit, which is the type of standard required
by Section 112. *
2. Allowing the ambient option even under the limited
conditions, may result in some criticism from environmental
' groups.
Option D:
Allow all sources to adopt the ambient sampling option, if
they so choose.
• Pro:
1. This option would eliminate any question of discrimination
1n the sources subject to the 10 grams per day emission limit.
2. This option would "permit every source, not just those
controlled under the AEC program, to choose between dispersion
of emissions and direct control of emissions to comply with
the standard. Since there is no known problem of beryllium
accumulation in the environment, dispersion would provide as
much protection as direct controls.
Con:
1. Disadvantage 1 under Option C would apply here.
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20
2. Unlike beryl!iurn sources which were controlled under
the AEC, other sources do not have a record of reliability
1n meeting ambient standards.
3. Although the limited number of sources which established
sampling networks under the AEC program would not create
enforcement problems, the numerous sources which probably
would elect to comply through sampling, networks would cause
problems. The adequacy and reliability of any ambient
sampling network are difficult to establish without
compromising protection of the public health.
4. This would be inconsistent with previous EPA policy of
not considering ambient sampling as an effective enforcement
tool.
Recommendation: '
Option C is the recommended action. ._....
MERCURY
More than with asbestos or beryllium, the issue of whether
mercury is hazardous has been controversial. Also the degree of
control required to provide an ample margin of safety has raised
controversy. -
Issue 1: -
Is mercury a hazardous pollutant within the meaning of
Section 112?
Discussion:
The most spectacular evidence of the hazards of mercury can
be found in the two epidemics of mercury poisoning in Japan.
Here, the problem was traced to mercury discharge into water,
where it was converted to methylmercury and concentrated in fish
and shellfish. While no one challenged the hazard of dietary
Intake of methylmercury, spokesmen for the chlor-alkali and
primary mercury industries disputed EPA's contention that mercury
Inhalation could be related to overall mercury intake.
Mercury occurs in the environment in the following forms:
elemental mercury, inorganic salts, and organic methylmercury.
Methylmercury is water-soluble; thus, it can appear in the
aquatic food chain, eventually reaching man. The path by
which elemental mercury emitted into the atmosphere is transformed
into methylr.ercury is poorly understood, but it is known that .
Inorganic mercury ions can be converted to methylmercury by
-------
certain microorganisms. Furthermore, the inhalation of mercury
vapor (elemental mercury) has been shown to cause serious effects
to the central nervous system, as does methylmercury ingestion.
Under these circumstances, the prodent assumption must be that
.mercury inhalation and methylmercury ingestion are additive in
their effects. Therefore, the hazards of mercury inhalation
must be considered in conjunction with likely levels of dietary
Intake of mercury.
Based on analysis of recorded cases of methylmercury poisoning,
4 yg/kg of body weight was determined to be the daily mercury intake
level at which symptoms began to occur in sensitive people. Applying
a safety factor of 10 yields a daily mercury intake of 0.4 yg/kg
of body weight, or 30 yg for a 70 kg human. Since the average
U. S. diet has been estimated to include 10-20 ug/day, mercury
Intake by inhalation must be limited to 20 yg/day.
The absorption efficiency of mercury vapor has been measured
at 75-85% at mercury concentration of 50-100 yg/m^. There are.
Indications that absorption efficiency increases as concentration
decreases. Thus, an assumption of 100% absorption efficiency at
low concentrations is reasonable and prudent. Since the average
daily intake of air is 20 cubic meters, mercury intake through
Inhalation can be limited to 20 yg only if the average ambient
mercury concentration is 1 yg/m^ or less. This ambient guideline
formed the basis for the proposed mercury standard,
To summarize, the listing of mercury as a hazardous air
pollutant was based on two effects. First, the contribution of
mercury inhalation to accumulation of mercury in the body requires
that ambient concentrations be limited to 1 yg/m^, assuming the
additivity of inhaled mercury vapor and ingested methylmercury.
Second, atmospheric emissions of mercury can, through methylation,
contribute to the buildup of methylmercury in the environment.
Industry spokesmen maintained that: (1) methylation of elemental
and inorganic mercury does not generally occur in the environment,
(2) the effects of mercury inhalation are not comparable with,
and certainly not additive to, the effects of methylmercury
Ingestion, and therefore (3) inhalation of mercury in concentrations
found in the ambient air is* not hazardous.
Option A:
Determine that the available data support the decision that
mercury is a hazardous air pollutant.
Pro:
1. Listing of mercury as a hazardous air pollutant is
consistent with EPA^s genera1 "policy uf control1ing mercury
in other media.
-------
JL2.
Con:
1. The available data do not clearly indicate that.mercury:
Inhalation is hazardous. Although mercury intoxication has
occurred as a result of occupational exposure to mercury
vapor, no case of mercury poisoning has been traced to
nonoccupational mercury inhalation.
2. The assumed additivity of inhaled and ingested methyl-
mercury remains questionable. .. . ... - • ;.
3. The extent to which other forms of mercury are converted
Into methylmercury in the environment remains unproved.
Option B: .. .
Determine that the available data clearly indicates that
mercury is not a hazardous air pollutant.
Pro: ......
1. This decision would avoid an otherwise likely
confrontation with the primary mercury and chlor-alkali
Industries. * ___
Con:
1. Although proof that mercury is a hazardous pollutant
1s far from conclusive, the available data are not sufficient
to prove that it clearly is not hazardous.
Recommendation:
Option A is the recommended action. Reasonable and prudent
assumptions, combined with the best data available to date,
justify treating mercury as a hazardous air pollutant.
Issue 2;
To what extent must mercury be controlled to provide an
ample margin of safety:
Discussion:
Although sources of atmospheric mercury emissions are numerous,
the major known sources are: mercury cell chlor-alkali plants,
primary mercury producers, nonferrous smelters, coal-firing power
plants, and perhaps incinerators. The mercury from power plants,
smelters, and incinerators ts -enfttted tn Itw-concentration, high-
-------
23
volume gas streams. Although these sources may emit quantities of \
mercury in excess of the emission limit, the dispersion from elevated i
stacks makes it unlikely that ambient concentrations in excess of 1 vg/m?
would occur. On the other hand, both mercury cell chlor-alkali plants
and primary mercury producers may cause such ambient concentrations,
because they emit mercury in high-concentration, low-volume gas
streams from low stacks or at ground level.
The proposed emission standard of 2300 grams per day for
primary extraction plants and chlor-alkali plants is based on
dispersion estimates for low-volume gas streams emitted at ground
level. Under the assumed conditions, it is the emission standard
which must be achieved in order to prevent ambient concentrations .
1n excess of 1 yg/m3. Control technologies, including vapor
condensing, chemical scrubbing, activated carbon adsorption,
molecular sieve adsorption, and new process configurations, are
available which will enable the affected sources to reduce their
mercury emissions to meet the standard.
Both affected industries have challenged the listing of
mercury as a hazardous air pollutant. Primary mercury producers
maintain that their emissions do not endanger the public health
and they should not be compelled to make any control investments.
In general, they are located in remote arfeas far away from populated
areas. However, having determined that atmospheric mercury is
hazardous in concentrations exceeding 1 vg/nv, EPA is compelled
to prevent the long-term occurrence of such concentrations in the
ambient air.
Option A: . '
Make the mercury standard applicable only to those source
categories which could cause the ambient guideline to be exceeded.
Pro:
1. The direct danger from mercury inhalation, even under
prudent EPA assumptions, is limited to concentrations in
excess of 1 vg/m3.
* - "
Con: .
1. Some smelters and power plants may actually emit greater
quantities -of mercury than some primary extraction plants;
which may close as a result of the 2300 gram/day emissiot
standard for mercury.
2. The relatively large quantities of mercury emitted b$
power plants and smelters may accelerate the accumulation of
mercury in some localized environments.
-------
Option B:
Extend coverage of NESHAPS to all significant sources of mercury.
Pro:
1. If implemented, this decision would have a much greater .
Impact on overall environmental accumulation of mercury than
Option A.
2. The superficial inequity of closing mercury extraction
plants while permitting larger emitters to continue without
controls would not occur.
Con:
1. Mercury emission control technology for smelters and
coal-fired power plants is not available. . '
2. The conversion of mercury emitted to the atmosphere into
harmful forms in the environment is poorly documented.
Recommendation: > .... ...."-.
Option A is the recommenHpd Action. On-gning efforts
are directed at defining the problem of mercury accumulation
1n the environment. As additional information becomes available
on other sources which should be controlled, the standard
will be revised.
GENERAL PROVISIONS
The primary purpose of the general provisions is to set
forth the enforcement aspects of the standards. OAWP and OEGC
have worked closely to develop provisions acceptable to both
offices. As a result of this mutual consultation, changes in
the proposed regulations are recommended. The two major issues
concerned are: (1) provisions for upset emissions and (2) provisions
for testing source compliance.
Issue 1: •
^^•^•^P^MMM^BBB ,
What should be included in the standards concerning upset
emissions?
Discussion:
Upset emissions are excessive emissions which occur as a
result of planned or unplanned reduction in effectiveness of
-------
25
control equipment. Planned reduction of control device
efficiency occurs during startup, shutdown and maintenance
operations. Unplanned reductions in control effectiveness
occur during malfunction of control or other process equipment.
In the originally proposed regulations, EPA did not attempt
to specify when and whether upset emissions would be excused
due to extenuating circumstances. EPA has adopted the same
approach in promulgating new source performance standards without
provisions for upset emissions. As a result of legal action
against EPA's new source performance standards, a formal basis
for determining when and whether upset emissions would be
construed to be violations of the standards was proposed on
August 25, 1972 (37 F.R. 17214). It is anticipated that these
regulations will be promulgated in the near future.
Option A:
Include no provisions or statements in the standards on-
upset emissions.
Pro:
>
1. This option gives maximum flexibility in dealing with
Con:
1. This option would be inconsistent with the action being
taken under new source performance standards.
2. There would probably be a legal action by industry on
the same grounds as the new source performance standards.
Option B:
Include no provisions in the standards on upset emissions
at this time, but add a statement to the Preamble that comparable
provisions to those for new source performance standards will be
promulgated later.
Pro:
1. These will be consistence with new source performance
standards.
2. EPA's intent to take some action should avoid legal
action.
-------
=26--
Con:
1. There will be a time lag between promulgation of the
standards and provisions for upset emissions.
Recommendation: , .
Option B is the recommended action. The provisions
for upset emissions which were proposed for new source performance
standards include a clause, all owing discretionary authority to
protect public health. Therefore, they would be adequate to
control upset emissions of hazardous air pollutants.
Issue 2:
Should sources covered by the standards be required-to- -•
conduct compliance testing on a routine basis?
Discussion:
> . . . • - .......
The proposed regulations for beryllium and mercury require
each sourcs tc tsst for cr-iccicrc every 90 days, or to obtain
a waiver of source testing from EPA. A waiver of source testing
can be obtained if the source is in compliance with the standard,
1f 1t is operating under a waiver of compliance, or if it has
applied for a waiver of compliance.
Ideally, the periodic source test requirements would provide
precise information for determining the status of compliance with
the standard. However, the continuing requirement to process
applications for waivers of source testing creates a significant
administrative burden for EPA. It seems reasonable that an initial
performance test should suffice as a certification that the source
1s 1n compliance with the standard. Without the periodic source
test requirement, EPA could still require source tests, under
Section 114 authority, for -those sources where compliance was in
question.
It 1s estimated that enforcing the beryllium and mercury
standards as first proposed would require approximately 27 man
years; 17 man years of these are necessary because of the source
testing requirement. The cost to industry to conduct each test
varies from $3000 to $5000.
Option A: -
Leave the periodic source testing requirement in the standards.
-------
Pro:
. 1. This option provides the most complete information,, on _ .
a continuous basis, on compliance status.
Con:
1. EPA's administrative burden remains heavy even after
all sources are certified to be in compliance. It is
highly questionable whether the benefits of processing
periodic applications for waiver of source testing are
anywhere near the costs.
2. The expense to industry will be high.
Option B:
Require only an initial performance test. Use Section 114
authority to require source testing whenever periodic EPA.inspection-
Indicates the need for a compliance test.
Pro: :
^ . _..•.."
1. This option eliminates the administrative manpower
necessary to review numerous applications for waivers "." "
of source testing.
2. Once~control equipment has been certified, inexpensive
EPA inspection can be used as the periodic compliance check.
3. The expense to industry will be minimized.
Con:
1. EPA will have to rely upon periodic inspections
for surveillance.
. 2. Inspections are not completely reliable as
compliance checks.
Recommendation: •
Option B is the recommended action. Although periodic
Inspections are -not completely reliable, even Option A permits
sources to apply for waiver of source test after compliance hss
been initially determined. Option B provides a significant
reduction of paperwork without a corresponding loss in enforcsnent
effectiveness.
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28
RESOURCE AND COST ANALYSIS
Asbestos
As recommended for promulgation, the standard for asbestos
would incur the following estimated administrative and economic costs:
1) Milling
2) 5 Major Manu. Sources
3) Assorted Smaller
Manu. Sources
a) Optimal Enforcement
b) Minimal Enforcement
4) Demolition
a) Optimal Enforcement
b) Minimal Enforcement
Number of
Sources
9
160
5,000
20,000
Enforcement
Manpower (M-Y)
0.3
3.4
62.0
8.0
2.6
0.6
Control Device
Costs ($106)
0.4
5.3
9.0
No Estimate
OE6C has identified two levels of enforcement effort - optimal and
minimal. Optimal enforcement is based upon completing a computerized
source inventory within one year, reviewing and answering all source
reports and waiver applications in great detail, and inspecting each
source once per year. Minimal enforcement is based upon completing
the source inventory within two years, reviewing and answering source
reports and waiver applications in moderate detail ("Great"'."Moderate"
8:1), and inspecting each source once every 10 years.
The regulations recommend for promulgation require fewer
administrative and economic resources than those originally proposed.
The proposed regulations covered an indeterminate number of additional
sources, as it was impossible to estimate the corresponding resources
required. •
Beryllium and Mercury:
OEGC has estimated that 11.26 man-years will be required to
enforce the beryllium and mercury standards. The basis for this
estimate appears in the following table.
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MANPOWER ESTIMATES TO ENFORCE BERYLLIUM AND MERCURY STANDARDS
(750 SOURCES)
.- .
. Manpower
Factor
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11."
Inventory Sources (750)
Process Source Registration (750)
New/Modified Source Approval
IX Growth (7.5)
Process Waiver of Compliance (562)
Process Waiver of Source Test (562)
Source Test Observation (750) x (25%)
Conduct scheduled Inspections (750 once/year)
Develop computer system for HAPEMS
Evaluation Source Test Report (750)
Evaluate AA monitoring method
(10/year) Rockets and extraction
Evaluate housekeeping practices Mercury
, (28/year) " .
Total
(.05
(.005
(.2
(.2
(.05
(.2
(.2
(.1
(.2
(.1
MW)
MW)
MW)
MW)
MW)
MW)
MW)
MW)
MW)
MW)
Total
Man Years
.72
.07
.03
2.16
.54
.75
2.9
2.5
1.5
.04
.05
11.26
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30
-The estimated required investment for mercury cell chlor-alkali
plants is $160,000 for a plant producing 100 ton/day. Because chlor-
al kali producers have the option of switching to the diaphragm cell
process* it is difficult to predict the total economic investment.
Some of the 30 mercury cell plants may be converted to the diaphragm
process. The annualized cost for controls amounts to $48,000, or
about 1% of sales.
The chlor-alkali industry appears healthy enough to absorb
control costs. The major impact of the standard probably will be
the replacement of some of the more marginal mercury cell plants by
diaphragm plants.
However, the U. S. mercury extraction industry is in a depressed
State. Because of the relatively low mercury content of the U. S.
ore, U. S. primary mines are high-cost producers compared to the
world industry. Mercury consumption has declined in recent years,
partially due to the impact on consumer industries of mercury effluent
limitations. The resulting drop in price has already reduced the
number of operating U. S. mines from 109 in 1969 to fewer than 10
1n October of 1972.
Although the control technology required by the standard is not
particularly costly, the few remaining primary extraction plants may
consider ™.cdest investments uneconomical. The approximately $105,000
of control investment required of a typical 100 ton per day facility
will amount to annualized costs of $32,000* or 10% of sales based on
the current depressed price of $255/flask. Many, if not all, producers
would probably shut down rather than comply with the standard.
RECOMMENDATION
It is recommended that the regulations be forwarded to the Office
of Management and Budget for Inter-Agency coordination.
Robert L. Sansom
• Assistant Administrator
for Air and Water Programs
Enclosures :
CONCURRENCES " .
AM, Carrol1 Concur Nonconcur iate
See Tab
AG, Quarles Concur Nonconcur Sate
See Tab
\
AR, Greenfield Concur Nonconcur ' iate_
See Tab
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Tab A
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS
Comparison of Provisions Proposed and Recommended for Promulgation
Provision
1) Waiver of Initial
Emission Test
Requirement
2) Requirement for
Periodic Emission
Testing
Proposed
F.R. Dec. 7, 1971
! Recommended
for Promulgation
GENERAL PROVISIONS
61.34, 61.55, 61.59
Required initial source
emission test from all
sources, with no provi-
sions for waiver.
61.34, 61.35, 61.55,
61.57, 61.59, 61.61
Required emission
tests every 90 days
but permitted sources
to apply for waiver of
requirement.
Permit sources to request
waiver of initial source
emission test, by satisfying
specified conditions.
No longer requires periodic
emission testing. Sources
not required to apply for
waivers. EPA can require
source emission tests, as
needed, via section 114
authority
Remarks
This change frees many small
sources from requirement to
make costly investment in
stack samples. It also
reduces EPA work load. The
change is justified because
proposed regulation required
many sources which are extremel
unlikely to violate the emissio
standard to make initial stack
tests.
The recommended change greatly
reduces enforcement manpower
requirements (for processing
waiver applications) without
diminishing EPA's authority to
require emission testing at
any time.
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ASBESTOS
Applicability to
Mining
Applicability
Fabricating
Operations
to
3) Applicability to
Manufacturing
Sources
4) Emission Standards
for Milling and
Manufacturing
Operations
61.20
Asbestos mines were
subject to proposed
standards.
61.20
Fabrication of asbestos
products was covered.
61.20
Any manufacturing source
which used asbestos was
covered.
61.22
Equipment specification
standards were proposed.
Recommended standards
do not apply to mining
operations.
Recommended standards do
not apply to fabricating
operations.
Recommended standards
apply to a specific list
of manufacturing operations,
The recommended standards
require no visible emissions,
with a provision for exemption
from the requirement by using
specified control equipment.
Major emission source in
mine vicinity is the asbestos
mill, which is still required
to control emissions. Bureau
of Mines and OSHA regulate
mining operations.
OSHA regulations require
emission controls for hand
and power tools used in
fabricating operations.
Fabricating operations are
very minor sources of asbestos,
The recommended standards
cover all known manufacturing
operations which may be major
sources of asbestos. Large
numbers of minor sources are
excluded from coverage,
reducing enforcement burden.
The large number of unexpected
emi ssion-generati ng operations
in mills and manufacturing
sources led to this change.
If all visible emissions can
be prevented by other methods,
specified control equipment
designed and intended for
major operations will not be
required.
-------
5) Demolition Standard
6) Standards for Spray
Application of
Asbestos Products
7) Control Equipment
Specifications
61.22(d)
Visible emissions from
demolition operations
were prohibited.
61.22 (e)
Spraying of any
asbestos product on
buildings or structures
or in the open was
prohibited.
61.23
The recommended standard
requires that good control
practice be followed during
demolition operations.
The recommended standard
limits the asbestos content
to less than 1% for materials
used on buildings and prohibits
visible emissions from other
specified operations.
The equipment specifications
were broadened to include
additional types of filter
material.
Technology to eliminate visible
emissions from demolition
operations is not available.
The recommended standards will
minimize asbestos emissions
without prohibiting demolition.
The recommended standard limits
the use of sprayed asbestos
materials without prohibiting
it.
This change was based on
information which became
available after the standard
was proposed.
-------
BERYLLIUM
Applicability
61.30
Applied to all machine
shops using beryllium
alloy.
The recommended standard
exempts machine shops
processing beryllium alloys
with less than 25% beryllium
content.
Machining beryllium alloys
of less than 25% beryllium
content is not likely to violate
the proposed emission standard.
Option for
Demonstration of
Compliance
by Ambient Sampling
61.32(b)
Any beryllium source
was permitted to
demonstrate compliance
by an approved air
sampling network,
showing that ambient
concentrations never
exceed .01 yg/nr for
a 30-day average.
The recommended standard
restricts the ambient
sampling option to those
sources which have already
operated sampling networks
for at least three years.
and can produce ambient data
to show that they can
meet the .01 yg/nr standard.
The change was needed to
make the NESHAP for beryllium
consistent with EPA policy on
outplant monitoring.
(See Briefing Memo)
-------
MERCURY
1) Option to Substitute
Good Control Practice
Standard for Emission
Test Requirement for
Mercury Cell Rooms
61.58(b)
Emissions from
mercury cell rooms
were subject to the
test requirement.
Mercury cell rooms in
which good housekeeping
practice is followed are
assumed to emit 1300
g/day; emission testing
is not required for such
cell rooms.
MISCELLANEOUS
Good housekeeping prac-
tices are the most
effective means for
controlling mercury
emissions from cell
rooms. The change
accomplishes the intent
of the regulations while
eliminating needless
expense.
There were minor changes made in order to clarify the regulations, or to reflect internal
EPA administrative changes (e.g. comments addressed to EPA Regional Offices rather than the
Division of Compliance). In the interest of brevity, these changes have not been enumerated
in this table.
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TITLE 40 - PROTECTION OF ENVIRONMENT
Chapter 1 - Environmental Protection Agency
Subchapter C - Air Programs
Part 61 - National Emission Standards for Hazardous Air Pollutants
On March 31, 1971 (36 F.R. 5931), pursuant to Section
112 of the Clean Air Act, as amended, the Administrator published
an initial list of three hazardous-air pollutants which in his
judgment may cause, or contribute to, an increase in mortality
or an increase in serious irreversible, or incapacitating reversible,
illness. The pollutants were asbestos, beryllium and mercury.
On December 7, 1971 (36 F.R. 23239), the Administrator proposed
standards for these pollutants.
Interested persons were afforded an opportunity to participate
in the rulemaking by submitting written comments or presenting
testimony at public hearings on the standards. Public hearings
were held in New York, N. Y. on January 18, 1972 and Los Angeles,
California on February 15 and 16, 1972. A hearing was scheduled
for Kansas City, Missouri on February 1, 1972, but was cancelled
as a result of a lack of requests to participate. Testimony was
given by 53 persons, and written comments were submitted by 49
persons, representing industry; Federal, State and local governmental
agencies; universities; and groups interested in the preservation
of the environment. The public hearing records are available for
inspection at each EPA Regional Office. The basis of the
Administrator's determination that asbestos, beryllium and mercury
-------
are hazardous, the derivation of the standards now adopted, the
Environmental Protection Agency's responses to the significant
comments received, and the principal revisions to the proposed
standards are summarized below.
A more detailed statement is available on request from the
Standards Development and Implementation Division, Environmental
Protection Agency, Research Triangle Park, North Carolina 27711,
Attention: Mr. Don Goodwin^
-------
ASBESTOS
Asbestos is a hazardous air pollutant within the meaning
of Section 112. Many persons exposed to asbestos dust have
developed asbestosis when the dust concentration was high or the
duration of exposure was long. A large number of studies has
shown that there is an association,between occupational exposure
to asbestos and a higher-than-expected incidence of bronchogenic
cancer. Asbestos also has been identified as an etiologic factor
in mesothelial malignancies; there are reports of mesothelioma
associated with non-occupational exposures in the neighborhood of
asbestos sources. An outstanding feature has been the long period,
commonly over 30 years, between the first exposure to asbestos
and the appearance of a tumor. There is evidence which indicates
that mesothelioma occurs at lower concentrations of asbestos than
the concentrations at which asbestosis occurs.
The principal compilations and evaluations of scientific
data relied upon by the Administrator in making his judgement
that asbestos is a hazardous air pollutant are:
1. National Academy of Sciences: Asbestos (The Need for
and Feasibility of Air Pollution Controls). Washington,
National Academy of Sciences, 1971, 40 pp.
