Draft
ENFORCEMENT WORKSHOP ON
PLANT INSPECTION AND
I EVALUATION PROCEDURES
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VOLUME II
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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
OFFICE OF GENERAL ENFORCEMENT
«£ WASHINGTON, D.C. 20460
. 02-00-&o-
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ENFORCEMENT WORKSHOP ON
PLANT INSPECTION AND EVALUATION
COUNTERFLOW INSPECTION PROCEDURES
FOR PERFORMANCE BASELINE ASSESSMENT
AND ROUTINE EVALUATION
by
John R. Richards
PEDCo Environmental, Inc.
505 South Duke Street
Durham, North Carolina 27701
Contract No. 68-01-4147
PN 3570-2-1
for
U.S. ENVIRONMENTAL PROTECTION AGENCY
DIVISION OF STATIONARY SOURCE ENFORCEMENT
OFFICE OF ENFORCEMENT
WASHINGTON, D.C. 20460
February 1980
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CONTENTS
Page
1. Counterflow Inspection Procedures for
Performance Baseline Assessment and
Routine Evaluation 1
1.1 Baseline Assessment 2
2. Counterflow Inspection Concepts 4
3. Pre-inspection Steps for Regulatory
Agency Inspectors 6
3.1 File Review 6
3.2 Inspection Announcement 7
3.3 Inspection Equipment 7
3.4 Plant Surroundings 8
3.5 Plant Entry 9
3.6 Pre-inspection Interview 9
4. Counterflow Inspection for Routine
Performance Evaluation 11
4.1 Step 1: Observe the Stack Effluent 11
4.2 Step 2: Check the Continuous Monitors 19
4.3 Step 3: Measure the Fan Parameters 20
4.4 Step 4: Analyze Control Device
Performance 26
4.4.1 Fabric filters 41
4.4.2 Wet scrubbers 42
4.4.3 Electrostatic precipitators 43
4.5 Step 5: Check the Ventilation System 45
4.6 Step 6: Evaluate Process Operating
Conditions 45
5. Post-inspection Steps for Regulatory Agency
Personnel 50
5.1 Plant Interview 50
5.2 File Update and Report Preparation 50
6. Safety Considerations 51
Appendix A: (See Working File Handout)
Appendix B: Sample Inspection Data Sheets 56
iii
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SECTION 1
COUNTERFLOW INSPECTION PROCEDURES FOR PERFORMANCE
BASELINE ASSESSMENT AND ROUTINE EVALUATION
The Counterflow Inspection Procedure has been developed
by PEDCo Environmental to aid both the source operators and
regulatory agency inspectors to routinely evaluate air pollu-
tion control equipment performance. The fundamental principal
of the Counterflow Techniques is simply that performance diag-
gnosis is done by comparison of observed operating conditions
with a site-specific baseline operating condition. It is
recognized that field measurements are sometimes subject to
error or impossible; therefore, diagnosis is based on sets
of trends rather than just one parameter. Even when some of
the basic data is missing, it is still possible to reach
meaningful and accurate conclusions.
The purpose of the Counterflow Technique is to rapidly
identify significant changes in performance and the possible
reasons for the changes. It does not, necessarily, provide
definite evidence of noncompliance nor does it, necessarily
provide a specific list of repairs required.
Persons utilizing the Counterflow Inspection Technique
should have a technical background—preferably engineering ex-
perience. As with any work involving equipment, care should
be exercised. Section 6 provides some minimum guidelines
and should be read and reread regularly. Formal safety train-
ing is highly recommended for this activity and any field
work involving air pollution control equipment.
No single technique can satisfy all source characteris-
tics and inspection circumstances. Inspectors and source
operators should modify these procedures whenever necessary.
1
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1.1 BASELINE ASSESSMENT
Baseline determinations are preferably done soon after
the unit is installed and the shakedown period has been suc-
cessfully completed. For existing units, an adequate baseline
can be developed during a properly conducted stack test.
The purpose of the baseline assessment is to provide a site-
specific comparison of equipment performance.
The inspection procedures (and forms) presented in this
report should be used for both the baseline assessment and
the routine evaluation. There are several additional items,
however, that should be accomplished, namely:
1. Request a set of general arrangement drawings of
the control equipment, ventilation system layout,
and waste handling system;
2. Evaluate the stack test location and procedures to
ensure the emissions data will be accurate and
complete;
3. Carefully describe all internal conditions (if
such inspections can be conducted safely). Photo-
graphs are extremely valuable and should be taken
if it is safe to do so and if plant personnel
permits;
4. The sounds of operating components, such as rap-
pers and solenoids, should be noted so that the
inspector will be able distinguish developing
problems;
5. Obtain a complete set of process operating condi-
tions, fan characteristics, and raw material
characteristics; and
6. Obtain Method 9 opacity readings.
Using the opacity observation and the stack test results,
the inspector should evaluate how close the source is operat-
ing to the applicable regulations. If the margin is small,
the variability is normal; performance may be enough to
result in frequent violations. If the source is initially
well-below the standard, major changes in operation or
severe deterioration of control equipment is needed to result
2
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in noncompliance. The inspector must always be congnizant
of the compliance margin. The Counterflow Inspection Proce-
dures are used to evaluate the significance of the changes
since the baseline assessment.
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SECTION 2
COUNTERFLOW INSPECTION CONCEPTS
Proceeding counter to the gas flow (backward through
the system) should minimize inspection time and reporting
requirements and maximize the amount of useful information
obtained. More specifically, the information on effluents
and control equipment gained early in the inspection is not
only the easiest to obtain, it can be used later either to
narrow the scope of the inspection or to terminate the
inspection without completing the most time-consuming part
of the evaluation—namely, the process equipment.
As shown in the list below, the steps start at the
stack, proceed backward through the system, and end with the
process equipment. For regulatory agency personnel, there
are some additional preinspection and post-inspection steps
required.
Counterflow Inspection Procedure
Observe the stack effluent
Check the continuous monitor(s)
Measure the fan parameters and evaluate physical
condition
Analyze the control equipment performance and
physical conditions
Check the ventilation system performance and
physical condition
Evaluate process operating conditions
Check raw materials and/or fuels
Pre-inspection Steps (regulatory agency personnel only)
Review the source files
Schedule the inspection
Check the inspection equipment
Observe the plant surroundings
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Request entry to the plant
Interview plant official(s)
Post-inspection Steps (regulatory agency personnel
only)
Interview plant official(s)
Update source files
Prepare report
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SECTION 3
PRE-INSPECTION
3.1 FILE REVIEW
A logical starting point for Agency inspectors is to
review the. files concerning the specific plant. The follow-
ing items should be checked. Copies of items 1 and 2 should
be obtained for the project files.
1. Pending compliance schedules,
2. Construction and/or operating permits pertaining
to source processes,
3. Past conditions of noncompliance,
4. Frequency of malfunctions reports, and
5. History of abnormal operations.
The inspector should also obtain a copy of appropriate plant
layout drawings for use in preparing the audit inspection
report. If possible, the files should be reviewed before
entry to the plant so that important characteristics will
be more easily remembered.
The inspector should prepare a concise file containing
basic plant information, process descriptions, flowsheets,
and acceptable operating conditions (Appendix A). It should
contain the following to facilitate inspections and/or
preparations:
1. A chronology of control actions, inspections, and
complaints concerning each major source in the
plant;
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2. A flowsheet identifying sources, control devices,
monitors, and other information of interest;
3. The most recent permits for each major source, and
4. Previous inspection checklists.
Volume IV presents a recommended flow charting technique.
In plants with complex control systems, it may be beneficial
to review the technical literature and/or the complete agency
file.
Based on reviews of agency and personnel files, the in-
spector should select a time when processes will probably be
operating at representative conditions. The scheduling of
time to visit plants with batch operations or other irregular
operating schedules (e.g., seasonal) is especially important.
3.2 INSPECTION ANNOUNCEMENT
Written instructions from the Agency supervisory person-
nel should be obtained concerning the advance announcement
of inspections. If it is desirable to announce the inspection
in advance, leads of 1 day to 1 week are generally adequate
to ensure that the necessary plant personnel will be available.
The person contacted should have the authority to release
data and samples and to arrange for access to specific
processes.
3.3 INSPECTION EQUIPMENT
Necessary tools and safety gear should be carried in a
portable case from source to source:
Carry at all Times
Hardhat
Safety glasses or goggles
Gloves
Coveralls
Safety shoes (steel tipped)
Ear protectors
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Tape measure
Flashlight
Manometer or differential pressure gauges
Stopwatch
pH paper
Brass rods
Duct tape
Pry bar
Pocket guide of industrial hazards
Other equipment can be left in a central location until needed,
Carry When Needed
Pipe wrench
Respirator with appropriate cartridge
Velometer
Pump and filter system
Bucket
Combustion gas analyzer
Thermometers or thermocouples
Multimeter
Sample bottles
Strobe
Inductance ammeter
. Tachometer
Oxygen and combustibles meter
Self-contained breathing equipment
Pipe wrench
Rope
Particularly important is the safety equipment—including the
hard hat, the safety glasses, and the ear protectors. Remem-
ber, it is the inspector's responsibility to have safety
equipment before entering the plant. Access to certain
industrial facilities can be rightfully restricted or refused
by plant representatives if designated equipment is not worn.
3.4 PLANT SURROUNDINGS
Observations of areas surrounding the plant may reveal a
variety of signs of operational practices and pollutant emis-
sions which can aid in the preentry evaluation, including:
1. Obvious vegetation damage near the plant,
2. Odors downwind of the plant,
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3. Deposits on cars parked closeby,
4. Other signs of "dusting" downwind of the plant,
5. Fugitive emissions near plant boundaries,
6. Conditions around the product and/or waste storage
piles, and
7. Conditions near lagoons and sludge ponds.
Some of the signs may mean that fugitive emission sources
should be added to the inspection agenda. If odors are a
problem, the weather conditions should be noted for later
inclusion in the inspection report. Once inside the plant,
olfactory fatigue may (under certain circumstances) reduce the
inspector's ability to detect odors.
3.5 PLANT ENTRY
Upon arrival at the plant offices, the inspector should
contact a responsible official to gain access to specific
areas. If requested, the inspector should display an employee
identification card which includes a photograph, and a physical
description including, but not necessarily limited to, height,
color of eyes, and color of hair. Visitor release forms
generally can be signed as long as they in no way restrict the
scope of the inspection.
If entry is refused for part or all of a facility within
the scope of the inspection, obtain 1) reason(s) for refusal of
entry, 2) plant official's name and title, and 3) time and date
entry was requested. Notify supervisory personnel by telephone
immediately. Under no circumstances should field inspectors
attempt to summarize the potential legal consequences of
refusal of entry.
3.6 PRE-INSPECTION INTERVIEW
The inspector should plan the initial interview with the
plant manager or other responsible officials prior to the in-
plant inspection. Some of the points for discussion are:
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1. The purpose of the inspection,
2. The type of measurements to be made,
3. The samples (if any) to be acquired,
4. The systems to be evaluated,
5. Changes in plant management that need to be noted in
the main file,
6. Process flowsheets needed to confirm that opera-
tional conditions in the file still pertain, and
7. Operating records required by Standards of Perform-
ance for New Sources (NSPS) and/or for determinations
of operating conditions specified in permits.
Applicable regulatory requirements should be reviewed careful-
ly, and their apecific applications to the source in question
should be discussed with appropriate engineering and/or legal
staff.
Other issues the inspector should be prepared to discuss
include:
1. Authority for the inspection,
2. Agency organization,
3. Scope, timing, and organization of the inspection
(preferred inspection agenda), and
4. Treatment of confidential data.
The inspector should ask plant officials about the operational
status of all processes and pollution control equipment within
the scope of the inspection and about the types and frequencies
of any malfunctions. If equipment is not at or near normal
conditions, the reasons for deviation should be noted, and the
times when units can be expected to achieve representative
operations should be recorded for use in scheduling follow-up
inspections, if necessary.
