Series-1 -200-7/82
EVALUATION OF STATIONARY
SOURCE PERFORMANCE TESTS
Observation and Evaluation
of Performance Test
US ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF AIR, NOISE AND RADIATION
STATIONARY SOURCE COMPLIANCE DIVISION
WASHINGTON DC 20460
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DRAFT
EVALUATION OF STATIONARY
SOURCE PERFORMANCE TESTS
Observation and Evaluation of Performance Tests
Prepared by
PEDCo Environmental, Inc.
505 South Duke Street, Suite 503
Durham, North Carolina 27701
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF AIR, NOISE AND RADIATION
STATIONARY SOURCE COMPLIANCE DIVISION
WASHINGTON, D.C. 20460
July 1982
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INTENDED PURPOSE
This is not an official policy and standards document. The opinions,
findings, and conclusions are those of the authors and not necessarily those
of the Environmental Protection Agency. Every attempt has been made to repre-
sent the present state of the art as well as subject areas still under eval-
uation. Any mention of products or organizations does not constitute endorse-
ment by the United States Environmental Protection Agency.
This document is issued by the Stationary Source Compliance Division,
Office of Air Quality Planning and Standards, USEPA. It is for use in work-
shops presented by Agency staff and others receiving contractual or grant
support from the USEPA. It is part of a series of instructional manuals
addressing compliance testing procedures.
Governmental air pollution control agencies establishing training pro-
grams may receive single copies of this document, free of charge, from the
Stationary Source Compliance Division Workshop Coordinator, USEPA, MD-7,
Research Triangle Park, NC 27711. Since the document is specially designed
to be used in conjunction with other training materials and will be updated
and revised as needed periodically, it is not issued as an EPA publication
nor copies maintained for public distribution.
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CONTENTS
Page
Section A. Performance TestAn Integral Part of the Enforcement
Cycle (lecture 201) A-l
1. Script for reviewing the new source enforcement cycle A-3
Section B. Overview of Observation of Performance Test B-l
(Lecture 202)
1. The role of the agency observer B-3
2. Slides B-15
Section C. Role, Responsibilities and Behavior of the Observer C-l
(Lecture 203)
1. Role, responsibilities and behavior of the observer C-3
2. Slides . C-5
Section D. Establishing Testing Protocol (Lecture 204) D-l
1. U.S. EPA performance test guidelines D-3
2. Slides D-13
Section E. Plant Entry and Pretest Meeting (Lecture 205) E-l
1. The pretest meeting E-3
2. Slides E-15
Section F. Observing the Test (Lecture 206) F-l
1. Observer's checklist package for EPA reference test methods F-3
2. Observer's methods checklist F-53
3. Slides F-63
Section G. Determining Representative Facility Operations G-l
(Lecture 207)
1. Observing and establishing plant operating baseline condi-
tions during compliance emission tests G-3
2. Slides G-37
Section H. Source Test Report Requirements and Review (Lecture 208) H-l
1. Source sampling report format H-3
2. General review guide for emission test reports H-6
3. Slides H-19
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CONTENTS (continued)
Page
Section I. NSPS Determination of Applicability (Lecture 250) 1-1
1. New source performance standards determinations of
applicability 1-3
Section J. Agency Approval of Equivalent and Alternative Methods J-l
(Lecture 251)
1. Use of the bias concept for alternative methods evaluation J-3
2. Approval of alternative and equivalent source test methods
applicable to enforcement of national emission standards J-10
3. Slides J-13
Section K. Enforceability Criteria for Development of Compliance
Test Methods (Lecture 252) K-l
1. Enforceability criteria for development of compliance test
methods K-3
2. Slides K-7
Section L. Safety in Stack Testing (Lecture 253) L-l
1. Stack sampling safety manual L-3
2. Slides L-85
Section M. Data Validation Techniques (Lecture 254) M-l
1. A data validation scheme for pulverized boilers M-3
2. Slides M-21
VI
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SECTION A. PERFORMANCE TESTAN INTEGRAL PART
OF THE ENFORCEMENT CYCLE
Subject Page
1. Script for reviewing the new source enforcement cycle A-3
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Performance Test - An Integral Part of
the Enforcement Cycle
by
Thomas Clark and William DeWees
[fl] The stationary source performance test is an important
part of the enforcement cycle. [#2] Let's review the new source
enforcement cycle.