2. National Institute for Occupational Safety and Health:
Occupational Exposure to Asbestos (Criteria for a
Recommended Standard). 'Washington,' U. S. Department
of Health, Education, and Welfare (PHS, HSMHA), 1972
(HSM 72-10267).
3. Selikoff, Irving J., William J. Nicholson, and Arthur M.
Langer, Asbestos Air Pollution. Arch. Environ. Health,
25 (1), 1-13, 1972.
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Two problems which have made developing a standard for
asbestos difficult are: (1) there are no quantitative data available
which can be used to establish the concentration of asbestos which
will not endanger public health, and (2) satisfactory methods for
measuring asbestos concentrations have just recently been developed.
Accordingly, it is necessary to evaluate the health risks from
asbestos exposure in terms of the nature of the source of exposure
rather than the quantitative^levels of exposure and it is also
necessary that the standards for asbestos exposure be established
on the same basis.
There is evidence to suggest a gradient of effect from
direct occupational, to indirect occupational exposure, to
families~of workers exposed to asbestos and persons in the
neighborhood of asbestos sources - in all of which situations
asbestos concentrations are undoubtedly high by comparison
with most community air. This suggests that there are levels
of asbestos exposure that will not be associated with any
detectable risk, although these levels are not known.
It is probable that the effects of asbestos inhalation are
cumulative; that is, low-level and/or intermittent exposure to asbestos
over a long time may be equally as important in the etiology
of asbestotic disease as high-level and/or continuous exposure over a
shorter period. On the other hand, the available evidence does not
indicate that levels of asbestos in most community air cause.asbestotic
disease. Taking both these considerations into account, the
Administrator has determined that, in order to provide an ample
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margin of safety to protect the public health |from asbestos, it
is necessary to control emissions from major sources of man-made
asbestos emissions into the atmosphere, but that it is not
necessary to prohibit all emissions.
The asbestos standard'promulgated below applies to asbestos
mills, selected manufacturing operations, the use of spray-on
asbestos materials, demolition operations, and the surfacing of .
roadways with asbestos tailings. As a result of the Administrator's
consideration of comments on the proposed asbestos standard and
of additional technical data, the standard promulgated below
differs from the proposed standard. The ways in which they
differ and the reasons why are presented in the following paragraphs.
As applied to mines, the proposed standard limited the emissions
from drilling operations, prohibited visible emissions of particulate
matter from mir* roads surfaced with asbestos tailings, and prohibited
the surfacing of any road with asbestos tailings. It was found that
regulations issued by the Bureau of Mines and by the Occupational
Safety and Health Administration deal with the control of emissions
from mining operations. Accordingly, the promulgated standard
is applicable to asbestos mines only in that the surfacing of
roadways with asbestos tailings at all locations other than the
ore areas of mining operations is prohibited.
For asbestos mills, the proposed standard applied to ore
dumps, open storage areas for asbestos-containing materials,
tailings dumps, ore dryers, air for processing ore, air for
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exhausting participate material from work areas, and any milling
operation which continuously generates visible emissions. The
promulgated standard prohibits visible emissions from any part of
the mill, but it does not apply to dumps or open storage areas.
Emissions from the dumps and storage areas are very small compared
with those from the mills. It is .the Administrator's judgment,
based in part on the testimony of medical experts and on studies
conducted in the vicinity of a mine-mill complex, that the
promulgated standard will protect the public health.
The proposed standard dealt with emissions to 'the atmosphere
from any manufacturing or fabricating operation which continuously
generates visible emissions, which results in forced gas streams
vented to the atmosphere, or which is conducted outside enclosures.
Comments received on the proposed standard indicated that considerable
confusion was created by the use of terms such as "any," "continuously,"
and "forced gas streams." The promulgated standard is more definitive
as to applicability of the provisions and does not require control of
minor sources. The promulgated standard prohibits visible emissions
from the manufacturing operations considered to be major sources
of asbestos emissions. The promulgated standard does not cover
fabricating operations because these operations are considered
minor sources of asbestos emissions. Too, the Occupational
Safety and Health Administration regulates emissions from the use
of hand-operated and power-operated tools, the source of most
emissions in fabricating operations.
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The proposed standard prohibited visible emissions of asbestos
participate material from the repair or demolition of any building
or structure other than a single-family dwelling. Comments
indicated that this would prohibit repair or demolition in many
situations, since'it would be impracticable, if not impossible, to
do such work without creating visible emissions. The proposed
standard applied to numerous small operations which would have
caused a massive administrative workload not justified by the
situation. The promulgated standard requires that major demolition
operations involving buildings or structures containing asbestos
material be reported to the Administrator, and the standard specifies
work practices that must be used to protect the public from emissions
of particulate asbestos material.
The proposed standard limited emissions from a number of
sources by the stipulation that such emissions could not exceed
the amounts which would be emitted from the source if the source
were equipped with a fabric filter or, in some cases, a wet-collection
air-cleaning device. This would have required each affected source j
to install air-cleaning equipment and measure the subsequent
t
emissions in order to determine allowable emissions. This approach
would have been impracticable for sources from which there were
already no visible emissions and would have required a standardized
emission-measuring technique, which is not currently available.
The promulgated standard prohibits visible emissions and provides
the option of using specified air-cleaning methods. The no-
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visible-emission standard promulgated requires, for enforcement,
only that emissions be visible and that it be shown that they
contain particulate asbestos material. The existence of particulate
asbestos material in a sample can be easily determined using either
optical or electron microscopy techniques. The proposed standard
stated that this air-cleaning requirement would not be met if
a number of listed faults, e.g., broken bags, leaking gases, thread-
bare bags, existed and required that collection hoppers on some bag
houses be emptied without generating visible emissions.
Comments received suggested that this negative approach
tended to make the required quality of air-cleaning operations
dependent upon the ability to include all the factors which would
constitute improper methods. Since the intent was, and is, to
require high quality air-cleaning operations, the promulgated
standard requires proper installation, use, operation, and maintenance.
The proposed standards prohibited the spraying of any product
containing asbestos on any portion of a building or structure,
prohibited the spraying of any product containing asbestos in an
area directly open to the atmosphere, and limited emissions from
all other spraying of any product containing asbestos to the
amount which would be emitted if specified air-cleaning equipment
were used. Comments received pointed out that this standard would
(1) prohibit the use of useful materials containing only the trace
amounts of asbestos which occur in numerous natural substances,
(2) prohibit the use of materials to which very small quantities of
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asbestos are added in order to entrance their;essential properties,
and (3) prohibit the use of materials in which the asbestos is
strongly bound and which would not generate particulate asbestos
materials. The promulgated standard applies to those uses of
spray-on asbestos materials which could generate major emissions of
particulate asbestos material. A no-visible-emission standard
applies to the use of spray-on materials containing one percent
or more asbestos, on a dry-weight-basis, in specified situations.
For those spray-on materials used to insulate or fireproof buildings,
structures, pipes, and conduits, the standard limits the asbestos
content to less than one percent. Although standard methods are not
available to quantitatively determine the content of asbestos in a
material, there are acceptable methods available, based on electron
microscopy, which independent laboratories have developed. Analysis
with these methods costs approximately $40 per sample and the results
are accurate within plus or minus fifty percent.
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BERYLLIUM
i
Beryllium is a hazardous air pollutant within the meaning
of Section 112. The proven effects of airborne beryllium-materials
on human health include both acute and chronic lethal inhalation
effects, as well as skin and conjunctiva! effects. Insufficient
data are available to incriminate beryllium as a human carcinogen, but
the lack of any mechanism for the total elimination of beryllium
/
body burdens, and the resulting possibly long residence time may
enhance the opportunity for cancer induction. The principal
compilations and evaluations of scientific data relied upon by
the Administrator in making his judgment that beryllium is a
hazardous air pollutant are:
1. ^National Academy of Sciences: Air Quality Criteria
for Beryllium and Its Compounds. Washington, National
Academy of Sciences, March 1, 1966, 13 pp.
2. National Institute for Occupational Safety and Health:
Occupational Exposure to Beryllium (Criteria for a_
Recommended Standard). Washington, U.S. Department of
Health, Education, and Welfare (PHS, HSMHA), 1972
(HSM 72-10268).
3. Massachusetts General Hospital, The Beryllium Case Registry.
The Beryllium Registry now contains over 820 proven cases of
beryllium-related disease, but since many of these were most likely
due to exposure prior to the institution of controls, proper
assessment of the period of exposure is not always possible; it is
known, however, that chronic beryllium disease is associated not
only with activities involving extraction processes, but also
that 64 Registry cases resulted from exposure during machining
operations on beryllium materials. There are over 60 cases of non-
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occupationally-incurred disease on file withithe Registry,
of which approximately half have, been fatal, and retrospective
studies of the concentrations of beryllium that resulted in some
cases of chronic beryllium disease from non-occupational exposure
have concluded that the lowest concentration which produced
disease was greater than 0.01 micrograms per cubic meter and
probably less than 0.10 micrograms per cubic meter. I
The only emission control maintained by beryllium industries
exercised today is self-imposed, as a carryover from the period,
beginning in 1949, when such controls were required by the U. S.
Atomic Energy Commission (AEC) to meet its guideline limit for
beryllium concentrations in community air (0.01 micrograms of
beryllium per cubic meter air at breathing height - 30-day average),
The requirements for such controls are no longer included in AEC
contractual agreements.
In the period since the implementation of the AEC guideline,
no reported cases of chronic beryllium disease have occurred as
a result of community exposure, and the Committee on Toxicology of
the National Academy of Sciences concluded that the AEC guideline
limit represents a safe level of exposure.
Accordingly, the Administrator has determined that in order
to provide an ample margin of safety to protect the public health
from beryllium, sources of beryllium dust, fume, or mist emissions
into the atmosphere should be controlled to insure that ambient
concentrations of beryllium.do not exceed 0.01 micrograms per cubic
meter - 30-day average. :
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The beryllium standard covers extraction plants, foundries,
ceramic manufacturing plants, machine shops (processing beryllium
or beryllium alloys containing in excess of 25% beryllium) and
disposal of beryllium-containing wastes. Most affected beryllium
sources are limited to emissions of not more than 10 grams of
beryllium per day. The emission limit of 10 grams per day was
determined through dispersion estimates as the level which would
protect against the occurrence of 30-day average ambient concentrations
exceeding 0.01 microgram per cubic meter. The assumptions and
equations used to make the dispersion estimates are given in the
Background Information Report for Asbestos, Beryllium, and Mercury
(APTD-0753), published at the time the standards were proposed.
Rocket testing facilities are required to meet the limit of
75 microgram minutes per cubic meter, accumulated during any period
of two consecutive weeks. The limit for rocket testing facilities
is the same as that developed in 1966 by the National Academy of
Science's National Research Council for protection of off-site
personnel from intermittent exposures to beryllium compounds
arising from the firing of rocket motors.
The scope of the beryllium standard has been changed
to include a ban on open burning of beryllium-containing waste.
This change was made because information received after proposal
indicated that such sources can cause ambient concentrations of
beryllium in excess of 0.01 micrograms per cubic meter and because
it is not possible to control the emissions from open burning. The
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standard does allow disposal of beryllium-containing waste in
incinerators which are controlled so as not to exceed the 10 gram
per day limit. The disposal of beryllium-containing explosive waste
is included in the standard covering rocket testing.
Due to data obtained by the Environmental Protection Agency
after the proposal of the standard, the scope of the standard
was changed to eliminate coverage of machine shops processing \
beryllium or beryllium alloys containing less than 25% beryllium.
Source tests conducted by the Environmental Protection Agency at
several such facilities indicated that these facilities would not
exceed the standard of 10 grams per day even without control devices.
A few existing facilities, which were designed to comply with
the Atomic Energy Commission control program based on ambient air
measurements, may continue to demonstrate compliance through ambient
air measurements. The proposed standard would have allowed all
sources of beryllium to choose between meeting the 10 gram per day
emission limit and complying by use of ambient monitoring to insure
that the 0.01 microgram per cubic meter 30-day average is never
exceeded. The standard being promulgated below allows this option
only to existing sources which have three years of current ambient
air quality data which demonstrate to the Administrator's
satisfaction that the 0.01 microgram per cubic meter level is being
met in the vicinity of the source. Because of the difficulty inherent
in using ambient air quality data, as opposed to emission data, as a
regulatory tool, the option of using ambient levels to demonstrate
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compliance is limited to those sources which'have demonstrated
over a reasonable past period that they can and have met the
ambient limitation.
The inclusion of this provision in the beryllium standard
does not represent an endorsement by the Environmental Protection
Agency of general use of ambient monitoring as a regulatory technique.
The circumstances involved in this .situation are unique and justify
allowing ambient monitoring^ The existing sources which could
qualify for this option are four beryllium extraction plants and,
possibly, a small number of machine shops. These sources were
designed or modified to facilitate compliance with the 0.01 microgram
per cubic meter ambient limit by use of tall stacks and a large
number of emission release points spread over extended areas to
insure effective atmospheric dispersion of emissions.
No known non-occupational cases of chronic beryllium disease
have been identified in the vicinity of these sources since the
0.01 microgram per cubic meter ambient levels have been met.
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MERCURY
Mercury is a hazardous'air pollutant within the meaning
of Section 112. Exposure to metallic mercury vapors may cause
central nervous system injury, and renal damage. Experience
with mercury vapor comes exclusively from animal experiments
and industrial exposures. Animal (rat) data indicate a risk
of accumulation in critical systems-upon prolonged exposure,
with a potential-,- for example", for selective brain damage.
Prolonged exposure in an industrial environment to about 100
micrograms mercury per cubic meter of air involves a definite
risk of mercury intoxication.
To determine the ambient air level of mercury that does
not impair health, the airborne burden must be considered
together with the water- and food-borne burdens. An expert
group concluded, based on its analysis of some episodes of
mercury poisoning in Japan that 4 micrograms of methylmercury
per kilogram of bodyweight per day would result in the intoxica-
tion of a sensitive adult; application of a safety factor of 10
yielded an acceptable exposure of about 30 micrograms per day
for a 70 kilogram man, and this level is also believed to
provide satisfactory protection against genetic lesions, and
poisoning of the fetus and of children.
The principal compilations and evaluations of scientific
data relied upon by the Administrator in making his judgment
that mercury is a hazardous air pollutant are:
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1. Clarkson, T. W.: Annual Review of Pharmacology. 12,
375-406, 1972. <
2. Transcript of the March 22-23, 1972 Hearing on the
Wisconsin Proposal of an Emission Standard for the
Discharge of Mercury to the Atmosphere.
3. Friberg, L., and J. Vostal, Mercury in^the Environ-
ment - a lexicological and Epidemioloqical Appraisal.
Research Triangle Park, N.C., U.S. Environmental
Protection Agency, 1971. j
4. Nelson, N., et al., Environmental Research, 4 (1),
1-69, 1971. - ""
5. 'U.S. Geological Survey: Mercury in the Environment.
Washington, U. S. Government Printing Office, 1970
(Geol. Survey Prof. Paper 713), 67 pp.
6. Wallace, R. A., et al.: Mercury in the Environment -
The Human Element. Oak Ridge, Tenn., Oak Ridge
National Laboratory, 1971 (ORNL-NSF-EP-1.)
7. Maximum Allowable Concentrations of Mercury Compounds,
Arch. Environ. Health, 19/891-905, 1969.
8. Smith, R. G., A. J. Vorwald, L. S. Patil, and T. F.
Mooney, Jr., Am. Indust. Hyg. Assoc. J., 31 (6),
687-700, 1970. "~
9. Druckrey, H., H. Hamperl, and D. Schmahl, Zeitschrift
fur Krebsforschung, 6J_, 511-519, 1957: Translated for
APTIC from the German by Leo Kanner Associates,
July 1972.
It should be noted that methylmercury is considered to be
by far the most hazardous mercury compound, particularly via
the ingestion of fish in which it has been concentrated through
the food chain. The Environmental Protection Agency, in view
of the present limited knowledge as to the effects of inhaled mercury in
the general population, and in order to best assure the requisite
"ample margin of safety to protect the public health",
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considers exposures to methylmercury (diet) and mercury vapor
(air) to be equivalent and additive. It has been estimated that
from average diets, over a considerable period, mercury intakes
of 10-20 micrograms per day may be expected, so that, in order
to restrict total intake to 30 micrograms per day, the average
mercury intake from air would have to be limited to 10-20
micrograms per day. Assuming inhalation of 20 cubic meters of
air per day, the air could contain an average daily concentration
of no more than 1.0 microgram of mercury per cubic meter.
The standard promulgated herein regulates the only two sources,
mercury ore processing facilities «nd mercury cell chlor-alkali
plants, which have been found to emit mercury in a manner that
could cause the ambient concentration to exceed the inhalation
effects limits of 1.0 microgram per cubic meter.
The standard limits emissions from these facilities to not
more than 2300 grams per day. The emission limit of 2300 grams
per day was derived from dispersion estimates as the level which
would protect against the violation of an average daily ambient
concentration of 1.0 microgram per cubic meter. The assumptions
and equations used to make the dispersion estimates are given
in the Background Information Report for Asbestos, Beryllium,
and Mercury (APTD-0753), published at the time the standards
were proposed.
Many mercury cell chlor-alkali plant cell rooms present
severe source testing problems due to their design and construc-
tion. Such sources may either reconstruct the cell room so that
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accurate source tests can be made or employ housekeeping and
maintenance practices that minimize mercury emissions from
the cell room. Source test data and calculations indicate
that when such practices are used, 1300 grams per day is a
reasonable estimate of emissions from the cell room. There-
fore, when this option is chosen, an emission of 1300 grams
per day will be assigned to the cell room. This permits
emissions of not more than 1000 grams per day from the hydrogen
and end box ventilation streams combined.
Compliance with the standard will be determined by the
EPA reference method or EPA-approved substitute methods. Where
a chlor-alkali plant chooses the housekeeping and maintenance
practices option, determination of compliance of the cell room
emission will be based on the use of EPA-approved practices.
The only major change in the mercury standard is the
introduction of the above option of assigning an emission
number to the cell room provided certain housekeeping and
maintenance requirements are met. When this option is chosen,
testing is not required for emissions from the cell room. This
option is offered because comments, testimony, and EPA source
testing experience indicated that most existing cell rooms
cannot be accurately tested for mercury emissions. Accurate
emission tests are unduly complicated and costly because of the
cell room configuration.
Some of the changes suggested in written comments and public
hearing testimony were considered by EPA but not made. The most
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significant one involved the environmental chemistry of mercury,
JT
that is, environmental mercury in the atmosphere is transformed
to mercuric oxide by the action of ultra-violet radiation, and
since mercuric oxide is not as toxic as elemental mercury, the
standard should be less stringent. This argument is based on
laboratory experiments under controlled conditions with
generated radiation. The reaction cited in the testimony occurs
when elemental mercury is irradiated with ultra-violet light
with a wavelength of 2537 angstrom (A). Naturally occurring
ozone in the upper atmosphere absorbs light in the ultra-violet
region below 3000 A; hence the wavelength of ultraviolet
necessary for the reaction is absent in the ambient atmosphere,
and the reaction does not proceed at as high a rate as
implied by the submitted testimony. Recent field measurements
of both mercury vapors and particulate mercury in ambient air
indicate that more than 96% of the mercury detected was in
elemental vapor form (Data collected by EPA at the Federal
Building in Moundsvilie, West Virginia).
The Environmental Protection Agency recognizes that mercury
and its compounds constitute a multimedia contamination problem,
i.e., strong evidence exists that all man-made uses of mercury alter
its natural distribution in the environment; that such uses may
cause or hasten additional deposits into water over and above those
occurring naturally, thereby building up aquatic concentrations;
and that mercury levels accumulate in the aquatic biota, with the
result that potentially dangerous residue levels are reached in
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aquatic foods consumed by man and animals. The Administrator has
determined, for example, that those uses of mercury products that
promise immediate contact with the aquatic environment create "an
imminent hazard in the environment." He therefore suspended
registration of such products on March 22, 1972, at which time he
also cancelled registration of all other mercury pesticide products
on the ground that there was a "substantial question of safety"
as to whether or not these uses, even in accordance with label
directions, were not injurious to man and other living animals.
It has been argued that man-made industrial mercury emissions
Into the atmosphere are small compared to crustal emissions. This
argument is based in part on the mercury content of preserved fish
flesh and glacier ice samples. However, available data are sparse and
inconclusive as to whether industrial emissions of mercury into the
atmosphere contribute significantly to environmental buildup in
other than the vicinity of such sources. Accordingly, the standard
promulgated herein is intended primarily to protect the public health
from the inhalation effects of mercury.
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ENFORCEMENT OF STANDARDS
The standards promulgated below are applicable to new,
modified, and existing sources. Any new or modified source
must comply with the standards upon beginning operation. Any
existing source must comply with the standards within 90 days
after promulgation, unless a waiver of compliance is granted.
«e
After considering the proposed general provisions and the
comments received on them, the Administrator made several changes
which are included in the standards promulgated below. A new
section was added to specifically require stationary sources to
notify the Administrator before beginning operation. The require-
ments for source reporting and request for waiver of compliance were
combined into one section. The time for submitting the source
report was extended from 30 to 90 days to be compatible with the
time required for a waiver of compliance request. This allows a
source to submit all information at one time. Appendix A was
added to provide sources a description and format of the information
required.
The proposed standards required all sources of mercury and
beryllium to test their emissions within three months of the
effective date and at least once every three months thereafter; a
provision was included to allow the Administrator to waive the
periodic tests for sources in compliance with a standard. The
standards promulgated below require the initial test within 90
days of the effective date and include a provision to allow the
Administrator to waive this requirement if the source is meeting
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the standard or has requested a waiver of compliance. The
Administrator may cancel a waiver of emission tests and require
a test under the authority of Section 114 of the Act at any time.
Appendix A specifies the information which a source must provide
the Administrator when applying for a waiver of emission tests.
These changes were made because comments indicated that the costs
«*
to sources to perform periodic tests were excessive and the
Administrator can require a test at any time.
The standards promulgated below do not require the owner
or operator to request a waiver before a specific date. However,
the owner or operator should submit the request within 30 days
after the effective date of the regulation to be assured that action
will be taken on the waiver application prior to the 90th day after
the effective date. Continued operation in violation of a standard
after the 90th day without a waiver is a violation of the Act.
The Administrator may grant an existing source a waiver,
permitting a period of up to two years for compliance, provided
that steps will be taken during the waiver period to assure
that the health of persons will be protected from imminent
endangerment. To be granted a waiver of compliance, a source
must submit a written request to the Administrator and provide
certain information to assist the Administrator in making a
judgment. Within 60 days after receiving a request, the
Administrator will notify the owner or operator of approval or
intention to deny the waiver. Any waiver of compliance granted
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by the Administrator will be in writing and specify conditions
the source must meet during the waiver period. If the
Administrator intends to deny a request, the owner or operator
will be given a specified time to provide additional information
or arguments prior to final action on the request. Final action
on a request will be in writing by the Administrator, and if
•T
denied, will include reasons for denial.
The President may exempt any new, modified or existing
stationary source from compliance with the standards for a
period of up to two years, provided the technology is not available
to implement the standards and the operation of such source is
required for reasons of national security. Also, the President may
grant exemptions for additional periods of two years or less.
The construction of a new source or modification of an existing
source covered by these standards cannot begin without approval
of the Administrator. To obtain approval, the owner or operator
of such sources must apply in writing to the Administrator. Within
60 days, the Administrator will notify the owner or operator of
approval or intention to deny approval. If the Administrator
intends to deny approval, a specified time will be given to provide
additional information or arguments prior to final action on the
application. The final action..on any application will be in
writing by the Administrator, and if denied, will include the
reasons for denial.
Each source covered by these standards is required to submit
to the Administrator within 90 days after promulgation certain
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Information pertaining to its operation. Changes in the information',
must be submitted within 30 days after the change, except where
the change is considered a modification. Then the requirements
for a modified source are applicable.
Emission tests must be conducted on all beryllium and mercury
sources covered by these standards by the owners or operators
within 90 days after promulgation. Sources of beryllium and
mercury emissions may receive waivers of the source testing
requirement upon application where the source can demonstrate to
the Administrator's satisfaction that the standards are being met.
