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* I ENFORCEMENT WORKSHOP ON
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PLANT INSPECTION AND
i EVALUATION PROCEDURES
VOLUME IX
8 1 OBSERVING COMPLIANCE TESTS
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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT -
OFFICE OF GENERAL ENFORCEMENT
WASHINGTON, D.C. 20460
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FOREWORD
The agency field inspector is often involved in observing the conduct
of source tests performed by the company or private testing firms
for the purposes of demonstrating compliance with the applicable emission
standards. The primary function of the agency observer at the test site
is to see that the test is performed- properly and that the process is
operated in a representative-manner to assure-the results will be a valid
assessment of the actual emission rate.
Although planning, coordination and evaluation of a complex com-
pliance test requires highly specialized skills and support from several
technical groups within the agency, the field inspector, because of his
familiarity with the plant facility, can be especially effective in monitoring
the operation of the process and control equipment during the test. Docu-
mentation of the process operation is of major importance in determining
the acceptability of the test results. The plant operator should be
encouraged to utilize good operating practices during the test, however,
it is not permissible to resort to specialized operating routines which
abnormally reduce emissions.
There are other valid reasons for the field inspector to witness
the compliance test. For example, process and control equipment operating
conditions and parameters recorded during the initial compliance test can
be used to establish baseline data for verifying and comparing conditions
observed in future inspections. Any significant deviations from these
baseline conditions noted later may indicate possible deterioration of
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equipment performance with a corresponding increase in emissions. For
the same reason it is also very useful to record stack or plume opacity
levels measured or observed during the test. Confirmation of low opacities
during test periods when the facility has been shown to be in compliance with
the emission standards provides a reliable reference point for comparison
of later opacity readings. Even though the facility may not be exceeding
the legal opacity limit, any detectable increase in opacity levels over a
period of time may indicate excessive emissions and signify the need for
a followup plant inspection and/or retesting.
•
A collection of papers, arid other information describing the role
and function of the agency observer and procedures for documenting compliance
test conditions are included in this reference manual. While the material
does not attempt to address all of the administrative and technical
aspects of planning, conducting and evaluating a source test, practical
information is provided on techniques to be used by the field inspector
in observing compliance tests as well as extensive checklists for
recording data.
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Detailed flow diagram for planning and performing a
stack test, prepared by J. Jahnke, Northrup Services
TABLE OF CONTENTS
1. "The Role of the Agency Observer", paper adapted by
J. Jahnke from paper of same title by W. DeWees,
PEDCo Environmental, Inc. x
2. Appendix B-F, checklists for on-site observation of
compliance tests, revised by L. Pilcher, U.S. Army
Environmental Hygiene Agency
3. "The Role of the Regulatory Agency Observer in a Source
Emission Test", paper by J. Feldman, presented at 1977
Air Pollution Association Meeting, Toronto, Ontario 43
4. "Observer's Report", paper by W. DeWees, PEDCo Environ-
mental," Inc. 57
5. Block diagram of test measurements and equations used
in deriving stack concentration estimates 73
6. Simplified chart outlining test activities involved
in conducting an emission test, prepared by J. Jahnke, 75
~ Northrup Services
77
8. Source sampling calculation sheet, revised by W. DeWees,
PEDCo Environmental, Inc., based on calculation sheet Q1
prepared by USEPA, Region VI, Dallas Office bl
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THE ROLE OF THE AGENCY OBSERVER*
Introduction
Air pollution control agency personnel who may not be directly in-
volved in the compliance sourse sampling process are often called upon
to evaluate source tests performed by environmental consultants or
companies. Since emission testing requires industry at their own ex-
pense to contact highly skilled source test teams, the source test ob-
server should be well prepared to insure that proper procedures are
followed and that representative data is obtained.
The main purpose for the Agency's observation of the compliance
test is-to determine that the test data is representative. There are
other valid reasons to observe the test such as establishing baseline
conditions for future inspections, but the major emphasis is in the
evaluation of the acceptability of the initial compliance test.
The seven steps an agency generally uses for establishing the com-
pliance of a source with the Agency's regulatory requiremetns are as
follows:
1. Familiarization - The agency establishes contact with the
source and becomes familiar with operations, emissions and
applicable regulations.
2. Schedule source test - This may be part of a compliance
schedule or Federal Standard of Performance for Stationary
Source Enforcement (NSPS).
3. Establish methodology - Testing requirements should-be
established and a testing plan developed by the agency
*Adapted by Jim Jahnke from: Supplemental Training for Tech-
nical Workshop on Evaluating Performance Tests" DSSE, EPA
by W. G. DeWees. PEDCo - Environmental Specialists Inc.
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4. Final Plan and test procedure development - A presurvey should be
conducted by a member of the testing team. A pretest meeting
between the agency, source representative and test team representa-
tive should be held to develop the final test plan.
5. Actual compliance tests - observation of the facility operations
and testing methodology by the observers.
6. Review of test data - determination of compliance and official
notification.
7. Continuing enforcement of compliance - follow-up inspections
using^data generated from source tests as baseline for comparison
purposes. ' '
In order for data to be representative, there are five areas where
problems might develop in obtaining a sample representative of the source
emissions. If a question arises as to the integrity of any one of these
areas, the compliance test may be considered non-representative. These
five areas are:
1. The process and control equipment must be operated in such a
manner as to produce representative atmospheric emissions.
2. The sample port and point locations must be repre-
sentative of the atmospheric emissions.
3. The sample collected in the sample train
must be representative of the sample points
4. The sample recovered and analyzed
must be representative of the
sample collected in the sample
train.
5. The reported sample results
must be representative of
the recovered and analyzed
sample.
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The source test to be monitored by the observer, then, is developed
and conducted by the source test team and observer in four major phases.
These phases are (1) preparation and planning, (2) conducting the test,
(3) recovery, transporting and analysis of sample (4) submitting report.
These phases are discussed below:
Preparation and Planning - In the initial phase of preparation and planning,
the agency must clarify for the source test team leader and process repre-
sentative all procedures and methods to be used during the entire testing
program.
•
The review of the compliance test protocol submitted by the plant
management or test consultant will explain the intended sampling plan
to the observer. Two of the more important items to be checked are any
deviations from standard sampling procedures and the proposed operation
of the facility during the compliance test.
Many types of process, sampling locations and pollutants may require
some modification to the standard sampling procedure. The agency must
determine if the modification will give equivalent and/or greater
measurement results than would be obtained with the standard method.
The other major determination to be made from the test protocol is
defining what constitutes normal operation of the facility. Example
checklists for power plants and electrostatic precipitators are presented
here:
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The plant representative should understand and agree to all facility
baseline conditions prior to the compliance testing, since the determination
of representative operation of the facility is for the protection of both
the Agency and the plant. The plant representative may suggest additonal
factors which should be considered as an upset condition and which would
not produce representative emissions.
The observer must be familiar with the process to be sampled. Whenever
possible, the Agency field inspector should be the "observer" for the pro-
cess and control equipment. If the process is large or complicated, the
observer ma> be aided by a process control engineer from the Agency. An
emission test run at the wrong process rating or without sufficient process
data will not constitute a valid test. Familiarity with the specific
process can be acquired through one or more of the many inspection manuals
prepared by the Environmental Protection Agency for this purpose. These
manuals will indicate the methods and devices employed in monitoring pro-
cess rates and/or weights.
The Source Test - Some compliance tests may be routine enough that a pre-
test meeting on the morning before sampling begins will be sufficient to
provide a complete understanding between all parties involved.
The review of the team leader's test protocol should have initiated
the formulation of the observer's sampling audit plan. The observer's
audit plan should contain the tentative testing schedule, facility base-
line conditions preparation or modification of observer's checklist, and
details for handling irregular situations that could occur during emission
testing.
The sample testing schedule should allow the observer to plan his
duties in a logical order and should increase his efficiency in obtaining
all of the required data.
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The observer's teating forms normally should need little modification.
Any accepted modification to the normal sampling procedure should be
covered by additional checks from the observer.
The observer should be prepared to handle any non-routine situations
which could arise during sampling procedures. A list of potential problems
and their solutions should be made prior to the actual testing. The list
should also include the unacceptable limits for when the minimum
sampling requirements and process rating are not meti for instance, if
the sampling box is unable to maintain the filter at minimum temperature
or if a power plant was unable to maintain full load conditions because
of poor coal. The observer should also know who in his organization is
authorized to make decisions which are beyond his capability or authority.
The number of Agency personnel observing the performance test must
be adequate to ensure that the facility operation (process and control
equipment) is monitored and recorded in such a manner as to provide a
basis for the present and future evaluations. The observing team should
be able to obtain visible emission readings and transmissometer data for
comparison with measured emission rates and should be able to ensure that
the prescribed Agency testing methodology was followed.
The plant representative should be available during testing to answer
any questions which could arise about the process or to make needed
process changes. It should be understood that, if any problems arise, all
three parties would be consulted. Since the observer may approve or
disapprove the test, his intentions should be stated at the pretest meeting,
An ideal emission test would be one where representative data was gathered
and where no clarification of sampling procedure was required from the
test leader.
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Before actually proceeding with the test, the observer should
check the calibration forms for the specific equipment to be used.
These as a minimum should include calibration of the following:
1) Pi tot tube
2) Nomograph (if used)
3) Dry Gas Meter
4) Orifice Meter
If there is any question as to whether proper calibration procedures
were followed, the problem should be resolved before initiating the
test.
During the test, the outward behavior of "the observer is of utmost
importance. He should perform his duties quietly, and thoroughly, and
with as little interference and conversation with the source test team
as possible. He should deal solely with the test supervisor and plant
representative or have a clear understanding with them should it become
necessary to communicate with the source test technicians or plant
operators. Conversely, he should exercise caution in answering queries
from the source test team technicians and plant operators directly and
refer such inquiries to their supervisor. He should, however, insure
that sampling guidelines are adhered to and inform the test team if
errors are being made.