10
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SECTION 4
COUNTERFLOW INSPECTION
The inspector starts the inspection at the gas exhaust
point (or endpoint) of the process and proceeds through the
process flow to the point where raw materials are input. Each
step shown on the flowsheet of Figure 1 should be based on data
from previous steps to derive increasingly precise analyses.
Examples of data received at each step are listed in column 2
of Table 1? the evaluations in column 3 gradually focus on air
pollution control effectiveness as the inspection continues,
due to the expanding data base in column 4. By the time the
in-plant inspection has ended, a series of ten or fifteen
distinct observations should provide a consistent and logical
assessment of performance conditions.
4.1 STEP 1: OBSERVE THE STACK EFFLUENT
The opacity readings of emission points should be
observed using Method 9 procedures. PEDCo recognizes that an
agency can, in many cases, develop a legally and technically
sound case solely on the basis of visible emission observa-
tions. In some cases, however, it is possible that the value
of opacity information will be primarily for diagnosing changes
in system performance. The following paragraphs describe how
the Counterflow Technique includes this diagnostic requirement.
aOnly staff with currently valid Visible Emission Certificates
should make these observations. It should be recognized that
an agency may choose to initiate enforcement actions directly
on the basis of these observations.
11
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STEP 6
INSPECT
PROCESS
STEP 5
INFLUENT GAS
HANDLING SYSTEM
STEP 1
OBSERVE S.TACK
STEP 4
INSPECT CONTROL DEVICE
AND WASTE HANDLING EQUIPMENT
STEP 3
INSPECT FAN
1-A
2-A
1-B
l-B
STEP 2
INSPECT
CONTINUOUS
MONITOR
1-C
CMR -
OPACITY
2-C
ESP SCA=350
BOTTOM
AGII
SILOS
FI.YASH
FLYASH
SILOS
V
FLYASH
Figure 1,
Steps in Counterflow Inspection Technique for coal-fired utility boilers
controlled by a "cold side" electrostatic precipitator.
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TABLE 1. COUI1TERFLOW TECHNIQUE, UTILIZATION OF DATA
Step
Data obtained
Preliminary evaluation
Support data
and steps obtained
1. Stack effluent
Change in opacity reading
Presence of detached plume
Presence and timing of puffs
Colors of emissions
None
None
2. Continuous monitors
Change in opacity reading
S02 and NO concentrations
Temperature of gas stream
Intermittent emission spikes
Representativeness of inspec-
tion period (review of
records)
Have emissions Increased to the point
of possible noncompllance?
Has size distribution of particles
changed?
Are there intermittent emission
problems?
Opacity - step 1
Opacity - step 1
Color - step 1
Puffs - step 1
3. Induced draft fan
Fan static pressure
Fan R.P.M.
Fan motor current
Gas temperature
Fan wheel vibration
Fan housing condition
Fan damper position
Has system pressure drop changed?
Has control system been bypassed?
Is effluent diluted?
Has gas flow rate changed?
Is demister operating satisfactorily?
Has operation changed fan R.P.M.?
None
Inspection stop point
Is further inspection necessary?
Opacity - step 1
Opacity - step 2
Gas temp - step 2 or 3
Fan static pressure - step 3
Fan motor current - step 3
Fan R.P.M. - step 3
4. Air pollution control
device external
inspection
Static pressure drop
Cleaning system operation
Hopper condition
Liquid flow rate
Liquid temperature
Liquid pH
Electrical parameters
Rapper operation
Solids/liquids discharge
rate
Has gas flow rate increased or
decreased substantially?
Has mass loading increased?
Has particle size distribution changed?
Are operating and maintenance practices
adequate?
Opacity - steps 1 and 2
Gas temperature - step 2 or 3
System pressure drop - step 3
Fan motor current - step 3
Opacity - steps 1 and 2
System pressure drop - step 3
Opacity - steps 1 and 2
Color of plume - step 1
(continue^
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TABLE 1. (continued)
Step
Data obtained
Preliminary evaluation
Support data
and steps obtained
Inspection stop point
Is further Inspection necessary?
Results of previous analyses,
plus comparison of control device
actual and baseline parameters
(diagnostic score)
5. Ventilation system
ductwork (effluent
delivery)
Hood capture velocities
Static pressures along duct-
work
Gas temperatures
Condition of cleanout traps
Integrity of ductwork
Have gas flow rates changed?
Are gas streams being diluted?
Are all sources being operated?
Fan current - step 3
Fan static pressure - step 3
Control equipment static
pressure drop - step 4
Gas temp - steps 2 and 3
6. Process equipment
Production data
Process monitors
Raw material information and
samples
Has production rate Increased?
Have operating conditions changed?
Have raw material characteristics
changed?
Has particle size distribution of
effluent changed?
Can an Internal Inspection of control
equipment be conducted safely?
Gas flow rate - step 5
Static pressure data - steps 4 and
Solids discharge rates - step 4
Opacity - steps 1 and 2
Fan motor current - step 3
Fan static pressures - step 3
Opacity - steps 1 and 2
Inspection stop point
Is an internal inspection of air
pollution control devices necessary
and feasible?
Process operating conditions - step 2
Control device conditions - step 4
7. Air pollution control
device (external
inspection^
Clean side deposits
Alignment of electrodes - ESP
Insulator conditions
Fabric condition
Gas distribution plate/vane
conditions
Air inleakage through welds
and holes
Hopper conditions
Confirm preliminary evaluations
- steps 1 through 6
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In most cases, there is a relationship between the opacity
observed during the inspection and the mass emissions penetra-
ting the control device. Regardless of the mathematical form
of this relationship, as the opacity increases, the mass
emissions generally increase. In Figure 2a, Case 1 represents
the most sensitive relationship—a small increase in opacity
indicates a large increase in mass emissions; however, errors
inherent in a small opacity increase can make any conclusions
meaningless in this case. Case 2 presents "contrary" prob-
lems—above a certain upper opacity level, there is no change
in mass emission rates; thus, at this level, opacity has no
diagnostic value. The ideal case is the linear relationship of
Case 3; fortuitously, this is generally the prevailing
relationship in most industries.
Despite the best efforts of regulatory development person-
nel, the mass emission regulations and opacity regulations may
not always agree. Linear relationships illustrate these possi-
ble disagreements in Figure 2b. Case 4 represents the intended
situation; that is, any violation of an opacity regulation also
involves a violation of the mass emission regulation. In
Case 5 there is a substantial opacity violation without a
violation of the mass standard. In other cases (represented by
line segment 6), a violation of mass emission standards might
not be suspected due to decreased sensitivity to opacity. The
point is: in certain cases the absolute magnitude of the
observed opacity is most useful when the opacity-mass
relationship is known.
In the diagnostic phase of the Counterflow approach, the
procedure uses (whenever possible) a change in opacity (ob-
served versus historical) rather than an absolute magnitude of
observed opacity. Regardless of the opacity-mass relationship,
(or the mathematical form) a change in opacity does indicate a
change in mass emissions. This information supported by a set
of facts herein provides the conclusions sought in a plant
inspection using the counterflow procedure.
15
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CASE 2
80
CASE 3 _
60
I
20
1 2 3 ^
MASS EMISSIONS, ARBITRARY UNITS
Figure 2a. Opacity-mass relationships.
16
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MASS EMISSIONS, ARBITRARY UNITS
Finure 2b. Opacity and mass emission violations,
17
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The color of -the effluent is another plume characteristic
which should be observed. For fossil fuel combustion sources,
the color is an indirect indication of operating conditions.
The following list (Table 2) was compiled by EPA's Control
Programs Development Divisions:
TABLE 2. PLUME CHARACTERISTICS AND COMBUSTION PARAMETERS
Plume color
White
Gray
Black
Reddish brown
Bluish white
Possible operating parameters to investigate
Excess combustion air; loss of burner flame in
oil-fired furnace
Inadequate air supply or distribution
Lack of air; clogged or dirty burners or in-
sufficient atomizing pressure, improper oil
preheat; improper size of coal
Excess furnace temperatures or excess air;
burner configuration
High sulfur content in fuel
For other types of sources, the color may not be as variable or
may not have a distinct meaning with respect to the process or
the control equipment. Nevertheless, a change in the color
indicates a change in the system. For example:
/
1. Increased quantities of bluish particulates generally
indicate increased generation of very small particles
(0.1 to 2 microns) which are difficult to collect in
most control devices.
2. A detached plume indicates fairly conclusively that
particulates are forming as the vapors are released
to the cold ambient air; detached plumes often cause
serious corrosion problems, since any cold surface in
the system is susceptible to acid-mist condensation.
3. The frequency and duration of "puffs" from the stack
are often caused by rapping reentrainment problems in
electrostatic precipitators (ESP's) or by fabric
leaking/cleaning problems in baghouses. Cyclic
process conditions can also lead to puffs.
18
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4.2 STEP 2: CHECK THE CONTINUOUS MONITORS
After observation of the stack effluent, the next logical
step is to check the continuous monitors downstream from the
control equipment.
1. The operation of the purge air blowers should be
confirmed and the alignment of the source and retro-
reflection should be checked.
2. The actual path length should be compared with the
value used in the instrument calibration.
3. In almost all cases, the zero and full-scale settings
can be checked and confirmed without taking the
instrument offline.
4. The status of the window inductor light should be
checked.
5. Also, the appearance of the instrument recording
trace and the changes in recorded values may indicate
reliability or unreliability of continuous monitor
data.
Process operating personnel should be able to supply data on
the technique and the frequency of calibrations.
The continuous opacity monitor (commonly called a trans-
missometer) indicates intermittent emission spikes caused by
rapping reentrainment (ESP's); pulse flexing of bag seams
(fabric filters); and other problems. A brief scan of the last
24 hours of chart paper may help to identify these problems and
to describe system performance.
The transmissometer data should be used to confirm and
clarify the opacity observations in step 1. Instrument prob-
lems should be suspected when there are substantial differences
between the opacity recorded in step 1 and that indicated on
the monitor. If the instrument response time and the recorder
chart speed have been set properly, it will be possible to
check for trends in the opacity levels.
1. A cyclic pattern suggests variation in process
operating conditions; and
19
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2. A continually deteriorating pattern suggests a
developing control device problem which is likely to
demand the attentions of the operator and the
inspector; the deterioration can also suggest a
gradual drift of the instrument or accumulation of
dirt on the optical surfaces.
Failure to properly operate and/or maintain an opacity monitor
can constitute a violation of regulations.
In step 2, the inspector should have:
1. Confirmed the visible emissions status with respect
to opacity regulations,
2. Confirmed the installation and operating status with
respect to continuous monitor regulations, and
3. Developed a preliminary idea of the process and the
control device operating conditions.
As yet, there would not be enough information to evaluate
mass emissions in cases where a reliable opacity-mass emission
correlation has not been identified.
4.3 STEP 3: MEASURE THE FAN OPERATING PARAMETERS
Three operating parameters of the induced draft fan are
useful in interpreting control system operations:
1. Increase in total static pressure across the fan,
2. Electrical current drawn by the fan motor, and
3. Revolutions per minute (R.P.M.'s) of the fan wheel.
Evaluated together these parameters indicate the gas flow rate
and the total system pressure drop. These changes are impor-
tant in diagnosing control system operating conditions.
If the fan parameters are not monitored at the plant, the
inspector should use an inductance ammeter, a manometer (or
magnehelic gauge), and a tachometer (or a strobe in cases where
the tachometer cannot be used). The inspector should request
that static pressure taps be made in the ductwork leading to
and from the induced draft fan. The inspector should not drill
or cut these holes unless the plant manager approves. Once
20
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taps are available, the static pressures at the fan inlet and
outlet should be measured using the set of magnehelic gauges.