Three terms are associated with determining compliance by
means of source testing: (1) reference method, (2) equivalent
method, and (3) alternative method. Reference methods are the
s
preferred methods of sampling and analyzing used to determine
compliance. The reference methods for beryllium and mercury are
Included in appendix B to this part. An equivalent method is
any method of sampling and analyzing which has been demonstrated to
the Administrator's satisfaction to have a consistent and
quantitatively known relationship to the reference method under
specified conditions. An alternative method is any method of
sampling and analyzing which does not meet all the criteria for
equivalency but which can be used in specific cases to determine
compliance. Alternative methods may be approved by the Administrator
for source testing; however, in cases where determinations of
compliance using an alternative method are disputed, use of the
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reference method or its equivalent will be required by the
Administrator. An approved alternative method for beryllium is
included in appendix B to this Part.
All emission data provided to or obtained by the Administrator
in carrying out these regulations will be available to the public.
Records, reports or information other than trade secrets will be
available to the public. __
Pursuant to Section 112(d)(l) of the Act, the Environmental
Protection Agency intends to delegate the authority to implement
and enforce national emission standards for hazardous air
pollutants to any State which submits an adequate procedure to
the appropriate Regional Administrator. The requisite procedure
for requesting such delegation will be issued in the future by the
Environmental Protection Agency. Responsibility for granting
waivers of compliance and exclusions shall rest with the Environ-
mental Protection Agency rather than being delegated to the States.
The standards promulgated herein contain no explicit provi-
sion to deal with incidents where, despite proper operating and
maintenance practices, unavoidable emissions in excess of the
standards occur. Such incidents include certain process startups
and shutdowns and infrequent mechanical failures which could not
have been anticipated and avoided. Occurrences of this type are
generally dealt with by the exercise of discretion in the Agency's
enforcement activities. However, on August 25, 1972 (37 F.R. 17214),
the Administrator proposed a formal process for dealing with
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Incidents of excess emissions during startup, shutdown and mal-
function of facilities subject to Standards of Performance for
New Stationary Sources. Substantial comment has been received
on that proposed rule making and, on October 13, 1972 the time for
comments was extended until November 24, 1972 (37 F.R. 21653). It
is intended to amend the standards promulgated herein to provide
for those same procedures when they are promulgated for the
Standards of Performance for New Stationary Sources.
The Administrator is issuing information on control
techniques for asbestos, beryllium, and mercury as directed by
Section 112(b)(2) of the Act. Copies of these documents may
be obtained free of charge from EPA Regional Offices.
The regulations for the national emission standards for
asbestos, beryllium, and mercury are hereby promulgated effective
upon promulgation ( ).
Date William D. Ruckelshaus
Administrator, Environmental
Protection Agency
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A NEW PART 61 IS ADDED TO CHAPTER 1, TITLE 40, CODE OF FEDERAL
REGULATIONS, AS FOLLOWS:
Subpart A - General Provisions
Sec.
61.01 Applicability.
61.02 Definitions.
61.03 Abbreviations.
61.04 Address.
61.05 Prohibited activities.
61.06 Determination of construction or modification.
61.07 .Application for approval of construction or modification.
61.08 Approval by Administrator.
61.09 Notification of start-up.
61.10 Source reporting and waiver request.
61.11 Waiver of compliance.
61.12 Emission tests and monitoring.
61.13 Waiver of emission tests.
61.14 Source test and analytical methods.
61.15 Availability of information.
61.16 State authority.
Subpart B - National Emission Standard for Asbestos
61.20 Applicability.
61.21 Definitions.
61.22 Emission standard.
61.23 Air-cleaning.
61.24 Reporting.
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Subpart C - National Emission Standard for Beryllium
61.30 Applicability.
61.31 Definitions.
61.32 Emission standard.
61.33 Stack sampling.
61.34 Air sampling.
Subpart D - National Emission Standard for Beryllium
Rocket Motor Firing
61.40 Applicability.
61.41 Definitions.
61.42 Emission standard.
61.43 Emission testing - rocket firing or propellent disposal.
61,44 Stack sampling.
Subpart E - National Emission Standard for Mercury
61.50 Applicability.
61.51 Definitions.
61.52 Emission standard. }
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61.53 Stack sampling.
Appendix A - Compliance Status Information
Appendix B - Test Methods
Method 101 - Reference method for determination of particulate and
gaseous mercury emissions from stationary sources (air
streams).
Method 102 - Reference method for determination of particulate
and gaseous mercury emissions from stationary
sources (hydrogen streams).
Method 103 - Beryllium screening method.
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Method 104 - Reference method for determination of beryllium
emissions from stationary sources.
Authority: 42 U.S.C. 1857 c-7.
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SUBPART A - GENERAL PROVISIONS
§ 61.01 Applicability.
The provisions of this part apply to the owner or operator
of any stationary source for which a standard is prescribed
under this part.
§ 61.02 Definitions.
As used in this part, all terms not defined herein shall
have the meaning given them in the"Act:
(a) "Act" means the Clean Air Act (42 U.S.C. 1857 et seq.).
(b) "Administrator" means the Administrator of the
Environmental Protection Agency or his authorized representative.
(c) "Alternative method" means any method of sampling and
analyzing for an air pollutant which does not meet all of the
criteria for equivalency but which has been demonstrated to the
Administrator's satisfaction to, in specific cases, produce,
results adequate for his determination of compliance.
(d) "Commenced" means that an owner or operator has undertaken
a continuous program of construction or modification or that an-
owner or operator has entered into a contractual obligation to
undertake and complete, within a reasonable time, a continuous
program of construction or modification.
(e) "Compliance schedule" means the date or dates by which
a source or category of sources is required to comply with the
standards of this part and with any steps toward such compliance
which are set forth in a request for waiver of compliance under
§ 61.10(b).
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(f) "Construction" means fabrication, erection, or installation
of a stationary source.
(g) "Effective date" is the date of promulgation in the Federal
Register of an applicable standard or other regulation under this part.
(h) "Equivalent method" means any method of sampling
and analyzing for an air pollutant which has been demonstrated
to the Administrator's satisfaction to have a consistent and
quantitatively known relationship to the reference method, under
specified conditions.
(i) "Existing source" means any stationary source which is
not a new source.
(j) "Modification" means any physical change in, or change
in the method of operation of, a stationary source which increases
the amount of any hazardous air pollutant emitted by such source
or which results in the emission of any hazardous air pollutant
not previously emitted, except that:
)
(1) Routine maintenance, repair, and replacement shall not
'be considered physical changes, and
(2) The following shall not be considered a change in the
method of operation:
(i) An increase in the production rate, if such increase
does not exceed the operating design capacity of the stationary
, i
source;
(ii) An increase in hours of operation.
(k) "New source" means any stationary source, the construction
or modification of which is commenced after the publication in the
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Federal Register of proposed national emission standards for
hazardous air pollutants which will be applicable to such source.
(1) "Owner or operator" means any person who owns, leases,
operates, controls, or supervises a stationary source.
(m) "Reference method" means any method of sampling and
analyzing for an air pollutant, as described in the appendix
to this part.
(n) "Startup" means the settfng in operation of a stationary
source for any purpose.
(o) "Standard" means a national emission standard for a
hazardous air pollutant proposed or promulgated under this part.
(p) "Stationary source" means any building, structure, facility,
or installation which emits or may emit any air pollutant which has
been designated as hazardous by the Administrator.
§ 61.03 Abbreviations.
The abbreviations used in this part have the following meanings:
°C . - Degrees Centigrade
c.f.m. - Cubic feet per minute.
2
ft - Square feet.
ft3 - Cubic feet.
°F - Degrees Fahrenheit.
in. - Inch.
1 - Liter.
ml - Milliliter.
M - Molar.
m - Cubic meter.
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nm - Nanometer.
oz - Ounces.
v/v - Volume per volume.
2
yd - Square yards.
w.g. - Water gauge.
in. Hg. - Inches of mercury.
•«
in. H20 - Inches of water.
g. - Grams.
mg. - Milligrams.
N - Normal.
°R - Degree Rankine.
min. - Minute.
sec. - Second.
x
avg. - Average.
I.D. - Inside Diameter.
O.D. - Outside Diameter.
yg - Micrograms (10~ gram).
% - Percent.
Hg - Mercury.
Be - Beryllium.
§ 61.04 Address.
All requests, reports, applications, submittals and other
communications to the Administrator pursuant to this part shall
be submitted in duplicate and addressed to the appropriate Regional
Office of the Environmental Protection Agency, to the attention
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of the Director, Enforcement Division. The Regional Offices are
as follows:
Region I, (Connecticut, Maine, Massachusetts, New Hampshire,
Rhode Island, Vermont) John F. Kennedy Federal Building, Boston,
Massachusetts 02203.
Region II, (New York, New Jersey, Puerto Rico, Virgin Islands)
Federal Office Building, 26 Federal Plaza (Foley Square), New York,
New York 10007.
Region III, (Delaware,- District of Columbia, Pennsylvania,
Maryland, Virginia, West Virginia) Curtis Building, Sixth and Walnut
Streets, Philadelphia, Pennsylvania 19106.
Region IV, (Alabama, Florida, Georgia, Mississippi, Kentucky,
North Carolina, South Carolina, Tennessee) Suite 300, 1421 Peachtree
Street/Atlanta, Georgia 30309.
Region V, (Illinois, Indiana, Minnesota, Michigan, Ohio,
Wisconsin) 1 North Wacker Drive, Chicago, Illinois 60606.
Region VI, (Arkansas, Louisiana, New Mexico, Oklahoma, Texas)
1600 Paterson Street, Dallas, Texas 75201. . \
Region VII, (Iowa, Kansas, Missouri, Nebraska) 1735 Baltimore
i
Street, Kansas City, Missouri 64108.
Region VIII, (Colorado, Montana, North Dakota, South Dakota,
Utah, Wyoming) 916 Lincoln Towers, 1860 Lincoln Street, Denver,
Colorado 80203.
^i
Region IX, (Arizona, California, Hawaii, Nevada, Guam,
American Samoa) 100 California Street, San Francisco, California 94111.
Region X, (Washington, Oregon, Idaho, Alaska) 1200 Sixth Avenue,
Seattle, Washington 98101.
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§ 61.05 Prohibited activities.
(a) After the effective date of any standard prescribed
under this part, no person shall construct or modify any
stationary source subject to such standard without first obtaining
written approval of the Administrator in accordance with
this subpart, except under an exemption granted by the President
under section 112(c)(2) of the Act. Sources, the construction or
modification of which commenced after the publication date of the
standards proposed to be applicable to such source, are subject
to this prohibition.
(b) After the effective date of any standard prescribed
under this part, no person shall operate any new source in
violation of such standard except under an exemption granted by
the President under section 112(c)(2) of the Act.
(c) Ninety days after the effective date of any standard
prescribed under this part, no person shall operate any existing
stationary source in violation of such standard, except under a '
i
i
waiver granted by the Administrator in accordance with this subpart
or under an exemption granted by the President under section 112(c)(2)
of the Act.
(d) No owner or operator subject to the provisions of this
part shall fail to report, revise reports, or report source
test results as required under this part.
§ 61.06 Determination of construction or modification.
Upon written application by an owner or operator, the
Administrator will make a determination of whether actions taken
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or Intended to be taken by such owner or operator constitute
construction or modification or the commencement thereof within
the meaning of this part. The Administrator will within 30 days
of receipt of sufficient information to evaluate an application,
notify the owner or operator of his determination.
§ 61.07 Application for approval of construction or modification.
(a) The owner or operator of any new source to which a
standard prescribed under this part is applicable shall, prior
to the date on which construction or modification is planned
to commence, or within 30 days after the effective date in
the case of a new source that already has commenced construction
or modification and has not begun operation, submit to the Administrator
an application for approval of such construction or modification.
A separate application shall be submitted for each stationary source.
(b) Each application shall include:
(1) The name and address of the applicant.
(2) The location or proposed location of the source. !
\
(3) Technical information describing the proposed nature, size,
\
design, operating design capacity, and method of operation of the ,
source, including a description of any equipment to be used for
control of emissions. Such technical information shall include
calculations of emission estimates in sufficient detail to permit
assessment of the validity of such calculations.
§ 61.08 Approval by Administrator.
(a) The Administrator will, within 60 days of receipt of
sufficient information to evaluate an application under § 61.07,
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notify the owner or operator of approval or intention to deny
approval of construction or modification.
(b) If the Administrator determines that a stationary source
for which an application pursuant to § 61.07 was submitted will,
1f properly operated, not cause emissions in violation of a
standard, he will approve the construction or modification of
such source.
(c) Prior to denying any application for approval of
construction or modification pursuant to this section, the
Administrator will notify the person making such application of
the Administrator's intention to issue such denial, together with:
(1) Notice of the information and findings on which such
intended denial is based, and
(2)~ Notice of opportunity for such person to present, within
such time limit as the Administrator shall specify, additional
information or arguments to the Administrator prior to final
action on such application.
(d) A final determination to deny any application for
approval will be in writing and will set forth the specific
grounds on which such denial is based. Such final determination
will be made within 60 days of presentation of additional
information or arguments, or 60 days after the final date
specified for presentation, if no presentation is made.
(e) Neither the submission of an application for approval
nor the Administrator's granting of approval to construct or modify
shall:
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(1) Relieve an owner or operator of legal responsibility for
compliance with any applicable provision of this part or of any
other applicable Federal, State, or local requirement, or
(2) Prevent the Administrator from implementing or enforcing
this part or taking any other action under the Act.
§ 61.09 Notification of startup.
(a) Any owner or operator subject to the provisions of this
part shall furnish the Administrator written notification as
follows: .
(1) A notification of the anticipated date of initial startup
of the source not more than 60 days nor less than 30 days prior to
such date.
(2) A notification of the actual date of initial startup
of the source within 15 days after such date.
i
§ 61.10 Source reporting and waiver request.
(a) The owner or operator of any existing source, or any
i
new source which began operation prior to the effective date and
which is subject to a standard prescribed under this part shall, <
within 90 days after the effective date, provide the following
information in writing to the Administrator:
(1) Name and address of the owner or operator.
(2) The location of the source.
(3) The type of hazardous pollutants emitted by the
stationary source.
(4) A brief description of the nature, size, design, and
method of operation of the stationary source including the
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operating design capacity of such source. Identify each point
of emission for each hazardous pollutant.
(5) The average weight per month of the hazardous materials being
processed by the source, over the last 12 months preceding the
date of the report.
(6) A description of the existing control equipment for
each emission point.
(1) Primary control device(s) for each hazardous
pollutant.
(11) Secondary control device(s) for each hazardous
pollutant.
(111) Estimated control efficiency (%) for each
control device.
(7) A statement by the owner or operator of the source
as to whether he can comply with the standards prescribed in this
part within 90 days of the effective date.
(b) The owner or operator of an existing source unable to '
operate in compliance with any standard prescribed under this
part may request a waiver of compliance with such standard for a
period not exceeding two years from the effective date. Any
request shall be in writing and shall include the following
Information:
(1) A description of the controls to be installed to
comply with the standard.
(2) A compliance schedule, including the date each step
toward compliance will be reached. Such list shall include
as a minimum the following dates:
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(1) Date by which contracts for emission control
systems or process modifications will be awarded, or date by which
orders will be issued for the purchase of component parts to
accomplish emission control or process modification;
(ii) Date of initiation of on-site construction or
installation of emission control equipment or process change;
(iii) Date by which on-site construction or installation
of emission control equipment or process modification is to be
completed; and
(1v) Date by which final compliance is to be
achieved.
(3) A description of interim emission control steps which
will be taken during the waiver period.
(c) Changes in the information provided under paragraph
(a) of this section shall be provided to the Administrator within
30 days after such change, except that if changes will result from
modification of the source, as defined in § 61.02 (j), the
provisions of § 61.07 and § 61.08 are applicable.
(d) The format for reporting under this section is included
as appendix A of this part. Advice on reporting the status
of compliance may be obtained from the Administrator.
§ 61.11 Waiver of compliance.
(a) Based on the information provided in any request under
§ 61.10, or other information, the Administrator may grant a
waiver of compliance with the standard for a period not exceeding
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two years from the effective date of such standard.
(b) Such waiver will be in writing and will:
(1) Identify the stationary source covered.
(2) Specify the termination date of the waiver. The waiver
may be terminated at an earlier date if the conditions specified
under § 61.11(b)(3) are not met.
(3) Require the dates of steps toward compliance to be met;
and impose such additional ^conditions as the Administrator
determines to be necessary to assure installation of the necessary
controls within the waiver period, and to assure protection of the
health of persons during the waiver period.
(c) Prior to denying any request for a waiver pursuant to
this section, the Administrator will notify the person making
such request of the Administrator's intention to issue such
denial, together with:
(1) Notice of the information and findings on which such
Intended denial is based, and
(2) Notice of opportunity for such person to present, within
such time limit as the Administrator specifies, additional
information or arguments to the Administrator prior to final
action on such request.
(d) A final determination to deny any request for a waiver
will be in writing and will set forth the specific grounds on which
such denial is based. Such final determination will be made within
60 days after presentation of additional information or arguments,
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or 60 days after the final date specified for such presentation, if
no presentation is made.
(e) The granting of a waiver under this section shall not
abrogate the Administrator's authority under section 114 of the Act.
§ 61.12 Emission tests and monitoring.
(a) Emission tests and monitoring shall be conducted and
reported as set forth in this part and appendix B to this part.
(b) The owner or operator of a new source subject to this
part, -and at the request of the Administrator, the owner
or operator of an existing source subject to this part, shall provide
or cause to be provided, emission testing facilities as follows:
(1) Sampling ports adequate for test methods applicable to
such source.
(2) Safe sampling platform(s).
(3) Safe access to sampling platform(s).
(4) Utilities for sampling and testing equipment.
§ 61.13 Waiver of emission tests.
(a) Emission tests may be waived upon written application
to the Administrator if, in his judgment, the source is meeting
the standard, or if the source is operating under a waiver of
compliance or has requested a waiver of compliance.
(b) If application for waiver of the emission test is
made, such application shall accompany the information required
by § 61.10. The appropriate form is contained in appendix A
to this part.
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(c) Approval of any waiver granted pursuant to this section
shall not abrogate the Administrator's authority under the Act or
in any way prohibit the Administrator from later cancelling such
waiver. Such cancellation will be made only after notice is given
to the owner or operator of the source. ...
§ 61.14 Source test and analytical methods.
(a) Methods 101, 102, and 104 in appendix B to this part
shall be used for all source tests required under this part, unless
an equivalent method or an alternative method has been approved by
the Administrator.
(b) Method 103 in appendix B to this part is hereby approved
by the Administrator as an alternative method for sources subject
to § 61.32(a) and § 61.42(b).
(c) The Administrator may, after notice to the owner or
operator, withdraw approval of an alternative method granted
under paragraph (a) or (b) of this section.
§ 61.15 Availability of information.
(a) Emission data provided to, or otherwise obtained by,
the Administrator in accordance with the provisions of this part
shall be available to the public.
(b) Any records, reports, or information, other than
emission data, provided to, or otherwise obtained by, the
Administrator in accordance with the provisions of this part
shall be available to the public, except that upon a showing
satisfactory to the Administrator by any person that such
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records, reports, or information, or particular part thereof
(other than emission data), if made public, would divulge
methods or processes entitled to protection as trade secrets
of such person, the Administrator will consider such records,
reports, or information, or particular part thereof, confidential
in accordance with the purposes of section 1905 of title 18 of the
United States Code, except that such records, reports, or information,
or particular part thereof^ may be disclosed to other officers,
employeesi or authorized representatives of the United States
concerned with carrying out the provisions of the Act or when
relevant in any proceeding under the Act.
(c) Waiver requests are considered proceedings under the Act.
§ 61.16 -State authority.
(a) The provisions of this part shall not be construed in any
manner to preclude any State or political subdivision thereof
from: ;
(1) Adopting and enforcing any emission limiting regulation
applicable to a stationary source, provided that such emission
limiting regulation is not less stringent than the standards
prescribed under this part.
(2) Requiring the owner or operator of a stationary source
to obtain permits, licenses, or approvals prior to initiating
construction, modification, or operation of such source.
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SUBPART B - NATIONAL EMISSION STANDARD FOR ASBESTOS
§ 61.20 Applicability.
The provisions of this subpart are applicable to those sources
specified in § 61.22.
§ 61.21 .Definitions.
The meanings of terms used in this subpart are found in the Act,
in subpart A of this part, or below:
(a) "asbestos" means actinolite, amosite, anthophyllite,
chrysotile, crocidolite, tremolite.
(b) "asbestos material" means asbestos or any material containing
asbestos.
(c) "particulate asbestos material" means finely divided particles
of asbestos material.
(d) "asbestos tailings" means any solid waste product of asbestos
mining or milling operations which contains asbestos.
(e) "outside air" means the air outside buildings, structures,
and enclosures.
(f) "visible emissions" means any emissions which are visually
detectable without the aid of instruments and which contain particulate
asbestos material.
§ 61.22 Emission standard.
(a) Asbestos mills. There shall be no visible emissions to the
outside air from any asbestos mill except as provided in paragraph
(f) of this section.
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(b) Roadways. The surfacing of roadways with asbestos tailings
is prohibited, except for temporary roadways on an area of asbestos
ore deposits. The surfacing of temporary roadways on an area of
asbestos ore deposits is exempt from the requirements of § 61.05(a),
§ 61.06, § 61.07, § 61.08; and § 61.09.
(c) Manufacturing. There shall be no visible emissions to the
outside air, except as provided in paragraph (f) of this section, from
/
any building or structure in which the following operations are
conducted or directly from any of the following operations if they
are conducted outside of buildings or structures.
(1) The manufacture of cloth, cord, wicks, tubing, tape, twine,
rope, thread, yarn, roving, lap, and other textile materials.
(2) The manufacture of cement products.
(3) The manufacture of fireproofing and insulating materials.
(4) The manufacture of friction products.
(5) The manufacture of paper, millboard, and felt.
(6) The manufacture of floor tile.
(7) The manufacture of paints, coatings, caulks, adhesives,
sealants.
(8) The manufacture of plastics and rubber materials.
(9) The manufacture of chlorine.
(d) Demolition. Any owner or operator of a demolition
operation who intends to demolish any building or structure or portion
thereof which contains any boiler, pipe, or structural member that
is insulated or fireproofed with asbestos material shall comply
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with the regulations set forth in this paragraph if such
demolition is a major demolition.
(1) A major demolition is demoliton of:
(i) "any single building or structure which has a total
2
floor area of 40,000 ft , or more, or
(ii) any group of buildings or structures located on
2
the same demolition site which has a total floor area of 40,000 ft
or more, or
(iii) any single building or structure which has more than
5000 linear feet of insulated pipe, or
(iv) any group of buildings or structures located on
the same demolition site which has more than 5000 linear feet of
insulated pipe.
(2) Notice of intention to demolish shall be provided to the
Administrator at least 20 days prior to commencement of such demolition.
Such notice shall include the following information:
(i) Name of owner or operator.
(ii) Address of owner or operator.
(iii) Size and description of the buildings or structures
to be demolished.
(iv) Address or location of each building or structure.
(v) Scheduled starting and completion dates of demolition.
(vi) Method of demolition to be employed.
(vii) Procedures to be employed to meet the requirements
of this paragraph.
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(3) The following procedures shall be used to prevent emissions
of particulate asbestos material to outside air:
(i) Asbestos materials, used to insulate or fireproof
any boiler, pipe,, or structural member, shall be wetted and removed
from any building or structure subject to this paragraph before
wrecking of structural members is commenced. The asbestos debris
shall be wetted at all stages of demolition and related handling
operations.
(ii) No structural member shall be dropped or thrown
from any building or structure to the ground but shall be lowered
to ground level by hoists or cranes.
(iii) No asbestos debris shall be dropped or thrown
from any building or structure to the ground or from any floor
to any floor below. For buildings or structures 50 feet or
greater in height, asbestos debris shall be transported to the
ground via dust-tight chutes or buckets.
(4) Sources subject to this paragraph are exempt from the
requirements of § 61.05(a), § 61.06, § 61.07, § 61.08, and § 61.09. ;
(5) Any person who intends to demolish a building or structure'
to which the provisions of this paragraph would be applicable but
which has been declared by proper state or local authority to be
structurally unsound and which is in danger of imminent collapse
is exempt from the requirements of this paragraph other than the
wetting of asbestos debris.