Several checks must be made by the observer to ensure adherance
to the proper sampling procedures. To eliminate the possibility of
overlooking a necessary check, an observer's checklist should be used
for the sampling procedures and facility operation. An example of one
of these checklists is included below.
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To understand the relative importance of the measurement of parameters
of emisssion testing, the observer should know the significance of errors.
A discussion of errors is given in the Second part of this chapter.
Generally, it is best to have two agency observers at the source test.
If only one observer is present, however, the schedule given below should
be followed.
For the first Method 5 run, the observer should go to the sampling
site, after the facility is operating in the correct manner, to observe
the sample train configuration and the recording of the initial data.
The observer should oversee both the initial leak check and the final
leak check. When the observer is satisfied with the sample train pre-
paration, the test should be started. The observer should then observe
the sampling at the first port and the change over to the second port.
If he is satisfied with the tester's performance, then he should go
to a suitable point from the stack and read visible emissions for a six
minute period.
The facility operations should then be checked. This includes data
from fuel flow meters, operating monitors, fuel composition, F factors,
etc. Data from continuous emissions monitoring equipment such as
opacity monitors and SC^ analyzers should also be checked. This data
will be useful in evaluating the method 5 data. If the process and
control equipment have operated satisfactorily and the data recorded as
specified, the observer should make another visible emission reading
over a six minute period. The observer should then return to the
sample site to observe the completion of the test. The final readings
and the leak check after the completion of the test are two of the more
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improtant items to be checked. The transport of the sample train to the
cleanup area and the sample recovery should then be observed.
If the observer is satisfied with all sampling procedures observed
during the first run, then the time of the second run will be spent
observing the process monitors with the exception of checking the sampling
team at the end of the sampling period. During the second run, two six
minute visible emission readings should be made with a check of the
facility operations between readings. The observer should be satisfied
that the facility data recorded are truly representative of the faci-
•
lity operations.
A visual observation of the particulate buildup on the filter and
in the acetone rinse from the first two tests should be correlated to
the visible emission readings or transmissometer data. This comparison
of particulate collected will only be valid if the sample volumes were
approximately the same. If the particulate catch on the fiter and in
the acetone rinse for the second test was consistent or greater than
the visible opacity correlated to the first run then the observer might
spend more time overseeing the facility operations. If the second run
when correlated to the opacity is less than the first test, more time
might be placed on observing the emission test procedures for the third
run.
Irregardless on the main emphasis of the third run, the observer
should still perform certain observations. The observer should again
check all facility operations prior to testing. Two six minute visible
emission readings should be made with a check of the facility operation
in between. The sample recovery of all tests should be witnessed and
the apparent particulate catch compared to the opacity readings. The
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additional time can be spent by the observer checking the suspected
weak points or problem areas.
Sample Recovery and Analysis - The observer should be present during
sample recovery. It is imperative that the sample recovery and analysis
be done under standard procedures and that each step be well documented.
The report may ultimately be subject to the requirements of the Rules of
Evidence. Therefore, the observer should have a sample recovery check-
list to ensure all tasks have been performed properly.
To reduce the possibility of invalidating the results, all of the
sample must be carefully removed from the sampling train and placed in
sealed, nonreactive, numbered containers. It is recommended that the
sample should then be delivered to the laboratory for analysis on the
same day that the sample is taken. If this is impractical, all the
samples should be placed in a carrying case (preferably locked) in
which they are protected from breakage, contamination, loss, or deteriora-
tion.
The samples should be properly marked to assure positive identifi-
cation throughout the test and analysis procedures. The Rules of
Evidence require impeccable identification of samples, analysis of which
may be the basis of future evidence. An admission by a lab analyst that
he could not be positive whether he analyzed sample No. 6 or sample No. 9,
for example, could destroy the validity of an entire report.
Positive identification also must be provided for the filters used
in any specific test. All identifying marks should be made before
taring. Three or more digits should suffice to ensure the uniqueness of
a filter for many years. The ink used for marking must be indelible and
unaffected by the gases and temperatures to which it will be subjected.
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If any other method of identification is desired, it should be kept in
mind that the means of identification must be positive and must not impair
the function of the filter.
Finally, each container should have a unique identification to
preclude the possibility of interchange. The number of a container should
be recorded on the analysis data sheet associated with the sample through-
out the test and analysis.
Samples should be handled only by persons associated in some way with
the task of analysis. A good general rule to follow is "the fewer hands
•
the better", even though a properly sealed sample may pass through a
number of hands without affecting its integrity.
It is generally impractical for the analyst to perform the field
test. The Rules of Evidence, however, require that a party be able to
prove the chain of custody of the sample. For this reason, each person
must have documented from whom he received the sample and to whom he
delivered it. This requirement is best satisfied by having each reci-
pient sign a standard chain of custody sheet that was initiated during
the sample recovery.
To preclude any omissions of proper procedures after the sample re-
covery, the observer should have a sample transport and analytical
checklist.
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Potential sources of error in the analysis lie in the contamination
of the sample, analyzing equipment, procedures, and documentation of
results. Since the analysis is often performed at a lab, distant from
the plant site, the observer is often not present at the sample analysis.
If there is any question in the observer's mind about the analyst's
ability to adhere to good analytical practices in analyzing and in
reporting data, the observer has two recourses. The observer may be
present during analysis or he may require the analysis to be done by a
certified laboratory if one is available. However, this is an unneces-
sary burden and should not be done as a general rule.
During the analysis, any remaining portions of the sample should
remain intact and placed in a safe place until the acceptance of the
final report. Laboratory equipment, especially the analytical balance,
should have been calibrated immediately before the sample weighing.
The laboratory data and calculations must be well documented and kept in
such a manner that the Agency can inspect the recording of any analysis
upon request.
As noted in the lectures of this course, the observer should be
aware of analytical tricks that can be used to bring a marginal test to
within +_ 10% of 100% isokinetic. Care should be taken that the value for
the nozzle diameter or Cp does not change. Also, the weight of the im-
pinger catch and silica gel for the determination of EL. should not be
W j
changed to accomodate a % isokinetic value. It has been suggested that
to ensure an unbiased test, the observer could supply the source tester
with his own pre-weighed filter and pre-weighed amount of silica gel.
This may be extreme, but may be necessary in special cases.
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The Final Report - Upon completion of the compliance field test work, the
observer can begin the final task of determining the adequacy of the com-
pliance test data. The observer will be required to write an observer's
report for attachment with the source tester's report. The facility
operation, data and the field checklists should provide the observer with
sufficient information to determine the representativeness of the process
and control equipment operation and the sample collection. All minimum
conditions should have been met. If the observer suspects a bias in the
results this bias should be noted. A resulting bias that can only produce
emission results higher than the true emissions would not invalidate the
i.'
results if the plant was determined to be in compliance. Therefore, any
bias that may occur should be listed along with the suspected direction
of the bias.
The test team supervisor is responsible for the compilation of the
test report and is usually under the supervision of a senior engineer who
reviews the report for content and technical accuracy. Uniformity of
data reporting will enable the agency to review the reports in less time
and with greater efficiency. For this reason, a report format should be
given to the test team supervisor along with the other Agency guidelines.
The first review of the test report should be made by the observer.
The observer should check all calculations and written material for
validity. One of the greatest problems in compliance testing is in the
calculation errors'made in the final report. Several agencies have gone
to the extreme of having the observer recalculate the results from the
raw data in order to more easily find any error. Errors should be noted
along with comments by the observer. Although the conclusions in the
observer's report are not the final authority, they should carry the
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greatest amount of weight in the final decision concerning the repre-.
sentativeness of the test.
Due to the importance of the observer's report and the likelihood
that it will be used as evidence in court, the observer should use a
standard report format that will cover all areas of representativeness
in a logical manner. An example of an observer's report format is
presented here:
In addition to the determination of representative data for the com-
pliance test, the observer should report all conditions under which the
facility must operate in the future to maintain their conditional com-
pliance status. These conditions will be reported to the facility as
conditions of their acceptance.
These reports and the conditions of the compliance acceptance will
provide any Agency inspector sufficient data to conduct all future
facility inspection trips.
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APPENDIX B
EQUIPMENT NEEDED BY OBSERVER
1. 'Tape Measure
2. Dtal type caliper micrometer (accurate to 0.001")
3. Nomograph
4. Calibrated thermometer or thermocouple
5. Rubber tubing (to connect to Pi tot tube for leak check)
6. Rubber tubing and stopper (to leak check metering system)
7. Rubber tubing clamps (to clamp off H line for meter system leak check
8. Stopwatch
9. Personal Protective Equipment
a. Hardhat
b. Safety Shoes
c. Safety glasses
d. Respiratory Protection
10. Calculator
11. Tools
a. Phillips head screwdriver
b. Flat-head screwdriver
c. PIi ers
d. Wrench
12. Literature
a. USAEHA Guidelines for Observing and Evaluating Source Tests
b. Applicable Emission Standards
c. Applicable Sampling Procedures
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d. Contractor's Test Protocol
e. Equipment Specifications
f« Nomographs (Entropy Env..}
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APPENDIX C
CHECKLIST FOR OPERATION OF PROCESS AND CONTROL EQUIPMENT
, Location
Date
Observer1s Name
Run No.
A. Boilers, Steam Plants, Indirect Heat Exchangers.
1. Equipment.
a. Designation of facility (Bldg No., Boiler No.)
•
b. Designation of unit- tested
c. Rated capacity
d. Capacity being tested
e. Type of stoker
f. Type combustion control
g. Type of soot blowing (continuous, period)
h. Unit operating controls (steam gauge, 02 C02)
i. Date of last calibration of operating controls
j. Type of air pollution control equipment
2. Fuel.
a. Type of fuel
b. Method of measuring fuel input
c. Amount of fuel used during test
d. Method of obtaining a fuel sample
e. Date last calibration of fuel gauges
f. Heat value of fuel (BTU/lb)
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g. Ash content of fuel (X)
h. Sulfur content of fuel (X)
3. Operation
a. Rate fuel burned
b. Heat input to boiler
c. Steam produced (obtain copy of steam charts)
d. Combustion recorders (obtain copies
where applicable)
(D
(2) C02
•
(3) Opacity (%) , _
(4) Other _
e. Soot blowing (time and duration) _
f. Method used to determine heat input to
boilers (F-f actor, steam flow, meter fuel input) _
Not
4. Checklist Yes ^Jo Required
a. Was the operating rate in conformance
with that specified by the regulatory agency? _ _ _
b. Were the operating conditions
representative of the normal operating
conditions?
c. Were fuel samples taken correctly?
d. Were there any malfunctions, load
fluctuations or other conditions that would
increase emissions?
e. Were opacity readings satisfactory
during the test?
f. Have metering devices, i.e., fuel
input, steam flow been calibrated recently?