[#3] Phase I
Pre-construction or Operating Permit Review - The agency
must ensure that the new source can comply with the standards and
that it will not cause significant deterioration to the sur-
rounding ambient air.
[#4] Phase II
Performance Test - The facility is required to demonstrate
that it is in compliance with all portions of the standard through
emission testing.
[#5] Phase III
Plant Inspection - The facility operating conditions should
have been established and agreed upon prior to the performance
test. During all followup plant inspections the agency will
check to ensure that the source is operating in a similar manner
and that a good operation and maintenance program is in effect.
[#6] Phase IV
Continued Compliance and Review - The source must maintain
continuing compliance with the applicable standard through good
operating practices which includes establishing and executing an
operation and maintenance program for the process, control equip-
ment, and continuous emission monitors if required. This phase
is usually regulated through the use of the agency's permit to
operate.
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The Enforcement Cycle for Existing Sources have the same
four phases but Phases II and III are reversed since the source
generally has an operating history.
To provide a better understanding of the enforcement cycle
and to illustrate the procedures to be used in observing and
approval of compliance tests we have created an enforcement
proceeding. [#7] The setting is a new source cement plant that
is located in a large state which has been delegated NSPS respon-
sibility.
The new source performance standard for cement plants is
Subpart F which regulates particulate matter arid opacity from the
kiln and clinker cooler.
[#8] The kiln is allowed 0.3 Ib particulate emission per ton
of dry feed and 20 percent opacity. [#9] The clinker cooler is
allowed 0.1 Ib particulate emissions per ton of dry feed and 10
percent opacity. Although these are the only two emission points
regulated by NSPS, the state agency should be aware that there
are other emission points at a cement plant that should be con-
trolled. For example, the finishing mill, storage silos, all
loading and unloading points, and all unpaved roads within the
plant's boundary. Twenty-six (26) potential points of emissions
are listed in the DSSE Inspection Manual on portland cement
plants.
[#10] Events leading up to the performance test are started
when Mark, one of the state engineers with the enforcement group,
receives the construction plans, projected startup date, and the
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environmental impact study from the cement plant. Mark will
perform an extensive new source review to ensure that the plant
can comply with all new source performance standards and there
will be no significant deterioration to the surrounding ambient
air.
[til] The performance test phase of the NSPS enforcement
cycle is initiated when Mark sends the approval letter and a copy
of the performance test guidelines to the source. These written
guidelines ensure and expedite information exchange relative to
the performance test.
An example performance test guideline document is contained
in the protocol manual. [#12] The plant engineer from the cement
plant receives the test guidelines and letter from the agency
requesting him to submit a written performance test protocol.
This written protocol along with the previous information sent
for the new source review, and the new source performance
standards will provide the basis for the New Source Performance
test.
[#13] The plants written testing protocol is then received
by the Agency. Tom, an engineer with the emission measurement
group, is placed in charge of the Performance Test. A review of
the test plan shows that this cement plant is unusual since it
has an alkaline bypass system which allows control of the
alkalinity of the mixture by varying the amount of alkaline
material entering the kiln from the preheater tower. The
alkaline bypass system is controlled by a separate baghouse. As
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a result/ Tom will have to make the proper legal and technical
determinations for this specific case. [#14] First, Tom visits
with a state attorney familiar with NSPS regulations. The attor-
ney tells Tom that multiple points of emissions does not increase
allowable emissions. This legal determination creates some
technical problems so Tom's next stop is to check with the super-
visor of his group. [#15] They discuss the proper technical
procedures to provide a representative test. Their final deci-
sion will double the number of samples that will have to be
collected from the kiln. The kiln will have to be tested with
the alkaline bypass system in the off position and in the full
bypass position to represent both extremes in kiln operation.