(e) Spraying. There shall be no visible emissions to the
outside air from the spray-on application of materials containing
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more than one percent asbestos, on a dry weight basis, used to
insulate or fireproof equipment and machinery, except as provided
in paragraph (f) of this section. Spray-on materials used to insulate
or fireproof buil'dings, structures, pipes, and conduits shall
•>
contain less than 1% asbestos on a dry-weight basis. The spray-
on application of asbestos-containing materials used to insulate or
fireproof buildings, structures, pipes, and conduits shall be
conducted in such a manner as to prevent the release of particul-
ate asbestos material to the outside air.
(1) Sources subject to this paragraph are exempt from the
requirements of § 61.05(a), § 61.06, § 61.07, § 61.07, § 61.08,
and § 61.09.
(2) .Any person who intends to spray asbestos materials,
whether or not such materials contain one percent asbestos, to
i
insulate or fireproof buildings, structures, pipes, conduits,
equipment, and machinery shall report such intention to the
Administrator at least 20 days prior to the commencement of the
spraying operation. Such report shall include the following
information:
(i) Name of owner or operator.
(ii) Address of owner or operator.
(iii) Location of spraying operation.
(iv) Procedures to be followed to meet the requirements
of this paragraph.
(f) Rather than meet the no-visible-emission requirements of
paragraphs (a), (c), and (e) of this section, an owner or operator
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may elect to clean emissions containing participate asbestos material,
using the methods specified by § 61.23, before such emissions
escape to, or are vented to, the outside air.
§ 61.23 Air-cleaning.
If air-cleaning is elected, as permitted by paragraph 61.22(f),
the requirements of this section must be met.
(a) Fabric filter collection devices must be used, except as
noted in paragraphs (b) and (c) of this section. Such devices
must be operated at a pressure drop of no more than 4 inches water
gauge, as measured across the filter fabric. The air flow
permeability, as determined by ASTM Method D737-69, must not exceed.
30 cfm/ft2 for woven fabrics or 35 cfm/ft2 for felted fabrics,
except that 35 cfm/ft2 for woven and 45 cfm/ft2 for felted fabrics
is allowed for filtering air from asbestos ore dryers. Each square
yard of felted fabric must weigh at least 14 ounces and be at least
1/16 inch thick throughout. Synthetic fabrics must not contain fill
yarn other than that which is spun.
*
(b) If the use of fabric filters creates a fire or explosion
hazard, the Administrator may authorize the use of wet collectors
designed to operate with a unit contacting energy of at least 40
inches water gauge pressure.
(c) The Administrator may authorize the use of filtering
equipment other than that described in paragraphs (a) and (b) of
this section if the owner or operator demonstrates to the satisfaction
of the Administrator that the.filtering of particulate asbestos
material is equivalent to that of the described equipment.
(d) All air-cleaning equipment authorized by this section must
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be properly Installed, used, operated, and maintained. By-pass
devices may be used only during upset or emergency conditions and
then only for so long as it takes to shut down the operation
generating the particulate asbestos material.
§ 61.24 Reporting''.
•»
The owner or operator of any existing source to which this
subpart is applicable shall, within 90 days after the effective date,
provide the following information to the Administrator:
(a) A description of the emission equipment used for each
process:
(1) If a fabric filter device is used to control emissions,
indicate the pressure drop across the fabric filter in inches
water gauge.
(-i) If the fabric filter device utilizes a woven fabric,
2
indicate the air flow permeability in cfm/ft ; and, if the fabric is
synthetic, indicate whether the fill yarn is spun or not spun.
(ii) If the fabric filter device utilizes a felted fabric,
2
indicate the density in oz/yd , the minimum thickness in inches, and
2
the air flow permeability in cfm/ft .
(b) Such information shall accompany the information required
by § 61.10. The appropriate form is contained in appendix A to
this part.
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SUBPART C - NATIONAL EMISSION STANDARD FOR BERYLLIUM
§ 61.30 Applicability.
The provisions of this subpart are applicable to the following
stationary sources:
(a) Extraction plants, ceramic plants, foundries, incinerators,
and propellent plants when these stationary sources are processing
beryllium ore, beryllium, beryllium oxide, beryllium alloys, or
beryllium-containing waste.
(b) Machine shops when these stationary sources are processing
beryllium, beryllium oxides, or any alloy when such alloy contains
more than 25^ percent beryllium by weight.
§ 61.31 Definitions.
As used in this subpart, all terms not defined herein shall
have the meaning given them by the Act and in Subpart A of this
part.
(a) "Beryllium" means the element beryllium. Where weights
or concentrations are specified, such weights or concentrations apply
to beryllium only, excluding the weight or concentration of any '
associated elements. '
(b) "Extraction plant" means a facility chemically processing
beryllium ore to beryllium metal, alloy, or oxide, or performing
any of the intermediate steps in these processes.
(c) "Beryllium ore" means any naturally occurring material
mined or gathered partially or exclusively for its beryllium content.
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(d) "Machine shop" means a facility performing cutting,
grinding, turning, honing, milling, deburring, lapping,
electrochemical machining, etching, or other similar operations.
(e) "Ceramic plant" means a manufacturing plant producing
ceramic items.
(f) "Foundry" means a facility engaged in the melting or
casting of beryllium metal or alloy.
(g) "Beryllium-containing waste" means material contaminated
with beryllium and/or beryllium compounds used or generated during
any process or operation performed by a source subject to this
subpart.
(h) -"Incinerator" means any furnace used in the process of
burning waste for the primary purpose of reducing the volume of the
waste by removing combustible matter.
(i) "Propellent" means a fuel and oxidizer physically or
chemically combined which undergoes combustion to provide rocket
propulsion.
(j) "Beryllium alloy" means any metal to which beryllium has
been added in order to increase its beryllium content and which contains
more than 0.1 percent beryllium by weight.
(k) "Propellent plant" means any facility engaged in the mixing,
casting, or machining of propellent.
§ 61.32 Emission standard.
(a) Emissions to the atmosphere from stationary sources,
subject to the provisions of this subpart, shall not exceed
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10 grams of beryllium over a 24-hour period,1 except as provided
in paragraph (b) of this section.
(b) Rather than meet the requirement of paragraph (a) of
this section, an owner or operator may request approval from the
Administrator to comply with the provisions of this subpart by demon-
strating that the ambient concentrations of beryllium in the vicinity
of the stationary source do not exceed 0.01 micrograms per cubic
meter, averaged over a 30-d_ay period. Such approval will
be granted by the Administrator provided:
(1) At least three years of current data which shows that
the ambient concentrations of beryllium in the vicinity of the
stationary source have averaged less than 0.01 yg/m for such three
year period. Such three year period shall be the three years
ending 30 days before the effective date of this standard.
(2) The owner or operator seeking approval notifies the
Administrator in writing within 30 days after the effective date
of this standard.
(3) The owner or operator submits a demonstration report to
the Administrator within 45 days after the effective date of
this standard which includes the following information:
(i) Description of sampling method including the
method and frequency of calibration.
(ii) Method of sample analysis.
(iii) Averaging technique for determining 30-day average
concentrations.
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(iv) Number, identity, and location (address, coordinates, or
distance and heading from plant) of sampling sites.
(v) Ground elevations and height above ground of sampling
inlets.
(vi) Plant and sampling area plots showing emission points and
sampling sites. Topographic features significantly affecting
dispersion including plant building heights and locations shall'be
Included. - I
(v11) Information necessary for estimating dispersion including
stack height, inside diameter, exit gas temperature, exit velocity
or flow rate, and beryllium concentration.
(viii) A description of data and procedures (methods or models)
used to design the air sampling network (i.e., number and location
of sampling sites).
(1x) Air sampling data indicating beryllium concentrations in the
vicinity of the stationary source for the three-year period specified in
§ 61.32(b)(l). This data shall be presented chronologically and
include the beryllium concentration and location of each individual
sample taken by the network and the corresponding 30-day average
beryllium concentrations.
(c) Within 60 days after receiving such demonstration report,
the Administrator will notify the owner or operator in writing whether
approval is granted or denied. Prior to denying approval to comply
with the provisions of paragraph (b) of this section, the
Administrator will consult with representatives of the stationary
-------
source for which the demonstration report was submitted. If
approval is denied, the provisions of paragraph (a) of this section
must be complied with within the time period allowed by the Act.
(d) The burning of beryllium and/or beryllium-containing
waste, except propel!ants, is prohibited except in incinerators,
emissions from which must comply with the standard.
§ 61.33 Stack sampling. I
(a) Unless a waiver of emission testing is obtained under
§ 61.13, each owner or operator required to comply with § 61.32(a)
shall test emissions from his source,
(1) Within 90 days of the effective date in the case of an
existing source or a new source which began operation prior to the
effective date; or
(2) Within 90 days of start-up in the case of a new source which
did not begin operation prior to the effective date.
(b) The Administrator shall be notified at least 30 days prior
to an emission test so that he may at his option observe the test.
(c) Samples shall be taken over such a period or periods as
are necessary to accurately determine the maximum emissions which will
occur in any 24-hour period. Where emissions depend upon the
relative frequency of operation of different types of processes,
operating hours, operating capacities, or other factors, the
calculation of maximum 24-hour-period emissions will be based
on that combination of factors which is likely to occur during
the subject period and which result in the maximum emissions.
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No changes in the operation shall be made, which would potentially
increase emissions above that determined by the most recent source
test, until a new emission has been estimated by calculation and
the results reported to the Administrator.
(d) All samples shall be analyzed and beryllium emissions
shall be determined within 30 days after the source test. All
determinations shall be reported to the Administrator by a registered
letter dispatched before the close of the next business day
following such determination.
(e) Records of emission test results and other data needed
/
to determine total emissions shall be retained at the source and
made available, for inspection by the Administrator, for a minimum
of two years.
§ 61.34 Air sampling.
(a) Stationary sources subject to § 61.32(b) shall locate air
sampling sites in accordance with a plan approved by the Administrator.
Such sites shall be located in such a manner as is calculated
to detect maximum concentrations of beryllium in the ambient air.
(b) All monitoring sites shall be operated continuously
except for a reasonable time allowance for instrument maintenance
and calibration, for changing filters, or for replacement of
equipment needing major repair.
(c) Filters shall be analyzed and concentrations calculated
within 30 days after filters are collected. Records of concentrations
at all sampling sites and other data needed to determine such
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concentrations shall be retained at the source and made
available, for inspection by the Administrator, for a minimum
of two years.
(d) Concentrations measured at all sampling sites shall
be reported to the Administrator every 30 days by a registered
letter.
(e) The Administrator may at any time require changes in,
or expansion of, the sampling network.
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SUBPART D - NATIONAL EMISSION STANDARD FOR BERYLLIUM ROCKET
MOTOR FIRING
§ 61.40 Applicability.
The provisions of this subpart are applicable to rocket motor
test sites.
§ 61.41 Definitions.
As used in this part, all terms not defined herein shall have
the meaning given them by the Act and in Subpart A of this part.
(a) "Rocket motor test site" means any building, structure,
facility, or installation where the static test firing of a
beryllium rocket motor and/or the disposal of beryllium propel 1 ant
is conducted.
(b) "Beryllium propel!ant" means any propel!ant incorporating
beryllium.
§ 61.42 Emission standard.
(a) Emissions to the atmosphere from rocket motor test sites
shall not cause time-weighted atmospheric concentrations of
beryllium to exceed 75 microgram minutes per cubic meter of air
within the limits of 10 to 60 minutes, accumulated during any 2
consecutive weeks, in any arsa in which an effect adverse to public
health could occur.
(b) If combustion products from the firing of beryllium
propellant are collected in a closed tank, emissions from such
tank shall not exceed 2 grams per hour and a maximum of 10 grams
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per day.
§ 61.43 Emission testing - rocket firing or propellant disposal.
(a) Ambient air concentrations shall be measured during and
after firing of a rocket motor or propel!ant disposal and in
such a manner that the effect of these emissions can be compared
with the standard. Such sampling techniques shall be approved
by the Administrator.
(b) All samples shall be analyzed and results shall be
calculated within 30 days after samples are taken and before
any subsequent rocket motor firing or propellent disposal at
the given site. All results shall be reported to the Administrator
by a registered letter dispatched before the close of the next
business day following determination of such results.
(c) Records of air sampling test results and other data
needed to determine integrated intermittent concentrations shall
be retained at the source and made available, for inspection by the
Administrator, for a minimum of two years.
(d) The Administrator shall be notified at least 30 days
prior to an air sampling test, so that he may at his option observe
the test.
§ 61.44 Stack sampling.
(a) Sources subject to § 61.42(b) shall be continuously
sampled, during release of combustion products from the tank,
in such a manner that compliance with the standards can be
determined. Provisions of § 61.14 apply.
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(b) All samples shall be analyzed, and beryllium emissions
shall be determined within 30 days after samples are taken and
before any subsequent rocket motor firing or propel!ant disposal
at the given site. All determinations shall be reported to
the Administrator by a registered letter dispatched before the
close of the next business day following such determinations.
(c) Records of emission test results and other data needed
to determine total emissions shall be retained at the source and
made available, for inspection by the Administrator, for a
minimum of two years.
(d) The Administrator shall be notified at least 30 days
prior to an emission test, so that he may at his option observe
the test."
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SUBPART E - NATIONAL EMISSION STANDARDS FOR MERCURY
§ 61.50 Applicability.
The provisions of this subpart are applicable to those
stationary sources which process mercury ore to recover mercury,
and to those which use mercury chlor-alkali cells to produce chlorine
gas and alkali metal hydroxide.
§ 61.51 Definitions.
As. used in this subpart, all terms not defined herein shall
have the meaning given them in the Act and in subpart A of this part.
(a) "Mercury" means the element mercury, excluding any
associated elements, and includes mercury in particulates, vapors,
aerosols, and compounds.
(b) "Mercury ore" means a mineral mined specifically for its
mercury content.
(c) "Mercury ore processing facility" means a facility processing
mercury ore to obtain mercury.
(d) "Condenser stack gases" means the gaseous effluent evolved
from the stack of processes utilizing heat to extract mercury metal
from mercury ore.
(e) "Mercury chlor-alkali cell" means a device which is
basically composed of an electrolyzer section and a denuder
(decomposer) section and utilizes mercury to produce chlorine gas,
hydrogen gas, and alkali metal hydroxide.
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(f) "Mercury chlor-alkali electrolyzer" means an electrolytic
device which is part of a mercury chlor-alkali cell and utilizes
a flowing mercury cathode to produce chlorine gas and alkali
metal amalgam.
(g) "Denuder" means a horizontal or vertical container which
is part of a mercury chlor-alkali cell and in which water and
alkali metal amalgam are converted to alkali metal hydroxide,
mercury, and hydrogen gas in a short-circuited, electrolytic reaction.
(h) "Hydrogen gas stream" means a hydrogen stream formed in
the chlor-alkali cell denuder.
(i) "End box" means a container(s) located on one or both ends
of a mercury chlor-alkali electrolyzer which serves as a connection
between the electrolyzer and denuder for rich and stripped amalgam.
(j) "End box ventilation system" means a ventilation system
which collects mercury emissions from the end-boxes, the mercury
pump sumps, and their water collection systems.
(k) "Cell room" means a structure(s) housing one or more
mercury electrolytic chlor-alkali cells.
§ 61.52 Emission standard.
Emissions to the atmosphere from stationary sources subject
to the provisions of this subpart shall not exceed 2,300 grams of
mercury per 24-hour period.
§ 61.53 Stack sampling.
(a) Mercury ore processing facility.
(1) Unless a waiver of emission testing is obtained under
-------
§ 61.13, each owner or operator processing mercury ore shall test
emissions from his source,
(1) Within 90 days of the effective date in the case of an
existing source or a new source which began operation prior to
the effective date; or
(ii) Within 90 days of start-up in the case of a new source
which did not begin operation prior to the effective date.
(2) The Administrator" shall be notified at least 30 days
prior to an emission test, so that he may at his option observe
the test.
(3) Samples shall be taken over such a period or periods
as are necessary to accurately determine the maximum emissions
which will occur in a 24-hour period. No changes in the operation
shall be made, which would potentially increase emissions above
that determined by the most recent source test, until the new emission
has been estimated by calculation and the results reported to
the Administrator.
(4) All samples shall be analyzed, and mercury emissions
shall be determined within 30 days after the source test. Each
determination will be reported to the Administrator by a registered
letter dispatched before the close of the next business day
following such determination.
(5) Records of emission test results and other data needed
to determine total emissions shall be retained at the source and
made available, for inspection by the Administrator, for a minimum
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of two years.
(b) Mercury chlor-alkali plant - hydrogen and end-box
ventilation gas streams.
(1) Unless a waiver of emission testing is obtained under
§ 61.13, each owner or operator employing mercury chlor-alkali ,
cell(s) shall test emissions from his source,
(i) Within 90 days of the effective date in the case of an
existing source or a new source which began operation prior to the
effective date; or
(1i) Within 90 days of start-up in the case of a new source which
did not begin operation prior to the effective date.
(2) The Administrator shall be notified .at least 30 days
prior to an emission test, so that he may at his option observe
the test.
(3) Samples shall be taken over such a period or periods
as are necessary to accurately determine the maximum emissions
which will occur in a 24-hour period. No changes in the operation
shall be made, which would potentially increase emissions above .
that determined by the most recent source test, until the new
emission has been estimated by calculation and the results
reported to the Administrator.
(4) All samples shall be analyzed and mercury emissions
shall be determined within 30 days after the source test. All
the determinations will be reported to the Administrator by a
registered letter dispatched before the close of the next business
-------
day following such determination.
(5) Records of emission test results and other data
needed to determine total emissions shall be retained at the
source and made available, for inspection by the Administrator,
for a minimum of two years.
(c) Mercury chlor-alkali plants - cell room ventilation system.
(1) Stationary sources using mercury chlor-alkali cells may
demonstrate compliance with"the cell room ventilation portion of the
allowable emissions by either (2) or (4) below.
(2) Unless a waiver of emission testing is obtained under
§ 61.13, each owner or operator shall pass all cell room
air in forced gas streams through stacks suitable for testing,
(i) Within 90 days of the effective date in the case of an
existing source or a new source which began operation prior to the
effective date; or
(1i) Within 90 days of start-up in the case of a new source
which did not begin operation prior to the effective date.
(3) The Administrator shall be notified at least 30 days
prior to an emission test, so that he may at his option observe
the test.
(4) An owner or operator may carry out approved design,
maintenance, and housekeeping practices. Source testing
of the cell room will not be required, and a value of 1300 grams
of mercury per 24-hour period will be assigned to the emissions
from the cell room, thus allowing 1000 grams of mercury per
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24-hour period as combined emissions from the hydrogen gas
stream and end-box ventilation system. These two process gas
streams shall be tested in accordance with paragraph (b) of
this section. Information regarding approved design, maintenance,
and housekeeping practices may be obtained from the Administrator.
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APPENDIX A
National Emission Standards for Hazardous Air Pollutants
Compliance Status Information
I. SOURCE REPORT
Instructions: Owners or operators of AGENCY USE ONLY
sources of hazardous pollutants subject
to the National Emission Standards for
Hazardous Air Pollutants are required
to submit the information contained in
Section I to the appropriate Environ-
mental Protection Agency Regional Office
I I I I l l i I I I i i l I
i I i I I l l I I I i
within 90 days after the standards are promulgated. A listing of regional offices
is provided in § 61.04. ._ _ .. .
A. SOURCE INFORMATION. Complete the following information for every build-
ing or structure (source) containing a process (or processes) which emit
hazardous pollutants to the atmosphere.
1. Identification/Location - Indicate the name and address of the source
using hazardous pollutants.
I'll L
STREET ADDRESS
iti f > i i i t-- l i t i t- I l ii i i
CITY STATE ZIP CODE
i i i l i i i i i i i i t
COUNTY
2. Contact - Indicate the name and telephone number of the owner or
operator or other responsible official whom EPA may contact con-
cerning this report.
i i i I i i i t i i i i i i
NAME TELEPHONE
3. Source Description - Briefly state the nature of the source (e.g.,
"Chloralkali Plant", or "Machine Shop").
i i i I r i i i i i i i i r t i i i t i
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4. Alternative Mailing Address - Indicate an alternative mailing
address if correspondence is to be directed to a location different
than that specified above.
i ) i i ' i i I i i I I I ! I l i i 1 i i
STRETT ADDRESS
i i t i t
CITY STATE ZIP CODE
5. Compliance Status - The emissions from this source can | _ | cannot |
meet the emission limitations contained in the National Emission
Standards after (date which is 90-days after the promulgation of the
standards). i
Signature of owner, operator or other
responsible official
NOTE: If the emissions from the source will exceed those limits set
by the National Emission Standards for Hazardous Air Pollutants, the
source will be in violation and subject ±o Federal enforcement actions
unless granted a waiver of compliance by the Administrator of the
Environmental Protection Agency. The information needed for such
waivers is listed in Section II of this form. •
B. PROCESS INFORMATION. Part B should be completed separately for each
process within the source which emits a hazardous pollutant to the outside
air.
1. Process Description - Provide a brief description of each process
(e.g., "hydrogen end box" in a mercury chloralkali plant, "grinding
machine" in a beryllium machine shop). Use additional sheets if
necessary.
i i i i i i i i i i i t > i i t i i t i i t i ill
2. Pollutant Emitted - Indicate the type of hazardous pollutant emitted
by the process. Indicate "AB" for asbestos, "BE" for beryllium, or
"HG" for mercury.
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3. Amount of Pollutant - Indicate the average weight of the hazardous
pollutant named in item 2 which enters the process in pounds per
month (based on the previous twelve months of operation).
it
4. Control Devices
a. Indicate the type of pollution control devices, if any, used to
reduce the emissions from the process (e.g., venturi scrubber,
baghouse, wet cyclone) and the estimated percent of the pollutant
which the device removes from the process gas stream.
i i i i i i i t i i i i i > i t I i t ! . i
PRIMARY CONTROL DEVICE TYPE PERCENT REMOVAL EFFICIENCY
I i i > i i i I t i i i I I i i i i I . I
SECONDARY CONTROL DEVICE TYPE PERCENT REMOVAL EFFICIENCY
b. Asbestos Emission Control Devices Only
i. If a baghouse is specified in Item 4a give the following
information:
' • The air flow permeability in cubic feet per minute per
square foot of fabric area:
f\
Air flow permeability - _ cfm/ft
• The pressure drop in inches water gauge across the filter
at which the baghouse is operated
Operating pressure drop = ______ _ inches w.g.
• If the baghouse material contains synthetic fill yarn_
check wether this material is spun ( [ or not spun
• If the baghouse utilizes a felted fabric, give the
average thickness in inches and the density in ounces
per square yard.
Thickness = inches Density = oz/ydr
ii. If a wet collection device is specified in item 4a, give the
designed unit contacting energy in inches water gauge.
Unit contacting energy = inches w.g.
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II. WAIVER REQUESTS
1 1
1 1
AGENCY USE ONLY
1 i 1 i i , |
i i i r i i J
WAIVER OF COMPLIANCE. Owners or
operators of sources unable to
operate in compliance with the
National Emission Standards for
Hazardous Air Pollutants by (date
which is 90 days after the standards
are promulgated) may request a waiver of compliance from the Administrator
of the Environmental Protection Agency for the time period necessary to
install appropriate control devices or make modifications to achieve
compliance. The Administrator may grant such waivers, permitting a source
to operate while emitting hazardous pollutants in excess of the prescribed
standard for a period of not more than two years after the effective date
of the hazardous pollutant standards, if he finds that the time period is
necessary for the addition of control equipment.
The reporting information provided in Section I must accompany this
application. Applications should be sent to the appropriate EPA regional
office listed below.
1. Processes Involved - Indicate the process or processes emitting
hazardous pollutants to which emission controls are to be applied.
Controls
Describe the proposed type of control device to be added or
modification to be made to the process to reduce the emissions
of hazardous pollutants to an acceptable level. Use additional
sheets if necessary.
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Describe the measures to be taken during the waiver period
to control the emission of hazardous pollutants. Use addi-
tional sheets if necessary.
3. Increments of Progress - Certify the dates by which the following
increments of progress will be met.
• Date by which contracts for emission control systems or process
modifications will be awarded; or date by which orders will be
issued for-the purchase-of the component parts to accomplish
emission control or process modification.
:MONTH DAY YEAR
Date of initiation of on-site construction or installation of
emission control equipment or process change.
MONTH - DAY YEAR
Date by which on-site construction or installation of emission
control equipment or process modification is to be completed.