The fan data can be used to estimate the gas flow at the
time of the inspection. After correction of all readings to
standard conditions, refer to the appropriate set of charac-
teristic curves to determine SCFM. Please remember that this
is only an estimate and is subject to errors due to variability
in fan performance, site-specific gas flow factors, and
physical condition of the wheel. The remainder of this section
concerns means to utilize fan data to diagnose changes since
the previous Counterflow Inspection. (Note: in most cases the
baseline data will not be available since fan parameters are
not measured in conventional inspections).
The type of fan used by most industrial sources with
particulate-laden effluents is the radial blade centrifugal
fan. Its operating parameters are illustrated in Figure 3;
this curve applies to a New York Blower Company size 332
general induced draft fan with an LS wheel operating at 1460
R.P.M.'s at standard conditions. As indicated, the static
pressure losses in the control equipment and ductwork (curve.A)
increase proportionally with the square of the flow rate. The
fan, however, develops less static pressure at higher flow
rates, and thus it has a strong negative slope (curve B). The
intersection of the system line and the fan pressure drop
curves define the operating point of the system. At this
point, the gas flow rate is 8,400 SCFM, and the brake horse-
power (curve C) is approximately 24.5. Figure 3 should be used
as baseline data in considering:
1. The potential effects of gas temperature,
2. The changes in system static pressure drop, and
3. The changes in fan speed.
Changes in the rotation speed of the fan wheel is possible in
many belt-driven units as shown by the curves in Figure 4. In
Case 1, an R.P.M. increase leads to a greater gas flow rate and
21
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11
.E 10
LU Q
o: 2
a.
00
CURVE A
SYSTEM AP
7 8 9 10
GAS FLOW RATE, SCFM X 103
38
36
"I
Q.
LU
30 £
o
X
10 UJ
2o ^
26
2/t
22
11
12
Figure 3. Operating characteristics of radial blade centrifugal fan
(New York blower size 332 with LS wheel @ 1460
22
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12
0 11
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higher static pressure. Increasing the R.P.M. is the course of
action at plants where process gas flow is insufficient; how-
ever, this can dangerously increase tip speed, and it can ad-
versely affect fabric filters or ESP's. The opposite situation
is illustrated in Case 2. An R.P.M. decrease (perhaps to save
energy cost) can decrease the flow substantially; this can
reduce the collection efficiency of cyclones and wet scrubbers
since these depend on impaction for particle collection and
since impaction efficiency is directly dependent on gas velo-
city. Increases in the fan wheel R.P.M. can occur because of
intentional actions of the operator. (Belt shippage can reduce
R.P.M. without operator's knowledge).
Other changes in fan operation can occur with or without
the operator's knowledge. For example, the fan motor current
decreases when the static pressure drop increases; Case 3 in
Figure 5 represents total system pressure drop increases.
Accompanying this Case 3 change should be an increase in the
fan motor current as indicated in Figure 5. As indicated in
Table 3, this change can be due to a variety of process and
control device operating factors. Pressure drop decreases can
be caused by (partial list):
1. Decreased effluent gas flow rate, and/or
2. Operating conditions such as control device short-
circuiting (open access doors, gaps in ductwork, open
by-pass dampers), and
3. Decreased scrubber liquor flow.
The cause of the change can be further analyzed by considering
the measured gas temperature at the fan inlet. A low tempera-
ture suggests either an open access hatch or a serious leak in
the ductwork.
System diagnoses are based on changes in the three fan
operating parameters. All three (total static pressure, motor
current, and wheel R.P.M.) must be measured since all three are
analyzed as a set. (The Counterflow Procedure does not require
24
-------
s 11 -
UJ
Q-
O
<
1/5
I
7 8 9 10
GAS FLOW RATE, SCFM x 103
11
12
Figure 5.
Fan characteristic curves—effect of system pressure drop
change.
25
-------
knowledge of fan characteristic curves.) With these, the
inspector should be able to determine if abnormal conditions
exist and which of the four cases is applicable.
In addition to analyzing the operation of the fan, the
inspector should observe the physical condition of the fan. If
it is possible to physically inspect the fan (be sure it is
locked off), note the presence of:
1. Blade abrasion,
2. Deposit buildups, and
3. Corrosion of the wheel and fan housing.
The first two problems indicate excess emissions of large
particles (lOy) and demister malfunction. The third problem
could be due to both the overloading of the demister and excess
emissions of corrosive gases. The induced draft fan operating
parameters indicate a number of important changes in control
device operating conditions (Table 3). The measured parameters
were corrected for the gas temperature at the fan inlet by
using the factors in Table 4.
At the end of step 3, the inspector should decide whether
or not further on-site efforts are necessary to determine com-
pliance with mass emission standards. If the fan operating
parameters (static pressure, motor current, and R.P.M.'s) are
+10% and if the gas temperature at the fan inlet is +20 F, it
is unlikely that mass emissions have changed significantly. In
some cases, the field inspection can be terminated with step 3.
Generally, it is necessary to inspect the control equipment
(step 4) to confirm the evaluations of steps 1, 2, and 3.
4.4 STEP 4: ANALYZE CONTROL DEVICE PERFORMANCE
Based on the previous three steps in the Counterflow
Procedure, the inspector should have a preliminary estimate of
the following:
1. Present gas flow rate through the control system and
changes since last Counterflow Inspection,
26
-------
TABLE 3. INTERPRETATION OF FAN OPERATING CONDITIONS
(RADIAL .BLADE TYPE ONLY)
Case
1
2
3
4
Fan parameters
Calculated
APSD at 70°F
Decreased
Increased
Increased
Decreased
Calculated
Amps at 70 F
Decreased
Increased
Decreased
Increased
Fan wheel
R.P.M.
Decreased
Increased
Unchanged
Unchanged
Possible causes
Operator decreased R.P.M.
Operator increased R.P.M.
a) Filter blinding
b) Filter cleaning problem
c) Hopper overflow
d) Scrubber bed pluggage
e) Decreased gas flow
f) Damper partially closed
a) Baghouse leaks
b) Shortcircuiting
c) Decrease in liquor flow
d) Increase in gas flow
e) Damper partially open
TABLE 4. FAN DATA, TEMPERATURE CORRECTION'
Temp
20
40
60
80
100
120
140
160
180
200
220
240
260
280
300
Factor
0.91
0.94
0.98
1.92
1.06
1.09
1.13
1.17
1.21
1.25
1.28
1.32
1.36
1.40
1.43
Temp
°F
320
340
360
380
400
420
440
460
480
500
520
540
560
580
600
Factor
1.47
1.51
1.55
1.59
1.62
1.66
1.70
1.74
1.77
1.81
1.85
1.89
1.92
1.96
2.00
Adapted from "Basic Energy/Environment Analysis"
series 67, by C. Heath, August 1978.
NAPA information
27
-------
2. Present total system static pressure drop and changes
since last Counterflow Inspection,
3. Changes in particulate emission levels since last
stack test or Counterflow Inspection,
4. Present temperature of the effluent, and
5. Presence of cyclic or intermittent emissions.
Results of these five observations should provoke specific
questions to guide the inspection of the control system.
When inspecting the control device and its auxiliary
equipment, the inspector should proceed in a logical sequence
to obtain the information needed for evaluating the perform-
ance. Detailed checklists (Appendix B) have been prepared for
wet scrubbers, fabric filters, and ESP's. The general approach
to all three is to use checklists as the inspector proceeds
from the control room (if applicable) to the control device.
These checklists are arranged to facilitate the inspection.
The checklists include preliminary diagnostic sections
(Tables 5-7) which are arranged according to commonly encount-
ered problems.
For example, the ESP diagnostic sheet includes, but is not
limited to:
1. Particle resistivity changes,
2. Insulator failures,
3. Broken discharge wires, and
4. Nonuniform gas distributions.
Under the each problem category is a list of readily observed
symptoms and the relative importance of each as indicated by a
rating factor. If the sum of the factors under any category is
>10, there is a reasonable probability that a problem does
exist; if so, further inspection and/or testing is needed and
should be recommended in the inspection report.
In most plants, it will be impractical to observe every
item listed in Figures 6-8 or to observe every symptom listed
28
-------
TABLE 5. FABRIC FILTERS COUNTERFLOW INSPECTION DIAGNOSTIC SECTION
Possible Operating Problems
NJ
Average Ba-seline
(Specify Value)
Observed Locution*
(Specify Value)
Abnormal Rating
(Check) (1-10)
Recommended Action
A.
B.
C.
Bag Tears or Pinholes
1. Filter house pressure
drop low (<80X avg.)
2. Opacity high
3. Dag age high (typical avg.)
.4. Some bags inaccessible N/A
5. Design A/C high (>120X avg.)
6. Actual A/C high (>120Z avg.)
7. Wear plate eroded H/A
6. Frequent high excursions
Bag Blinding
1. Filter house pressure
drop high ,<>150j; ftvg.)
2. Opacity low
3. Cleaning frequency high
(cycles/day)
4. Gas temp low (<20°F avg.)
5. Moisture in gas stream N/A
6. Pnrticulnte sticky H/A
7. Air in-leakage (hoppers/ N/A
access doors)
8. Unit not insulated N/A
Bag Bleeding
1. Opacity high
2. Pressure drop gradually
increasing
3. Cleaning frequency high
E
E
E
N/A I
E
E
...'N/A~ I
E or I
E
E
E
k E
H/A E
H/A E
N/A I
K/A E
E
E
E
(Continued)
3
5
5
, 2
It
4
3
A
r -
7
2
5
4
4
4
2
2
E -
5
2
_ 5 ^
Z -
If sum (I) of ratings is > IQ,
perform internal inspection.
Check for deposits on fil-
ter house clean side. Check
inaccessible bags. Use
fluorescent dye technique. '
Check integrity of fabric by ,
attempting to extend rips.
If sum (E) of ratings is >10,
perform internal inspection.
Check dirty side of bags for
coatings (this nay be diffi-
cult to identify in some
.sees) . Check records for
steady rise in filter house
pressure drop. Reschedule
inspection in near future •
If sum (E) of ratings is >10,
attempt to confirm uses oT
fluorescent dye and black
light.
^Location: E is external, and I is internal.
-------
TABLE 5 (Continued)
OJ
o
Possible Operating Problems Average Baseline
(Specify Value)
D. Cleaning System
1. Filter house pressure drop
high
2. Pulse-jet air header pres-
sure low
3. Solenoids inoperative
4. Reverse air fan inoperative
5. Shaker motor inoperative
6. Bag length long
7. Equipment inaccessible
8. High intensity cleaning
required
E. Hopper
1. Filter house pressure
drop high
2. Solids-removal run in-
termittent
3. Indicator level existent
nnd/or inoperative
4. Heaters nonexistent and/or
inoperative
5. Vibrators nonexistent
nnd/or inoperative
6. 'llopper valves corroded
7. llopper slope <60°
8. Hoppers not insulated
9. Winter
10. Hammer markings on hopper
walls
11. Conveyor inoperative
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Observed Location* Abnormal Rating Recommended Action
(Specify Value) (Check). (1-10)
N/A
N/A
N?A
N/A
•
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
E
E
E or I
•J or I
E or I
E
I
E • ]
E
E
E
E
F.
1
E
E
E
E
E
5 If aura (E) of ratings is '>10,
perform internal inspection
5 and check deposits on dirty
ilde of bags. Check bag ten-
10 slon. Reschedule inspection
10 In near future.
10
2
2
2
E •
5 If aura (E) of ratings is >10,
perform Internal inspection
3 of hoppers.
2
2
2
3
2
7
2
2
10
E -
*Locationi E is external, and I la internal.
-------
TABLE 6. SCRUBBERS COUNTERFLOW INSPECTION DIAGNOSTIC SECTION
Poaaible Operating Problems Average Baseline
(Specify Value)
A.
B.
C.