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Not
Yes No RequJr
g. Was soot blowing conducted during
the test?
«•»
h. Was the soot blowing during the
sampling conducted in accordance with the
regulatory agency's requirements?
5. Comments, unusual operating conditions, and special observations.
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Location
Date
Observer's Name
Run No.
B. Incinerators
1. Equipment.
a. Type of incinerator _
b. Capicity _
c. Auxiliary fuel type _
d. Control meters __
e. Type of air pollution control equipment __
f. Charging method (manual of automatic) ___
2. Operation.
a. Charging rate during testing __
b. Type of waste changed __
c. Temperature in primary chamber (range, avg) __
d. Temperature in secondary chamber (range, avg.) _
e. Amount of time primary burner on during test _
f. Amount of time secondary burner on during test _
g. Amount of auxiliary fuel metered
Not
3. Checklist Yes N£ Required
a. Was the operation of the incinerator
representative of normal operation?
b. Was the waste charged representative
of the waste normally changed?
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Not
Yes No Required
c. Was the Incinerator changed a,t the
rate, required by the regulatory agency?
d.. Was the auxiliary fuel metered or the
burners timed to determine the contribution of
C02. from the auxiliary fuel?
e. Were opacity readings satisfactory
during the test?
4. Comments, unusual operating conditions, and special observations.
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Location
Date
Observer's Name
Run No.
C. Process Equipment
1. Equipment.
a. Type of process _
b. Raw materials __
c. Product _
d. Capacity of unit _
e. Air pollution control equipment __
2. Operation.
a. Production rate during test __
b. Raw material input during test
Not
3. .Checklist Yes No Required
a. Was the unit operated in a
representative manner?
b. Was the rate of operation in conformance
with the regulatory agency's requirements?
c. Was opacity readings satisfactory
during the test?
d. Were there any upset conditions during
the test that may invalidate the results?
4. Comments, unusual operating conditions, and special observations (e.g.
cyclical operation, batch process, continuous process).
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Location
Date
Observer's Name
Run No. _
D. Electrostatic Predpitators
1. Equipment Design Parameters
a. Gas Volume (acfm) __
b. Gas Velocity (fps) _
c. Ga.s Temperature (°F) _
d. Voltage (kW) _
e. Current (mi Hi ampere) _
f. Sparking rate (sparks/minute) _
g. Design Efficiency __
h. No. electrical fields in direction of flow __
i. No. rappers in direction of flow _
j. Method of cleaning plates _
k. Rapping sequence _
1. Hopper ash removal sequence _
2. Operation during test
a. Gas volume (acfm) __
b. Gas Velocity (fps) _
c. Gas temperature (°F) __
d. Voltage (kW) _
e. Current (mi 11iamperes) _
f. Sparking rate (sparks/minute) _
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g. Electrical fields 1ri direction of flow
h. No. of rappers in direction of flow
1. Rapping sequence
j. • Hopper ash removal sequence
k. Temperature of flue, gas to ESP
Not
3. Yes Nk) Required
a. Was the ESP operation representative of
normal operation? •
b. Were there any malfunctions that would
bias results high?
4. Comments, unusual operating conditions, and special observations,
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Location
Date
Observer's Name
Run No.
E. Fabric Filters
1. Equipment Design Parameters.
a. Pressure drop across collection just
before bag cleaning _
b. Pressure drop across collector just
after bag cleaning
•
c. Gas volume to bag house (acfm)
d. Type of cleaning
e. Cleaning cycle
f. Particulate removal sequence
g. Last time filters were changed
h. Design efficiency
i. Type of filter (material & size)
2. Operation during test
a. Pressure drop across filter just
before bag cleaning
b. Pressure drop across filter just after
bag cleaning
c. Gas volume to bag house (acfm)
d. Cleaning cycle
e. Particulate removal sequence
f. Temperature of flue gas to bag house
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Not
3. Checklist Yes No Required
»
a. Was operation of filter representative
of normal operation?
b. . Did filters malfunction during test?
Comments, unusual operating conditions, and special observations,
25
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Location
Date
Observer's Name
Run No.
F. Wet Scrubbers
1. Equipment Design Parameters
a. Type of scrubber __
b. Desgin efficiency _
c. Pjressure drop across scrubber (1n. HgO) _
d. Nozzle pressure (pounds/sq 1n) _
e. Gas flow out of scrubber (acfm) _
f. Liquid flow rate to scrubber (gal/m1n) _
g. Recirculation rate _
h. Gas temperature of scrubber _
2. Operation during test
a. Pressure drop across scrubber (in. ^0) _
b. Nozzle pressure (pounds/sq. in.) __
c. Gas flow out of scrubber (acfm) __
d. Liquid flow rate to scrubber (gal/min) _
e. Recirculation rate _
f. Gas temperature of flue gas to scrubber _
Not
3. Checklist Yes No Required
a. Was the operation of the scrubber
representative of normal operation?
b. Did scrubber malfunction during test?
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4. Comments, unusual operating conditions and special observations.
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Date
Observer's Name
Run No.
G. Multicyclones (cyclones)
1. Equipment Design Parameter
a. Design efficiency __
b. Pressure drop across collector (in.
c. Gas volume (acfm)
d. Gas temperature (°F)
e. No. dampers to sectionalize collection
f. Hopper ash removal sequence
g. Type of cyclone
2. Operation during test
a. Pressure drop across collection (in.
b. Gas volume (acfm)
c. Gas temperature
d. No. of dampers closed during test
e. Hopper ash removal sequence
Not
3. Checklist Yes No Require*
a. Was the operation of the multicyclone
(cyclone) representative of normal
operation?
b. Were there any malfunctions or unusual
conditions that would bias results high? •
4. Comments, unusual operating conditions and special observations.
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APPENDIX D
CHECKLIST FOR
SAMPLING LOCATIONS, PORTS AND POINTS
Location
Date_
Observer's Name _
Run No.
A. Measurement and Calcualtions.
1. Draw diagram of sampling location on back of this page.
2. Stack cross section dimensions (measured). _
3. Equivalent diameters (if stack is not round). _
4. Number of sampling ports. _
5. Location of ports. __
a. Distance upstream of a disturbance. _
b. Number of duct diameters upstream of a disturbance __
c. Distance downstream of a disturbance. _
d. Number of duct diameters downstream of a downstream._
5. Number of sampling points required. __
6. Number of sampling points per port.
Not
B. Checklist Yes NX) Required
1. Are the sampling ports properly located?
2. Is the tester sampling at a sufficient
number of points?
3. Is the sampling port flush with the inside
of the stack?
29
-------
Not
Yes No Required
4. Has the breeching on stack been checked
to determine if it needs cleaning?
5. If necessary, was the duct walls and
bottom cleaned?
6. Is the duct diameter at least 12 inches
or the cross sectional area at least
113 square inches?
7. Is cyclonic flow suspected?
8. Was verification or absence of cyclonic
flow determined?
9. For stacks 12-24 inches in diameter, is
the first sample point at least 0.5 inches (or
the nozzle diameter) from the stack wall?
10. For stacks greater than 24 inches in
diameter is the first sample point at least
one inch from the stack wall?
11. Are the sampling ports located at
least 2 stack diameters downstream and at
least 1/2 stack diameter upstream from a
flow disturbance?
12. Do the sampling port locations and
number of sampling points meet the criterion
of the air pollution control regulatory
agency?
13. Are there any special circumstances with
the stacks e.g., tapered, small,
eccentric-shaped stack?
14. Were any modifications made to the
criterion for sample point location?
15. Were modifications to the location of
sampling ports approved by the regulatory
agency?
30
-------
APPENDIX E
CHECKLIST FOR OBSERVING SAMPLING PROCEDURES
Location
Date
Observer's Name
Run No.
A. Background Information
1. Sampling Method
a. Sampling method used
b. Sampling Method required by state standard
2. Equipment and Calibration.
a. Draw schematic of sampling train on back of this page.
b. Condition of equipment _
c. Obtain copy of all calibration data __
d. Cp value for Pi tot tube _
e. AH@ of meter box _
f. Lining of probe _
g. Length of probe _
h. Nozzle diameter (as measured with micrometer) _
3. Pretest checks.
a. Barometric Pressure (How determined?) _
b. Leak test rate (CFM @ 15 in. Hg) _
c. Nomograph set up
(1) Estimated meter temperature (*F) _
(2) Estimated value of Ps/Pm
31
-------
(3) Estimated moisture content (5).
(4) C-Factor
(5) Estimated stack temperature (°F)
(6) Desired nozzle diameter
4. Sampling
a. Average time to reach isokinetlc sampling rate
at each point
b. How was Orsat analysis performed (from integrated
bag or stack)? '
c. Length of time each point sampled?
d. If data sheets cannot be copied record the
following data:
(1) Approximate stack temperature (*F)
(2) Nozzle diameter (inch)
(3) Volume metered (acfm)
(4) Range of AP reading (in. ^0)
(5) Average AP reading (in. ^0) .
(6) Average dry gas meter temperature (°F)
5. Post-test checks
a. Leak test rate cfm @ in.
b. Orsat data from check against ambient air % C02
02
% CO
% N2
32
-------
B. Checklist
Not
1. Sampling Method Yes Jto Required
a. Is the sampling method "used the same
as required by the regulatory agency?
b. Did the regulatory agency approve any
alternate sampling procedures?