MONTH DAY YEAR
i
Date by which final compliance is to be achieved.
MONTH DAY YEAR
Signature of owner or operator i
B. WAIVER OF EMISSION TESTS. A waiver of emission testing may be granted
to owners or operators of sources of beryllium or mercury pollutants if,
in the judgment of the Administrator of the Environmental Protection
". Agency the emissions from the source comply with the appropriate standard
or if the owners or operators of the source have requested a waiver of
compliance.
This application should accompany the reporting information provided in
Section I.
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1. Reason - State the reasons for requesting a waiver of emission
testing. If the reason stated is that the emissions from the
source is within the prescribed limits, documentation of this
condition must be attached.
Date Signature of the owner or operator
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APPENDIX B - TEST METHODS
METHOD 101. REFERENCE METHOD FOR DETERMINATION OF PARTICULATE
AND GASEOUS MERCURY EMISSIONS FROM STATIONARY SOURCES
- (AIR STREAMS)
1. Principle and Applicability
1.1 Principle. Particulate and gaseous mercury emissions are
isokinetically sampled from the source and collected in acidic iodine
monochloride solution. The mercury collected (in the mercuric form)
is reduced to elemental mercury in basic solution by hydroxylamine
sulfate. Mercury is aerated from the solution and analyzed using
spectrophotometry.
1.2 Applicability. This method is applicable for the determination
of particulate and gaseous mercury emissions when the carrier gas
stream is principally air. The method is for use in ducts or stacks
at stationary sources. Unless otherwise specified, this method
is not intended to apply to gas streams other than those emitted
directly to the atmosphere without further processing.
2. Apparatus
2.1 Sampling train. A schematic of the sampling train used by
EPA is shown in Figure 101-1. Commercial models of this train
• i
... .
' are available, although construction details are described an
APTD-0581,* and operating and maintenance procedures are described
in APTD-0576. The components essential to this sampling train
are the following:
*These documents are available for a nominal cost from the National
Technical Information Service, U. S. Department of Commerce,
5285 Port Royal Road, Springfield, Virginia 22151.
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ACID
TRAP
HEATED AREA FILTER HOLDER THERMOMETER/ CHUCK
\ /(OPTIONAL)
P30BE
i TYPE S
-'PITOT TUBE
PITOT MANOMETER
ORIFICE
THERMOMETERS
VACUUM
GAUGE
MAIN VALVE
7
DRY TEST METER
Figure 101-1. Mercury sampling train
AIR-TIGHT
PUMP
VALVE
VACUUM
LINE
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3
2.1.1 Nozzle—Stainless steel or glass with sharp, tapered
leading edge.
2.1.2 Probe--Sheathed Pyrex* glass. A heating system
capable of maintaining a minimum gas temperature of 250° F at the
probe o'utlet during sampling may be used to prevent condensation from
occurring.
2.1.3 Pitot tube—Type S (Figure 101-2), or equivalent,
with a coefficient within 5% over the working range, attached
to probe to monitor stack gas velocity.
2.1.4 Impingers--Four Greenburg-Smith impingers connected in
series with glass ball joint fitting:;. The first, third and fourth
impingers may be modified by replacing the tip with a 1/2 inch ID glass
tube extending to 1/2 inch from the bottom of the flask. |
2.1.5 Acid Trap—Mine Safety Appliances Air Line Filter,
Catalogue Number 81857, with acid absorbing cartridge and suitable
connections, or equivalent.
2.1.6 Metering system--Vacuum gauge, leakless pump,
thermometers capable of measuring temperature to within 5°F, dry
gas meter with 2% accuracy, and related equipment, described in
APTD-0581, to maintain an isokinetic sampling rate and to determine
sample volume.
* Mention of trade names or specific products does not constitute
endorsement by the Environmental Protection Agency.
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PIPE COUPLING
TUBING ADAPTER
Figure 101-2. Pilot tube - manometer assembly..
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5
2.1.7 Filter Holder (optional)-Pyrex glass. A filter
may be used in cases where the gas stream to be sampled contains
large quantities of particulate matter. The filter holder must
provide a positive seal against leakage from outside or around the
filter. A heating system capable of maintaining the filter at a
. minimum temperature of 250°F should be used to prevent condensation
from occurring.
2.1.8 Barometer—To measure atmospheric pressure to +_ 0.1
in. Hg.
2.2 Measurement of stack conditions (stack pressure, temperature,
moisture and velocity).
2.2.1 Pitot tube—Type S, or equivalent, with a coefficient
within 5% over the working range.
2.2.2 Differential pressure gauge—Inclined manometer, or
equivalent, to measure velocity head to within 10% of the minimum
value. Micromanometers should be used if warranted.
2.2.3 Temperature gauger-Any temperature measuring device to
measure stack temperature to within 1°F.
2.2.4 Pressure gauge—Pitot tube and inclined manometer, or
equivalent, to measure stack pressure to within 0.1 in. Hg.
2.2.5 Moisture determination—Wet and dry bulb thermometers,
drying tubes, condensers, or equivalent, to determine stack gas
moisture content to within 1%.
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6
2.3 Sample Recovery.
2.3.1 Leakless glass sample bottles--500 ml. and 100 ml. with
Teflon lined tops.
2.3.2 'Graduated cylinder—250 ml.
2.3.3 Plastic jar--Approximately 300 ml.
2.4 Analysis.
2.4.1 Spectrophotometer--To measure absorbance at 253.7 nm.
Perkin Elmer Model 303, with a cylindrical gas cell (approximately 1.5
in. O.D. x 7 in.) with quartz glass windows, and hollow cathode source,
or equivalent.
2.4.2 Gas sampling bubbler-Tudor Scientific Glass Co.,
Smog Bubbler, Catalogue No. TP-1150, or equivalent.
2.4.3 Recorder—To mavch output of spectrophotometer.
3. Reagents
3.1 Stock Reagents.
3.1.1 Potassium iodide—Reagent grade.
3.1.2 Distilled water.
3.1.3 Potassium Iodide Solution, 25%--Dissolve 250 g. of
potassium iodide (reagent 3.1.1) in distilled water and dilute
to 1 1.
3.1.4 Hydrochloric acid—Concentrated.
3.1.5 Potassium iodate—Reagent grade.
3.1.6 Iodine monochloride (IC1) l.OM—To 800 ml. of 25%
t
potassium iodide solution (reagent 3.1.3), add 800 ml. of concentrated
hydrochloric acid. Cool to room temperature. With vigorous stirring,
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7
slowly add 135 g. of potassium iodate and continue stirring until
all free iodine has dissolved to give a clear orange-red solution.
Cool to room temperature and dilute to 1800 ml. with distilled
water. The solution should be kept in amber bottles to prevent
degradation.
3.1.7 Sodium hydroxide pellets—Reagent grade.
3.1.8 Nitric acid--Concentrated.
3.1.9 Hydroxylamine sulfate--Reagent grade.
3.1.10 Sodium chloride—Reagent grade.
3.1;11 Mercuric chloride—Reagent grade.
3.2 Sampling.
3.2.1 Absorbing solution, 0.1M ICl—Dilute 100 ml. of the
l.OM IC1 stock solution (reagent 3.1.6) to 1 1. with distilled water.
The solution should be kept in glass bottles to prevent degradation.
This reagent should be stable for at least two months; however,
periodic checks should be performed to ensure quality.
3.2.2 Wash acid—1:1 V/V nitric acid - water.
3.2.3 Distilled, deionized water.
3.2.4 Silica gel — Indicating type, 6 to 16 mesh, dried at
350°F for 2 hours.
3.2.5 Filter (optional)-Glass fiber, Mine Safety Appliances
1106BH, or equivalent. A filter may be necessary in cases where
the gas stream to be sampled contains large quantities of
particulate matter.
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3.3 Analysis
3.3.1 Sodium Hydroxide, 10 N--Dissolve 400 g. of sodium
hydroxide pellets in distilled water and dilute to 1 1.
3.3.2 Reducing agent, 12% hydroxylamine sulfate, 12% sodium
chloride—To 60 ml. of distilled water, add 12 g. of hydroxylamine
sulfate and 12 g. of sodium chloride. Dilute to 100 ml. This
.quantity is sufficient for 20 analyses and must be prepared daily.
3.3.3 Aeration gas--Zero grade air.
3.3.4 Hydrochloric acid, 0.3N--Dilute 25.5 ml. of concentrated
hydrochloric acid to 1 1. with distilled water..
3.4 Standard Mercury Solutions.
3.4.1 Stock solution--Add 0.1354 g. of mercuric chloride
to 80 ml. of 0.3N hydrochloric acid. After the mercuric chloride has
dissolved, add 0.3N hydrochloric acid and adjust the volume to
100 ml. One ml. of this solution is equivalent to 1 mg. of free
mercury.
3.4.2 Standard solutions—Prepare calibration solutions by
serially diluting the stock solution (3.4.1) with 0.3N hydrochloric
acid. Prepare solutions at concentrations in the linear working
range for the instrument to be used. Solutions of 0.2 yg/ml.,
0.4 yg/ml. and 0.6 yg/ml. have been found acceptable for most
instruments. Store all solutions in glass-stoppered, glass
t
bottles. These solutions should be stable for at least two months;
however, periodic checks should be performed to ensure quality.
-------
4. Procedure
4.1 Guidelines for source testing are detailed in the following
sections. These guidelines are generally applicable; however,
most sample sites differ to some degree and temporary alterations
such as stack extensions or expansions often are required to ensure
the best possible sample site. Further, since mercury is hazardous,
care should be taken to minimize exposure. Finally, since the total
quantity -of mercury to be collected generally is small, the test must
be carefully conducted to prevent contamination or loss of sample.
4.2 Selection of a sampling site and minimum number of
traverse points.
4.2.1 Select a suitable sampling site that is as close
as is practicable to the point of atmospheric emission. If possible,
stacks smaller than 1 foot in diameter should not be sampled.
4.2.2 The sampling site should be at least.eight stack
or duct diameters downstream and two diameters upstream from any
flow disturbance such as a bend, expansion or contraction. For
a rectangular cross section, determine an equivalent diameter
from the following equation:
De = 2LW eq. 101-1
L+W
where:
De = equivalent diameter
L = length
W = width
-------
- 10
4.2.3 When the above sampling site criteria can be met,
the minimum number of traverse points is four (4) for stacks- 1 foot in
diameter of less, eight (8) for stacks larger than 1 foot but 2 feet in
diameter or less, and twelve (12) for stacks larger than 2 feet.
4.2.4 Some sampling situations may render the above sampling
site criteria impractical. When this is the case, choose a
convenient sampling location and use Figure 101-3 to determine the
minimum number of traverse points. However, use Figure 101-3
only for stacks 1 foot in diameter or larger.
4.2.5 To use Figure 101-3, first measure the distance from
the chosen sampling location to the nearest upstream and downstream
distrubances. Divide this distance by the diameter or equivalent
diameter to determine the distance in terms of pipe diameters.
Determine the corresponding number of traverse points for each .
distance from Figure 101-3. Select the higher of the two numbers
of traverse points, or a greater value, such that for circular
stacks the number is a multiple of four, and for rectangular stacks
the number follows the criteria of section 4.3.2.
4.2.6 If a selected sampling point is closer than one inch
from the stack wall, adjust the location of that point to ensure
that the sample is taken at least one inch away from the wall.
4.3 Cross-sectional-layout and location of traverse points.,
4.3.1, For circular stacks locate the traverse points on
i
at least two diameters according to Figure 101-4 and Table 101-1. The
traverse axes shall divide the stack cross section into equal parts.
-------
0.5
50
40
30
20
1.0
NUMBER OF DUCT DIAMETERS UPSTREAM"
(DISTANCE A)
1.5 2.0
2.5
O
a.
UJ
CO
cc
UJ
K.
UJ
CO
y|
A
<
J
E
1
i
5
-,
4
1
4
/DISTURBANCE
•
L SAMPLING
SITE
DISTURBANCE
Eb
10
'FROM POINT OF ANY TYPE OF
DISTURBANCE (BEND, EXPANSION, CONTRACTION. ETC.)
NUMBER OF DUCT DIAMETERS DOWNSTREAM'
(DISTANCE B)
10
Figure 101-3. Minimum number of traverse points.
-------
Table 101-1. Location of traverse points in circular stacks
(Percent of stack diameter from inside wall to traverse point)
Traverse
point
number
on a
diameter
1
2
3
4
5
6
7
8
9
10
11
- 12
13
14
15
16
17
18 '
19"
20
21
22
23
24
Number of traverse points on a diameter
2
14.6
85.4
4
6.7
25.0
75.0
93.3
«•
6
4.4
14.7
29.5
70.5
85.3
95.6
8
3.3
10.5
19.4
32.3
67.7
80.6
89.5
96.7
10
2.5
8.2
14.6
22.6
34.2
65.8
77.4
85.4
91.8
97.5
12
2.1
6.7
11.8
17.7
25.0
35.5.
64.5
75.0
82.3
88.2
93.3
97.9
14
1.8
5.7
9.9
14.6
20.1
26.9
36.6
63.4
73.1
79.9
85.4
90.1
94.3
98.2
16
1.6
4.9
8.5
12.5
16.9
22.0
28.3
37.5
62.5
71.7
78.0
83.1
87.5
91.5
95.1
98.4
18
1.4
4.4
7.5
10.9
14.6
18.8
23.6
29.6
38.2
61.8
70.4
76.4
81.2
85.4
89.1
92.5
95.6
98.6
20
1.3
3.9
6.7
9.7
12.9
16.5
20.4
25.0
30.6
38.8
61.2
69.4
75.0
79.6
83.5
87.1
90.3
93.3
96.1
98.7
22
1.1
3.5
6.0
8.7
11. f
14.6
18.0
21.8
-26.1
31.5
39.3
60.7
68.5
73.9
78.2
82.0
85.4
88.4
91.3
94.0
96.5
98.9
t
24
1.1
3.2
5.5
7.9
10.5
13.2
16.1
19.4
23.0
27.2
32.3
39.8
60.2
67.7"
72.8
77.0
80.6
83.9
86.8
89.5
92.1
94.5
96.8
98.9
-------
Figure 101-4. Cross section of circular stack showing location of
traverse points on perpendicular diameters.
o
••
o
1
o
i
' 0 ' 0
1
1
1
r i
i
0 | 0
1
I
r r - i
i
i
O | O
1
1
1
0
o
r
o
Figure 101-5. Cross section of rectangular stack divided into 12 equal
areas, with traverse points at centroid of each area.
-------
14
4.3.2 For rectangular stacks divide the cross section into
as many equal rectangular areas as traverse points, such that the ratio '
of the length to the width of the elemental areas is between one and
two. Locate the traverse points at the centroid of each equal area
according to Figure 101-5.
4.4 Measurement of stack conditions.
4.4.1 Set up the apparatus as shown in Figure 101-2. Make
sure all connections are tight .and leak-free. Measure the velocity'
head and temperature at the traverse points specified by section
/.2 and 4.3.
4.4.2 Measure the static pressure in the stack.
4.4.3 Determine the stack gas moisture.
4.4.4 Determine the stack gas molecular weight from the
measured moisture content and knowledge of the expected gas stream
composition. A standard Orsat analyzer has been found, valuable at
combustion sources. In all cases, sound engineering judgement should
be used.
4.5 Preparation of sampling train.
4.5.1 Prior to assembly, clean all glassware (probe, impingers,
and connectors) by rinsing with wash acid, tap water, 0.1M IC1, tap
water, and finally distilled water. Place 100 ml. of 0.1M I.C1 in each
of the first three impingers, and place approximately 200 g. of preweighed
silica gel in the fourth impinger. Save 80 ml. of the 0.1M IC1 as a blank
in the sample analysis. Set up the train and the probe as in Figure
101-1.
-------
15
4.5.2 If the gas stream to be sampled is excessively dirty
or moist, the first impinger may clog or become dilute too rapidly
for sufficient testing. A filter can be placed ahead of the
impingers to collect the particulates. An initial empty impinger
may also be used to remove excess moisture. If a fifth impinger
is required, the final impinger may have to be carefully taped to the
outside of the sample box.
4.5.3 Leak check the sampling train at the sampling site.
The leakage rate should not be in excess of 1% of the desired
sampling rate. If condensation in the probe or filter is a problem,
probe and filter heaters will be required. Adjust the heaters to
/
provide a temperature of at least 250°F. Place crushed ice around
i
the impingers. Add more ice during the test to keep the temperature
of the gases leaving the last impinger at 70°F or less.
4.6 Mercury train operation.
4.6.1 For each run, record the data required on the
example sheet shown in Figure 101-6. Take readings at each sampling .
point at least every five minutes and when significant changes in
stack conditions necessitate additional adjustments in flow rate.
4.6.2 Sample at a rate of 0.5 to 1.0 cfm. Samples shall be
taken over such a period or periods as are necessary to accurately
determine the maximum emissions which would occur in a 24-hour period.
In the case of cyclic operations, sufficient tests shall be made so as to
i
allow accurate determination or calculation of the emissions which will
occur over the duration of the cycle, A minimum sample time of 2 hours
-------
PLANT
LOCATION.
OPERATOR.
DATE
RUN NO.
SAMPLE BOX NO._
METER BOX NO._
METERAH^
C FACTOR
AMBIENT TEMPERATURE,
BAROMETRIC PRESSURE.
ASSUMED MOISTURE. %_
HEATER BOX SETTING ,_
PROBE LENGTH, m..
NOZZLE DIAMETER, in. _
PROBE HEATER SETTING.
SCHEMATIC OF STACK CROSS SECTION
TRAVERSE POINT
NUMBER
TOTAL
AVERAGE
SAMPLING
TIME
(e). min.
STATIC
PRESSURE
(Ps). in. Hfj.
STACK
TEMPERATURE
-------
is recommended. In some instances, high mercury concentrations can
prevent sampling in one run for the desired minimum time. This is
indicated by reddening in the fii-st impinger as free iodine is
liberated. In this case, a run may be divided into two or more
sub-runs to ensure that the absorbing solutions are not depleted.
4.6.3 To begin sampling, position the nozzle at the first
traverse point with the tip pointing directly into the gas stream.
Immediately start the pump and.adjust the flow to isokinetic conditions.
Sample for at least 5 minutes at each traverse point; sampling time
.must be the same for each point. Maintain isokinetic sampling throughout
the sampling period. Nomographs which aid in the rapid adjustment of
the sampling rate without other computations are in APTD-0576 and are
available from commercial suppliers. Note that standard nomograplis
are applicable only for Type S pitot tubes and air or a stack gas with
an equivalent density. Contact EPA or the sampling train supplier for
instructions when the standard nomograph is not applicable.
4.6.4 Turn off the pump at the conclusion of each run
and record the final readings. Immediately remove the probe and
nozzle from the stack and handle in accordance with the sample
recovery process described in section 4.7.
4.7 Sample recovery.
4.7.1 (All glass storage bottles and the graduated cylinder must
be precleaned as in section 4.5.1). This operation should be performed
in an area free of possible mercury contamination. Industrial laboratories
and ambient air around mercury-using facilities are not normally free of
-------
18
mercury contamination. When the sampling train is moved, care must be
exercised to prevent breakage and contamination.
4.7.2 Disconnect the probe from the impinger train.
Place the contents (measured to ^ 1 ml.) of the first three
impingers into a 500 ml. sample bottle. Rinse the probe and all
glassware between it and the back half of the third impinger with
two 50 ml. portions of 0.1M IC1 solution. Add these rinses to
the first sample bottle. For a blank, place 80 ml. of the 0.1M IC1
in a 100 nl. sample bottle. If used, place the filter along with
100 ml. o:c 0.1M IC1 in another 100 ml. sample bottle. Retain a filter
blank. Place the silica gel in the plastic jar. Seal and secure all
containers for shipment. If an additional test is desired, the glass-
ware can be carefully double rinsed with distilled water and reassembled.
However, if the glassware is to be out of use more than two days, the
initial acid wash procedure must be followed.
4.8 Analysis.
4.8.1 Apparatus preparation—Clean all glassware according
to the procedure of section 4.5.1. Adjust the instrument settings
according.to the instrument manual, using an absorption wavelength
of 253.7 nm.
4.8.2 Analysis preparation--Adjust the air delivery pressure
and the needle valve to obtain a constant air flow of about 1.3 l./min.
The analysis tube should be bypassed except during aeration. Purge the
r
equipment for 2 minutes. Prepare a sample of mercury standard solution
(3.4.2) according to section 4.8.3. Place the analysis tube in
-------
19
the line, and aerate until a maximum peak height is reached on the
recorder. Remove the analysis tube, flush the lines, and rinse
the analysis tube with distilled water. Repeat with another
sample of the same standard solution. This purge and" analysis
cycle is to be repeated until peak heights are reproducible.
4.8.3 Sample preparation--Just prior to analysis, transfer
a sample aliquot of up to 50 ml. to the cleaned 100 ml. analysis tube.
Adjust the volume to 50 ml. with 0.1M IC1 if required. Add 5 ml.
of 10 N sodium hydroxide, cap tube with a clean glass stopper and shake
vigorously. Prolonged, vigorous shaking at this point is necessary
to obtain an accurate analysis. Add 5 ml. of the reducing agent
(reagent 3.3.2), cap tube with a clean glass stopper and shake
vigorously and immediately in sample line.
4.8.4 Mercury determination—After the system has been
stabilized, prepare samples from the sample bottle according
to section 4.8.3. Aerate the sample until a maximum peak height
is reached on the recorder. The mercury content is determined
by comparing the peak heights of the samples to the peak heights of
the calibration solutions. If collected samples are out of the
linear range, the samples should be diluted. Prepare a blank
from the 100 ml. bottle according to section 4.8.3 and analyze
to determine the reagent blank mercury level.
5. Calibration
5.1 Sampling Train.
-------
20
5.1.1 Use standard methods and equipment as detailed in
APTD-0576 to calibrate the rate meter, pitot tube, dry gas meter,
and probe heater (if used). Recalibrate prior to each test series.
5.2 Analysis.
5.2.1 Prepare a calibration curve for the spectrophotometer
using the standard mercury solutions. Plot the peak heights read
on the recorder versus the concentrations of mercury in the
standard solutions. Standards should be interspersed with
the samples since the calibration can change slightly with time.
A new calibration curve should be prepared for each new set of
samples run.
6. Calculations
6.1 Average dry gas meter temperature, stack temperature,
stack pressure and average orifice pressure drop. See data sheet
(Figure 101-6).
.6.2 Dry gas volume. Correct the sample volume measured by
the dry gas meter to stack conditions by using equation 101-2.
Vms = Vm Ts (pbar + ^M eq. 101-2
where: Vm = volume of gas sample through the dry gas meter
(stack conditions),
Vm = volume of gas sample through the dry gas meter
(meter conditions), ft .
TS = average temperature of stack gas, °R.
Tm = average dry gas meter temperature, °R.
-------
21
P. = barometric pressure at the orifice meter, in. Hg.
AH = average pressure drop across the orifice meter,
in. H20.
13.6 = specific gravity of mercury.
Ps = stack pressure, P, +_ static pressure, in. Hg.
6.3 Volume of water vapor.
vws = *w Vlc Ts eq. 101-3
where:
Vw = volume of water vapor in the gas sample (stack conditions),
ft 3.
Kw = 0.00267 in.Hg.-ft3, when these units are used.
ml.-"R
Vj = total volume of liquid collected in impingers
and silica gel (see Figure 101-7), ml.
Ts = average stack gas temperature, °R.
Ps = stack pressure, P. +_ static pressure, in. Hg.
6.4 Total gas volume.
V* «. , = Vm + Vw eq. 101-4
total ms ws n
where :
V n = total volume of gas sample (stack conditions), ft^.
tO t Sx
m = volume of gas through dry gas meter (stack conditions),
V
Vw = volume of water vapor in gas sample (stack conditions), ft .
-------
i---_iu~::uj»_I_t/_. -~iaitii*t ._
FINAL
INITIAL
LIQUID COLLECTED
TOTAL VOLUME COLLECTED
VOLUME OF LIQUID
WATER COLLECTED
IMPINGER
VOLUME.
ml
SILICA GEL
WEIGHT.
g
9* ml
•CONVERT WEIGHT OF WATER TO VOLUME BY dividing total weight
INCREASE BY DENSITY OF WATER. (1 g/ml):
- 9 = VOLUME WATER, ml
g/ml)
Figure 101-7. Analytical data.