No Liquor Flow
1. Pumps are inoperative N/A
2. Inlet and outlet gas temps N/A
same
3. Opacity high
.4. Scrubber pressure drop low
5. Nozzles plugged N/A
Low Liquor Flow
1. Nozzle operating pressure
(<80X avg.)
2. Gas temp high (10Z above
avg.)
3. Opacity high
4. Reclrculatlon liquor pH
low (<5)
5. Flow rate monitor value low
(<80Z avg.)
6. Scrubber pressure .drop low
(<80Z ovg.)
7. Exit water temp high
(>20Z above avg.)
Gns Flow Rate High
1. Opncity high
2. Outlet RBB stream temp
high (>20°F above avg".)
3. Exit water temp high
Observed Location*
(Specify Value)
Yea, No E
N/A E
E
E
Yea. No I
E
E
E
E
E
E
E
E
E
E
Abnormal Rating
(Check) . (1-10)
10
10
5
5
7
E -
3
3
5
3
7
3
3
E -
5
5
5
Recomaended Action
If sun (E) of ratings >10,.
request Immediate correction
action, and/or stack teat.
If sura (E) of ratings Is >lu,.
attempt to measure exit water
flow rate to. confirm conclu-'
slons. Request stack test.
If sum (E) of ratings Is > 10,
check process equipment and
production rate.
(>20°F above avg.)
*Location: E is external, and I la internal.
(Continued) *
E -
-------
TABLE 6 (Continued)
to
Feasible Operating Problems Average Baseline
(Specify Value)
D.
E.
F.
Gaa Flow Rate High
1. Opacity high __
2. Temp of outlet gas low
(>20°F below avg.)
3. Temp of exit liquor low
(>20°F below avg.)
4. Scrubber pressure drop low
(<80X avg.)
Bed Plugging
1. Scrubber pressure drop high
(>40X above avg.)
2. Liquor turbidity high N/A
3. Liquor pH high (>B)
Nozzle Erosion
1. Nozzle operating pressure
drop low (<80X avg.)
2'. Opacity high
3. Liquor turbidity high N/A
4. Corrosive liquor N/A
5. Nozzles unchanged in N/A'
6 months
6. Nozzles operable N/A
Observed Location*
(SpeclfyValue)
E
E
E
E
E
N/A ii
E
E
E
H/A E
N/A E
N/A E
N/A 1
Abnormal Rating
(Check) fl-10)
' 5
______ 5
5
. 5
T« —
5
5
5
E -
5
3
3.
3
3
10
Recommended Action
If sum (E) of ratings is >10,
check process equipment and
production rate. Request stack
test if problem is serious.
If sum (£) of ratings is >10,
check for bypassing of efTluent
around scrubber. Request
immediate corrective action,!
If sum (E) of ratings is >10,
recommend nozzle replacement .
*Location: E is .external, and I is Internal.
(Continued)
-------
TABLE 6 (Continued)
Possible Operating Problems
to
to
Average Baseline
(Specify Value)
Observed Location* Abnormal Rating Recommended Action
(Specify Value) (Check) (1-10)
G.
U.
I.
J.
Demlster
1. No water flow to demlster
2. Gas velocity high (>10 ft.
per second)
3. Fan vibrating
tfenturi Throat Adjustment
1. Scrubber pressure drop low
(<80I avg.)
2, Visible evidence of changes N/A
3. Opacity high
ImplnRcraent Plate or Tray Collapse
1. Pressure drop low (<80Z avg.)
2. Opacity high
3. Build-up of liquor in sump N/A
In-lcakaRe of Air
1. Temp of gas stream low
2. Obvious shell corrosion N/A
I
E
E
E
N/A E
B
E
E
N/A 1
Z
N?A I
5
10
5
E -
4
4
4
E •
4
4
4
E -
5
5
E -
If earn (E) of ratings is >10,
check for changes in producti'o
rate. Reschedule inspection
in near future in anticipation
of fan unbalance problem.
If sura (E) of ratings is >10,
request corrective action"
immediately or request stack
test.
If sun (E) of ratings is >10,
attempt -internal inspection.
If sum (E) of ratings is >10,
attempt Internal inspection.
^Location: E is external, and I is Internal.
-------
TABLE 7. ELECTROSTATIC PRECIPITATORS COUNTERFLOW INSPECTION DIAGNOSTIC SECTION
Possible Operating Problems
Average Baseline
(Specify Value)
Observed Location* Abnormal Rating
(Specify Value) (Check) (1-10)
Recommended Action
I. ELECTRICAL
A. . Particle Resistivity
It Peak voltage low
(down 5-10 kv)
2. Rapping intensity
increased
3. Temp changed (+50°F)
4. 'Spark rate increased
(±50 sparka/min)
5. Opacity high
6. Coal sulfur content
low (<1.0Z)
B. Transformer-Rectifier Set Problems
1. No secondary current N/A
2. No penthouse purge N/A
3. Voltage rero, current N/A
high
4. Opacity high
C. Insulator Failure
1. Peak voltage low
2. Penthouse purge (not N/A
used)
3. Penthouse temp high
(+20°F)
4. Opacity high
5. Cracks visible N/A
E
E
E
E
E
E
N/A E
~ N/A E
N/A E
E
E
~_ N/A E
E
— r— E
N/A I
5
5
3
5
6
6
E -
10
2
10
6
E -
5
5
3
6
10
If sum (E) of ratings is >10,
request in-situ resistivity tea
and check sulfur content of
fuel, moisture content of gas,
and temperature of gas.
If sum (E) of ratings is >10,
request repair. ~"
If sum (E) of ratings is >10,
request repair.
;Continued)
•Location! E is external, and I is internal.
E -
-------
TABLE 7 (Continued)
Possible Operating Problems
OJ
ui
Average Baseline
(Specify Value)
Observed Location* Abnormal Rating Recommended Action
(Specify Value) (Check) (1-10)
D. Broken Dincharfte Wlren
1. Deposits on vires N/A
2. Violent meter flue- . N/A
tuating
3. Hopper level indicator N/A
not used
A. Spark rate high (+50
sparks/min)
5. Opacity high
6. Broken discharge wires N/A
N/A I
N/A K
N/A E
E
E
N/A I
5 If sum (E) of ratings is >tO,
10 request repair.
2
5
3
10
E -
II. CAS FLOW
A. Excessive Velocity
1. Flow rate high
2. Voltages high, cur-
rents low
3. Opacity high
E
E
E
5 If sum '(£)' of ratings is HO,
5 check production and/or genera-
tor rate.
5
N/A
B. Nonuniforra Distribution
1. Flow rate Increased
2. Secondary currents
nonparallel
3. Hopper levels differ-
ences on parallel
branches
4. Rappers on distribu-
tion plates not used
^Location: E is external, and I is inteiual.
N/A
E -
N/A
E or I
2 If sum (E) of ratings is >10,
5 request velocity traverse.
E -'.
(Continued)
-------
TABLE 7 (Continued)
Possible Operating Problems Average Baseline Observed Location* Abnormal • Rating
(Specify Value) (Specify Value) (Check) (1-10)
Recommended Action-
l/J
en
III. MECHANICAL
A. Rapper Problems
1. Puffs visible
2. Peak voltage changed,
secondary current
constant
3. Spark rate changed
4, Low sulfur coal used
5. Dust sticky
B. Hopper Solids Removals
1. Broken discharge wires
2, Mass loading probably
. increased
3. Nonuniform gas distri-
bution
4. Hoppers not emptied
continuously
S. Level indicators not
used
6. Heaters not used
7. Vibrators not used
8( Hoppers not insulated
9. Corrosion around. out-
let valves
10. Hopper slope <60°
11. Hoppers full or
bridged
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A""
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
7 N/A
E
E
E
E ~
E
I
E
E -
E
E
E
E
E
I
E
I
5
5
_ 3
Z 3
5
5
_ 3
5
_ 3
2
2
10
E -
If sum (E) of ratings is >10,
request internal inspection by
plant personnel. Request inten
eity measurement, if approprlat
If sum (E) of ratings is >10,
request internal Inspection
and/or changes in operational
practices.
^Location! E ij external, and 1 in internal.
(Continued)
-------
TABLE 7 (Continued)
Poaaible Operating Problems
Average Baseline Observed Location* Abnormal Rating
(Specify Value) (Specify Value) (Check) (1-10)
Recommended Action
III. MECHANICAL (continued)
C. Collection Plate Warp and Halalignment
1.
2.
3.
A.
Change In air load
Repeated hopper over-
flow
Air in-leakage
Halalignment visible
N/A
N/A
N/A
N/A
N/A
N/A "
N/A
N/A ~
E
E or I
E
I
5 If sum (C) of ratinga la >10.
3 requeat alignment check.
3
10
r ••
CO
-J
IV. EFFLUENT CHARACTERISTICS
A. Haas Loading Increases
1. Opacity high
2, Inlet section, secon-
dary currents low
3. Hopper unloading fre-
quency increases
6 If sum (1) of ratings la >IQ,
5 check production and/or genera-
tor rate.
I -
*Locationi E la external, and I Is Internal.
-------
NO
YES - ENTER UNIT
Check pressure drop across
each compartment; also,
check condition of lines
and pressure gauges.
ENTER RESULTS ON LINES Al,
Bl, Cl, Dl, and El, OF
CHECKLIST.
Check cleaning system:
-Pulse jet pressure
-Solenoids
-Reverse air blowers
-Shakers
ENTER RESULTS IN SECTIONS
B, C, and D OF CHECKLIST.
Check condition of bags:
^Bag tears
-Bag deterioration
-Dropped bags
-Oily bags
-Wet bags
-Improper bag tension
-Deposits on floor
ENTER RESULTS IN REPORT.
Check solids removal equip-
ment:
-Screw conveyor
-Pneumatic system
-Heaters
-Vibrators
ENTER RESULTS IN SECTION E
OF CHECKLIST.
Are
there any
indications of
nonoptimal per-
formance?
Check clean air chamber for
possible leakage.
Check hoppers
Incomplete solids removal
Corrosion
ENTER UNIT TO CONFIRM
EVALUATIONS. MAY NEED
TO RESCHEDULE INSPECTION.
END INTERNAL FABRIC FILTER
INSPECTION.
NO - END FABRIC FILTER INSPECTION
Figure 6. Fabric filter inspection flowsheet.
38
-------
1
««s
r
Reschedule inspection
for a time when unit is
operational
i
r
Inspect internal parts:
Nozzle condition
Presensft of corrosion
Presense of erosion
Presence of scaling
i
f
Check integrity of shell
retention grids, and othe:
parts.
,
Check slurry handling
system.
Check pumps on purge,
make-up, and recircula-
tion lines.
Read flow meters if avail
able. Check liquor temp
on inlets and outlets.
ENTER RESULTS IN SECTIONS
A AND B.
I
Check pressure gauges am
differential pressure
monitors across the fol-
lowing:
Spray nozzles
Scrubber beds
Venturi throat
Demisters
ENTER RESULTS ON CHECK-
I.TST.
Check sunp and recircu-
lation tanks:
-Liquor temperature
-Liquor pH
:NTER RESULTS
1ST.
ON CKECK-
Check inlet conditions:
-Gas temperature
-Presaturator water
flow rate
ENTER RESULTS ON CHECKLIST
END SCRUBBER INSPECTION
Figure 7. Scrubber inspection flowsheet.
39
-------
Perform Internal
Inspection.
T
NO
Top section, check:
-Rappers
-Drives
-Insulators
-Heaters
-Blowers
Electrical Field section,
check:
-Alignment
-Build-up
-Rappers
-Drives
-Insulators
-Erosion
-Corrosion
Check:
-Hopper section
-Build-up
-Corrosion
-Hopper baffles
T
Check:
Gas distribution devices
ESP -Inlet
-Outlet
-Ductwork
• -Corrosion
-Erosion
-Plugging
-Rapping systems
i
End ESP inspection, return
for operational inspection.
YES
Identify bus section numbering
system.