[#16] Now that Tom has determined the acceptable legal and
technical requirements for the test, he then meets with Joe, one
of the State's field inspectors. Joe was chosen since the cement
plant is in his district. The use of field inspectors for
process observation during the performance test will strengthen
their position and knowledge of that specific source on all
followup plant inspections.
[#17] Prior to the pretest meeting both Tom and Joe review
all test protocol material and obtain and review EPA manuals on
Portland cement plants. The pretest meeting is to be held at the
plant site one month prior to the scheduled performance test
since the alkaline bypass system has complicated the test plan.
Often times the test plan is simple enough to finalize by phone.
[#18] The pretest meeting has the recommended participants;
representatives from the state agency, Tom and Joe, the plant
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manager, plant engineer, and a representative from the emission
testing firm - which is usually the test team leader for that
job.
[#19] To establish the proper lines of communication and
eliminate any question of authority, each of the three parties
designates an official representative. All communications and
discussion before, during, and after the performance test will be
made through that individual. The plant manager indicates that
his plant engineer will be their representative, the source test
representative says he will take charge for his company. Tom
says he will be the key contact for the state.
[#20] Tom then provides each person present a copy of the
state's pretest checklist which is used to organize the meeting
and ensure all pertinent areas are discussed.
The first item is the Agreement of- facility operations
during the test. This agreement includes process parameters to
be monitored and recorded, raw materials to be processed, the
input feed rate, the number of process conditions to be run and
the air pollution control equipment operating parameters.
[121] The plant engineers gives a detailed explanation of
the plant lay out. The plant is computer monitored and operated.
This discussion by the plant engineer prior to the actual visit
will provide a much better understanding of the plant. Detailed
discussions during the on-site inspection of the process are
generally very difficult due to the background noise level.
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[#22] The plant engineer explains that all raw material and
product storage silos have fabric filter control systems and that
all loading and unloading sites have vacuum pickup systems that
are controlled by a fabric filter system. Also all unpaved roads
in the plant are watered to reduce fugitive dust from moving
vehicles.
Now that all parties have a general idea of what is to be
required during the performance test, an inspection of the facil-
ity operations are in order. [#23] Since all parameters are
monitored and recorded by computer in the control room, Tom and
Joe initially determine if the data recordings and prinouts will
be sufficient for their purposes. [#24] A few quick checks are
made comparing actual instrument readings to computer printout
values. The plant engineer informs Joe that the plant is cur-
rently operating at its maximum sustained rate of production.
Also the type of material being processed is the same as was
agreed upon for the performance test.
[#25] The party leaves the control room and proceeds to the
kiln and clinker cooler. As an indication of process production
rate Joe times one revolution of the kiln. By correlating the
kiln revolution time with the known production rate a basis can
be established which will give an indication of the feed rate any
time in the future by just timing the rotation of the kiln since
the kiln rotating speed is proportional to production rate.
[#26] During the visit no fugitive emissions were observed from
either process. Joe then inspects the fabric filter control
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system. Only two parameters are monitored for the control equ±p-
ment. [127] One parameter is the temperature just prior to the
inlet. This temperature must be kept at less than 450°F by water
and/or air quenching to protect the bags. [#28] The other param-
eter recorded is pressure drop across the control system. This
is used to determine the correct interval for the cleaning cycle
and to indicate if bags are starting to blind. A 4-inch water
pressure drop is the nominal setting for these fabric filters.
Joe also times the cleaning cycle of each fabric filter.
[t29] During their tour, Joe has observed that no visible
emissions are being discharged from the silos and that the vacuum
system works well at the alkaline bypass material loading point.
The fabric filter controlling the finishing mill has a visible
emission discharge.