-------
23
6.5 Stack gas velocity.
Use equation 101-5 to calculate the stack gas velocity.
- KpCp w^avg. l/^s'ayg. eq. 101-5
PSMS
where:
(vs) = average stack gas velocity, feet per second.
KD = 85.53 ft. / lb.-in.Hg \ ' , when these units are used.
- ( lb.-in.Hg V
sc. ^lb.mole-"R-in.H20/
sec.
Cp = pitot tube coefficient, dimensionless.
(Ts) = average stack gas temperature, °R.
= average square root of the velocity head of stack
1/2
gas, (in. H20) ' (see Fig. 101-8).
Ps = stack pressure, P. +_ static pressure, in. Hg.
summation of the products of the molecular weight of
each component multiplied by its volumetric proportion
in the mixture, Ib./lb. mole.
Figure 101-8 shows a sample recording sheet for velocity traverse
data. Use the averages in the last two columns of Figure 101-8
to determine the average stack gas velocity from equation 101-5.
6.6 Mercury collected. Calculate the total weight of mercury
collected by using eq. 101-6.
Wt = V^j - VbCb (+VfCf) eq. 101-6
where:
Wt = total weight of mercury collected, yg.
-------
PLANT.
DATE
RUN NO.
STACK DIAMETER, in.
BAROMETRIC PRESSURE, in. Hg.
STATIC PRESSURE IN STACK (Pg), in. Hg.
OPERATORS
SCHEMATIC OF STACK
CROSS SECTION
Traverse point
number
Velocity head,
in. H20
Stack Temperature
-------
25
Vj = total volume of condensed moisture and IC1 in sample bottle, ml.
GI = concentration of mercury measured in sample bottle, yg/ml.
Vjj = total volume of IC1 used in sampling (impinger contents
and all wash amounts), ml.
0^ = blank concentration of mercury in IC1 solution, yg/ml.
Y£ = total volume of IC1 used in filter bottle (if used), ml.
Cf = concentration of mercury in filter bottle (if used), yg/ml.
6.7 Total mercury emission. Calculate the total amount of mercury
emitted from each stack per day by eq. 101-7. This equation is applicable
for continuous operations. For cyclic operations, use only the time per
day each stack is in operation. The total mercury emissions from a source
will be the summation of results from all stacks.
R = Wt (vc) Ac 86400 seconds/day eq . 101-7
'
_ _
Vtotal 106yg/g.
where:
R = rate of emission, g./day.
Wf. = total weight of mercury collected, yg.
V = total volume of gas sample (stack conditions), ft .
(vs) = average stack gas velocity, feet per second.
2
As = stack area, ft .
6.8 Isokinetic variation (comparison of velocity of gas in
probe tip to stack velocity) .
Vtotal eq. 101-8
-------
26
where:
I = percent of isokinetic sampling.
V . = total volume of ^Gjsssiple (stack conditions), ft .
2
A = probe tip area, ft .
0 = sampling time, sec. r--.
(vs) = average stack gas velocity, feet per second.
7. Evaluation of Results
*
7.1 Determination of Compliance.
7.1.1 Each performance test shall consist of three
repetitions of the applicable test method. For the purpose of
determining compliance with an applicable national emission standard,
the average of results of all repetitions shall apply.
-------
27
7.2 Acceptable Isokinetic Results
7.2.1 The following range sets the limit on acceptable
isokinetic sampling results:
If 90% <_ I <_ 110%, the results are acceptabl'e; otherwise,
reject the test and repeat.
-------
28
8. References
1. Addendum to Specifications for Incinerator Testing at Federal
Facilities, PHS, NCAPC, December 6, 1967.
2. Determining Dust Concentration in a Gas Stream, ASME Performance
+
Test Code #27, New York, New York, 1957.
3'. Devorkin, Howard, et al., Air Pollution Source Testing Manual,
Air Pollution Control District, Los Angeles, Calif., November 1963.
4. Hatch, W. R. and W. L. Ott, "Determination of Sub-Microgram
Quantities of Mercury by Atomic Absorption Spectrophotometry,"
Anal. Chem., 40:2085-87, 1968.
5. Mark, L. S., Mechanical Engineers' Handbook, McGraw-Hill Book
Company, Inc., New York, New York, 1951.
6. Martin, Robert M., Construction Details of Isokinetic Source
Sampling Equipment, Environmental Protection Agency, APTD-0581.
7. Methods for Determination of Velocity, Volume, Dust and Mist
Content of Gases, Western Precipitation Division of Joy Manufacturing
Co., Los Angeles, Calif. Bulletin WP-50, 1968.
8. Perry, J. H., Chemical Engineers' Handbook, McGraw-Hill Book
Company, Inc., New York, New York, 1960.
9. Rom, Jerome J., Maintenance, Calibration, and Operation of
Isokinetic Source Sampling Equipment, Environmental Protection Agency,
APTD-0576.
10. Shigehara, R. T., W. F. Todd, and W. S. Smith, Significance of
Errors in Stack Sampling Measurements, Paper presented at the Annual
Meeting of the Air Pollution Control Association, St. Louis, Missouri,
June 14-19, 1970.
-------
29
11. Smith, W. S., et al., Stack Gas Sampling Improved and
Simplified with New Equipment, APCA paper No. 67-119, 1967.
12. Smith, W. S., R. T. Shigehara, and W. F. Todd, A Method of
+
Interpreting Stack Sampling Data, Paper presented at the 63rd
Annual Meeting of the Air Pollution Control Association, St. Louis,
Missouri, June 14-19, 1970.
13. Specifications for Incinerator Testing at Federal Facilities
PHS, NCAPC, 1967.
14. Standard Method for Sampling Stacks for Particulate Matter,
In: 1971 Book of ASTM Standards, Part 23, Philadelphia, 1971, ASTM
Designation D-2928-71.
15; Vennard, J. K., Elementary Fluid Mechanics, John Wiley and Sons,
Inc., New York, 1947.
-------
METHOD 102. REFERENCE METHOD FOR DETERMINATION OF PARTICIPATE AND
GASEOUS MERCURY EMISSIONS FROM STATIONARY SOURCES
(HYDROGEN STREAMS)
."'»'" -T f
1. Principle and Applicability
1.1 Principle. Particulate and gaseous mercury emissions are
isokinetically sampled from the source and collected in acidic iodine
monochloride solution. The mercury collected (in the mercuric form)
is reduced to elemental mercury in basic solution by hydroxylamine
sulfate. Mercury is aerated from the solution and analyzed using
spectrophotometry.
1.2 Applicability. This method is applicable for the determination
of particulate and gaseous mercury emissions when the carrier gas
stream, is T>rincir>2l!y hy^T^g^p. Thp. method is for use in ducts or
stacks at stationary sources. Unless otherwise specified, this
method is not intended to apply to gas streams other than those
emitted directly to the atmosphere without further processing.
2. Apparatus
2.1 Sampling train. A schematic of the sampling train used
by EPA is shown in Figure 102-1. Commercial models of this train
are available, although complete construction details are described
in APTD-0581* and operating and maintenance procedures are described
in APTD-0576. The components essential to this sampling train
These documents are available for a nominal cost from the National
Technical Information Service, U. S. Department of Commerce,
5285 Port Royal Road, Springfield, Virginia 22151.
-------
ACID
TRAP
THERMOMETERCHECK
VALVE
PROBE 1
TYPES /
PITOT TUBE
~l
ORIFICE \J \~J.
THERMOMETERS
VACUUM
GAUGE
MAIN VALVE
DRY TEST METER AIR-TIGHT
PUMP _
VACUUM
LINE
Figure 102-1. Mercury sampling train
-------
32
are the following:
2.1.1 Nozzle—Stainless steel or glass with sharp, tapered
leading edge.
2.1.2 Probe--Sheathed Pyrex* glass.
2.1.3 Pitot tube—Type S (Figure 102-2), or equivalent,
with a coefficient within 5% over the working range, attached to
probe to monitor stack gas velocity.
2.1.4 Impingers--Four Greenburg-Smith impingers connected in
series with glass ball joint fittings. The first, third and fourth
impingers may be modified by replacing the tip with a 1/2 inch
ID glass tube extending to 1/2 inch from the bottom of the flask.
2.1.5 Acid Trap-Mine Safety Appliances Air Line Filter,
Catalogue Number 81857, with acid absorbing cartridge and suitable
connections, or equivalent.
2.1.6 Metering system--Vacuum gauge, leakless pump,
thermometers capable of measuring temperature to within 5°F, dry
gas meter with 2% accuracy, and related equipment, described in
APTD-0581, to maintain an isokinetic sampling rate and to determine
sample volume.
2.1.7 Barometer--To measure atmospheric pressure to +_ 0.1
in. Hg.
*Mention of trade names or commerical products does not constitute
endorsement by the Environmental Protection Agency.
-------
PIPE COUPLING
TUBING ADAPTER
Figure 102-2. Pilot tube -manometer assembly
-------
34
2.2 Measurement of stack conditions (stack pressure, temperature,
moisture and velocity).
2.2.1 Pitot tube—Type S, or equivalent, with a coefficient
within 5% over the working range.
2.2.2 Differential pressure gauge—Inclined manometer, or
equivalent, to measure velocity head to within 10% of the minimum
value. Micromanometers should be used if warranted.
2.2.3 Temperature gauge—Any temperature measuring device
to measure stack temperature to within 1°F.
2.2.4 Pressure gauge--Pitot tube and inclined manometer,
or equivalent, to measure stack pressure to within 0.1 in. Hg.
2.2.5 Moisture Determination--Drying tubes, condensers,
or equivalent, to determine stack gas moisture content in hydrogen
to within 1%.
2.3 Sample Recovery.
2.3.1 Leakless glass sample bottles—500 ml. and 100 ml.
with Teflon lined tops.
2.3.2 Graduated cylinder--250 ml.
2.3.3 Plastic jar--Approximately 300 ml.
2.4 Analysis.
•
2.4.1 Spectrophotometer—To measure absorbance at 253.7 nm.
Perkin Elmer Model 303, with a .cylindrical gas cell (approximately
1.5 in. O.D. x 7 in.) with quartz glass windows, and hollow cathode
source, or equivalent.
-------
35
2.4.2 Gas sampling bubbler-Tudor Scientific Co.
Smog Bubbler, Catalogue No. TP-1150, or equivalent.
2.4.3 Recorder--To match output of spectrophotometer.
3. Reagents
3.1 Stock Reagents.
3.1.1 Potassium iodide--Reagent grade.
3.1.2 Distilled water.
3.1.3 Potassium Iodide solution, 25%--Dissolve 250 g. of
potassium iodide (reagent 3.1.1) in distilled water and dilute to
1 1.
3.1.4 Hydrochloric acid—Concentrated.
3.1.5 Potassium iodate--Reagent grade.
3.1.6- Iodine monochloride (IC1) 1.0M--To 800 ml. of 25%
potassium iodide solution (reagent 3.1.3), add 800 ml. of concentrated
hydrochloric acid. Cool to room temperature. With vigorous stirring,
slowly add 135 g. of potassium iodate and continue stirring until
all free iodine has dissolved to give a clear orange-red solution.
Cool to room temperature and dilute to 1800 ml. with distilled water.
The solution should be kept in amber bottles to prevent degradation.
3.1.7 Sodium hydroxide pellets—Reagent grade.
3.1.8 Nitric acid—Concentrated.
3.1.9 Hydroxylamine sulfate—Reagent grade.
3.1.10 Sodium chloride--Reagent grade.
3.1.11 Mercuric chloride—Reagent grade.
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36
3.2 Sampling.
3.2.1 Absorbing solution, 0.1M ICl-Dilute 100 ml. of the
l.OM IC1 stock solution (reagent 3.1.6) to 1 1. with distilled water.
The solution should be kept in glass bottles to prevent degradation.
This reagent should be stable for at least two months; however,
periodic checks should be performed to ensure quality.
3.2.2 Wash acid--l:l V/V nitric acid-water.
3.2.3 Distilled, deionized water.
3.2.4 Silica gel — Indicating type, 6 to 16 mesh, dried at
350°F for 2 hours.
3.3 Analysis.
3.3.1 Sodium hydroxide, 10 N--Dissolve 400 g. of sodium hydroxide
3.3.2 Reducing agent, 12% hydroxylamine sulfate, 12% sodium
chloride--To 60 ml. of distilled water, add 12 g. of hydroxylamine
sulfate and 12 g. of sodium chloride. Dilute to 100 ml. This quantity
is sufficient for 20 analyses and must be prepared daily.
3.3.3 Aeration gas--Zero grade air. ,
3.3.4 Hydrochloric acid, 0.3N--Dilute 25.5 ml. of concentrated
hydrochloric acid to 1 1. with distilled water.
3.4 Standard mercury solutions.
3.4.1 Stock solution—Add 0.1354 g. of mercuric chloride
to 80 ml. of 0.3N hydrochloric acid. After the mercuric chloride
has dissolved, add 0.3N hydrochloric acid and adjust the volume to
100 ml. One ml. of this solution is equivalent to 1 mg. of free mercury.
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37
3.4.2 Standard solutions—Prepare calibration solutions by
serially diluting the stock solution (3.4.1) with 0.3N hydrochloric
acid. Prepare solutions at concentrations in the linear working
range for the instrument to be used. Solutions of 0.'2 yg/ml.,
0.4 yg/ml. and 0.6 yg/ml. have been found acceptable for most
instruments. Store all solutions in glass-stoppered, glass bottles.
These solutions should be stable for at least two months; however,
periodic checks should be performed to ensure quality.
4. Procedure
4.1 Guidelines for source testing are detailed in the following
sections. These guidelines are generally applicable; however,
most sample sites differ to some degree and temporary alterations such
as stack extensions or expansions often are required to ensure the
best possible sample site. Further, since mercury is hazardous, care
should be taken to minimize exposure. Finally, since the total quantity
of mercury to be collected generally is small, the test must be carefully
conducted to prevent contamination or loss of sample.
4.2 Selection of a sampling site and minimum number of traverse
points.
4.2.1 Select a suitable sampling site that is as close as
is practicable to the point of atmospheric emission. If possible,
stacks smaller than 1 foot in diameter should not be sampled.
4.2.2 The sampling site should be at least eight stack
or duct diameters downstream and two diameters upstream from any
flow disturbance such as a bend, expansion or contraction. For
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38
rectangular cross section, determine an equivalent diameter from
the following equation:
De = 2LW eq. 102-1
L+W
where:
De = equivalent diameter
L = length
W = width
4.2.3 When the above sampling site criteria can be met,
the minimum number of traverse points is four (4) for stacks 1 foot
in diameter or less, eight (8) for stacks larger than 1 foot but
2 feet in diameter or less, and twelve (12) for stacks larger than
2 feet.
4.2.4 Some sampling situations may render the above sampling
site criteria impractical. When this is the case, choose a
convenient sampling location and use Figure 102-3 to determine the
minimum number of traverse points. However, use Figure 102-3 only
for stacks 1 foot in diameter or larger.
4.2.5 To use Figure 102-3, first measure the distance from
the chosen sampling location to the nearest upstream and downstream
disturbances. Divide this distance by the diameter or equivalent
diameter to determine the distance in terms of pipe diameters.
Determine the corresponding number of traverse points for each
distance from Figure 102-3. Select the higher of the two numbers
-------
0.5
50
40
30
20
10
1.0
NUMBER OF DUCT DIAMETERS UPSTREAM'
(DISTAMCE A)
1.5 2.0
2.5
CO
O
Q_
LU
CO
cc
cc
LU
CO
•FROM POINT OF ANY TYPE OF
DISTURBANCE (BEND. EXPANSION, CONTRACTION. ETC.)
X
T
A
A
I
B
I
1
|
1
^
7 DISTURBANCE
_ SAMPLING
SITE
DISTURBANCE
10
NUMBER OF DUCT DIAMETERS DOWNSTREAM'
(DISTANCE B)
Figure 102-3. Minimum number of traverse points.
-------
40
of traverse points, or a greater value, such that for circular
stacks the number is a multiple of four, and -for rectangular
stacks the number follows the criteria of section 4.3.2.
*
4.2.6 If a selected sampling point is closer than one
inch from stack wall, adjust the location of that point to ensure
that the sample is taken at least one inch away from the wall.
4.3 Cross-sectional layout and location of traverse points.
4.3.1 For circular stacks locate the traverse points
on at least two diameters according to Figure 102-4 and Table 102-1.
The traverse axes shall divide the stack-cross section into equal
parts .
4.3.2 For rectangular stacks divide the cross-section into
•"**««,/
ratio of the length to the width of the elemental areas is between
one and two. Locate the traverse points at the centroid of each
equal area according to Figure 102-5.
4.4 Measurement of stack conditions.
4.4.1 Set up the apparatus as shown in Figure 102-2. Make
sure all connections are tight and leak free. Measure the velocity
head and temperature at the traverse points specified by section
4.2 and 4.3.
4.4.2 Measure the static pressure in the stack.
4.4.3 Determine the stack gas moisture.
-------
• •->-
Figure 102-4. Cross section of circular stack showing location of I
traverse points on perpendicular diameters. j
o
—
o
1
o
1 J— -'
1
• • : •
i
i _
r I
i
0 | 0
!
r- -r T - -i
1
0 1 0
1
1
1 1 1
o
o
r
o
Figure 102-5. Cross section of rectangular stack divided into 12 equal •
areas, with traverse points at centroid of each area.
-------
Table 102-1. Location of traverse points in circular stacks
(Percent of stack diameter from inside wall to traverse point)
Traverse
point
number
on a
diameter
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Number of traverse points on a diameter
2
14.6
85.4
4
6.7
25.0
75.0
93.3
'
6
4.4
14.7
29.5
70.5
85.3
95.6
8
3.3
10.5
19.4
32.3
67.7
80.6
89.5
96.7
10
2.5
8.2
14.6
22.6
34.2
65.8
77.4
85.4
91.8
97.5
.
12
2.1
6.7
11.8
17.7
25.0
35.5
64.5
T r-. r\
/ ^ .U
82.3
88.2
93.3
97.9
14
1.8
5.7
9.9
14.6
20.1
26.9
36.6
63.4
73.1
79.9
85.4
90.1
94.3
98.2
16
1.6
4.9
8.5
12.5
16.9
22.0
28.3
37.5
62.5
71.7
78.0
83.1
87.5
91.5
95.1
98.4
18
1.4
4.4
7.5
10.9
14.6
18.8
23.6
f\r\ r
C.3 . u
38.2
61.8
70.4
76.4
81.2
85.4
89.1
92.5
95.6
98.6
20
1.3
3.9
6.7
9.7
12.9
16.5
20.4
or n
30.6
38.8
61.2
69.4
75.0
79.6
83.5
87.1
90.3
93.3
96.1
98.7
22
1.1
3.5
6.0
8.7
11.6
14.6
18.0
01 O
b. 1 • O
26.1
31.5
39.3
60.7
68.5
73.9
78.2
82.0
85.4
88.4
91.3
94.0
96.5
98.9
24
1.1
3.2
5.5
7.9
10.5
13.2
16.1
19.4
23.0
27.2
32.3
39.8
60.2
67.7°
72.8
77.0
80.6
83.9
86.8
89.5
92.1
94.5
96.8
98.9
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43
4.4.4 Determine the stack gas molecular weight from the
measured moisture content and knowledge of the expected gas stream
composition. Sound engineering judgement should be used.
*
4.5 Preparation of sampling train.
4.5.1 Prior to assembly, clean all glassware (probe, impingers,
and connectors) by rinsing with wash acid, tap water, 0.1M IC1, tap
water, and finally distilled water. Place 100 ml. of 0.1M IC1 in each
of the first three impingers, and place approximately 200 g. of preweighed
silica gel in the fourth impinger. Save 80 ml. of the 0.1M IC1 as
a blank in the sample analysis. Set up the train and the probe as
in Figure 102-1.
4.5.2 Leak check the sampling train at the sampling site.
The leakage rate should not be in excess oT l"o uT Luc Jcoircd sairipling
rate. Place crushed ice around the impingers. Add more ice during
the run to keep the temperature of the gases leaving the last impinger
at 70°F or less.
4.6 Mercury train operation.
4.6.1 Safety procedures. It is imperative that the sampler
conduct the source test under conditions of utmost safety, since
hydrogen and air mixtures are explosive. The sample train essentially
is leakless, so that attention to safe operation can be concentrated at
the inlet and outlet. The following specific items are recommended:
4.6.1.1 Operate only the vacuum pump during the test.
The other electrical equipment, e.g. heaters, fans and timers,
normally are not essential to the success of a hydrogen stream test.
-------
44
4.6.1.2 Seal the sample port to minimize leakage of
hydrogen from the stack.
4.6.1.3 Vent sampled hydrogen at least 10 feet away
from the train. This can be accomplished easily by attaching a
1/2 in. I.D. Tygon tube to the exhaust from the orifice meter.
4.6.2 For each run, record the data required on the
sample sheet shown in Figure 102-6. Take readings at each sampling
point at least every five minutes and when significant changes
in stack conditions necessitate additional adjustments in flow rate.
4.6.3 Sample at a rate of 0.5 to 1.0 cfm. Samples shall
be taken over such a period or periods as are necessary to accurately
determine the maximum emissions which would occur in a 24-hour period.
In the case of cyclic operations, sufficient tests shall be made so as
to allow accurate determination or calculation of the emissions which
will occur over the duration of the cycle. A minimum sample time of
2 hours is recommended. In some instances, high mercury concentrations
can prevent sampling in one run for the desired minimum time. This
is indicated by reddening in the first impinger as free iodine is
liberated. In this case, a run may be divided into two or more
sub-runs to ensure that the absorbing solutions are not depleted.
4.6.4 To begin sampling, position the nozzle at the first
traverse point with the tip pointing directly into the gas stream.
Immediately start the pump and adjust the flow to isokinetic conditions,
Sample for at least 5 minutes at each traverse point; sampling time
-------
PLANT
LOCATION.
OPERATOR .
DATE
RUN NO.
SAMPLE BOX NO
METER BOX NO..
METER AH@
C FACTOR
AMBIENT TEMPERATURE.
BAROMETRIC PRESSURE.
ASSUMED MOISTURE. %
PROBE LENGTH, m... _
NOZZLE DIAMETER, in.
SCHEMATIC OF STACK CROSS SECTION
TRAVERSE POINT
NUMBER
TOTAL
AVERAGE
SAMPLING
TIME
(e). min.
STATIC
PRESSURE
(Ps), in. Hg.
STACK
TEMPERATURE
(TS). ° F
VELOCITY
HEAD
(A PS).
PRESSURE
DIFFERENTIAL
ACROSS
ORIFICE
METER
( A H).
in. H2O
GAS SAMPLE
VOLUME
(Vm), ft3
GAS SAMPLE TEMPERATURE
AT DRY GAS METER
INLET
(Tmin).°F
Avg.
Avg.
OUTLET
-°F
t
Avg.
SAMPLE BOX
TEMPERATURE.
°F
IMPINGER
TEMPERATURE,
°F
Figure 102-6. ' Field data
-------
46
must be the same for each point. Maintain isokinetic sampling through-
out the sampling period, using the following procedures.
4.6.4.1 Nomographs which aid in the rapid adjustment
of the sampling rate without other conputations are in APTD-0576
and are available from commercial suppliers. The available nomographs,
however, are set up for use in air streams, and minor changes are
required to provide applicability to hydrogen.
4.6.4.2 Calibrate the meter box orifice. Use the
techniques as described in APTD-0576.
4.6.4.3 The correction factor nomograph discussed in
APTD-0576 and shown, on the reverse side of commercial nomographs
will not be .used. In its place, the correction factor will be
calculated using equation 102-2.
C = 0.01 (CpMc)2 Ps Tm eq. 102-2
where :
C = correction factor.
Cp = pitot tube coefficient.
Mc = mole fraction dry gas .
PS = stack pressure, in. Hg.
Pm = meter pressure, in. Hg.
Tm = meter temperature, °R.
Ms = molecular weight of stack gas (from 4.4.4), Ib/lb. mole
AH§ = meter box calibration factor, obtained in step 4.6.4.2.
-------
47
4.6.4.4 Set the calculated correction factor on the front
of the operating nomograph. Select the proper nozzle and set the K-factor
on the nomograph as detailed in APTD-0576.