Check for bus sections which
are not operating.
Check electrical characteris-
tics of each bus section
that is operating.
-Primary voltage
-Primary current
-Secondary current
-Secondary voltage (if
measured)
-Spark rate
Check rapper sequence and
timing.
Check insulators purge and
heating system.
ENTER RESULTS IK APPROPRIATE
PLACES ON CHECKLIST.
Check operational status
Hopper heaters & vibrators
Solids removal system
ENTER RESULTS ON CHECKLIST.
ESP IN-
SPECTION.
Reschedule operational in-
spection. Recocisiend mainte-
nance work.
END ESP INSPECTION.
Figure 8. Electrostatic precipitator inspection flowsheet.
40
-------
in Tables 5-7. This is why the diagnostic sheets are designed
to reflect combinations of observations. In the extreme situa-
tion where there are essentially no equipment monitors and
where access to components is restricted, the difficulty and
limitations involved in performance evaluation should be noted
in the inspection report.
During each stage of the control device evaluation, the
inspector should compare the observed operating conditions with
the baseline values obtained from compliance stack tests or
from manufacturer's specifications. Deviations from site-
specific baseline values are the best indicators of abnormal
performances.
The following discussions of control devices do not extend
to standard design methodology and operating procedures. It is
assumed that the field inspector is familiar with most control
devices and has performed in-plant inspections in the past.
4.4.1 Fabric Filters
Five major categories of fabric filter operating problems
are listed in the left column of Table 5. Only one of these—
Bag Tears/Pinholes—causes immediate excess emissions. The
others strain the fabric to the point that extensive repair
and/or replacement is eventually necessary.
There are two basic approaches to the inspection of fabric
filters. With the most common one, the unit is not shutdown
during the inspection. The field inspector should decide if
the observed performance symptoms call for a follow-up internal
inspection and if a stack test should be recommended. With the
second approach, the system can be shutdown (or compartments
isolated one-by-one) long enough to perform the internal
inspection. If the opacity observed in step 1 and/or step 2 is
high and if the internals are accessible, we highly recommend
proceeding along the right-hand path of Figure 6. Internal
checks are the only truely reliable means for identifying fab-
ric filter problems. Only if access to the unit is impossible
41
-------
do we suggest the use of the indirect approach illustrated on
the left of Figure 6; in this case, the inspector evaluates
whether a return trip (when the unit is down) is justified.
Some of the symptoms on the diagnostic checklists are
design factors. Fabric filter design is very significant with
respect to long-term performance. Design deficiencies at any
source should be checked routinely during each inspection.
4.4.2 Wet Scrubbers
To evaluate the performance of a wet scrubber, the PEDCo
inspector should first confirm that the recirculation pump is
operating. If there is no water/liquid circulating through the
system, the inspector should recommend a follow-up inspection
when the scrubber will be operational. If there is circula-
tion, the inspector should proceed along the flow of water
through the system (water flow is generally counter to gas
flow).
Next, the inspector should confirm that the pumps are on,
and if so, should read the flow meter (if any). In the line
going to the spray nozzles, low pressure indicates erosion of
the nozzles and likely increases in the water spray droplet
size. If the line pressure does not change when the flow is
temporarily shut off (the inspector must not adjust valves),
the nozzles are plugged. Static pressure drop across each
stage should be recorded, if possible, to help in problem
diagnosis.
To complete the check of the water system, the inspector
should measure the temperature and the pH of the sump liquor.
It is advisable to take a liquor sample; however, the expense
should not be incurred unless there are reasons to suspect
operational and/or corrosion problems (chain-of-custody pro-
cedures must be followed). During the inspection, the integ-
rities of the scrubber shell and the component parts should be
rountinely checked.
42
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4.4.3 Electrostatic Precipitators
There are four problems which can affect the performance
of an ESP:
1. Electrical,
2. Gas flow,
3. Mechanical, and
4. Effluent.
In each problem category, there are three to five symptoms
which occur with reasonable frequency, but the observed
symptoms do not often indicate a particular problem. Due to the
complexity caused by the interfacing of these problems, it is
important that the inspector use a combination of symptoms in
identifying operational difficulties.
The checklist (Table 7) and the flowsheet (Figure 8) are
logical approaches to the evaluation of an ESP. Unlike the
comparable charts for fabric filters and wet scrubbers, those
for an ESP include a preliminary flowcharting step for use if
a diagram is not available, so that the electrical data can be
simplified and understood.
The inspector should begin in the main control room (or
the substation) where much of the electrical data can be ob-
tained. Performance evaluation should include, but not
necessarily be limited to:
1. Power density calculations,
2. Evaluation of parallel field secondary currents,
3. Evaluation of inlet field secondary currents,
4. Spark rate,
5. Hopper heater/vibrator operational status,
6. Penthouse purge fan operational status,
7. Hopper unloading frequency,
8. Rapper operational status, and
9. Rapper frequency in various locations.
43
-------
We recommend that internal ESP inspections be done only when
the inspector is accompanied by a company representative. Fur-
thermore, the inspector should always wear a respirator, hard-
hat, and gloves; should fully understand the lockout procedures
used at the plant, and should strictly adhere to safety
procedures due to the many potential hazards. A precipitator
is essentially a giant capacitor.
Inside the unit, it is possible to identify many operating
problems which are hard to diagnose otherwise. Particular
attention should be given to:
1. Dust accumulation on turning vanes and distribution
plates which can indicate and/or cause poor gas
distribution and low particulate control efficiency;
2. Obvious corrosion which suggests in-leakage of air or
operating below the acid dewpoint;
3. A full hopper which causes misalignment of the col-
lection plates, which in turn can reduce collection
efficiency;
4. Removal of a large number of discharge wires in a bus
section which can indicate alignment problems and/or
design deficiences; and
5. Inadequate rapping of collection plates, and/or
discharge wire.
Broken discharge wires can generally be located by checking for
bottle weights hanging below the normal level.
At the end of step 4, the inspector decides whether or not
the ventilation system and the process, itself, need to be
inspected. If the operation and maintenance of the control
system appear to be adequate and if there are no indications of
changes in effluent characteristics (e.g., increased gas flow
rates, smaller particle size distribution, higher temperature),
the inspection should be terminated. Otherwise, the ventila-
tion system (if applicable) and the process operations should
be visited.
44
-------
4.5 STEP 5: CHECK THE VENTILATION SYSTEM
To inspect the ventilation system, the inspector checks
the capture velocities of hoods to the extent possible using
the velometer. Factors which could cause inadequate capture
efficiency include the following problems (partial list):
1. Inadequate hood design and location,
2. Thermal drafts,
3. Cross-drafts in the vicinity of the hood, and
4. Leaking of air into hoods and/or ducts within the
system.
If the ductwork is accessible, the static pressures at various
points should be inspected; furthermore, the physical condi-
tions of ducts should be observed to locate leaks. Improper
hood locations can account for drops in pollutant mass loading
or for changes in particle size distributions. Releases of
emissions to roof monitors or as fugitive material should be
checked, especially for movable hoods.
4.6 STEP 6: EVALUATE PROCESS OPERATING CONDITIONS
The purpose of the process inspection is to answer ques-
tions and to confirm conclusions reached in earlier steps.
However, if the source is subject to special state/local regu-
lations or -to New Source Performance Standards or to National
Emission Standards for Hazardous Air Pollutants, compliance
with recordkeeping and monitoring requirements should be
checked first, using a DSSE-published series of documents which
includes checklists and associated information.
The inspector can seek answers to questions which were
derived from steps 1 through 5. The inspector addresses prob-
lems which could be individually or collectively responsible
for nonoptimal performance, including, but not limited to:
1. Has the production rate increased (higher mass
loading and/or gas flow rate)?
45
-------
2. Have the raw materials and/or fuels changed to the
extent that effluent characteristics are different?
3. Has the process equipment deteriorated to the extent
that emissions are affected?
4. Have changes in operating conditions resulted in more
difficult collection problems (particle size
decreases)?
The process inspector should begin at the control centers where
process monitors are located to look for signs of changes in
operating conditions and to observe current operating/mainte-
nance practices. At these centers, process operating data are
available; a process flowsheet is generally posted on the con-
trol panel; plant operators are generally nearby; and the
subdued noise level is conducive to technical discussions.
While in the control room, the inspector should seek out
the process monitors and/or records most pertinent to the
compliance questions. Example "inspection points" for six
source-types are in Table 2; several generalizations can be
drawn from this table.
1. In most cases, the inspector can confirm increased
production rate by using data available in the
control room;
2. The inspector can confirm raw material changes by
inspecting records kept either in the control room or
in the administrative offices;
3. The inspector cannot easily confirm process opera-
tional changes;
4. For batch operations, it is necessary to observe the
equipment since little useful information is
available in the control room; and
5. For other processes, it is possible to identify
changes in operating conditions, but the significance
of the changes is hard to determine.
Follow-up questions remaining after the inspection of records
and monitors in the control room can be quite time consuming
due to the cyclic processes and to distances between inspection
46
-------
points at large plants. The follow-up can be guided by the
items listed in Table 8, but the inspector is encouraged to
develop more extensive lists for specific plants. The presence
of fugitive emissions should be noted.
47
-------
£>•
00
TABLE 8. EXAMPLE INSPECTION POINTS, COUNTERFLOW INSPECTION
PROCEDURES
Type of
Industry/Source
Inspection in the
Office and/or Control Room
Inspection of
Specific Equipment
. !• Confirm the Rates of Production and/or Generation
Sulfuric
acid
Aaphalt
Utility or
industrial
boiler
Cement
Refinery
Check acid production records, and
observe acid flow rate Indicator.
N/A
Check megawatt generation and steam
production rates.
N/A
Observe number of batches shipped
per hour of plant operation.
N/A
Check raw material feed rate records. N/A
Check throughput records on catalytic N/A
cracker.
2. Confirm Raw Material Changes
Asphalt N/A
Utility or Check daily records of analyses:
Industrial I ash, US, Btu content, ash fusion
boiler temp.
Sulfuric Check records of feed content; high
acid .levels contribute acid mist. .
Perform lab tests to determine coal
gradation and surface moisture
percentage.
Take sample for later analyses.
K/A
Refinery
Checlj: production inventory records.
-------
TABLE 8 (Continued)
Typo of Inspection la the
Industry/Source Office and/or Control Room
Inspection of
Specific Equipment
3. Confirm Process Operational Changes
Sulfuric
acid
Secondary
brass and
bronze
Utility or
industrial
boiler
Check catalyst bed temp and air flow
rate to catalyst bed if 502 monicor
values are high. Check acid concen-
tration temp and flow to absorbers.
Check records for percentage of zinc
in alloy and for pouring temp.
Check air preheater exit
temperatures.
N/A
Check for grease and oil on scrap and
for operational practices such as
maintenance integrity of slag load.
Check hood caption velocity in
furnace area. Determine if zinc is
added before furnace temp is maximum.
N/A
4. Confirm Process Equipment Deteriotation
Sulfuric
acid
Secondary
brass and
bronze
Utility or
Industrial
boiler
Observe SO2 concentration monitors;
check for inactive or poisoned
catalyst if S02 is high.
M/A
Check excess air level by means of
0- readings.
Check pressure drop across mist
eliminator. If low, check for
shortcircuiting; if high, check for
plugging.
Check hoods and ductwork'for
physical damage and caption velocity.
Check to see if stoker boiler
draft above fuel beds has >0.10"
negative pressure.
Refinery
N/A
Observe flow rate/
-------
SECTION 5
POST-INSPECTION
5.1 PLANT INTERVIEW
Having evaluated the exhaust system, monitoring equipment,
control systems, and possibly the process itself, the inspector
should meet-with a responsible plant official to:
1. Ask follow-up questions as necessary,
2. Review inspection notes so that there is general
agreement on the technical facts, and
3. Discuss need for followup inspection or additional
records.