[#30] The last stop on this visit is to reaffirm the suit-
ability of the sampling sites. The drawings previously supplied
by the plant show that they are acceptable. [#31] A quick check
of all four sampling sites shows that the sampling locations are
well designed and constructed and property located for obtaining
a representative sample.
[#32] The men return to the meeting room to finalize the
test plan. Tom explains that the manner in which the facility is
operated during the performance test will effect its future
operating procedures since these conditions will be reflected in
the permit to operate.
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[#33] A final test plan is agreed upon and a test date is
set. The kiln will be tested under two conditions, with the
alkaline bypass off, and in the full bypass position. These two
conditions will represent each extreme in kiln operation. The
clinker cooler will be tested at one condition. [#34] Since
visible emissions were observed from the finishing mill, during
the inspection, the finishing mill will be tested under SIP
regulations. Testing of other SIP regulated sources will be
waived at this time.
One month later at the specified testing date all parties
are ready to conduct the performance test. The state agency
personnel, Tom and Joe, have 3 major areas of responsibility:
[#35] 1) to observe testing methodology, [#36] 2) to observe the
facility operation, and 3) to take visible emission or opacity
readings.
[137] Prior to the start of the actual test a check should
be made among all parties to see if any problems have arisen.
[#38] Tom, the agency person most familiar with test procedure,
observes the testing firm unpack their truck, [#39] set up the
field laboratory, and assemble a sampling train in preparation
for the first sample run. [#40] A close inspection of all equip-
ment and procedures prior to testing may give some indication of
any problems that may arise during testing. Tom would let the
test team leader know of any potential problems prior to the
start of the test. The agency observer wants the test team to
collect a valid and representative sample so an accurate compli-
ance determination can be made. His purpose is not to catch the
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test team making an error so the report will be rejected and
another test run. A retest only costs the agency and facility
additional time and money and delays the determination of compli-
ance status. The on-site observation includes both performance
audits and system audits. To audit performance on both the flow
rate and flow totalizing devices, Tom has the test team check
their control module with the use of a critical orifice. tt41]
This device is plugged into the control module. An acceptable
volume of air should be metered in the specified time. [#42] Tom
completes his pretest checks as he watches the test team finalize
the assembly of their equipment on the stack. [43] During this
time Joe has been making several checks on the process and con-
trol equipment to determine whether they are operating in the
prescribed manner. The facility appears to be operating in the
agreed upon manner. Joe then gives Tom the word that the test
can begin any time the test team is ready.
[#44] Tom closely observes the start of each sample run,
since he knows that normally the most critical times for close
observation are the start and finish of each run. [#45] This
includes all initial and final data recording and [#46] the
leakage rate check on the sampling equipment. [#47] Tom checks
off the successful completion of the testing procedures. [#48]
Special attention is paid during the sample recovery phase at the
conclusion of each run. The weight of sample recovered will
ultimately be multiplied by a factor of over 100,000 to get the
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total stack emission rate, so any errors in sample recovery would
be critical.
[#49] During each of the sample runs, Joe will take at least
two 6-minute visible emission readings with a check on the facil-
ity operation between readings. Joe is a qualified visible
emissions observer and has recertified within the last 6 months.
Visible emissions, facility operations, and the amount of particu-
late matter recovered can many times be correlated as explained
in the Role of the Observer paper. This correlation can give an
indication if there are problems with facility operations or
sampling. [#50] Despite the fact that the facility operations
are computer monitored and recorded, Joe still uses the stan-
dardized process and control equipment data forms to make periodic
data recordings. These recordings will give the agency a written
record and will be used to provide a check on the facility's data
report.
Often times sources required to use continuous emission
monitors would perform the continuous emission monitor certifi-
cation tests along with the performance tests. If this were the
case, Tom would also be responsible for observing the monitor
certification.
[#51] The test program progressed and concluded according to
schedule. The fabric filter air pollution control systems have
performed according to design specifications for this facility.