4.6.4.5 Read the velocity head in the stack at each sample
point from the manometer in the meter box. Convert the hydrogen AP to
an equivalent value for air by multiplying by a ratio of the molecular
weight of air to hydrogen at the stack moisture content. Insert this
value of AP onto the nomograph and read off AH. Again, convert the AH,
which is an air equivalent value, to the AH for hydrogen by dividing
by 13. This factor includes the ratio of the dry molecular weights and
a correction for the different orifice calibration factors for hydrogen
and air. This procedure is diagrammed below:
Observe AP —w Multinl h /MWairi—*• Sfit this on nomnoranh.
Read off AH —>- Divide by 13 = WH to be used on meter box.
4.6.4.6 Operate the sample train at the calculated AH
at each sample point.
4.6.5 Turn off the pump at the conclusion of each run and
record the final readings. Immediately remove the probe and nozzle
from the stack and handle in accordance with the sample recovery process
described in section 4.7.
4.7 Sample recovery.
4.7.1 (All glass storage bottles and the graduated cylinder
must be precleaned as in section 4.5.1). This operaton should be
-------
48
performed in an area free of po'ssible mercury contamination. Industrial
laboratories and ambient air around mercury-using facilities are not
normally free of mercury contamination. When the sampling train is
moved, care must be exercised to prevent breakage and contamination.
4.7.2 Disconnect the probe from the impinger train. Place the
contents (measured to +_ 1 ml.) of the first three impingers into 3
500 ml. sample bottle. Rinse the probe and all glassware between it
and the back half of the third impinger with two 50 ml. portions of
0.1M IC1 solution. Add these rinses to the first bottle. For a blank,
place 80 ml. of the 0.1M IC1 in a 100 ml. sample bottle. Place the
silica gel in the plastic jar. Seal and secure all containers for
shipment. If an additional test is desired, the glassware can be
carefully double rinsed with distilled water and reassembled.' However,
if the glassware is to be out of use more than two days, the initial
acid wash procedure must be followed.
4.8 Analysis.
4.8.1 Apparatus preparation—Clean all glassware according
to the procedure of section 4.5.1. Adjust the instrument settings
according to the instrument manual, using an absorption wavelength of
253.7 nm.
4.8.2 Analysis preparation—Adjust the air delivery pressure
and the needle valve to obtain a constant air flow of about 1.3 l./min.
The analysis tube should be bypassed except during aeration. Purge the
equipment for 2 minutes. Prepare a sample of mercury standard solution
(3.4.2) according to section 4.8.3. Place the analysis tube in the line,
-------
49
and aerate until a maximum peak height is reached on the recorder.
Remove the analysis tube, flush the lines, and rinse the analysis
tube with distilled water. Repeat with another sample of the same
standard solution. This purge and analysis cycle is to be repeated
until peak heights are reproducible.
4.8.3 Sample preparation—Just prior to analysis, transfer
a sample aliquot of up to 50 ml. to the cleaned 100 ml. analysis
tube. Adjust the volume to 50 ml. with 0.1M IC1 if required.
Add 5 ml. of 10 N sodium hydroxide, cap tube with a clean glass
stopper and shake vigorously. Prolorged, vigorous shaking at this
point is necessary to obtain an accurate analysis. Add 5 ml. of the
reducing agent (reagent 3.3.2), cap tube with a clean glass stopper
and shake vigorously and immediately place in sample line.
4.8.4 Mercury det.ermination~-After the system has been
stabilized, prepare samples from the sample bottle according to
section 4.8.3. Aerate the sample until a maximum peak height
is reached on the recorder. The mercury content is determined
by comparing the peak heights of the samples to the peak heights
of the calibration solutions. If collected samples are out of
the linear range, the samples should be diluted. Prepare a
blank from the 100 ml. bottle according to section 4.8.3 and
analyze to determine the reagent blank mercury level.
-------
50
5. Calibration
' 5.1 Sampling Train.
5.1.1"- Use standard methods and equipment as detailed in
APTD-0576 to calibrate the rate meter, pitot tube and dry gas
meter. Recalibrate prior to each test series.
5.2 Analysis.
5.2.1 Prepare a calibration curve for the spectrophotometer
using the standard mercury solutions. Plot the peak heights
read on the recorder versus the concentration of mercury in the
standard solutions. Standards should be interspersed with the
samples since the calibration can change slightly with time.
A new calibration curve should be prepared for each new set of
samples run.
6. Calculations
6.1 Average dry gas meter temperature, stack temperature, stack
pressure and average orifice pressure drop. See data sheet (Figure
102-6).
6.2 Dry gas volume. Correct the sample volume measured by
the dry gas meter to stack conditions by using equation 102-3. ,:
Vms = Vm Ts (Pbgr ^ AH ) .. eq. 102-3
Tm Ps
where:
Vm = volume of gas sample through the dry gas meter
o
(stack conditions), ft .
-------
51
Vm = volume of gas sample through the dry gas meter
3
(meter conditions),, ft .
Ts = average temperature of stack gas, °R.
Tm = average' dry gas meter temperature, °R.
P, = barometric pressure at the orifice meter, in. Hg.
AH = average pressure drop across the orifice meter, in.
H20.
13.6 = specific gravity of mercury.
Ps = stack pressure, P, +_ static pressure, in. Hg.
6.3 Volume of water vapor.
Vws = Kw Vlc Ts eq. 102-4
Pi
where:
Vw = volume of water vapor in the gas sample (stack
conditions), ft3.
KW = Q.00267 in. Hg.-ft3 ,
—.......&.. »,•.•—, when these units are used.
ml. - R '
v"i = total volume of liquid collected in impingers
and silica gel (see Figure 102-7), ml.
Ts = average stack gas temperature, °R.
Ps = stack pressure, P, +_ static pressure, in. Hg.
6.4 Total gas volume.
Vtotal = 'V-s * V«s . **' 102-5
where:
V . = total volume of gas sample (stack conditions),
total
-------
-
FIIMAL
INITIAL
LIQUID COLLECTED
TOTAL VOLUME COLLECTED
VOLUME OF LIQUID
VVAirii COLLCCTFO
IMPINGER
VOLUME.
ml
SILICA GEL
WEIGHT.
g
g* ml
•CONVERT WEIGHT OF WATER TO VOLUME BY dividing total weight
INCREASE BY DENSITY OF WATER. (1 g/ml):
INCREASE. 9
(1 g/ml)
= VOLUME WATER, ml
Figure 102-7. Analytical data.
-------
53
Vm = volume of gas through dry gas meter (stack
i>
conditions), ft-^.
V'w -. volume of water vapor in gas sample (stack
conditions),
6.5 Stack gas velocity.
Use equation 102-6 to calculate the stack gas velocity.
(Vc) = Kn C-. ( VAP) ^ (HQJ im £
5 avg. P P *• v avg. ^ / *- s-avg. eq. 102-6
where:
(v,.) = average stack gas velocity, feet per second.
•' avg.
y] /?
K-p = 85.53 ft. I . lb.-in.Hg V > when these units are used.
sec.y Ib. mcle-k-xn.
Cp = pitot tube coefficient, dimensionless.
(T -,avg. = average stack gas temperature, °R.
0\/AP), = average square root of the velocity head of stack
1/2
gas, (in. H20) ' (see Figure 102-8).
PS = stack pressure, P. + static pressure, in. Hg.
bar —
Ms = molecular weight of stack gas (wet basis), the
summation of the products of the molecular weight
of each component multiplied by its volumetric
proportion in the mixture, Ib./lb-mole.
Figure 102-8 shows a sample reco7:ding sheet for velocity traverse
data. Use the averages in the last two columns of Figure 102-8
to determine the average stack gas velocity from equation 102-6.
6.6 Mercury collected. Calculate the total weight of mercury
-------
PLANT,
DATE
RUN NO.
STACK DIAMETER, in.
BAROMETRIC PRESSURE, in. Hg._
STATIC PRESSURE IN STACK (P }, in. Hg.
OPERATORS
SCHEMATIC OF STACK
CROSS SECTION
Traverse point
number
-•
Velocity head,
in. H.2O
AVERAGE:
v£7
Stack Temperature
(TS),°F
Figure 102-8- Velocity traverse data.
-------
55
collected by using eq. 102-7.
Wt = VC - VC eq. 102-7
where:
W = • total weight of mercury collected, .yg.
V = total volume of condensed moisture and IC1 in sample
bottle, ml.
• C. = concentration of mercury measured in sample bottle,, pg/ml
V, = total volume of IC1 used in.sampling (impinger
contents and all wash amounts), ml.
C, = blank concentration of mercury in IC1 solution, yj/ml.
6.7 Total mercury emission.. Calculate the total amount of
mercury emitted from -each stack per day by eq. 102-8. This equation
is applicable for continuous operations. For cyclic operations, use
only the time per day each stack is in operation. The total mercury
emissions from a source will be the summation of results from all stacks.
R = Wt (VsW AS x 86400 seconds/day ^ 1C2_g
Vtotal~ 10 "8/S-
where:
R = rate of emission, g./day.
Wt = total weight of mercury collected, ug.
3
V = total volume of gas sample (stack conditions) , ft .
total
(vs), - average stack gas velocity, feet per second.
As = .stack area, ft .
6.8 Isokinetic variation (comparison of velocity of gas in
probe tip to stack velocity).
-------
56
I = 100 V ^ . ... Q
total eq. 102-9
An0 (v.)
11 s avg.
where:
I = percent of isokinetic sampling.
total = total volume of gas sample (stack conditions), ft .
An = probe tip area, ft .
' 0 = sampling time, sec.
(vs) = average stack gas velocity, feet per second.
7. Evaluation of Results
7.1 Determination of Compliance.
7.1.1 Each performance, test shall consist of three
repetitions of the applicable test, method. For the purpose of
determining compliance with an applicable national emission standard,
the average of results of all repetitions shall apply.
-------
57
7.2 Acceptable Isokinetic Results
7.2.1 The following range sets the limit on acceptable
isokinetic sampling results:
If 90% <^ I <_ 110%, the results are acceptable;
otherwise, reject the test and repeat.
-------
58
8. References
1.- Addendum to Specifications for Incinerator Testing at Federal
Facilities, PHS, NCAPC, December 6, 1967.
2. Determining Dust Concentration in a Gas Stream, ASME Performance
Test Code #27, New York, New York, 1957.
3. Devorkin, Howard, et al., Air Pollution Source Testing Manual,
Air Pollution Control District, Los Angeles, Calif., November 1963.
4. Hatch, W. R. and W. L. Ott, "Determination of Sub-Microgram
Quantities of Mercury by Atomic Absorption Spectrophotovnetry,"
Anal. Chem., 40:2085-87, 1968.
5. Mark, L. S., Mechanical Engineers' Handbook, McGraw-Hill Book
Company, Inc., New York, New York, 1951.
6. Martin, Robert M., Construction Details of Isokinctic Source
Sampling Equipment, Environmental Protection Agency, APTD-0581.
7. Methods for Determination of Velocity, Volume, Dust a.nd Mist
Content of Gases, Western Precipitation Division of Joy Manufacturing
Co., Los Angeles, Calif. Bulletin WP-50, 1968.
8. Perry, J. H., Chemical Engineers' Handbook, McGraw-Hill Book
Company, Inc., New York, New York, 1960.
9. Rom, Jerome J., Maintenance, Calibration, and Operation of
Isokinetic Source Sampling Equipment, Environmental Protection Agency,
APTD-0576.
10. Shigehara, R. T., W. F. Todd, and W. S. Smith, Significance of
Errors in Stack Sampling Measurements, Paper presented at the Annual
Meeting of the Air Pollution Control Association, St. Louis, Missouri,
June 14-19, 1970.
-------
59
11. Smith, W. S., et al,, Stack Gas Sampling Improved and
Simplified with New Equipment, APCA paper No. 67-119, 1967.
12. Smith, W. S., R. T. Shigehara, and W. F. Todd, A Method of
Interpreting Stack Sampling Data, Paper presented at the 63rd
Annual Meeting of the Air Pollution Control Association, St. Louis,
Missouri, June 14-19, 1970.
13. Specifications for Incinerator Testing at Federal Facilities
PHS, NCAPC, 1967.
14. Standard Method for Sampling Stacks for Particulate Matter,
In: 1971 Book of ASTM Standards, Part 23, Philadelphia, 1971, ASTM
Designation D-2928-71.
15. Vennard, J. K., Elementary Fluid Mechanics, John Wiley and Sons,
Inc., New York, 1947.
-------
METHOD 103. BERYLLIUM SCREENING METHOD
1. Principle and Applicability
1.1 Principle. Beryllium emissions are isokinetically
sampled from three points in a duct or stack. The collected
sample is analyzed for beryllium using an appropriate technique.
1.2 Applicability. This procedure details guidelines and
requirements for methods acceptable for use in determining beryllium
emissions in ducts or stacks at stationary sources, as specified under
the provisions of §61.14 of the regulations.
2. Apparatus !
2.1 Sampling train. A schematic of the required sampling train
configuration is shown in Figure 103-1. The essential components of
the train are the following: <•
2.1.1 Nozzle - Stainless steel, or equivalent, with sharp,
tapered leading edge.
2.1.2 Probe - Sheathed Pyrex* glass.
2.1.3 Filter - Millipore AA, or equivalent, with appropriate
filter holder that provides a positive seal against leakage from
outside or around the filter. It is suggested that a Whatman 41, or
equivalent, be placed immediately against the back side of the Millipore
filter as a guard against breakage of the Millipore. Include the Whatnan
41 in the analysis. Equivalent filters must be at least 99.95% efficient
(DOP Test) and amenable to the analytical procedure.
*Mention of trade names or specific products does not constitute
endorsement by the Environmental Protection Aoencv.
-------
FILTER
\
NOZZLE
PROBE
ETER-PUMP
SYSTEM
Figure 1.03-1. Beryllium screening method: sample train schematic.
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62
2.1.4 Meter-Purnp System--Any system that will maintain'
isokinetic sampling rate, determine sample volume, and is capable of
a sampling rate of greater than 0.5 cfm.
2.2 Measurement of stack conditions (stack pressure, temperature,
moisture and velocity). The following equipment shall be used in the
manner specified in section 4.3.1.
2.2.1 Pitot tube—Type S, or equivalent, with a coefficient
within 5% over the working range.
2.2.2 Differential pressure gauge—Inclined manometer, or
equivalent, to measure velocity head to within 10% of the minimum value.
2.2.3 Temperature gauge—Any temperature measuring device to
measure stack temperature to within 5°F.
2.2.4 Pressure gauge—Any device to measure stack pressure
to within 0.1 in. Hg.
2.2.5 Barometer--To measure atmospheric pressure to within
0.1 in. Hg.
2.2.6 Moisture determination—Wet and dry bulb thermometers,
drying tubes, condensers, or equivalent, to determine stack gas
moisture content to within 1%.
2.3 Sample Recovery.
2.3.1 Probe cleaning equipment—Probe brush or cleaning rod
at least as long as probe, or equivalent. Clean cotton balls, or
equivalent, should be used with the rod.
2.3.2 Leakless glass sample bottles.
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63
2.4 Analysis.
2.4.1 Equipment necessary to perform an atomic absorption,
spectrographic, fluorometric, chromatographic, or equivalent analysis.
3. Reagents
3.1 Sample recovery.
3.1.1 Acetone--Reagent grade.
3.1.2 Wash acid--l:l V/V hydrochloric acid-water.
3.2 Analysis.
3.2.1 Reagents as necessary for the selected analytical
procedure.
4. Procedure
4.1 Guidelines for source testing are detailed in the following
sections. These guidelines are generally applicable; however, most
sample sites differ to some degree and temporary alterations such as
stack extensions or expansions often are required to ensure the
best possible sarrple site. Further, since beryllium is hazardous.
care should be taken to minimize exposure. Finally, since the total
quantity of beryllium to be collected is quite small, the test must
be carefully conducted to prevent contamination or loss of sample.
4.2 Selection of a sampling site and number of runs.
4.2.1 Select a suitable sampling site that is as close
as practicable.to the point of atmospheric emission. If possible,
stacks smaller than 1 foot in diameter should not be sampled.
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64
4.2.2 The sampling site should be at least eight stack
or duct diameters downstream and two diameters upstream from any
flow disturbance such as a bend, expansion or contraction.
For rectangular cross-section, determine an equivalent diameter
using the following equation:
De = 2LW eq. 103-1
L-i-W
where:
De = equivalent diameter
L = length
W = width
4.2.3 Some sampling situations may render the above
sampling site criteria impractical. When this is the case, an
alternate site may be selected but must be no less than two
diameters downstream and one-half diameter upstream from any point of
disturbance. Additional sample runs are recommended at any sample site
not meeting the criteria of section 4.2.2.
4.2.4 Three runs shall constitute a test. The runs shall be
conducted at three different points.- The three points shall proportionately
divide the diameter, i.e. be located -at 25, 50 and 75% of the diameter from
the inside wall. For horizontal ducts, the diameter shall be in the
vertical direction. For rectangular ducts, sample on a line through the
centroid and parallel to a side. If additional runs are required per section
4.2.3, proportionately divide the duct to accommodate the total number of
runs.
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65
4.3 Measurement of stack conditions.
4.3vl Measure the stack gas pressure, moisture, and •
temperature, using the equipment described in section 2.2. Determine
the molecular weight of the stack gas. Sound engineering estimates
may be made in lieu of direct measurements. The bases for such estimates
shall be given in the test report.
4.4 Preparation of sampling train.
4.4.1 Assemble the sampling train as shown in Figure 103-1.
It is recommended that all glassware be precleaned by soaking in wash
acid fcr two hours.
4.4.2 Leak check the sampling train at the sampling site.
The leakage rate should not be in excess of 1% of the desired sample rate.
4.5 Beryllium train operation.
4.5.1 For each run, measure the velocity at the selected
sampling.point. Determine the isokinetic sampling rate. Record the
velocity head and the required sampling rate.
4.5.2 Place the nozzle at the sampling point with the tip
pointing directly into the gas stream. Immediately start the pump
and adjust the flow to isokinetic conditions. At the conclusion
of the test, record the sampling rate. Again measure the velocity
head at the sampling point. The required isokinetic rate at the
end of the period should not have deviated more than 20% from that
originally calculated.
4.5.3 Sample at a minimum rate-of 0.5 cfm. Samples shall
be taken over such a period, or periods as are necessary to determine the
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66
the maximum emissions which would occur in a 24-hour period.. In the case
of cyclic operations, sufficient tests shall be made so as to allow
determination or calculation.of the emissions which would occur over the
duration of the cycle. A minimum sampling time of two hours is recommended.
4.5.4 All pertinent data should be included in the test report.
4.6 Sample recovery.
.4.6.1 It is recommended that all glassware be precleaned
as in section 4.4.1. Sample recovery should also be performed in
an area free of possible beryllium contamination. When the sampling
train is moved, exercise care to pi-event breakage and contamination.
Set aside a portion of the acetone ,used in the sample recovery as a
blank for analysis. The total amount of acetone used should be
measured for accurate blank correction. Blanks can be eliminated if
prior analysis shows negligible amounts.
4.6.2 Remove the filter and any loose particulate matter
from filter holder and place in a container.
4.6.3 Clean the probe with acetone and a brush or long rod
and cotton balls. Wash into the container. Wash out the filter
holder with acetone and add to the same container.
4.7 Analysis.
4.7.1 Make the necessary preparation of samples and
analyze for beryllium. Any currently acceptable method such as atomic
absorption, spectrographic, fluorometric, chromatographic, or
equivalent may be used.
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67
•*• Calibration- and Standards
5.1 Sampling train.
5.1.1 As a procedural check, sampling rate regulation
should be compared with a dry gas meter, spirometer, rotameter
(calibrated for prevailing atmospheric conditions), or equivalent,
attached to nozzle inlet of the complete sampling train.
5.1.2 Data from this test and calculations should be
shown in test report.
5.2 Analysis.
5.2.1 Standardization is made as suggested by the
manufacturer of the instrument or the procedures for the analyticr.l
method.
6. Calculations
6.1 Total beryllium emission. Calculate the total amount of
beryllium emitted from each stack per day by equation 103-2. This
equation is applicable for continuous operations. For cyclic
operations, use only the time per day each stack is in operation.
The total beryllium emissions from a source will be the summation
of results from all stacks.
R = wt (vs) As , 86400 seconds/day
x ~ ' '
Vtotal
where :
R = rate of emission, g./day.
Wt = total weight of beryllium collected, yg.
V. , = total volume of gas sampled, ft-\
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68
(vs) = a.verage stack gas velocity, feet per second.
A's = stack area, £t,2.
7. Test Report
7.X A test report shall be prepared which shall include
as a minimum:
7.1.1 A detailed description of the sampling train used
and results of the procedural check with all data, and calculations
made.
7.1.2 All pertinent data taken during test, the basis
for any estimates made, calculations, and results.
7.1.3 A description of the test site, including a block
diagram with a brief description of the process, location of the
sample points in the cross-section, dimensions and distances from
any point of disturbance.
-------
METHOD 104. REFERENCE METHOD FOR DETERMINATION OF BERYLLIUM
EMISSIONS FROM STATIONARY SOURCES
^' Principle and Applicability
1.1 Principle. Beryllium emissions are isokinetically sampled
from the source, and the collected sample is digested in an acid
solution and analyzed by atomic absorption spectrophotometry.
1.2 Applicability. This method is applicable for the determination
of beryllium emissions in ducts or stacks at stationary sources.
Unless otherwise specified, this method is not intended to apply to
gas streams other than those emitted directly to the atmosphere
without further processing.
'2. Apparatus
2.1 Sampling train. A schematic of the sampling train used by
EPA is shown in Figure 104-1. Commercial models of this train
are available, although construction details are described in
APTD-OSS1*, and operating and maintenance procedures are described
in APTD-0576. The components essential to this sampling train
are the following:
2.1.1 Nozzle—Stainless steel or glass with sharp, tapered
leading edge.
:2.1.2 Probe--Sheathed Pyrex** glass.. A heating system
capable of maintaining a minimum gas temperature in the range of the
stack temperature at the probe outlet during sampling may be used
to prevent condensation from occurring.
*These documents" are available for a nominal cost from the National
Technical Information Service, U. S. Department of Commerce,
5285 Port Royal Road, Springfield, Virginia 22151.
**Mention of trade names on specific products does not constitute
endorsement by the Environmental Protection Agency.
-------
HEATED AREA FILTER HOLDER THERMOMETER CHECK
-VALVE
PROBE
TYPE S
PITOT TUBE
PITOT MANOMETER
ORIFICE
THERMOMETERS
VACUUM
GAUGE
MAIN VALVE
AIR-TIGHT
PUMP
DRY TEST METER
Figure 104-1.' Beryllium sampling train
VACUUM
LINE
-------
.71
• 2.1.3 Pitot tube—Type S (Figure 104-2), or equivalent,
with a coefficient within 5%. over the working range, attached to
probe to monitor stack gas velocity.
2.1.4 Filter holder--Pyrex. glass. The filter holder .must
provide a. positive seal against leakage from outside.or around the
filter. A heating system capable of maintaining the filter at a minimum
temperature in the range of the stack temperature may be used to
prevent condensation from occurring.
2.1.5 Impingers--Four Greenburg-Smith impingers connected
in series with glass ball joint fittings. The first, third^ and
fourth impingers may be modified by replacing the tip with a 1/2
inch ID glass tube extending to 1/2 inch from the bottom of the flask.
2.1.6 Metering system--Vacuum gauge, leakless pump, thermometers
capable of measuring temperature to within 5°F, dry gas meter with
2% accuracy, and related equipment, described in APTD-0581, to maintain
an isokinetic sampling rate and to determine sample volume.
2.1.7 Barometer--To measure atmospheric pressure to +_ 0.1
in. Hg.
2.2 Measurement of stack conditions (stack pressure, temperature,
moisture and velocity).
2.2.1 Pitot tube--Type S, or equivalent, with a coefficient
within 5% over the working range.
2.2.2 Differential pressure gauge--Inclined manometer, or
equivalent, to measure velocity head to within 10% of the minimum value.
-------
PIPE COUPLING
TUBING ADAPTER
TYPE S PITOT TUBE
Figure 104-2. Pitot tube - manometer assembly.
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73
2.2.3 Temperature gauge--Any temperature measuring device
to measure stack temperature to within 5°F.
2.2.4 Pressure gauge--Pitot tube and inclined manometer,
or equivalent, to measure stack pressure to within 0.1 in. Hg.