5.2 FILE UPDATE AND REPORT PREPARATION
All appropriate file entries should be changed as
necessary. The conclusions of the inspector, based on
observations and calculations, should be clearly stated in a
concise paragraph in the inspection report which should also
include two sheets—the control device diagnostic checklist and
a coverpage (Table 9)—with the following information:
-Any change in responsible plant personnel,
-Requested permit changes or reported process modifica
tions,
-Results of Counterflow evaluation,
-Action requested,
-Inspector's signature, and
-Date of inspection.
A copy of both sheets should be kept in the inspector's source
file and in the agency's central file.
50
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SECTION 6
SAFETY CONSIDERATIONS
The field inspector should take any precautions necessary
to absolutely ensure that the inspection is conducted safely.
All applicable OSHA regulations should be satisfied. If
there is any question whether all or part of the inspection *
can be -done-safely, that part should be delayed until the
issue is adequately resolved.
There- are several principles which should be obeyed
during a field inspection, namely:
1. Prior to the inspection, the files should be
reviewed to assess possible hazards. Consult
references, such as the Pocket Guide of Industrial
Hazards and Occupational Diseases, a Guide to
Their Recognition;
2. The inspection should bring all necessary safety
equipment (in good working order);
3. Safety equipment should be worn whenever necessary
regardless of the practices of plant personnel;
4. The inspector should proceed with the inspection
at a controlled pace so there is time to fully as-
sess possible hazards and so foolish accidents do
not occur;
5. Inspectors should not work alone. If plant person-
nel are not available or willing to accompany the
inspector, then the inspector should wait until
additional help is available from the agency or
the company;
6. Prior to any confined space entry, the inspector
should read Appendix C, and follow the recommenda-
tions completely;
51
-------
7. Physical examinations should be completed annual-
ly;
8. Accidents should be reported to supervisory personnel
immediately, regardless of the suspected severity
of the injury;
9. Lock-out procedures should be followed completely;
10. Entry to electrostatic precipitators should not be
done until grounding hooks have been used in all
areas to be inspected;
11. Hoppers full of material should never be opened or
entered by the inspector; and
12. ..Jf.ans vibrating severely should be avoided and
plant personnel should be notified immediately.
A field inspector cannot afford to under-estimate potential
hazards. The inspector is inherently exposed on a regular
basis to a wide variety of hazards and does not have the
opportunity to acquaint himself or herself with the details
of each plant. For these reasons, it is particularly important
that the inspector adhere to the basic principles outlined
above. It should also be realized that these are simply a
starting point and other precautions will be needed in most
circumstances.
52
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TABLE 9. CONTROL DEVICE DIAGNOSTIC CHECKLIST AND COVERPAGE
INSPECTION
REPORT
I. GENERAL INFORMATION
A. Sources Inspected
IlKPORT NUMBER
PLANT NAME
PLANT I.D.
SPECIAL ACTION RECOMMENDED (Yes) (No)
Production Status
B. Reasons for Inspection (Check Appropriate Items)
Routine Inspection
Complaint Investigation
Stack Testing Observed _
Special Studies
Other
Compliance Progress
Permit Review/Renewal
Tax Certification
Emergency Episode
Equipment Malfunction
C. Plant Representative Contacted (Name and Title)
D. Inspection Procedures and Conditions
Prior Notice (Check One) Yes No
Time/Date Duration On-Site
Type Inspection (Check One) Counterflow
Other
Weather
Follow-Up
Wind Direction
II. PRE-INSPECTION INTERVIEW
A. Production Status: Normal
B. Control Equipment: Normal
C. Permit/Compliance Schedule Changes Needed: Yes
D. Comments
Abnormal
Abnormal
No
(continued)
53
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TABLE 9. (continued)
Report Number
III. INSPECTION RESULTS
A. General Conclusions
All Sources In Compliance with:
Mass Emission Regulations: Yes No N/A
Visible Emission Regulations: Yes No N/A
Fuel Quality Regulations: Yes No N/A
Continuous Monitoring Regulations: Yes No N/A
Sampling/Testing Requirements: Yes No N/A
Recordkeeping Requirements: Yes No N/A
Permit Stipulations: Yes No N/A
Special Orders: Yes No N/A
OStt'Practices: Good Average Poor
Housekeeping: Good Average Poor
B. Specific Conclusions
Compliance Questionable Due To:
Changes in Raw Materials and/or Fuels
Production Rates Increases
Operational Changes in Process
Deterioration of Process Equipment
Operational Problems in Control 'Equipment (Check Appropriate Items Below)
Electrostatic Fabric Wet
Precipitators Filters . Scrubbers
Resistivity
TR Sets
Insulators
Discharge Wires
High Velocity
Gas Distribution
Rappers
Solids Handling
Plate Warpage
Mass Overload
Other
Tears/Pinholes
Blinding
Bleeding
Cleaning System
Hopper Overflow
Corrosion
Low Liquor Flow
Gas Flow Rate Low
Bed Plugging
Nozzle Erosion
Demisters
Throat Adjustment
Tray Collapse
Corrosion
C. Samples Taken (Describe)
D. Comments/Recommended Action
Inspector Date
Reviewer Dace
54
-------
APPENDIX A
(See Working File Handout)
55
-------
APPENDIX B
(Sample Inspection Data Sheets)
56
-------
PEDCO ENVIRONMENTAL
INSPECTION DATA SHEET
A. INSPECTION INFORMATION
1. IDENTIFICATION
Company
Plant Name
Plant I.D. Number_
Address
Control Device/System Number_
Process Served
2. PROCEDURES AND CONDITIONS
Prior Notice: Yes No_
Time(s) On-Site
Type Inspection
Inspectors
Plant Representatives
Information Claimed Confidential: Yes No
57
-------
B. Visible Emissions Inspection No.
Observations Equipment No. "
Confidential: Yes No_
Page No. of
1. STACK CHARACTERISTICS
Location
Height
Temperature
Exit Dimensions_
Orientatfon
Other Information
2. STACK EFFLUENT
Detached Plume: No Yes Distance_
Color
Puffing: Yes No
Opacity
Time Average Opacity Observation Point Sheet No.
3. FUGITIVE EMISSIONS
Control Device: Yes No
Solids Removal System: Yes No
Process: Yes No
Continuous Intermittent
Adjacent Deposits: Yes No
58
-------
Z. Fan Data
Inspection No.
Equipment No._
Confidential:
Page No.
Yes_
of
No
FAN MOTOR
Manufacturer^
Model No.
Rated Horsepower_
Volts
Maxifnum!"R":P.M.
Operating Current: Panel
Type
Maximum Amps
Service factor
Other
DRIVE
Direct
Sheath Reduction
Belt
Audible Belt Slippage: Yes_
Other
No
FAN
Manufacture^
Model No.
Fan Vibration
Gas Temperature at inlet, °F
Fan R.P.M.
Type_
Fan Static Pressures: Inlet
Outlet
Differential Static Pressures:
Fan Housing Condition
Dampers
Fan Exit
Measured
Panel
59
-------
D. Electrostatic Precipitator
Data
Inspection No.
Equipment No._
Confidential:
Page No.
Yes_
of
No
1. DESCRIPTIVE INFORMATION
Type
Manufacturer
Model Number
Plant Inventory Number_
Date Installed
Number of Chambers
Number of Fields in Series*
Specific Collection Area (FtVlOOO Ft3)_
Design Superficial Viscosity (Ft/Sec)
Pulse Energization (Yes/No)
LOCATION
Building/Area_
Elevation
LAYOUT (SKETCH FIELD LAYOUT AND NUMBER FIELDS, SHOW FANS)
60
-------
E. Electrostatic Precipitator
External Inspection
Inspection No.
Equipment No._
Confidential:
Page No.
Yes
of
No
HOPPER LAYOUT (SKETCH TOP VIEW AND NUMBER; SHOW SOLIDS HANDLING
SYSTEM)
2. HOPPER DESCRIPTION
Vibrators: Yes
Heaters: Yes
Insulation: Yes
Level Indicators: Yes
Physical Condition (Characterize),
No_
No_
No_
No
Type_
Transport Equipment: Screws Pneumatic
Transport Equipment Operating: Yes
Characterize Discharge
Other
No
61
-------
E.Electrostatic Precipitator
External Inspection
Inspection No.
Equipment No._
Confidential:
Page No.
Yes
of
No
3. HOPPER VALVES
Type: Screw_
Speed/Cycle Times_
Blade Type_
Other
4. RAPPER LAYOUT (SKETCH TOP VIEW, SHOW DISCHARGE WIRE UNITS AS D,
COLLECTION PLATE UNITS AS C AND DISTRIBUTION PLATE UNITS AS X).
62
-------
E. Electrostatic Precipitator
External Inspection
Inspection No.
Equipment No,_
Confidential:
Page No.
Yes_
of
No
5. RAPPER PERFORMANCE (Continued)
COLLECTION PLATE RAPPERS
No.
Ci
C2
C3
Cu
C5
C6
C7
C8
C9
Cio
CM
Cj2
Cl3
Ciu
Cis
Cl6
Cl7
Cl8
Cig
Cao
Time Interval
(Minutes)
Duration
(Seconds)
•
-
/
Comments
63
-------
E. Electrostatic Precipitator
External Inspection
Inspection No._
Equipment No._
Confidential:
Page No.
Yes.
of
No
5. RAPPER PERFORMANCE
DISCHARGE WIRE RAPPERS
No.
Di
D2
D3
D,,
Ds
D6
D7
D8
D9
Dio
On
Dl2
Dl3
Dm
Dl5
Die
Dl7
Die
Dis
D20
Time Interval
(Minutes)
Duration
(Seconds)
Comments
64
-------
E.Electrostatic Precipitator
External Inspection
5.
6.
Inspection No._
Equipment No._
Confidential:
Page No.
Yes,
of
No
RAPPER PERFORMANCE (Continued)
DISTRIBUTION PLATE RAPPERS
No.
Xi
X2
X3
x.»
xs
X6
Time Interval
(Minutes)
Duration
(Seconds)
Comments
RAPPER DESCRIPTION
DISCHARGE WIRES
Type
Number
Manufacturer
Air Pressure
COLLECTION PLATES
Type
Number
Manufacturer _
Air Pressure _
DISTRIBUTION PLATES
Type
Number
Manufacturer
Air Pressure
65
-------
E. Electrostatic Precipitator
External Inspection
Inspection No.
Equipment No._
Confidential:
Page No.
Yes_
of
No
7. TRANSFORMER - RECTIFIER SET LAYOUT (SKETCH TOP VIEW SHOWING T-R
SETS ON CHAMBERS AND FIELDS)
8. TRANSFORMER - RECTIFIER SET DESCRIPTION
Power Control
Mode Voltage
Yes
No
Current
Spark Rate
No.
T-Ri
T-R2
T-R3
T-R,,
T-R5
T-R6
T-R7
T-Re
T-R9
T-Rio
Plant
No.
Manufacturer
Model
No.
Mi Hi amp
Rating
Type
66
-------
E.Electrostatic Precipitator
External Inspection
Inspection No.
Equipment No._
Confidential:
Page No.
Yes_
of
No
9. TRANSFORMER - RECTIFIER SET CONDITIONS
No.
T-R-la
T-R-lb
T-R-2a
T-R-2b
T-R-3a
T-R-3b
T-R-4a
T-R-4b
T-R-5a
T-R-5b
T-R-6a
T-R-6b
T-R-7a
T-R-7b
T-R-8a
T-R-8b
T-R-9a
T-R-9b
T-R-lOa
T-R-lOb
Primary
current
(amperes)
Primary
voltage
(volts)
Secondary
current
(milliamps)
Secondary
voltage
(kilovolts)
Spark
rate
#/mi n
Control
mode
M-manual
A-automatic
67
-------
E. Electrostatic Precipitator Inspection No.
External Inspection Equipment No.J
Confidential: Yes No_
Page No. of
10. OPERATING INFORMATION
Gas Inlet Temperature, °F
Hopper Heater Operational Indicator Lights (Identify units not on)
Penthouse Heater/Blower Operational Indicator Lights (Identify units
not on)
Comments
11. OPACITY MONITORS
Opacity - Minimum, %
Average, %
Maximum, %
Spikes (Characterize Frequency, Duration, Intensity)_
Calibration Spikes (Characterize Levels, Frequency)
Comments
68
-------
F. Electrostatic Precipitator
Interal Inspection
Inspection No.