Visible emissions were less than 10 percent opacity for the kiln
and finishing mill and no emissions were visible from the clinker
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cooler. No facility operational problems were reported or ob-
served during the test series. All testing was performed in the
prescribed manner.
[#52] During the performance test both Tom and Joe used
standardized data sheets and checklists. The use of standardized
forms avoids loss of data, provides written documentation and
allows other agency personnel to more easily review the data.
After Tom and Joe return to the office/ both men make an official
accounting of the performance test. [#53] This generally only
takes a couple of hours since both men used the prepared data
sheets. Putting all special occurrences into writing is impor-
tant since it will probably be 3 or 4 weeks before they receive
the report of the test they have just observed.
Tom and Joe's work is not completed on this task until they
receive the emission test report. [#54] Let's now follow the
source team leader (Rick) through his duties of preparing the
emission test report.
[#55] After returning to the home laboratory, Rick has the
integrity of the samples checked and ensures that all data sheets
are complete. [#56] The samples are sent to the lab for analy-
sis. Analysis for particulate matter consists of drying and then
weighing the sample residue on an analytical balance. The state
generally does not observe sample analysis unless conditions seem
to warrant such action.
[#57] When a more complicated analytical procedure is re-
quired such as a sulfate titration in the sulfur dioxide
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reference method, the agency will provide the test team with one
or more audit samples to be analyzed with the field samples.
[158] The use of audit samples will give the agency an indication
of the precision and accuracy of the testing firm's analytical
techniques. The results of the audit samples should be presented
in the test report.
[#59] Rick then sends the data sheets to his computer sup-
port service. The use of a computer greatly reduces the chances
of calculation error. [#60] After receiving the computer print-
out, Rick writes the emission test report using the standardized
report format contained in the testing guideline package. The
test results show that emissions from the facility was well
within the performance standards.
[#61] The report is then sent to the cement plant manage-
ment. Here both the plant engineer and plant manager review the
report for accuracy. The responsibility for the source test
report is that of the facility not the source test firm.
After reverifying the plant information contained in the
report, the plant engineer then sends the report to [#62] Tom
with a cover letter certifying that the process data contained in
the report is accurate. Tom also reviews the report for accuracy
with regard to the emission test data. Joe then reviews the
report for accuracy with regard to facility operations. The
source test report, Tom's and Joe's summary report, and their
recommendations are then sent to the enforcement group.
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The performance test show that the facility is well in
compliance with the standard under all conditions tested.
[#63] The state attorney then writes the plant manager a
letter confirming the fact that the state has found the source to
be in compliance. The letter also explains that a permit to
operate will soon follow and is contingent upon the source main-
taining good operating practices and developing and executing an
operation and maintenance program. The source is also instructed
to report any changes in raw materials, product, process equip-
ment and [#64] control equipment which might affect emission
levels and compliance status. Any violation of the conditions of
the permit will result in its cancellation and another compliance
test will be scheduled to determine compliance.
[#65] The first step in the cement plants continued compli-
ance program is the issuance of their permit to operate. Sandy,
one of the engineers in the permits group, issues the cement
plant a 3-year conditional permit. [#66] The permit requires the
source to 1) monitor and record their feed rate as required by
NSPS, [#67] 2) implement a routine program of internal inspection
of baghouses with repair or replacement of defective or worn
bags, [#68] 3) establish and conduct a program of good operating
practices and proper maintenance for the process and control
equipment to minimize malfunction and upset conditions, 4) prop-
erly dispose of collected particulate matter, and 5) continue to
water all unpaved roads to minimize fugitive emissions.
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[#69] The use of continuous emission monitors is a very
useful means of determining continuing compliance; however, this
cement plant is not required by either the state or federal
agency to install and operate monitors. All agencies should
strongly consider the use of continuous emission monitors.