2. Equipment and Calibration
a. Does the equipment meet the design
criteria of the sampling procedure as
required by the regulatory control agency?
b. Has the P1tot tube been properly
calibrated?
c. Does P1tot tube meet geometry standards
of EPA Method 5?
d. Is the probe lining appropriate for the
type of source and temperature of the
gas stream (see Method 5, para 2.1.2 4QCFR60
as amended by 42 FR 41777)? '
3. Pretest Check
a. Meter box level
b. Pitot tube Manometer (or magnahelic
guage) zeroed
c. Orifice manometer zeroed
d. Probe markings correct
e. Probe warmed-up along entire length'
f. Filter compartment preheated to proper
temperature (normally 248°F ± 25°F)
g. Thermometer in filter compartment
to determine temperature
h. Impingers iced down
i. Filter holder clean before test
33
-------
Not
Yes No Required
j. Filter holder assembled correctly
k. Filter clearly Identified
1. Probe Uner clean before test
m. Nozzle clean
n. Nozzle tip undamaged
o. Implngers clean before test
p. Implngers In correct order and
correctly charged
q. P1 tot-lines leak checked
r. Does the Pi tot line leak check?
s. Was the metering system leak checked?
t. Does C-Factor on nomograph equal
0.95 when AH@ » 1.80, Tm » 100eF, f,\\^ * 10 %,
and Ps/Pm - 1.00?
u. Does AP Reference on the nomograph
equal about 0.118 when O0.95, Ts « 200°F,
and Dn - 0.375
v. Align AP » 1.0 with AH - 10 on the
nomograph. Does AP » 0.01 align with
AH = 0.1?
w. Does stack thermometer check against
ambient temperature?
x. Was the gas sampling equipment
leak checked?
y. Was the gas sampling bag leak checked?
z. Was the gas sampling probe and liner
thoroughly purged with stack gas before
sampling?
34
-------
Not
Yes No Required
aa. Was the filter checked visually
against light for 1rregulaHttw-fcr
bb. Was the filter properly (and uniquely)
labeled?
cc. Was filter weighed to constant weight?
4. Sampling
a. Was sampling begun Immediately
after probe was put 1n stack? •
b. If not, was the nozzle sealed
when the" probe was 1n stack and
pump turned off?
c. Did the nozzle scrape the stack
wall or the Inside of the port
opening?
d. Is an effective seal made around
the probe at the port opening
(especially important if stack has
negative static pressure)?
e. Is probe seal made without
disturbing flow inside stack?
f. Is the probe moved to each point
at the proper time?
g. Are probe markings adequate to
properly locate each point?
h. Are nozzle and Pi tot tube kept
paralled to stack wall at each point?
i. Was nozzle changed during run?
j. Is the data recorded completely
and in a permanent manner?
k. Is nomograph setting changed when
stack temperature changes significantly
(i.e., 10 % change)?
35
-------
Not
Yas No Rtqulrtd
1. Are velocity pressures UP)
recorded accurately?
m. Was static pressure determined
correctly?
n. Was the gas sample determined
correctly for the type of source (e.g.,
Integrated sample for an Incinerator, see
40 CFR 60, Subpart C through AA)?
o. Was the gas sampling bag leak
checked according to Method 3 (40 CFR 60)?
p. Were.filters or any other components
changed during the test (if yes,
explain 1n comment section)? •
q. Did the observer obtain a copy
of the raw data sheets?
r. If Integrated Method 3 sampling
is performed, 1s the bag sample taken
simultaneously with and for the total length
of time as the particulate sample run?
s. Was the sampling tube and sampling
volume equal to or greater than the minimum
sampling time specified in the test procedures
or required by the regulatory agency?
t. Was sampling time at each point
at least 2 minutes?
5. Post-test checks
a. Is a leak test performed at
completion of the run at the maximum
vacuum encountered?
b. Was Orsat analyzer leak checked
after analysis?
c. Was Orsat analyzer checked against
ambient air?
36
-------
Not
Yes No Required
d. Were the P1tot lines leak
checked (mandatory)?
e. Was there breakthrough of the
silica gel?
C. Comments, observations, and special conditions.
37
-------
APPENDIX F
CHECKLIST FOR OBSERVING SAMPLE RECOVERY AND ANALYSIS
Location
Date
Observer's Name
Run No.
Not
1. Checklist Yes No Required
a. Is the probe triple brushed
and rinsed?
b. Is the stainless steel or other metal
probe liner brushed and rinsed six times?
c. Was brush brought out too
quickly and sample lost?
d. Are there any visible particles
on the filter (should be none)?
e. Are there any brush bristles in
the probe washings?
f. Was the probe adequately cooled
before sample recovery?
g. Were the ends of the probe
capped before transporting to the
cleanup site?
h. Is all external particulate
matter wiped off the probe before
sampl e recovery?
i. Is the grease removed from the
probe before the end is capped?
j. Is the grease removed from the
inlet and outlet of the filter holder and the
the inlet and outlet capped?
k. Is the nozzle removed before
cleaning the probe liner?
39
-------
Not
Yes No Required
1. Is the sample recovery site 1n an
area free of wind?
m. Are the wash bottles clean?
n. Are the brushes clean?
0. Are the brushes rusty and
bristles loose?
p. Are the recovery jars clean?
q. Is the reagent grade acetone used?
r. Is the filter recovery and handling
adequate?
s. Is the probe handling adequate?
t. Are the impinger handled
satisfactorily?
u. Was there breakthrough on the
silica gel?
v. Are acetone blanks (and water
if needed) taken?
w. Is the probe lining clean (after
nozzle is removed and probe held up to a
light source)?
x. Is the filter holder clean?
y. Is front half of filter holder
cleaned and particulates put with probe
washings?
z. Are the impingers clean?
aa. Is the nozzle clean?
bb. Are the recovery jars adequately
labeled?
cc. Are the recovery jars sealed
tightly?
40
-------
Not
Y«s No Required
dd. Is the liquid level marked on
the jars?
ee. Are the recovery jars packed
adequately for transporting?
ff. Is the sample recovery procedure
adequate?
gg. Is the sample recovery procedure
for condenslbles adequate?
2. Other data.
a. Grade of acetone used
b. Specification for residue on evaporation for
the acetone
c. Specification on chemicals used for condenslble
analyses
3. Comments and observations.
41
-------
THE ROLE OF THE REGULATORY AGENCY OBSERVER
IN A SOURCE EMISSION TEST
by
J. B. Feldman
(Formerly with U. S. Environmental Protection
Agency/ Region I, JF Kennedy Federal Bldg.
Bosto.n, Mass. 02203)
Paper presented at 70th Annual
Air Pollution Control Association Meeting,
Toronto/ Ontario, June 1977
ABSTRACT
From the technical and legal standpoint, the emission test is
the ultimate determination of compliance. While the test may be
manpower and equipment intensive as well as expensive, the results
of a test are of great significance to both the regulatory agency
and the source. The results often determine the course of future
litigation between the agency, the source, and control manufacturer.
Considering the significance attached to the results, it is im-
portant that the test be performed in a valid representative manner.
This paper describes the technical and administrative responsi-
bilities of the agency observer in efforts to assure the adequacy
of an emission test. It covers the observer's involvement from
initial coordination work, through the pretest survey and conference,
on-site testing activities, and report review. The relationship
between the observer, the source, and the test consultant are
discussed. The various procedures including questionnaires, forms
and on-site calculations used to effectively track and validate
a test program are described.
43
-------
77-12.6
Introduction
Historically, the Involvement of regulatory agency personnel
1n compliance testing activities has varied from a brief review of the
emission test report to total responsibility and performance for the test
program. The degree of Involvement depended upon the resources available
within the agency and the relative significance of the source belnq tested.
The recent emphasis 1n the achievement of Ambient Air Quality Standards
through restrictive source emission limitations has resulted In expanded
regulatory Involvement In the hundreds of emission tests performed each
year for compliance determination purposes. The complex nature of the
.various sampling methods coupled with extremely low emission standards,
has put added responsibilities on agency personnel to assure each test
1s an accurate representation of a source's actual emissions.
The objective of this paper 1s to describe the technical and
administrative functions of the regulatory agency observer 1n his efforts
to assure the adequacy of a compliance test. It will discuss the proce-
dures necessary for Implementing and coordinating a successful test pro-
gram from the regulatory standpoint.
Significance of an Emission Test
From the legal and technical standpoint, the emission test 1s
the ultimate determination of compliance. While opacity observations and
continuous monitoring Instrumentations are used to determine how adequately
a source 1s operated and maintained, It Is the emission test that deter-
mines If the inherent design of a facility and Its associated control
equipment can meet the emission standard.
For the most part, an emission test is equipment and manpower
intensive. Because only a small fraction of the total exhaust flow can
be actually sampled, and many variables can be encountered in flowing
gas streams, complex test methods and extreme care must be exercised in
obtaining representative samples. Satisfactory sampling sites are usual-
ly found 1n loglstically difficult locations, often hundreds of feet up
in the stack. While the expense and effort involved in performing an
emission test can be considerable, It is Important to keep in perspec-
tive the significance of obtaining a valid representative sample. The
results of the test will determine the future course of regulatory
action. They will serve as legal evidence to both the regulatory
agency and the source as a demonstration of the compliance status of the
facility. Significant monetary decisions concerning control equipment
expenditures are often based upon the results of the compliance test.
44
-------
77-12.6
In the case where control equipment Guarantees are Involved, the results
may determine the future course of litigation between the source and its
equipment vendor.
Considering the significance attached to the compliance test,
it is imperative it be performed in a satisfactory manner and the valid
representative data are obtained. The following sections will discuss
the various aspects involved in coordinating and implementing a success-
ful test program, with particular emphasis on the role of the regulatory
agency observer.