Equipment No._
Confidential:
Page No.
Yes_
of
No
1. PURPOSE
Reason(s) Necessary_
SAFETY EVALUATION
Lockout Procedure Followed'
Plant Employee Performing Lockout,
Grounding Straps Available: Yes_
Time Period De-energized (Hours)_
Purge Completed: Yes
02» %
Combustibles, %
Noise
Other
No
No
Inspection Not Conducted Due to Potential Hazards ( Characterize)
2, AREAS INSPECTED (SKETCH TOP VIEW AND INDICATE ENTRY POINTS)
69
-------
F. Electrostatic Precipitator Inspection No.
Internal Inspection Equipment No. "
Confidential: Yes No_
Page of
3. HATCH CONDITIONS
Gaskets
Corrosion
4. PENTHOUSE CONDITIONS
Purge Air
Heater(s)
Insulators
Alignment of Collection Plates_
Comments
70
-------
F. Electrostatic Precipitator Inspection No.
Internal Inspection Equipment No: "
Confidential: Yes No_
Page No. of
5. ELECTRODE CONDITIONS
DISCHARGE WIRES
Type
Diameter_
Material
Spacing and Length_
Conditions
COLLECTION PLATES
Type
Material
Spacing and Length_
Conditions
Alignment_
71
-------
F. Electrostatic Precipitator Inspection No.
Internal Inspection Equipment No/
Confidential: Yes No_
Page No. of
6. INTERNAL SUPPORTS
Describe
Conditions
7. GAS DISTRIBUTION EQUIPMENT
Type
Condition
8. HOPPERS
Baffle Condition
Hopper Condition_
72
-------
G. Continuous Monitor Evaluation
1. DESCRIPTIVE DATA
Manufacturer
Model.
Type_
Date Installed
Inspection No.
Equipment No._
Confidential: Yes No_
Page No. of
Single or Multiple Breeching (Describe Sources).
NSPS Applicable: Yes_
No
2. TRANSMISSOM'ETER
LAYOUT (SHOW LOCATION RELATIVE TO FLOW RESTRICTIONS)
73
-------
G. Continuous Monitor Evaluation
Inspection No.
Equipment No._
Confidential: Yes No_
Page No. of
2. TRANSMISSOMETER (Continued)
Approximate Path Length, (Feet)_
Mounting (Characterize)
Vibration (Characterize)
Housing (Characterize)
Purge Air (Condition of Blowers and Hoses)
Filters (Characterize Type and Describe Condition)
Alignment (Window Check)
3. CONSOLES
Breeching/Stack Correlation
Zero/Span_
Comments
74
-------
H. Electrostatic Precipitator Inspection No.
Evaluat1on Equipment No. "
Confidential: Yes No_
Page No. of
1. FILES/ADMINISTRATIVE
Specification Sheets Available: Yes No_
Prints Available (Characterize)
Supervisor of Unit
0 and M Personnel (Describe Staff and Organization)
2. RECORDKEEPING
Type Records
Operating Records (List Parameters)
Diagnostic Records (Characterize)
3. PROCEDURES
Spare Parts Inventory (Characterize)
O&M Plan (Characterize)
Troubleshooting (Character!ze)
75
-------
I. Samples Inspection No._
Equipment No.
Confidential: Yes No_
Page No. of
1. Solids
Sample No.
Location Obtained
Date/Time Obtained_
Results
2. Other Samples
Sample No.
Location Obtained
Date/Time Obtained_
Permeability
Tensile Strength_
Count
Weight/Yard2
3. Other
76
-------
J. Electrostatic PreclpHator
Evaluation
Inspection No.
Equipment No._
Confidential:
Page No.
Yes.
of
No
1. POWER INPUT
Collection Plate Area/Field
Inlet
Other
Discharge Wire Length/Field
Inlet
Field
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
Other
Secondary
Currents
(Mi 11iamps)
Power
Input
(Watts)
Current Densities
(Mill lamps/Ft) Watts/Ft2
77
-------
K. Process Inspection No.
Equipment No.
Conf 1 denti al: Yes No_
Page No. of
1. PROCESS TYPE
Characterize Source
Operating Schedule_
2. OPERATION
Product Type During Inspection_
Production Da-ta During Inspection_
Raw Materials During Inspection_
Fuels During Inspection_
78
-------
L. Summary
1. POWER INPUT
2. MECHANICAL
Inspection No.
Equipment No._
Confidential: Yes No_
Page of ._
3. SOLIDS REMOVAL
4. EFFLUENT QUANTITY/CHARACTERISTICS
5. OTHER
6. SHEETS
A. B. C.
D. E. F.
6. H. I.
J. K.
Preparer: Name
Signature
Date
Reviewer: Name
Signature
Date
Copy Received: Initials
Date
79
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PEDCO ENVIRONMENTAL
INSPECTION DATA SHEET
A. INSPECTION INFORMATION
1. IDENTIFICATION
Company
Plant Name
Plant I.D. Number_
Address
Control Device/System Number_
Process Served
2. PROCEDURES AND CONDITIONS
Prior Notice: Yes No_
Time(s) On-Site
Type Inspection
Inspectors
Plant Representatives_
Information Claimed Confidential: Yes No
80
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B. Visible Emissions
Observations
Inspection No.
Equipment No._
Confidential:
Page No.
Yes_
of
No
1. STACK CHARACTERISTICS
Location
Height
Temperature
Exit Dimensions_
Orientation
Other Information
2. STACK EFFLUENT
Detached Plume:
Color
No
Yes
Distance
Puffing: Yes
Opacity
Time Average Opacity
No
Observation Point
Sheet No.
3. FUGITIVE EMISSIONS
Control Device: Yes
Solids Removal System:
Process: Yes No_
Continuous
No
Yes
No
Adjacent Deposits: Yes
Intermittent
No
81
-------
C. Fan Data
Inspection No.
Equipment No._
Confidential:
Page No.
Yes_
of
No
1. FAN MOTOR
Manufacture^
Model No.
Rated Horsepower
Volts
Maximum R.P.M.
Operating Current: Panel
_ Type
Maximum Amps
Service factor
Other
2. DRIVE
Direct
Sheath Reduction
Belt
Audible Belt Slippage: Yes_
Other
No
3. FAN
Manufacture^
Model No.
Fan Vibration
Gas Temperature at inlet, °F_
Fan R.P.M.
Fan Static Pressures: Inlet
Type
Outlet
Differential Static Pressures:
Fan Housing Condition
Dampers
Fan Exit
Measured
Panel
82
-------
D. Fabric Filter Data
Inspection No.
Equipment No.
Confidential: Yes No
Page No. of
1. DESCRIPTIVE INFORMATION
Fabric Filter Type
Manufacturer
Model No.
Plant Inventory No.
Date Installed
2. LOCATION
Building/Area
Inside
Outside
3. LAYOUT (SKETCH FABRIC FILTER, FAN, INLET, SOLIDS REMOVAL, ETC.)
~l
83
-------
E.Fabric Filter External
Inspection
Inspection No.
Equipment No.
Confidential: Yes
Page No. of
No
1. SOLIDS REMOVAL
Valve Type: Rotary
Flapper
Valve Speed/Frequency
Transport Equipment: Screws
Transport Equipment Operating: Yes
Transport Equipment Discharging Solids:
Characterize Discharge
Other
Other
No
Yes
No
Hopper Vibrators: Yes
Hopper Insulation: Yes
Hopper Level Indicators
No _
No
Hopper Condition
Disposal Method
2. SHELL CONDITIONS
Insulated: Yes
No
Possible Weld/Seam Gaps, Characterize
84
-------
E. Fabric Filter External Inspection No.
InsPection Equipment No. .
Confidential: Yes No
Page No. of
3. OPERATING CONDITIONS
Static Pressure on Clean Side, in. H20
Static Pressure on Dirty Side, in. H20
On-site Monitor, Differential Static .Pressure in. H20
Tap Conditions
Gas Inlet Temperature ?F
4. CLEANING SYSTEMS
Type ;
Frequency
Air Pressure, PSIG
Drier: Yes No
Evidence of Water and/or Oil Problems
Solenoids Inoperative
5. PRECLEANERS
Type
Static Pressures: Inlet Outlet in. H20
Gas Inlet Temperature °F
85
-------
Fabric Filter Internal Inspection No.
Inspection Equipment No. .
Confidential: Yes No
Page No. of
1. PURPOSE
Reason(s) Necessary
Inventory Check
Comprehensive Inspection
Other
Safety Evaluation (Describe if applicable)
Respirator Necessary
Temperature °F
02' %
Combustibles %
Electrical Grounding
Mechanical Hazards
Noise
Other
. Inspection Conducted: Yes No
Inspection Not Performed Due to Safety
2. BAG LAYOUT (ATTACH DRAWING)
No. of bags
Length ft
Diameter in.
Material (Characterize)
Attachment(s)
86
-------
R Fabric Filter Internal Inspection No.
Inspection Equipment No. .
Confidential: Yes No
Page No. of
3. HATCH CONDITIONS
Gaskets
Corrosion
Bolts/Ears
Ease of Access
4. LEAK JETS
Location
Number
5. BAG CONDITIONS
87
-------
F. Fabric Filter Internal
Inspection
Inspection No.
Equipment No.
Confidential: Yes
Page No. of
No
6. HOPPERS AND BLAST PLATES
7. CLEANING APPARATUS
88
-------
G Samples Inspection No.
Equipment No.
Confidential: Yes No
Page No. of
SOLIDS DEPOSITS
Sample No..
Location Obtained _
Date/Time Obtained
Results
2, FABRIC SAMPLES
Sample No.
Location Obtained _
Date/Time Obtained
Permeability
Tensile Strength
Count
Weight/Yard2
3. OTHER
89
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H Ventilation System
Inspection No.
Equipment No.
Confidential: Yes No
Page No. of
1. DUCTS (SHOW STATIC PRESSURES ON LAYOUT.)
MILL
2. HOOD
Configuration
Average Capture Velocity
Thermal Drafts (Characterize)
ft/mi n
Cross Currents (Characterize)
Estimated Effectiveness
90
-------
I Process
1. PROCESS TYPE
Characterize Source
Inspection No.
Equipment No.
Confidential: Yes No
Page No. of
Operating Schedule
2. OPERATION
Product Type During Inspection
Production Rate During Inspection
Raw Materials During Inspection
Fuels During Inspection
91
-------
o-
-$
o
Possible Operating Problems Average Baseline
(Specify Value)
Observed Location* Abnormal RntJiif, RecommcMidril Art Ion
(Specify Value) (Check) (1-10)
D. Cleaning System
1.
2.
3.
4.
5.
6.
7.
8.
E. Hoj
D 1-
J
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Filter house pressure drop
high
Pulse- iet air header pres-
sure low
Solenoids inoperative
Reverse air fan inoperative
Shaker motor Inoperative
Bag length long
Equipment inaccessible
High intensity cleaning
required
?per
Kilter house pressure
drop high
Solids-removal run In-
termittent
Indicator level existent
and/or inoperative
Heaters nonexistent and/or
inoperative
Vibrators nonexistent
and/or inoperative
Hopper valves corroded
Hopper slope <60°
Hoppers not Insulated
Winter
Hammer markings on hopper
ua 1 1 s
Conveyor inoperative
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
E
E
E or I
E or 1
E or 1
E
I
E
E
. E
E
E
E
1
E
E
E
E
E
5 If sum (X) of nil lugs is >IO,
perform internal Inspection
5 and rherk deposits on dirty
side of bans. Check bag ten-
10 ston. Reschedule inspection
10 in near future.