2.2.5 Moisture determination--Wet and dry bulb thermometers,
drying tubes, condensers, or equivalent, to determine stack gas moisture
content to within 1%.
2.."> Sample recovery.
2.3.1 Probe cleaning rod--At least as long as probe.
2.3.2 Leakless glass sample bottles—500 ml.
«•
2.3.3 Graduated cylinder--250 ml.
2.3.4 Plastic jar—Approximately 300 ml.
2.4 Analysis. '
2.4.1 Atomic absorption spectrophotometer--To measure
absorbance at 234.8 nm. Perkin Elmer Model 303, or equivalent, with
N20/acetylene burner.
2.4.2 Hot plate.
2.4.3 Perchloric acid fume hood.
3. Reagents
3.1 Stock Reagents.
3.1.. 1 Hydrochloric acid--Concentrated.
3.1.2 Perchloric acid--Concentrated, 70%.
3.1.3 Nitric acid--Concentrated.
3.1.4 Sulfuric acid--Concentrated.
3.1.5 Distilled and deionized water.
3.1.6 Beryllium powder--98% minimum purity.
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74
3.2 Sampling.
3.2.1 Filter—Millipore AA, or equivalent. It is
suggested that a Whatman 41 filter be placed immediately against
the back side of the Millipore filter as a guard against breaking
the Millipore filter. In the analysis of the filter, the Whatman 41
filter should be included with the Millipore filter.
.3.2.2 Silica gel—Indicating type, 6 to 16 mesh, dried
at 350°F for two hours.
3.2.3 Distilled and deionized water.
3.i Sample recovery.
3.3.1 Distilled and deionized water.
3.3.2 Acetone--Reagent grade.
3.3.3 Wash acid--l:l V/V hydrochloric acid-water.
3.4 Analysis.
3.4.1 Sulfuric acid solution, 12 N--Dilute'333 ml. of
concentrated sulfuric acid to 1 1. with distilled water.
3.4.2 25% V/V hydrochloric acid-water.
3.5 Standard beryllium solution.
3.5.1 Stock solution--!.0 yg/ml. beryllium. Dissolve .
10.0 mg. of beryllium in 70 ml. of 12 N sulfuric acid solution and
dilute to a volume of 1000 ml. with, distilled water. Dilute a 10 ml.
aliquot to 100'ml. with 25% V/V hydrochloric acid, giving a concentration
of 1.0 yg/ml. This dilute stock solution should be prepared fresh
daily. Equivalent strength (in beryllium) stock solutions may be
prepared from beryllium salts such as BeCl2 and Be(NO3)? (98% minimum
purity).
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75
4. Procedure
4.1 Guidelines for source testing are detailed in the following
sections. These guidelines are generally applicable; however, most
sample sites differ to some degree and temporary alterations such as
stack extensions or expansions often are required to ensure the
best possible sample site. Further, since beryllium is hazardous,
care should be taken to minimize exposure. Finally, since the total
quantity of beryllium to be collected is quite small, the test must
be carefully conducted to prevent contamination or loss of sample.
4.2 Selection of a sampling site and minimum number of traverse
points.
4.2.1 Select a suitable sampling site that is as close as
practicable to the point of atmospheric emission. If possible,
stacks smaller than 1 foot in diameter should not be sampled.
4.2.2 The sampling site should be at least eight stack
or duct diameters downstream and two diameters upstream from any
flow disturbance such as a bend, expansion or contraction. For a
rectangular cross-section, determine an equivalent, diameter from
the following equation:
De = 2LW eq. 104-1
L+W
where:
De = equivalent diameter
L = length
W = width
-------
0.5
50
Z 40
O
a.
1.0
NUMBER OF DUCT DIAMETERS UPSTREAM'
(DISTANCE A)
1.5 2.0
2.5
CO
or
LU
O
c:
UU
CO
30
20
\ /DISTURBANCE
'}
A
\
•
E
.
\
3
_
A'
1
i
SAMPLING
SITE
DISTURBANCE
=zb
10
'FROM POiMT OF ANY TYPE OF
DISTURBANCE (BEND. EXPANSION. CONTRACTION, ETC.)
NUMBER OF DUCT DIAMETERS DOWNSTREAM'
(DISTANCE B)
10
t-igure 104-3. Minimum number of traverse points.
-------
Figure 104-4. Cross section of circular stack showing location c*
traverse points on perpendicular diameters.
o
0
o
1
1
1
• o o
1
1
i
r I
1
0 | O
1
1
r - -
1
0 1 P
i
i
o
o
r
0
Figure 104-5. Cross section of rectangular stack divided into 12 e:
areas, with traverse points at centroid of each area.
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78
4.2.3 When the above sampling site criteria can be met,
the minimum nuipner of traverse points is four (4) for stacks, 1 foot
in. diameter or less, eight (8) for stacks larger than 1 foot but
2 feet in diameter or less, and twelve (12) for stacks larger than
2 feet.
4.2.4 Some sampling situations may render the above
sampling site criteria impractical. When this is the case, choose
a convenient sampling location and use Figure 104-3 to determine
the minimum number of traverse points. However, use Figure 104-3
only for stacks 1 foot in diameter o:-? larger.
4.2.5 To use Figure 104-3, first measure the distance
from the chosen sampling location to the nearest upstream and downstream
disturbances. Divide this distance by the diameter or equivalent
diameter to determine the distance in terms of pipe diameters.
Determine the corresponding number of traverse points for each distance
from Figure 104-3. Select the higher of the two numbers of traverse
points., or a greater value, such that for circular stacks the number
is a multiple of four, and for rectangular stacks the number follows
the criteria of section 4.3.2.
4.2.6 If a selected sampling point is closer than one inch
from the stack wall, adjust the location of that point to ensure
that the sample is taken at least one inch away from the wall.
4.3 Cross-sectional layout and location of traverse points
-------
Table 104-1'. Location of traverse points in circular stacks
(Percent of stack diameter from inside wall to traverse po.int)
Traverse
point
number
on a
diameter
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19'
20
21
22
23
24
Number of traverse points on -a diameter
2
14.6
85.4
4
6.7
25.0
75.0
93.3
6
4.4
14.7
29.5
70.5
85.3
95.6
8
3.3
10.5
19.4
32.3
67.7
80.6
89.5
96.7
10
2.5
8.2
14.6
22.6
34.2
65.8
77.4
85.4
91.8
97 . 5
12
2.1
6.7
11.8
17.7
25.0
35.5
64.5
75.0
82.3
88.2
93.3
97.9
14
1.8
5.7
9.9
14.6
20.1
26.9
36.6
63.4
73.1
79.9
85.4
90.1
94.3
98.2
16
1.6
4.9
8.5
12.5
16.9
22.0
28.3
37.5
62.5
71.7
78.0
83.1
87.5
91.5
95.1
98.4
18
1.4
4.4
7.5
10.9
14.6
18.8
23.6
29.6
38.2
61.8
70.4
76.4
81.2
85.4
89.1
92.5
95.6
98.6
20
1.3
3.9
6.7
9.7
12.9
16.5
20.4
25.0
30.6
38.8
61.2
69.4
75.0
79.6
83.5
87.1
90.3
93.3
96.1
98.7
•
22
1.1
3.5
6.0
8.7
11.6
14.6
18.0
21.8
26.1
31.5
39.3
60.7
68,5
73.9
78.2
82.0
85.4
88.4
91.3
94.0
96.5
98.9
24
1.1
3.2
5.5
7.9
10.5
13.2
16.1
19.4
23.0
27.2
32.3
39.8
60.2
67.7°
72.8
77.0
80.6
83.9
86.8
89.5
92.1
94.5
96.8
98.9
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80
4.3.1 For circular stacks locate the traverse points on
at least two diameters according to Figure 104-4 and Table 104-1.
The traverse axes shall divide the stack cross-section into equal
parts.
4.3.2 For rectangular stacks divide the cross section into
as many equal rectangular areas as traverse points, such that
the ratio of the length to the width of the elemental areas is
between one and two. Locate the traverse points at the centroid
of each equal area according to Figure 104-5,
4.4 Measurement of stack conditions.
4.4.1 Set up the apparatus as shown in Figure 104-2. Make
sure all connections are tight and leak free. Measure the velocity
head and temperature at the traverse points specified by section
4.2 and 4.3.
4.4.2 Measure the static pressure in the stack.
4.4.3 Determine the stack gas moisture.
4.4.4 Determine the stack gas molecular weight from the
measured moisture content and knowledge of the expected gas stream
composition. A standard Orsat analyzer has been found valuable
at combustion sources. In all cases, sound engineering judgement.
should be used.
4.5 Preparation of sampling train.
4.5.1 Prior to assembly, clean all glassware (probe,
impingers and connectors) by soaking in wash acid for two hours.
Place 100 ml. of distilled water in each of the first two impingers,
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81
leave the third impinger empty, .and place approximately 200 g. of
preweighe.d silica gel in the fourth impinger. Save a portion of the
distilled water as a blank in the sample analysis. Set up the train
and the probe as in Figure 104-1.
4.5.2 Leak check the sampling train at the. sampling site.
The leakage rate should not be in excess of 1% of the desired
sampling rate. If condensation in the probe or filter is a
problem", probe and filter heaters will be required. Adjust the
heater? to provide a temperature at or above the stack tempei'atui'e.
.However, membrane filters such as the Millipore AA are limited to
about 225°F. If the stack gas is in excess of about 200°F, consideration
should be given to an alternate- procedure such as moving the filter
holder downstream of the first impinger to ensure that the filter does
not exceed its temperature limit. Place crushed ice around the
impingers. Add more ice during the test to keep the temperature
of the gases leaving the last impinger at 70°F or less.
4.6 Beryllium train operation.
4.6.1 For each run, record the data required on the example
sheet shown in Figure 104-6. Take readings at each sampling point at
least every five minutes and when significant changes in stack conditions
necessitate additional adjustments in flow rate.
4.6.2 Sample at a rate of 0.5 to 1.0 cfm. Samples shall be
taken over such a period or periods as are necessary to accurately
determine the maximum emissions which would occur in a 24-hour period.
In the case, of cyclic operations, sufficient tests shall be made
-------
PLANT
LOCATION.
OPERATOR.
DATE
RUN NO.
SAMPLE BOX N0
.METER BOX NO.
METER * H ^
C FACTOR
AMBIENT TEMPERATURE,
BAROMETRIC PRESSURE_
ASSUMED MOISTURE, %_
HEATER BOX SETTING
PROBE LENGTH, m..
NOZZLE DIAMETER, in. _
• PROBE HEATER SETTING.
SCHEMATIC OF STACK CR.OSS SECTION
TRAVERSE POINT
NUMBER
TOTAL
SAMPLING
TIME
.(e). min.
-
"
,
AVERAGE
STATIC
PRESSURE
(Ps). in. Hg.
STACK
TEMPERATURE
(TO- °F
VELOCITY
HEAD
UPS).
PRESSURE •
DIFFERENTIAL
ACROSS
ORIFICE
METER
( A H).
in. H2O
GAS SAMPLE
VOLUME
(Vm). ft3
GAS SAMPLE TEMPERATURE
AT DRY GAS METER
INLET
(Tmjn).°F
Avg.
OUTLET
'UF
•
Avg.
Avg.
SAMPLE. BOX
TEMPERATURE.
°F
IMPINGER
TEMPERATURE,
°F
i
.
'
1 .
Figure 104-6. Field data
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83
so as to allow accurate determination or calculation of the emissions
which will occur over the duration of the cycle. A minimum sample
time of 2 hours is recommended.
4.6.3 To begin sampling, position the nozzle, at the first
traverse point with the tip pointing directly into the gas stream.
Immediately start the pump and adjust the flow to isokinetic conditions,
Sample for at least 5 minutes at each traverse point; sampling time
must be the same for each point. Maintain isokinetic sampling
throughout the sampling period. Nomographs which aid in the rapid
adjustment of the sampling rate without other computations are in
APTD-0576 and are available from commercial suppliers. Note that
standard nomographs are applicable only for Type S pitot tubes and air
or a stack gas with an equivalent density. Contact EPA or the sampling
train supplier for instructions when the standard nomograph is not
applicable.
4.6.4 Turn off the pump at the conclusion of each run and
record the final readings. Immediately remove the probe and nozzle
from the stack and handle in accordance with the sample recovery
process described in section 4.7.
4.7 Sample recovery.
4.7.1 (All glass storage bottles and the graduated cylinder
must be precleaned as in section 4.5.1). This operation should be
performed in an area free of possible beryllium contamination. When
the sampling train is moved, care must be exercised to prevent breakage
and contamination.
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84
4.7.2 Disconnect the probe from the impinger train.
Remove the filter and any loose particulate matter from the filter
holder and place in a sample bottle. Place the contents
(measured to +_ 1 ml.) of the first three impingers into another
sample bottle. Rinse the probe and all glassware between it and
the back half of the third impinger with water and acetone, and
add this to the latter sample bottle. Clean the probe with a brush
or a long slender rod and cotton balls. Use acetone while cleaning.
Add these to the sample bottle. Retain a sample of the water and
acetone as a blank. The total amount of wash water and acetone
used should be measured for accurate blank correction. Place the
silica gel in the plastic jar. Seal and secure all sample containers
for shipment. If an additional test is desired, the glassware can
be carefully double rinsed with distilled water and reassembled. However,
if the glassware is to be out of use more than two days, the initial
acid wash procedure must be followed.
4.8 Analysis.
4.8.1 Apparatus preparation--Clean all glassware according
to the procedure of section 4.5.1. Adjust the instrument settings
according to the instrument manual, using an absorption wavelength
of 234.8 nm.
4.8.2 Sample preparation--The digestion of beryllium samples
is accomplished in part in concentrated perchloric acid. CAUTION:
The analyst must ensure that the sample is heated to light brown
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85
fumes after the initial nitric acid addition otherwise dangerous
perchlorates may result from the subsequent perchloric acid digestion.
Perchloric acid also should be used only under a perchloric acid hood.
4.8.2.1 Transfer tire'filter and any loose particulate
matter from the sample container to a 150 ml. beaker. Add 35 ml.
concentrated nitric acid. Heat t,::"d hot plate until light brown
fumes are evident to destroy all organic matter. Cool to room
temperature and add 5 ml. concentrated sulfuric acid and 5 ml.
concentrated perchloric acid. Then proceed with step 4.8.2.4.
4.8.2.'2 Place a portion of the water and acetone sample
into a 150 ml. beaker and put on a hot plate. Add portions of the
remainder as evaporation proceeds and evaporate to dryness. Cool
the residue and add 35 ml. concentrated nitric acid. Heat on a hot
plate until light brown fumes are evident to destroy any organic matter.
Cool to room temperature and add 5 ml. concentrated sulfuric acid,
and 5 ml. concentrated perchloric acid. Then proceed with step 4.8.2.4.
4.8.2.3 Weigh the spent silica gel and report to the
nearest gram.
4.8.2.4 Samples from 4.8.2.1 and 4.8.2.2 may be combined
here for ease of analysis. Replace on a hot plate and evaporate to
dryness'in a perchloric acid hood. Cool and dissolve the residue
in 10.0 ml. of 25% V/V hydrochloric acid. Samples are now ready for
the atomic absorption unit. The beryllium concentration of the sample
must be within the calibration range of the unit. If necessary, further
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dilution of sample with 25% V/V hydrochloric acid must be performed
to bring the sample within the calibration range.
4.8.3 Beryllium determination—Analyze the samples prepared
in 4.8.2 at 234.8 nm. using a ' °,t "••:-js.^xide/acetylene flame. Aluminum,
silicon and other elements can interfere with this method if present
in large quantities. Standard nn-tMds are available, however, to
effectively eliminate these interferences. (See Reference 5)
5. Calibration
5.1 Sampling train.
5.1.1 Use standard methods and equipment as detailed in
APTD-0576 to calibrate the rate meter, pitot tube, dry gas meter
and probe heater (if used). Recalibrate prior to each test series.
5.2 Analysis.
5.2.1 Standardization is made with the procedure as suggested
by the manufacturer with standard beryllium solution. Standard
solutions will be prepared from the stock solution by dilution with
25% V/V hydrochloric acid. The linearity of working range should
be established with a series of standard solutions. If collected
samples are out of the linear range, the samples should be diluted.
Standards should be interspersed with the samples since the calibration
can change slightly with time.
6. Calculations
6.1 Average dry gas meter temperature, stack temperature, stack
pressure and average orifice pressure drop. See data sheet (Figure 104-6).
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6.2 Dry gas volume. Correct the sample volume measured by the
dry gas meter to stack conditions by using equation 104-2.
+ AH \ eq. 104-2
13.6/
Tm PS
where:
Vm = volume of gas sample through the dry gas meter
3
(stack conditions) , ft .
Vm = volume of gas sample through the dry gas meter
(meter conditions) , ft .
Ts = average temperature of stack gas, °R.
Tm = average dry gas meter temperature, °R.
P. = barometric pressure at the orifice meter, in. Hg.
AH = average pressure drop across the orifice meter,
in. H20.
13.6 = specific gravity of mercury.
PS = stack pressure, P, +_ static pressure, in. Hg.
6.3 Volume of water vapor.
Vws = Kw V1(. Ts eq. 104-3
P~
s
where:
Vw = volume of water vapor in the gas sample (stack
o
3
conditions), ft .
3
Kw = 0.00267 in. Hg-ft , when these units are used.
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Vj = total volume of liquid collected in impingers and
silica gel (see Figure 104-7), ml.
Ts = average stack gas temperature, °R.
Ps = stack pressure, P, + static pressure, in. Hg.
oar —
6.4 Total gas volume.
* «- i
total
where :
~ vm + vw ' eq. 104-4
m w M
V , = total volume of gas sample (stack conditions)
total
ft3.
Vm = volume of gas through dry gas meter (stack
(conditions), ft3.
Vwe- = volt™6 °f water vapor in gas sample (stack
conditions), ft3.
6.5 Stack gas velocity.
Use equation 104-5 to calculate the stack gas velocity.
eq. 104-5
avgr avg.
where:
(vs) = average stack gas velocity, feet per second.
KD = 85.53 ft. / Ib.-in Hg. \1/2 , „,
P —TT- =—trfr^ TT-r: t when these units
sec.y Ib.mole- R-in. H20 / '
are used.
Cp = pitot tube coefficient, dimensionless.
(Ts) = average stack gas temperature, °R.
= average square root of the velocity head of
1/2
stack gas, (in. 1^0) ' (See Figure 104-8).
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PLANT,
DATE
RUN NO.
STACK DIAMETER, in.
BAROMETRIC PRESSURE, in. Hg.
STATIC PRESSURE IN STACK (Pg). in. Hg.
OPERATORS
SCHEMATIC OF STACK
CROSS SECTION
Traverse point
number
Velocity head.
in. H20
AVERAGE:
Stack Temperature
Figure 104-8- Velocity traverse data.
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FINAL
INITIAL
LIQUID COLLECTED
TOTAL VOLUME COLLECTED
VOLUME OF LIQUID
WATER COLLECTED
IMPINGER
VOLUME.
ml
i
SILICA GEL
WEIGHT.
g
g* ml
•CONVERT WEIGHT OF WATER TO VOLUME BY dividing total weight
INCREASE BY DENSITY OF WATER. (1 }/m\):
.INCREASED =
(1 g/ml)
Figure 104-7. Analytical data.
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91
PS = stack pressure, P, +_ static pressure, in. Hg.
Ms = molecular weight of stack gas -(wet basis), the
summation of the products of the molecular weight
of each component multiplied by its volumetric
proportion in the mixture, Ib./lb.-mole.
Figure 104-8 shows a sample recording sheet for velocity traverse
data. Use the averages in the last two columns of Figure 104-8 to
determine the average stack gas velocity from equation 104-5.
6.6 Beryllium collected. Calculate the total weight of
beryllium collected by using equation 104-6.
Wt = ViCj - VWCW - VaCa eq. 104-6
where:
YI = total volume of hydrochloric acid from step 4.8.2.4, ml.
Cj = concentration of beryllium found in sample, yg/ml.
Vw = total volume of water used in sampling (impinger
contents plus all wash amounts), ml.
Cw = blank concentration of beryllium in water, yg/ml.
Va = total volume of acetone used in sampling (all wash
amounts), ml.
Ca = blank concentration of beryllium in acetone, jig/ml.
6.7 Total beryllium emissions. Calculate the total amount of
beryllium emitted from each stack per day by equation 104-7. This
equation is applicable for continuous operations. For cyclic operations,
use only the time per day each stack is in operation. The total beryllium
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emissions from a source will be the summation of results from all stacks.
R = Wt (vs) AS x 86400 seconds/day eq. 104-8
where:
R = rate of emission, g./day.
Wt = total weight of beryl-rruiu collected, pg.
3
V .. = total volume of gas sample (stack conditions), ft .
(vs) = average stack gas velocity, feet per second.
2
AS = stack area, ft .
6.8 Isokinetic variation (comparison of velocity of gas in
probe tip to stack velocity).
V
total eq. 104-8
AflQ^sJavg.
where:
I = percent of isokinetic sampling.
3
V . = total volume of gas sample (stack conditions), ft .
AJJ = probe tip area, ft .
0 = sampling time, sec.
(Vg) = average stack gas velocity, feet per second.
7. Evaluation of Results
7.1 Determination of Compliance.
7.1.1 Each performance test shall consist of three
repetitions of the applicable test method. For the purpose of
determining compliance with an applicable national emission standard,
the average of results of all repetitions shall apply.
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7.2 Acceptable Isokinetic Results
7.2.1 The following range sets the limit on acceptable
isokinetic sampling results:
If 90% £ I £ 110%, the results are acceptable;
otherwise, reject the test and repeat.
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7. References
1. Addendum to Specifications for Incinerator Testing at Federal
Facilities, PHS, NCAPC, December 6, 1967.
2. Amos, M.D., and Willis, J. B., "Use of High-Temperature Pre-
V?-,.- 'J;
. •*. / "'
Mixed Flames in Atomic Absorption Spectroscopy," Spectrochim.
Acta, 22: 1325, 1966.
3. Determining Dust Concentration in a.Gas Stream, ASME Performance
Test Code #27, New York, New York, 1957.
4. Devorkin, Howard, et al., Air Pollution Source Testing Manual, Air
Pollution Control District, Los Angeles, Calif. November 1963.
5. Fleet, B., Liberty, K. V., and West, T. S., "A Study of Some
Matrix Effects in the Determination of Beryllium by Atomic
Absorption Spectroscopy in the Nitrous Oxide-Acetylene Flame,"
Talanta, 17: 203, 1970.
6. Mark, L. S., Mechanical Engineers' Handbook, McGraw-Hill Book
Company, Inc., New York, New York, 1951.
7. Martin, Robert M., Construction Details of Isokinetic Source
Sampling Equipment, Environmental Protection Agency, APTD-0581.
8. Methods for Determination of Velocity, Volume, Dust and Mist
Content of Gases, Western Precipitation Division of Joy Manu-
facturing Company, Los Angeles, Calif. Bulletin WP-50, 1968.
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95
9. Perkin Elmer Standard Conditions (Rev. March 1971).
10. Perry, J. H., Chemical Engineers' Handbook, McGraw-Hill Book
Company, Inc., New York, New York, 1960.
11. Rom, Jerome J. , Maintenance," Calibration, and Operation of Isokinetic
Source Sampling Equipment, Environmental Protection Agency, APTD-0576.
12. Shigehara, R. T., W. F. Todd, and,. W. S. Smith, Significance of
Errors in Stack Sampling Measurements, Paper presented at the
Annual Meeting of the Air Pollution Control Association, St. Louis,
Missouri, June 14-19, 1970.
13. Smith, W. S., et al., Stack Gas Sampling Improved and Simplified
with New Equipment, APCA paper No. 67-119, 1967.
14. Smith, W. S., R. T. Shigehara, and V!. P. To-™, A Method of
Interpreting Stack Sampling Data, Paper presented at the 63rd
Annual Meeting of the Air Pollution Control Association, St. Louis,
Missouri, June 14-19, 1970.
15. Specifications for Incinerator Testing at Federal Facilities, PHS,
NCAPC, 1967.
16. Standard Method for Sampling Stacks for Particulate Matter, In: 1971
Book of ASTM standards, Part 23, Philadelphia. 1971, ASTM
Designation D-2928-71.
17. Vennard, J. K. Elementary Fluid Mechanics. John Wiley and Sons, Inc.,
New York, 1947.
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