Initial Coordination
Generally; most source tests are performed at the specific
request of the regulatory agency or as a result of established adminis-
trative regulations. Once the requirement for testing has been estab-
lished, it is the obligation of the regulatory agency to inform the
source what will be expected, considering the burden of actually per-
forming the sampling usually rests with the source and/or its test
consultant. It is at this point where the regulatory agency observer
should Initiate the communication process, specifying to the source
the general test procedures and requesting Information in return con-
cerning the specific application of these methods. Exhibit 1 contains
a suggested Pretest Informational Questionnaire for 1molement1ng this
communication process. While standardized test methods have been estab-
lished, the application of these methods and the defining representative
operating conditions is often unique to each facility. The Questionnaire
references the test procedures and regulations used by the aqency, thus
giving the source a starting point from which it can determine Its appli-
cability and testing requirements. It requests specific responses from
the source concerning the operation of the process, how the general test
methods will be applied, what sampling and process data will be collected,
along with chain of custody and quality assurance procedures.
Satisfying the informational requirements of the Questionnaire
serves several important purposes benefiting all the oartles Involved 1n
the test program. The information supplied as well as requested 1n the
document alerts the source to the general requirements of the aqency.
The response of the source will serve as the basic test protocol from
which further specific matters concerning the test program may be dis-
cussed. The regulatory observer should review the information submitted
by the source, familiarize himself with the operation of the facility,
and check to see if the test plan submitted as a result of the Question-
naire satisfies all legal and technical requirements.
45
-------
77-12.6
Pretest Conference
Assuming all the parties Involved 1n the test program now have
a basic understanding of the test plan, the next step Involves finalizing
the plan at the pretest conference. Here, the Involved parties (agency,
source, test consultant), can personally discuss the specifics of the test ,
program, resolve any ambiguities or problems concerning test methodology,
and establish representative process operating conditions for the test
period. At the meeting, each party should designate a prime contact,
through which any problems or communication can be appropriately dir-
ected as the test program progresses.
The meeting should be held at the source and should Include a
survey which will allow'all parties to become familiar with the physical
set up and operation of the facility. Depending upon the complexity of
the source and the test program, It should take place anywhere from
several days to several weeks prior to the scheduled test date. This
will allow adequate time for any modifications or Installation of sup-
port equipment which may be required to accomodate the samollng anpara-
tus. The format of the meeting should Include a survey of the facility
followed by a discussion covering the Information contained 1n the Pre-
test Questionnaire. Since the regulatory observer will be making the
ultimate decisions concerning the adequacy and acceptability of the
test plan, he should play a lead role 1n directing the discussion.
While standardized methods have been established for compliance
tests, the application of these methods may vary from source to source.
Most regulations grant agency oersonnel some flexibility 1n approving minor
modifications to the methods to accomodate special circumstances. In
approving such modifications by giving consideration to the practicality
of a situation, the regulatory observer must assure himself that the
validity of the test both from the technical and legal standpoint will
not be sacrificed. The pretest conference provides the forum where these
situations as well as others can be discussed and resolved, 1n an effort
to assure an orderly successful test program. Above all, the meeting
should preclude any problems from arising due to a lack of communication
between the involved parties.
On-site Testing Activities
The primary function of the regulatory observer at the test site
1s see the tests are performed properly and that the process is operated
in a representative manner in an effort to assure the results will be
46
-------
77-12.6
a valid assessment of the actual emission rate. From the aqency stand-
point, the observer has the responsibility to insure the legal and tech-
nical.aspects of the test are sufficiently satisfied. This involves
constant monitoring and evaluation of the test procedures and process
operating parameters.
Prior to actually initiating the samplina, it is recommended
all parties meet briefly to review the current status of the test oro-
gram and to discuss any unforeseen problems that miqht have arisen since
the pretest conference. It should be recognized by all involved parties
that the intent of the observer 1s not to look over the shoulder and
criticize the work of the test personnel but to Indicate if there are
any problems in the procedures or process operating conditions which
might sacrifice the-validity of the test results. If such a situation
occurs, the observer should promptly inform the appropriate contact
person so the nature of the problem can be discussed and clarified
prior to continuation of the test program. In this respect, it 1s
Important to all parties that any problems be brought to Haht at
this point, to avoid any after-the-fact difficulties from arising,
considering the significance of the tests. Generally, where the
involved parties have an understanding'Tthe test plan along with
each other's responsibilities and objectives, most problems at the
test site can be promptly settled 1n a professional manner. The
value of the pretest conference becomes evident at this point, in
that most significant problems will have already been addressed and
clarified prior to initiation of the actual sampling.
After each test run, 1t 1s recommended all involved parties
review the test and process data to assure it is comolete and no
obvious discrepancies exist. The observer will generally carry a
log book for recording significant events and some of the test and
process data for his own purposes. It is usually the responsibility
of the test personnel and source to obtain a complete log of all perti-
nent data for preparation of, and inclusion into, the report document.
The purpose of performing the on-site post test data review is
to determine if any additional tests or measurements will be required
prior to disassembling and packing up the test equipment. It will pre-
clude situations where several days after conclusion of the test, while
performing the data reduction calculations, the sampled volume is found
to be inadequate or the sampling rate is non-isokinetic. This presents
an embarrassing situation to the test consultant, finding that the
statutory requirements of the test method along with his obligation
to his client are not truly fulfilled. Furthermore, the agency is put
Into an awkward position, having to decide whether to accept or re.ject
the test results because of questionable validity. While some minor
47
-------
77-12.6
1neonsIstences in the method can be tolerated to an extent with tech-
nical justification, when the results of a test are marginal 1n com-
parison to the standard, this becomes an uncomfortable situation for
all Involved parties.
In order to preclude the above situation from occurring, the
on-s1te data review Is recommended. In the case of partleulate testing,
where an isoklnetlc sampling rate must be satisfied, an abbreviated set
of calculations can be performed within minutes with a pocket calculator,
to determine if the rate is in the general ballpark. Exhibit 2 1s a
typical calculation sheet used for this purpose. The procedure involves
calculation of an average velocity head sguare route (V5P)ave, and measur-
ing the volume of condensed impinger water and the silica gel weight gain
on-s1te. Other parameters such as average temperatures, oressures, mole-
cular weights, which their relative accuracy is not extremely critical to
the Isoklnetlc calculation, are "eyeballed" from the field data sheet.
While the isokinetlc value calculated is not truly exact, 1t is usually
accurate enough to flag any significant variations, where a more detailed
analysis can be performed. The use of this sheet in special test situa-
tions (high moisture, high stack oressure or vacuum, unloue flue gas con-
stituents) 1s subject to caution.
Access by the observer to the above field data at the conclusion
of the tests for purposes of performing this isokinetic calculation should
be understood by the Involved parties. The few minutes it takes to per-
form the computations Is of benefit to all parties. It precludes the
possibility of a complete retest of the facility at a future date due to
unrecognized sampling deficiencies at the site.
Review of the Emission Test Report
The emission test report should contain all pertinent data con-
cerning the test program. In addition to reoorting the results, it should
Include descriptions of the source, the sampling and analytical methodology
used, the process operating conditions, all field data and calculation
methods. It should be representative of a quality engineering or scien-
tific report, its contents presented in an understandable, orderly manner.
Since the report will serve as evidence to both the agency and the source
as a demonstration of the compliance status of the facility, it is impor-
tant it be complete in content and adequate in quality. Exhibit 3 (Emis-
sion Test Reporting Requirements) contains a suggested format and content
for a typical emission test report. It 1s recommended these requirements
be sent to the source with the Pretest Informational Questionnaire (Exhibit 1]
48
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77-12.6
This will provide the source with an overall understanding of all sub-
mittal requirements at the onset and should help assure the adequacy
of the test program.
The observer will usually review the test report to determine
If it is adequate in content and if the results, as reported, are valid.
This involves an overall review of the supporting data contained in the
report, along with his independent observations taken at the test site.
As a check on the calculation procedures used to process the field and
analytical data, it is recommended the results be independently calcu-
lated directly from the field and laboratory data. In the event of a
discrepancy in results, the observer should perform a detailed analysis
of the input parameters and calculation methods used by both parties,
to determine where the-problem lies. Upon comoletion of the review,
the observer should appropriately contact the source to inform them
of his findings, and to discuss any discrepancies or inadequacies which
might be present.
Summary and Conclusions
1. The achievement of National Ambient Air Ouality Standards through
restrictive source emission limitations has resulted in significant numbers
of source emission tests being performed for compliance determination pur-
poses.
2. From the legal and technical standooint, the emission test is
the ultimate determination of compliance, the result of which determines
the future course of regulatory action. The need to obtain accurate repre-
sentative emission measurements through the use of complex test methods
has resulted in increased responsibilities on the part of the aaency
observer to assure the tests are adequately performed.
3. In order for a test program to be successful, a significant
amount of communication, coordination, and cooperation between the
Involved parties (agency, source, test consultant) is required. The
agency observer should play a ma.jor role in brining these various needs
together, to assure all regulatory aspects will be satisfied.
4. The Pretest Informational Questionnaire and the Pretest Confer-
ence provide vehicles through which the communication and planning pro-
cesses of the test program can be effectively implemented.
5. On-site data review and quick check calculations should be per-
formed immediately after each test, to assure statutory sampling criteria
have been satisfied.
49
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77-12.6
6. In an effort to assure the adequacy of the emission test report,
the agency should establish minimum reoortinq requirements. The review
of the report should .Include an Independent evaluation, starting with
the field data.
Disclaimer
The content and recommendations Included In this report are
those of the author. They may not necessarily reflect the views or
policies of the U.S. Environmental Protection Agency.
50
-------
77-12.6
Exhibit 1. Pretest Informational Questionnaire
PRETEST INFORMATIONAL REQUIREMENTS
In order to establish uniform reouirements and helo ensure
proper test methods and procedures are utilized, the information
specified below must be submitted to (indicate regulatory agency
office) at least 30 days prior to the scheduled test data. After
review of the information, a pretest conference will be scheduled by
the agency to discuss and finalize the test plan. In the event of any
major deficiencies or discrepancies in the test protocol, the company
and/or test consultant will be notified prior to the conference. Sub-
mittal of this information will minimize the possibility of a test
rejection as a result of improper sampling or data collection proce-
dures.