[#70] Joe will ensure that the cement plant meets the condi-
tions of the permit to operate. The size of Joe's district
allows him to view the cement plant from the road about once a
month. [#71] If any major problems are noted during these
sitings or from excess emissions reports, [#72] Joe visits the
plant to investigate that specific problem. Also, on an annual
basis, [#73] a complete review of all process and control equip-
ment operating records and hardware is made. The annual inspec-
tion is a scheduled inspection and ensures that the facility
maintains the process and air pollution control equipment at
least on an annual basis. Detailed records are always kept by
the agency for all visible emission sitings and plant visits.
Observing, reviewing, and evaluating Stationary Source
Performance Tests comprises a very important step in the enforce-
ment cycle. Proper documentation of process and control equip-
ment operation during the performance test can provide a founda-
tion for identifying and resolving future compliance problems.
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SECTION B. OVERVIEW OF OBSERVATION OF PERFORMANCE TEST
Subject
1. The role of the agency observer B~3
2. Slides B"15
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THE ROLE OF THE AGENCY OBSERVER
by
William DeWees
INTRODUCTION
Under current environmental regulations a plant or facility that emits
pollutants to the atmosphere must maintain the emissions at or below certain
levels, as set forth in the applicable Federal, State, or local standards.
An important aspect of this overall program of air pollution control is com-
pliance testing, in which emissions are sampled while the plant operates under
"typical" conditions considered representative of day-to-day operations.
To ensure that the compliance test will meet all requirements of the
responsible environmental control agency, officials of most plants engage
the services of an independent, professional testing consultant firm. Thus,
three groups are usually involved in the planning and execution of a compliance
test: officials of the plant being tested, the^consultant testing team, and
the responsible control agency. This paper deals with the responsibilities of
the agency representative whose function is to observe the compliance test;
specifically, the task of the agency observer is to evaluate the representative-
ness of the test. He is not involved directly in the testing process; in fact,
he must specifically avoid any action that could interfere with performance of
the test by the professional testing team, who are engaged at the expense of
the plant seeking compliance status. Requirements for the agency observer in
compliance testing involve both technical skill and considerable tact in his
dealings with the test team and plant personnel.
Responsibilities of the Control Agency
Because the results of any compliance test may be contested, the control
agency staff must be aware of potential legal implications of the compliance
test. They must prepare written guidelines and clearly delineate the accepta-
ble sampling procedures. They must inform the test team and the plant repre-
sentative of all baseline or minimum conditions to be met in the test, and
provide clear guidelines for calculation and presentation of test data. Having
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developed these criteria, the Agency must then ensure that they are applied
uniformly. For this reason any new or inexperienced agency staff members must
be thoroughly trained before being assigned a responsibility as critical as
compliance determination. The availability of written protocols will minimize
the need for impromptu decisionmaking by the agency observer during the com-
pliance test.
The following seven steps summarize the means by which control agency per-
sonnel will approach the determination of compliance:
1. Orient agency staff and plant personnel. Establish contact with
the plant; become familiar with operations, emissions, and appli-
cable regulations.
2. State the requirement for a source test. This requirement may be
part of an overall regional compliance schedule or a Federal Stan-
dard for a New Source Performance Test (NSPS).
3. Set requirements for testing methodology. Formulate written testing
requirements.
4. Conduct planning sessions. Meet with test team and plant representa-
tives to finalize testing procedures; perform a pretest survey.
5. Observe compliance tests. Assign at least one agency staff member to
observe facility operations and testing methodology throughout the
test.
6. Review test data. Determine compliance status and give official noti-
fication.
7. Continue enforcement of compliance. Perform follow-up inspections
using data generated from the compliance test as baseline for compari-
son.
Responsibilities of the Agency Observer
As stated earlier, the principle function of the agency observer is to
evaluate the representativeness of the compliance test. This evaluation is
made in terms of five criteria, if any one of these criteria is not met, the
compliance test is considered nonrepresentative:
1. Process and control equipment must be operated in such a manner
as to produce representative atmospheric emissions.
2. Locations of the sample port and sample points must provide samples
representative of the atmospheric emissions.