10
2
2
2
I =
5 If sum (I) of ratings Is >10,
perform internal inspection
3 of hoppers.
2
2
2
3
2
2
2
2
10
T. =
fD
-S
CU
rt-
-a c~> m
QJ o -O
in 3 c
o
a. 3
CD fD
3 3 -"•
rt- rt- O
-•• 3
tu ~Z.
— • O Z
... O
tt>
O (/>
-b
*Location: E Is external, and I is internal.
-------
U)
Possible Operating Problems Average Baseline
(Specify Value)
A.
B.
>
)
C.
Bag Tears or Pinholes
1. Filter house pressure
drop low (<80% avg.)
2. Opacity high
3. Bag age high (typical avg.)
4. Some bags inaccessible N/A
5. Design A/C high (>120X avg.)
6. Actual A/C high (>120% avg.)
7. Wear plate eroded N/A
8. Frequent high excursions
Bag Blinding
1. Filter house pressure
drop high (>150% avg.)
2. Opacity low
3. Cleaning frequency high
(cycles/day)
4. Gas temp low (<20°F avg.)
5. Moisture in gas stream N/A
6. Particulate sticky N/A
7. Air in-leakage (hoppers/ N/A
access doors)
8. Unit not insulated N/A
Bag Bleeding
1. Opacity high
2. Pressure drop gradually
Increasing
3. Cleaning frequency high
Observed Location*
(Specify Value)
E
E
E
N/A I
E
E
N/A I
E or I
E
E
E
E
N/A E
N/A E
N/A I
N/A E
E
E
E
Abnormal Rating
(Check) (1-10)
3
5
5
2
tt
4
3
4
I =
7
2
5
4
4
4
2
2
I =•
5
2
5
I =
Recommended Action
If sum (!') of ratings is > 10
perform internal Inspection.
Check for deposits on fil-
ter house clean side. Check
inaccessible bags. Use
fluorescent dye technique.
Check integrity of fabric by
attempting to extend rips.
If sura (E) of ratings is >10.
perform internal inspection.
Check dirty side of bags for
coatings (this may be diffi-
cult to Identify in some
cases). Check records for
steady rise in filter house
pressure drop. Reschedule
inspection in near future.
If sum (1) of ratings Is >10,
attempt to confirm uses of
fluorescent dye and black
light.
CT
1
o
ft)
-s
<
OJ
O
3
-o
OJ
n>
o
-h
o m •—<
o .a 3
3 c in
-h -•• -a
—*• "O fD
Q. 3 O
(D ft> «-h
3 3 -*•
«-h rt- O
n>
*Locatlon: E is external, and I Is Internal.
-------
K Summary Inspection No.
Equipment No.
Confidential: Yes No
Page No. of
CONTROL SYSTEM PERFORMANCE
System Air Flow Based on Fan Data ACFM
System Air Flow Based on Pi tot Traverse
System Air Flow Based on Process
Actual Air to Cloth Ratio
Design Air to Cloth Ratio
Fabric Compatibility with Environment
2. ADDITIONAL COMMENTS
3. SHEETS INCLUDED
A.
G.
Preparer:
Reviewer:
B.
H.
Name
Date
Name
Date
C. D. E. F.
I. J. K.
Signature
Signature
Copies Received Initials Date
94
-------
Fabric Filter Supplemental Inspection No.
Information Equipment No. .
Confidential: Yes No
Page No. of
95
-------
Fabric Filter Supplemental Inspection No.
Information P . ^ ,,
Equipment No.
Confidential: Yes No
Page No. of
96
-------
PEDCO ENVIRONMENTAL
WET SCRUBBER INSPECTION DATA, SHEET
LOCATION
DESIGNATION
CLIENT
PN
CLAIMED
CONFIDENTIAL Yes
NO
DATA SHEET NO.
DATE
INSPECTOR(S) _
INSPECTION NO.
DESCRIPTIVE INFORMATION
Wet Scrubber Type
Manufacturer
Model Number
Date Installed
Process/Source Controlled _
Particulate Characteristics
B. COMPONENT INFORMATION (Describe if applicable)
1. Gas Pretreatment:
Presaturator
Cyclones
Settling Chamber
Other
Demister:
Cyclone _
Chevron
Fiberous Mat
Other
Pumps:
Number
Recirculation
Pump Manufacturer
Recirculation
Pump Rated Horsepower
Recirculation Pump Type
97
-------
Inspection No.
Data Sheet No.
Preparer
Confidential: Yes No
B. COMPONENT INFORMATION (continued)
4. Fan/Motor (Specify)
Fan Manufacturer
Blade Type: Radial
Drive: Direct
Backward
Belt
Forward
Damper Position .
Motor Manufacturer
Model No.
Rated Horsepower
Location: Forced Draft
Induced Draft
5. Instrumentation (Check if Applicable)
Differential
Pressures:
Temperatures:
Throat
Separator
Demister
Gas Outlet
Gas Inlet
pH:
Liquor Inlet
Liquor Outlet
Recirculation
Exit Liquor _
Fan Motor Current
Other
Flow Rates:
Motor Current:
Nozzle Pressure
Recirculation
Makeup
Purge
Fan
Pump
98
-------
Inspection No.
Data Sheet No.
Preparer
Confidential: Yes No_
B. COMPONENT INFORMATION (continued)
6. Materials of Construction (Specify type and gauge)
Presaturator
Throat
Scrubber Shell
Trays/Bed Supports
Demister
Fan Housing
99
-------
Inspection No.
Data Sheet No.
Preparer
Confidential: Yes No
C. DIAGRAM
1. Sketch wet scrubber system. (Show all major compon-
ents and processes controlled.)
2. Sketch wet scrubber layout (each square 1' x I1)
100
-------
Inspection No.
Data Sheet No.
Preparer
Confidential: Yes
No
SAMPLE ANALYSIS
Scrubber Liquor Effluent
Sample No. ____•
Location Obtained
Date/Time Obtained
Results:
Suspended Solids
Dissolved Solids
PH
Chloride
Scrubber Recirculation
Sample No.
Location Obtained
Date/Time Obtained
Results:
Suspended Solids
Dissolved Solids
PH
Chloride
ppm
ppm
ppm
ppm
ppm
ppm
Other
101
-------
Inspection No.
Data Sheet No.
Preparer
Confidential: Yes
No
H
CONTROL SYSTEM PERFORMANCE
Gaseous Flow
(implied from fan operation)
. Gaseous Flow
(calculated from pitot traverse)
Gaseous Flow
(implied from process operation)
Liquor Flow
L/G Ratio
Bypass ,(% of total gas flow)
Throat Velocity
Superficial Velocity (design)
(effective)
Visible Emissions (residual)
ADDITIONAL COMMENTS
ACFM
ACFM
ACFM
gpm
FPS
FPM
FPM
Sheets Included:
A
D
G
B
E
H
C
F
Inspector's Signature
Date Prepared
Reviewer's Signature
Date Reviewed •
Date Filed
102
-------
PEDCO ENVIRONMENTAL
MECHANICAL COLLECTOR INSPECTION DATA SHEET
LOCATION
DESIGNATION
CLIENT
PN
CLAIMED
CONFIDENTIAL Yes
NO
A. DESCRIPTIVE INFORMATION
Mechanical Collector Type
DATA SHEET NO.
INSPECTION NO.
INSPECTOR(S) _
DATE
Cyclone
Cyclone Bank
Multiclone
Settling Chamber
Double Vortex Cyclone
Other (describe)
Manufacturer
Model Number
Date Installed
Process/Source Controlled
Particulate Characteristics
B. COMPONENT INFORMATION
1. Cyclone
Diameter of Body
Cone Angle
ft.
degrees
Material of Construction
Gauge of Metal
Number of Cyclones
Hoppers
Number
Slope
Insulation: Yes
Heating: Yes
Vibrators: Yes
No
No
No
103
-------
Inspection No.
Data Sheet No.
Preparer
Confidential: Yes
No
B. COMPONENT INFORMATION (continued)
3. Solids Removal (Check applicable items and provide
dimensions)
Rotary Valves
Flapper Valves
4.
Screw Cpnveyors
Pneumatic Conveyors
Free Fall
Fan/Motor
Fan Manufacturer
Model Number
Blade Type: Radial
Drive: Direct
Backward
Forward
Belt
Motor Manufacturer
Model Number
Rated Horsepower
RPM
Location: Forced Draft
Induced Draft
SYSTEM LAYOUT
104
-------
Inspection No.
Data Sheet No.
Preparer
Confidential: Yes
No
D. EXTERNAL INSPECTION
Fan Inlet Static Pressure
Fan Outlet Static Pressure
Fan Motor Current
Fan Rotational Speed
Fan Damper Position
Gas Temperature at Fan Inlet
Fan Vibration (low, moderate, severe)
Static Pressure at Collector Outlet _
Static Pressure at Collector Inlet
On-site Differential Pressure Gauge Reading
Gas Temperature at Collector Inlet
Rotary Valve Rotational Speed
Flapper Gate Frequency
Hopper Conditions (Check if applicable)
Cold
Dented
Warped
Corroded
in. of H-O
in. of H-O
amperes
rpm
in.
in.
in.
o.
of H20
of H2O
of H20
F
rpm
(f/hr)
lOi
-------
Inspection No.
Data Sheet No.
Preparer
Confidential: Yes No_
E. INTERNAL INSPECTION
Hoppers (plugged or corroded)
Hopper Baffles Nonexistent (Characterize potential abra-
sion)
Inlet Vanes Plugged/Eroded (Characterize severity)
Cones Plugged (location, number)
Flow Disturbances (Characterize severity)
Outlet Tube Erosion (Characterize potential bypassing)
Corrosion (Characterize)
Scaling (Characterize)
106
-------
Inspection No.
Data Sheet No.
Preparer
Confidential: Yes No
F. CONTROL SYSTEM PERFORMANCE
Air Flow Rate (implied from fan operation) ACFM
Air Flow Rate (calculated from pi tot tube) ACFM
Air Flow Rate (implied from process operation) ACFM
Inlet Velocity '_ FPS
Opacity - %
G. ADDITIONAL COMMENTS
Sheets Included: A B C
E F G
Inspector's Signature
Date Prepared
Reviewer's Signature
Date Reviewed
Date Filed
10.7
-------
SOURCE NAME
SOURCE ID NUMBER
OBSERVATION
DATE
OBSERVER'S NAME (PRINT)
ORGANIZATION
CERTIFIED BY
OPERATING MODE
CONTROL EQUIPMENT
OPERATING MODE
DESCRIBE EMISSION POINT
EMISSION POINT HEIGHT
ABOVE GROUND LEVEL
EMISSION POINT HEIGHT
RELATIVE TO OBSERVER
DISTANCE TO
EMISSION POINT
DIRECTION TO
EMISSION POINT
DESCRIBE EMISSIONS
CONTINUOUS Q FUGITIveJj
INTERMITTENTQ
COLOR OF EMISSIONS
WATER VAPOR PRESENT
IF YES. IS PLUME
ATTACHED DETACHED
AT WHAT POINT WAS OPACITY
DETERMINED
DESCRIBE BACKGROUND
COLOR OF BACKGROUND
SKY CONDITIONS
WIND DIRECTION
AMBIENT TEMPERATURE
RELATIVE HUMIDITY
READINGS ABOVE
AVERAGE OPACITY
RANGE OF OPACITY
READINGS
SOURCE LAYOUT SKETCH
DRAW NORTH
X
EMISSION PT.
OBSERVER'S SIGNATURE
I HAVE RECEIVED A COPY OF THESE OPACITY OBSERVATIONS
SIGNATURE
108
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|