Testing shall be performed in strict accordance with proce-
dures specified in the Code of Federal Regulations, Title 40, Part 60,
Apoendix A, Standards of Performance for New Stationary Sources, as
amended (or as stipulated by the control agency). A satisfactory test
shall consist of three repetitive runs. Any variations in the sampling
or analytical procedures must be indicated in the pretest Information
.and receive approval from this office prior to testing.
1. Identification and a brief description of the source
to be tested. The description should include:
a) type of industrial process or combustion facility
b) type and quantity of raw and finished materials
used in the process
c) description of any cyclical or batch operations
which would tend to produce variable emissions
with time.
d) basic operating parameters used to regulate the
process
e) rated capacity of the process.
2. A brief description of the air pollution control equipment
associated with the process including:
a type of control device
b operating parameters
c rated capacity and efficiency
d) ultimate disposal of wastes.
51
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77-12.6
3. Type of pollutant to be sampled (participate, NOX, S02,
hydrocarbon, etc.).
4. A description of the emission samollna equipment Includ-
ing a schematic diagram of the sampHnq train.
5. A description of the samp Una and analysis orocedures.
Reference standard methods, 1f apollcable. Indicate any
proposed variations with justification.
6. A sketch with dimensions Indicating the flow of exhaust
gases from the process, through the control equipment and
associated ductwork to the stack.
*T "
7. According to Method 1, 40 CFR 60:
a) An elevation view with dimensions of the stack
configuration indicating the location of the
sampling ports and distances to the nearest
upstream and downstream flow interferences.
b) A cross-sectional sketch of the stack at the
sampling location with dimensions indicating
the location of the sampling traverse points.
8. Estimated flue gas conditions at sampling location, includ-
ing temperature, moisture content, and velocity pressure.
9. A description of the orocess ooerating conditions or ranges
during which the tests will be run, along with background
Information substantiating the conditions are representa-
tive of maximum normal operation.
10. A description of the process and control equipment ooerating
data to be collected during the samnling period.
11. Copies of the field data sheet form to be used durina the
tests.
12. Names and titles of personnel who will be performing the
tests.
13. A description of the procedures for maintaining the inteority
of the samples collected, including chain of custody and
quality control assurance.
52
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77-12.6
14. Calibration sheets for the dry gas meter, orifice meter,
pitot tube, and any other equipment or analytical pro-
cedures which require calibration.
15. A list of preweiqhed filters to be used during particulate
emission testing, including identification and tare weights.
(Requirements 14 and 15 must be submitted prior to actual
testing, but do not have to be included with the pretest
Information.)
53
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77-12.6
Exhibit 2. Isokinetic On-Site Quick Check
Source:
(each traverse point)
Date:
Run No.
Total
No. Points
(v/~£fr)ave
Ts « 460 +
Tm - 450 +
°F
°F
°R
"Eyeball" Average
°R "Eyeball" Average
"Eyeball" Average
VI » ml. gain impingers +
.." wt. gain silica gel •
Ms - 27 to 30 (Use 29 for most boilers)
An • D2/183.35 * 0« nozzle diameter, inches
Pbar J=>*29.9 *»Ps (usually) 9 * Sample time, mfnutes
Vm std - Vm
&H/13.6)
Tm
Vw std « 0.0474 (VI)
Bwo
Vs
Vw std
Vw std + Vm std
Check Bwo calculated vs.
Bwo nomograph
- 85.48
Ts[( 0.00267) VI
1.657
6 Vs Ps An
90 < I 5110 ?
54
-------
77-12.6
Exhibit 3. Emission Test Reporting Requirements
The emission test report should contain all pertinent data con-
cerning the tests including a description of the process and operating
conditions under which the tests were made, the results of the tests,
and test procedures. While the exact format of the report will vary
depending upon the type and objective of the tests, indicated below is
a suggested format containing required information.
1 . Introduction
a) Identification, location, and dates of tests.
b) Purpose of tests.
c) Brief description of source.
d) Name and affiliation of person in charge of tests.
2. Summary of results
a) Operating and emission data.
b) Comparison with applicable emission regulations.
3. Source description
a) Description of process including ooeration of emis-
sion control eouipment.
b) Flow sheet (if applicable).
c) Type and quantity of raw and finished materials
processed during the tests.
d] Maximum normal rated capacity of the process.
e) Description of process instrumentation monitored
during the test.
4. Sampling and analytical procedures
a) Description of sampling train and field orocedures.
Description of recovery and analytical procedures.
Sketch indicating samoling port locations relative
to process, control equipment, upstream and down-
stream flow disturbances.
d) Sketch of cross-sectional view of stack indicating
traverse point locations.
Test results and discussion
a) Detailed tabulation of results including orocess
operating conditions, flue gas conditions.
b) Discussion of significance of results relative
to operating parameters and emission regulations.
c) Discussion of any divergencies for normal sampling
procedures or operating conditions which could have
affected test results.
55
-------
OBSERVER'S REPORT*
The observer's report is usually written in two segments.
The first segment is written as soon as possible after the
observer returns from the field testing. This allows maximum
recollection of events for summarizing all notes, checklists,
logs and other data. The field testing evaluation portion of
the observer's report is written independently of the source
test report and will provide a separate accounting of the
tests. The observer's determination of representativeness of
data could not be influenced at this time by the measured
pollutant values.
The second segment of the observer's report is written
upon the receipt of the emission test report which will
probably be 30 to 60 days later. This portion of the ob-
server's report deals with the review of the source test report
to determine its acceptability- The main emphasis of the
procedures to be presented will deal with the first segment of
the observer's report for writing the field evaluation summary.
The review of the source test report is covered in "Source
Testing Reports Suggested Format and Review Procedures", EPA
Contract 68-01-3172, Task 5.
Paper by W. DeWees included in Compliance testing observation
and evaluation workshop manual - Volume III, Administrative
Aspects of Performance Tests, prepared for Division of
Stationary Source Enforcement, U.S. Environmental Protection
Agency.
5?
-------
The source test report documents all events and data
gathered by the emission testers, and the observer's report
documents the sequence of events as he perceived them. The
observer's report will accompany the source test report
through the entire agency's review procedure.
Since the observer may not be present during the final
determination of the acceptibility of the compliance test
and or may not perform the review of the compliance test
report, a diligent effort must be put forth to provide an
«
accurate picture of representativeness-of the field test
work. The observer should also be aware that a logged entry
•of an event by one party usually takes legal precedence over
another party that witnessed the same event without an entry
into a log.
The observer's representativeness evaluation of field
testing will be based on the sampling procedures and facil-
ity operating conditions that were agreed upon through the
use of a test protocol and pretest meeting. The facility
operation conditions include the established baseline con-
ditions for the process and the air pollution control equip-
ment. The standard sampling procedures include calibration,
sample collection, sample recovery, and sample analysis.
All operating conditions and standard procedures should be
58
-------
agreed upon prior to the compliance field testing. No
additional restrictions and or conditions should have to be
placed on the facility or emission testers after the field
testing begins.
Reporting Requirements
The observer's report should be written with the idea
that the report will be used as evidence in court and will
be presented to layman. Because the final legal decision on
compliance may be made by individuals with little or no
knowledge of emission testing, the observer's report must be
clear/ concise, traceable to the proper point in time, and
present all documentation of materials, discussions, and
decisions used to form the basis for determining the re-
presentativeness of compliance test data. The observer's
summary and presentation of data must demonstrate the facil-
ity's and test team's performance or non-performance of all
established baseline conditions and procedures.
The inability of the facility or test team to meet all
the established conditions will not always invalidate the
test. Many conditions may either produce only a small
percentage error or will tend to always bias the results in
the same direction. If the facility was in violation then
biases which produce higher values would still be acceptable
59
-------
to the agency but would be brought up in court by the facil-
ity to invalidate the test.
Although the observer determines only representative-
ness of compliance test data, not compliance with control
regulations, the observer should be aware that the only
conditions for which the test would be acceptable to the
facility and agency are: (1) compliance or violation with no
biases, (2) compliance with known high bias, and (3) viola-
tion with, known low bias(s). For this reason if biases are
known to the observer, he should explain the source of the
error and the magnitude and direction on the results if
known or determinable.
A standard observer's report format as shown in Figure
1 should be used to provide uniformity and efficiency in
report preparation and ease of use by other agency per-
sonnel. The observer's report format should be tailored to
the source test report which has been designated by the
agency for ease in comparison and review.
The data collection and reporting procedures will not
be the same for every agency. The agency should only re-
quire the testers and facility to collect data that will be
used by the agency. For any process and control equipment
data collection requirements the agency should be able to
justify in court that the data will be used for some pur-
poseful meaning within the agency.
60
-------
OBSERVER'S REPORT FORMAT
COVER
1. Plant name and location (Federal AQCR)
2. Source sampled
3. Date sampled
*
4. Testing firm
5. Control agency
CERTIFICATION
1. Certification by observer(s)
2. Certification by author if not observer
3. Certification by key agency personnel
INTRODUCTION
1. Agency name
2. Purpose for observer's report
3. Purpose for test
4. Plant name, location and process type
5. Test dates
6. Pollutants tested
7. Applicable regulations
8. Agency sections and personnel directly involved
SUMMARY OF REPRESENTATIVENESS OF DATA
1. Compliance test protocol
2. Calibration of sampling equipment
Figure 1. Observer's report format.
61
-------
3. Process data
4. Control equipment data
5. Sampling procedures
6. Sample recovery procedures
7. Analytical procedures
8. Compliance test report
FACILITY OPERATION
1. Description of process and control device
2. Baseline conditions
3. Observer's facility data (checklists)
4. Representativeness of process and control device
5. Baseline conditions for agency inspector
SAMPLING PROCEDURES
1. Acceptability of sample port and point locations
2. Compliance test protocol
3. Calibration of sampling equipment
4. Observer's sampling data (checklist)
5. Representativeness of sampling
6. Observer's sample recovery data (checklist)
7. Representativeness of recovered sample
8. Observer's analytical data
9. Representativeness of sample
COMPLIANCE TEST REPORT
1. Introduction
2. • Summary of results
3. Facility operation
Figure 1. (cont.)