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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 results must be representative of the sample recovered
and analyzed.
The following sections of this paper describe more fully the responsibili-
ties of the agency observer as related to four phases of the compliance test:
1) preparation and planning, 2) conducting the test, 3) recovery, transport,
and analysis of the sample, and 4) preparing the compliance test report.
PREPARATION AND PLANNING
In the initial phase, preparation and planning, the agency observer must
clarify for the test team leader and the plant representative all procedures
to be followed during the entire test program. The compliance test guidelines
will assist the test team leader in formulating a compliance test protocol
that is compatible with agency requirements. In reviewing the compliance test
protocol submitted by the plant representative or the test consultant, the
agency observer will give close attention to two important items: 1) any devia-
tions from standard sampling procedures and 2) proposed operation of the facility
during the compliance test.
Many processes, sampling locations, and pollutants may entail some modifi-
cation of the standard sampling procedures. The agency must determine whether
the modification will give results that are equivalent to and/or greater than
those that would be obtained with the standard method.
The other major determination to be made from the test protocol involves
defining a representative facility operation. The agency should develop stan-
dard facility checklists for each type of process and air pollution control
system. Examples of such checklists for power plants (representing fossil-fuel-
fired indirect-heat-exchange processes) and electrostatic precipitators (repre-
senting a widely used control device) are presented as Tables 1 and 2 in the
appendix.
Using the appropriate facility checklists and the proposed compliance
test protocol, agency officials will designate conditions for operation of
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the process and control equipment during the test period. These baseline condi-
tions will form the basis on which to determine the representativeness of the
facility operation during testing. The Agency should submit these baseline
conditions to the plant representative at the pretest meeting. The plant
representative should understand and agree to all facility baseline conditions
prior to the compliance test, since the determination of representativeness
of the facility operation is for protection of both the Agency and the plant.
The plant representative may suggest additional factors that would constitute
an upset condition and would not produce representative emissions.
The observer must become familiar with the process to be sampled. When-
ever possible the agency field inspector should be the "observer" for the pro-
cess and control equipment. If the process is large or highly complicated, the
observer may be aided by an agency process control engineer. An emission test
performed at the wrong process rating or without sufficient process data will
not be considered valid. The observer may learn details of a specific process
by consulting one or more of the many inspection manuals prepared by the U.S.
Environmental Protection Agency for this purpose. These manuals indicate the
methods and devices used in monitoring process rates and/or weights.
Review of the team leader's test protocol should initiate formulation
of the observer's sampling audit plan. The observer's audit plan will contain
the tentative testing schedule, the baseline operating conditions, the observer's
checklists (modified as necessary), and details for handling of irregular situa-
tions that could occur during the test.
Observer's Checklists
The observer's checklists normally will need little modification. Any
accepted modification of the normal sampling procedure will be covered by
entering additional factors on the checklists.
The observer should be prepared to handle any nonroutine situations that
arise during the compliance test. Before the test begins, he should prepare
a list of potential problems and possible solutions. The list will establish
limits at which the minimum requirements for sampling and process rating are
not met; for example, sampling may be unacceptable if the sampling box cannot
maintain the filter at minimum temperature, and process rating is unacceptable
if a power plant is unable to maintain full load because of poor quality coal.
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In preparing to meet such emergencies in testing, the observer must know who
in his organization is authorized to make decisions that are beyond his capabi-
lity or authority.
The number of agency personnel observing the compliance test must be ade-
quate to ensure that 1) the facility operation (both process and control equip-
ment) is monitored and recorded in a manner that provides a basis for present
and future evaluations of representativeness, 2) visible emission rates as an
index of continuing compliance, and 3) the prescribed testing methodology is
followed. With respect to item (2), it is helpful if the agency personnel who
will make future inspections of the facility can observe facility operations
and take visible emission readings during the compliance test.