62
-------
4. Sampling procedures
5. Appendices
APPENDICES
A. Copy of pertinent regulations
B. Related correspondence
C. Compliance test protocol
D. Observer's checklists
E. Observer's test log
F. Other related material
Figure 1. (cont.)
63
-------
The following is a discussion of each reporting re-
quirement and guidelines to supplement the outline. (Figure
1)
Cover
The cover should indicate the name and location of the
plant tested, along with a description for the specific
source sampled. A date containing the month and year should
be included to discriminate this report from a previous test
or retest .of the same process. The name and address of the
testing firm (or agency) who conducted" the test should be
given. Finally the name and address of the responsible
agency.
Certification
The report should be certified by a minimum of two
individuals. The observer(s) should certify that the facil-
ity operations and sampling procedures were performed during
their direct observation and general guidance. The author
of the report, if not the observer, should certify that all
data and conclusions are authentic and accurate. The last
certification should be by a key person within the agency
certifying that he has reviewed the report and that the
conclusions are accurate and supporable.
Introduction
The introduction should explain to the reader the
purpose and content of the report. All parties involved
64
-------
should be identified along with their duties and respon-
sibility. The plant name, location and process type should
be given. The applicable regulations, important regulation
dates or descisions, sampling and analyticol procedures, and
facility operating procedures should be given to provide the
basis for the report.
A detailed explanation of all procedures and guidelines
is not warranted but should be referenced. If presented in
court the introduction would include sufficient information
•
to provide understanding of the purpose for the compliance
test and agency's review.
Summary of Representativeness of Data
Since the purpose of the report is to determine the
representativeness of the observed compliance test the
report should not make a direct statement with regard to
compliance with the performance regulations. The observer
may indirectly make a compliance judgement by presenting the
degree of realiability of the compliance test but this
statement will be directed toward the acceptability of the
compliance test and report.
A summary of representativeness of the facility opera-
tions, sampling and analytical procedures, and the evalua-
tion of the source test report should be presented. The
facility operations include the determination of whether the
65
-------
process operating conditions were within the limits set by
the agency and the control equipment was operated in a
normal manner. The sampling and analytical procedures
should include any deviation from the written and agreed
upon procedures. The evaluation of the source test report
should include any inaccuracies or deficiencies of com-
pliance test data presentation.
All deviations from the set procedures and conditions
should be initialed into the summary. The expected mag-
*
nitude and direction of-the bias for each deviation should
be given if known or determinable. As previously mentioned
the compliance test may contain a known bias and still be
acceptable to the agency and facility.
All unusual occurances which were logged by the ob-
server should also be mentioned. These occurances would
include such things as process upsets, exclusion of tests,
restart of tests, and extreme weather conditions.
Most errors or inaccuracies presented in the report by
the observer should not come as a suprise to the testers or
the facility. The observer's purpose is not just to deter-
mine representativeness of one compliance test data, but to
aid the facility and testers in obtaining representative
test data. In this way the actions and decisions by the
agency and facility can be expedited to achieve the main
goal of compliance.
66
-------
Facility Operations
Facility operations are composed of the process opera-
tions and air pollution equipment operation. Most control
agencies have a good working knowledge of air pollution
equipment operations. The direct effect on emissions for
various process operations is not usually known by the
agency because detailed studies have not been made to
provide the needed data. The facility operating procedures
presented must be tailored to the agency's laws, regulations
»
and definitions.
The agency normally defines the facility operations.
The process is generally operated at its normal maximum
operating capacity during testing. This capacity normally
produces the greatest steady state emissions. The process
after the compliance determination is then allowed to oper-
ate at any condition which does not exceed some percentage
above normal maximum capacity as long as the process is not
modified.
If the agency uses process and control equipment oper-
ating conditions as an enformcement tool, then the documenta-
tion of the facility operations during the compliance test
will become part of the performance regulations.
Conditions for process and air pollution equipment
operations must be established for the compliance test and
must be adhered to by the facility after the compliance
test.
67
-------
The first portion of this section should present the
basis for the evaluation of the representativeness of the
facility operation during the compliance test. The baseline
conditions for the process operations established by the
agency and agreed upon by the facility prior to the com-
pliance field testing should be presented. The observer
should base his determination on these conditions and not
on a post test after thought. After the basis for a re-
presentativeness determination has been presented, the ob-
server's process checkli-st and test log should provide
sufficient data to demonstrate representativeness or non-
representativeness of process operations. Any deviation
from the prescribed conditions should be presented along
with the expected effect on the emissions or results. Any
statement or conclusion of non-representativeness of process
operation with established conditions should have been
documented to include the event/ time and participants.
References should also be used whenever possible to help
support the baseline conditions set by the agency that have
not been met or that may be challanged at a later data.
The baseline conditions for the control equipment are
normally established from the facility request, since 'it is
usually to their advantage to optimize the control equipment
operation. Since the agency may deem that the baseline
68
-------
condition for the control equipment must be met during all
future operations, the facility may desire to operate the
control equipment at less than maximum efficiency to reduce
operating expenses. The agency could not normally invali-
date the compliance test from the control equipment opera-
tion stand point, unless the control equipment was operated
in such a manner as to reduce the emissions only during the
testing period.
If specified by agency regulations, the conditions set
•
for and during the compliance test must be continually met
to demonstrate compliance. The process operating conditions
established for the test and the control equipment operating
conditions set by the test would then be presented in the
report to aid in future inspections.
Sampling and Analytical Procedure
The applicable sampling and analytical procedures
should be referenced and presented in the Appendix since
these procedures may be revised from time to time. Any
additional quality assurance procedures or modifications to
the prescribed procedures requested and agreed upon by the
agency and emission testers, and the test protocol submitted
by the emission testers should also be presented in the ap-
pendix.
69
-------
A detailed written explanation of all the sampling and
analytical procedures should not be presented in the text.
The observer's field testing checklists should provide suf-
ficient information for all check points by the observer to
demonstrate compliance with the prescribed procedures. Any
procedures or events that did not conform with the pre-
scribed procedures should include a detailed explanation of
the deviation and it's expected impact on the test results.
The observer should again, as with the facility operation,
aid the emission testers in adhering to the prescribed
procedures. Many errors, if caught in time, will have
little or no effect on the final results.
Any reported on-site sampling or analytical errors should
have been discussed with the emission testing supervisor at
the earliest opportunity.
All cheklists, errors, and unusual occurances should be
presented in the following chronological order:
1. Calibration of sampling equipment
2. Acceptibility of_sample point and point locations
3. Sample train preparation
4. Sample collection
5. Sample recovery
6. Sample transport
7. Sample analysis
70
-------
All unusual events, non-prescribed procedures and
errors should have been immediately logged along with the
respective time and participants. These bias should not be
presented in the text without proper documentation. All
statements of biases should be based on written legal and
technical procedures and not on the suspections of the
observer. If the observer feels that the equipment has not
been calibrated properly then an independant check should be
made. The observer should not state that in his opinion he
•
feels that the equipments was not calibrated sufficiently.
Review
A detailed explanation of the compliance test report
and calculations review procedures are included in "Source
Testing Reports Suggested Format and Review Procedures", EPA
Contract 68-01-3172 Task 5.
71
-------
-4
U)
cs -
pmr$
T
PHot Tube
i s
18
trt
Ap
JU
Am • 0_
Under IsoUnettc conditions c • c
%
. "«
Isokfnetfc Rate
Orifice Heter
Dry Cas Meter
V -
*•
'md
18 BWW T. Pf
IB
AP
Pollutant
Collector
Figure 1. Schematic of Isokinetric Sampling Technique
-------
ISOTOCE TEST OUT!IJTEl
Calibrate Equipment
.Nozzles
.Probe Heater
.OCX
.Orifice Meter
.Meter Console
.Pilot Tubes
.Homograph
Prepare To Take
Integrated Sample
Of Flue Gas During
Entire Duration
Of Test
Analyze Using
Orsat
Assemble Sampling Train
teak Test
.Pleat Lines
.Meter Console
Sampling Train
.Mark Dry And Desicate
Filters To Constant
Weight
.Assemble la Filters And
Seal Until Ready To Use
Estimate COj
Concentration
Using Fyrite
•
Calculate Sample Point
Using Method 1
1
IDo Preliminary Temperature
And Velocitv Traverse
£stiaate H-
Osing Met
| S«t Up Monograph Or Calculator!
Fill Out Data Sheet
.Date .DCM Reading
.Tim* .Test Time At-Each Point
Monitor Boiler
Operation
Monitor At Each Test Point
.DQt - On Time
.A?
.Appropriate AK
.Stack Temperacare
.Sample Case Temperature
.Xmpinger Temperature
SCOP Test And Record
.Final DGM
.Stop Time
.Notes On Sampling And
Appearance of Sample
Leak Test At Highest Vacuum
Reached Durine Test
Record Fuel Feed
Rate And Production
Race
Sanple Clean-Uo
.Probe & Nozzle .H20
.Filter .Silica Oel
J_
Cal <
.Moisture Content Of Gas
.Molecular Weight Of Gas (Dry & Wet
.Average Gas Velocity
.Z isokinetic
.Pollutant Mass Rate
(concentration and ratio of areas)
I Write Report
Reprinted from Source Sampling Workbook
Air Pollution Training Institute, EPA
75
-------
FLOW DIAGRAM FOR PLANNING ANO j
PERFORMING * STACK TEST
DETERMINE NECESSITY OF .; SSURCE TEST
~~. Decide on data required
. Determine that lource test will
give this data
Analyze ease
EACH STACK TEST SHOULD 3E
CONSIDERED AH OH 1C I HAL
SCIENTIFIC EXPERIMENT
STAT- SOURCE TEST OBJECT IVES
Process evaluation
. Process design data
Regulatory csmalianee
DESIGN
Develop* simp I ing approach
Select equipment to aaet
test objective!
Select sampling method
Select analytical method
Evaluate possible errors on
biases and correct sampling
approach
Determine manpower needed for
test
Determine time required for test
with margin for breakdowns
Thoroughly evaluate entire experiment
with regard to applicable State and
Federal guidelines
t-SURVEY SAMPLING SITE
(I) . Locate notels and restaurants '"
In area
(2) . Contact plant personnel
(3) . Inform plant personnel at testing
Objectives and requirements for
completion
(I) . Note process operations
(5) . Note shift charges
(6) . Determine accessibility of
sampling site
(7) . Inspect samoling site
(3) . Evaluate safety
(3) . Determine port locations and
applications to methods I and 2
(12/23/71 Federal Register)
(10) . Locate electrical power supply
to site
(II) . Locate rest rooms and food at
plant
(12) . Drawings, photographs, or
blueprints of lampling site
(13) - Evaluate applicability of
sampling approach from experiment
design
(Ik) . Note any special equipment needed
RESEARCH LITERATURE
. &asic Process operation
. Type of Pol lutant
emitted from process
. Physical state at
source conditions
. Probable points of
emission from process
. Read sampling reports
from other processes
~l) Problems to expect
2) Estimates of variables
a. HjO vapor
b. Temperature at
source
Study analytical procedures
used for processing test
samples
Reprinted from
Source Sampling
Workbook
Air Pollution
Training Institute
EPA
CALIBRATE EQUIPMENT
. 00*
. Orifice meter
. Determine console 4H9
. Nozzles
. Thermometers and
thernocouples
. Pressure gauges
. Orsat
• PI tot Cube and probe
. Nomographs
FINALIZE TEST PLANS
. Incorporate presurvey into experiment
design
. Submit experiment design for approve
Industry and Regulatory Acency
. Jet test daces and duration
* --
PREPARE ECUI?r£NT ?CS TEST
by
I
... -_ .... -.. •
. Assemol* ana confirm operation
. Prepare for snipping
. Include spare parts and reserve esuiomenc
CONFIRM T'AVEL A.HO SirtPLE TEAM ACCOf'MOSATIONS AT SITE j
1-
CONFIRM TEST DATE AMO PROCESS OPSRATIOM
. Final jeep aeror« travel arriving
at lice
PREPARE FILTERS ANB
REAGEHTS
. nark filters with in-
soluble ink
. Oesicate CO constant
weight
. Record ~<«i9hts In
permanent laboratory
file
. Copy file for on site
record
. Measure de ionized
distil led 14,3 for
iopingers
. VUigh jil ica gel
. Clean sample s to race
contai ner j
ARRIVAL AT SITE
Kotiif plant and
regulatory agency
personnel
Review test plan with
all concerned
Check weather forecasts
, Confirm proceis opera-
ting parameters In
control rcon
SArtPLI.IC FOR PARTICL'lATe e,-,1l SS IQ.'lS
. Carry equipment Co lampling $ice
. Locate electrical connections
DETERMINE A
MOLECULAR WEIGHT OF STACX
SAS USING FYRITE AKO
ICHSCRAPHS
APPROXIMATE N,0 ViPOR
CONTENT OF STACK GAS
77
-------
RECORD ALL INFORMATION
ON DATA SHEETS
Sample case number
Meter console number
Probe length
Barometric pressure
Nozzle diameter
C factor
Assumed H^O
Team supervisor
Observers present
Train leak test rate
General comments
Initial DGM dial
readings
t
PRELIMINARY CAS VELOCITY TRAVERSE
. Attach thermocouple or thermometer to
pi toe-probe assembly^
. Calculate sample point* from guidelines
outlined In method | «nd 2 of Federal
Register
. Mark oI tot-probe
. Traverie dues for velocity profile.
. Record AP'j and temperature
. Record'duet static pressure
USE NOMOGRAPH OR CALCULATOR TO SIZE NOZZLE
AND OETESMINE C FACTOR
. Adjust for molecular weight and pi toe
tube Cp
. Set K aivot golnt on nomograph
LEAK TEST COMPLETELY ASSEMBLED SAMPLING TRAIN
9 IS" Hg VACUUM AND MAXIMUM LEAK RATE OF 0.02 CFM
±
L NOTIFY ALL CONCERNED THAT TEST IS ABOUT TO STAST |
* -
| COMF1 Rfl PROCESS OPERATING PARAMETERS |
TAKE INTEGRATED SAMPLE
OF STACK GAS FOR ORSAT
ANALYSIS(OR PERFORM
MULTIPLE FYRITE READINGS
ACROSS DUCT)
ANALYZE STA.:x CAS FOR •
CONSTITUENT CASES
. Determine molecular
weight
. COj and Oj concen-
tration for F-factor
calculations
PREPARE OTHER TRAINS
FOR REMAINING SAMPLING
i
START SOURCE TEST
. Record start time - military base
. Record gas velocity
. Determine AH desired from nomograph
. Start pump and set orifice meter
differential manometer to desired AM
. Record
I. Sample point
2. Time from zero
3. OGM dial reading
*. Desired AH
5. Actual AM
6. All temperatures OGM, stack, sample case
. Maintain Isokinetie AH at all times
. Reoeat for all points on traverse
TAKE MATERIAL SAMPLES
IF NECESSARY
JTAKE CONTROL ROOM OATA
AT CONCLUSION OF TEST 3ECORO
. Stop time - military base
. Final OGM
. Any gertlnent observations en samole
LEAK TEST SAMPLE TRAIN
. Test at highest vacuum (in Hg) achieved during
test
. leak rate should not exceed 0.02 CFM
. Note location of any leak if possible
REPACK EQUIPMENT AFTER
SAMPLING IS COMPLETED
±
REPEAT PROCEED IMG STEPS FOR THREE PARTICULATE
SAMPLES
±
SAMPLE CLEAN-UP AND RECOVERY
. Clean samples In laboratory or other clean
area removed from site and protected from
the outdoors
. Note sample condition
. Store samples in quality assurance containers
. Mark and label all samples
.. Pack carefully for shipping If analysis Is
not done on site
ANALYZE SAMPLES
. Follow federal Register or State guidelines
. Document procedures and any variations
employed
. Prepare Analytical Report Data
T
79
-------
CALCULATE
floisture concent of stack gas
Molecular weight of gas
Volumes sampled at standard conditions
Concentration/Standard volume
Control device efficiency
Volumetric flow rate of stack gas
Calculate ootlutant mass rate
WKITE HEPORT
. Prepare as possible legal document
. Summarize results
. Illustrate calculations
. Slve calculated results _
. Include alt raw data (process' t'test)
. Attach descriptions of testing and
analytical methods
. Signatures of analytical and test
personneI
SEND REPORT WITHIM MINIMUM TiME FRAME TO
PAHTItt
81
-------
83.
-------
Company_
Test Team
Test Date
Observer
SOURCE SAMPLING CALCULATION SHEET
Address
Address
(1) WATER VAPOR VOLUME: (Vw-std)
Vstd
(2) DRY GAS VOLUME: (V td)
m
Evaluation Date
Evaluator
Run
Run
Run
Run
Run
Run
scf
ml
Vstd
Run
Vn
Tn
Pt
At
\
Run
a
1
1
>ar
1
r s
Run
Run
scf,
Run
dry
Run
cf
°R
"Hg
"H2
83
-------
(3) MOISTURE CONTENT: (B )
x 100
std
m-std
Run
Run
Run
scf
scf
w
Run
Run
Run
(4) GAS ANALYSIS: (Md)
%C02 x 0.44 =
%02 x 0.32 =
%CO x 0.28 =
%N2 x 0.28 =
Md =
CO =
N2 =
Run
Run
Run
Run
Run
Run
*
#/#-mole, dry
(5) GAS MOLECULAR WEIGHT:
M_ /U \ / T
- \n . ) \ i
s o
M s
s
SJ.'N 4. 1 Q / "\
' Too} 18(W
Run
Run
Run
84
#/#-mole, wet
-------
(6) ABSOLUTE STACK PRESSURE (P.)
|
13.6
(7) STACK VELOCITY: (Vj
Run
Run
Run
"Hg.
s-avg
s-avg
85.48(C )(
Run
l£~) V
s-avq
CP
d/ApT)avg «
s-avg
Run
Run
Run
Run
Run
fps
°R
"Hg
85
-------
(8) ISOKINETIC VARIATION: (I)
I = -J ?-avg
'Vavg^V^V
I =
(9) PARTICULATE CONCENTRATION: (c)
A
8
R
std =
A / B =
Run
--
s-avg
vl
a
s
v =
s-avg
Ps
e
A
n
Y
Run
s
s
Run
Run
Run
Run
%
ml
cf
fps
11 Hg.
min.
sq. ft.
Run
Run
Run
mg.
scf
c = 35,310(R)
= 0.0154(R)
= 2.205 x 10"6(R)
Run
Run
Run
micrograms/cubic meter, nor
grains/std. cubic foot
pounds/std. cubic foot
86
-------
(10) VOLUMETRIC FLOW RATE (Actual ):(Q)
For circular ducts
Q = 47-] (V
For rectangular ducts
Q = (L)(W)(V ) x 60
3— ovy
Run
V
s-avg
Ds "
L
W
Run
:
E
:
F
Run
tun
Run
acfm
Run
fps
ft.
ft.
ft.
JL=
(11) VOLUMETRIC FLOW RATE (Standard Conditions): (Q
rf
B
17.65(1 - J
s-avg
B
w
s-avg
Run
Run
Run
Of
/Q
acfm
11 Hg.
°R
Run
Run
Run
scfm, dry
87
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(12) POLLUTANT MASS RATE: PMR
= 1.323 x 10""
Run
Run
Run
scfm
PMR
Run
Run
Ibs/hr
For circular ducts
1.323 x 10°4(Mn) /D2
PMRa =
a
For rectangular ducts
1.323 x 10"4(Mn)(L)(W)
PMR, =
Run
Run
M =
n
=
Ds =
D =
n
L =
W =
An =
Run
F
*un
Ibs/hr
Run
Run
..
mg.
min.
ft.
ft.
ft.
ft.
sq. ft
38
-------
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