Pretest Meeting
Before compliance testing, the agency observer, the test team leader, and
a plant representative with process control authority should meet to finalize
sampling plans, to establish baseline conditions, and to coordinate the testing
schedule. At this meeting the compliance test protocol will be finalized and
agreed upon by all parties. A pretest checklist should be used to organize
the meeting and ensure that all pertinent areas,are discussed. A pretest check-
list is presented in Table 3 in the appendix. The test team supervisor must
know the exact sampling procedures to be used, the minimum data requirements,
and the conditions that constitute an invalid test. Likewise, the plant repre-
sentative should know what process parameters will be recorded, the intervals
of data collection, the raw materials that will be used, and the conditions
that constitute an invalid test.* Execution of the compliance test in accord-
ance with the established protocol should constitute a valid test.
Some compliance tests of relatively simple processes may be routine enough
that a pretest meeting on the morning of the test before sampling begins will
be adequate to ensure complete understanding among all parties involved. In
all cases, however, whether the process is simple or complex, it is the observer's
responsibility to be certain that all details of the test procedure are under-
stood and accepted before the test begins.
*Since the agency observer will have authority for approval or disapproval of
the compliance test, he must be certain that all aspects of the test protocol
are clearly understood.
B-7
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CONDUCTING THE TEST*
The attitude and behavior of the agency observer during the compliance
test, are of utmost importance. He should perform his duties quietly and
thoroughly, conversing with the test team and plant personnel as little as
possible. If test procedures do not follow the established guidelines, he
should deal solely with the test supervisor and plant representative or should
have a clear understanding with them if it is necessary to communicate with the
test technicians or plant operators. Conversely, he should refrain from answerinc
queries from the test team and plant operators directly, referring such inquiries
to the appropriate supervisor. The ideal emission test is one in which the data
gathered is representative and no discussion of the test procedure is required.
During the test the observer must make several checks to ensure adherence
to specified sampling procedures. To eliminate the possibility of overlooking
necessary check, he should use a checklist covering details of the sampling pro-
cedures. An example checklist is presented in Table 4 in the appendix.
Measurement Errors
To understand the relative importance of the measurements in emission
testing, the observer should know the significance of errors. The procedure
for determining pollutant emission rates by stack sampling involves measure-
ment of a number of parameters. Errors of measurement associated with each
parameter combine to produce an error in the calculated emission rate. Measure-
ment errors are of three types: bias, blunders, and random errors.
Bias errors, usually a result of poor technique, cause the measured value
to differ from the true value in one direction. This operator error often
can be minimized by proper calibration and by adequate training in instrument
operation. Most bias errors should have been eliminated with receipt of docu-
mentation of the calibration of emission measuring equipment in the pretest
meeting. The observer may believe, however, that a one point field check of
calibration is warranted. Minimizing bias errors requires diligent effort by
skilled sampling teams who adhere closely to the prescribed methods.
Most blunder errors occur during collection, recovery, or transportation
of the sample or during analysis. For example, if the sample nozzle is allowed
*Because of the diversity of possible pollutants and sampling procedures, this
discussion is presented solely in terms of particulate sampling. (EPA Method 5)
B-8
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to touch the inner stack wall and collects foreign material from the wall, the
resulting error may be extremely large. Unfortunately, such errors are diffi-
cult to observe and the total effect cannot be calculated. Elimination of all
blunders should be a main concern of the observer.
Random errors, which result from a variety of factors, cause a measured
value to be either higher or lower than the true value. Such errors are caused
by inability of sampling personnel to read scales precisely, poor performance
of equipment indicators, and lack of sensitivity in measurement devices. The
usual assumption is that random errors are normally distributed about a mean
or true value and can be represented statistically in term of probabilities.
Determining the maximum expected error, however, does not require a strict
statistical approach. It can be estimated by summing the maximum expected
errors for each factor.
The First Test
The observer should be present when the test team starts preparations.
They will unpack the test equipment, check all equipment for damage, set up
the sample recovery lab, and assemble the sampling train. The observer should
inspect the sample recovery area and observe the .assembly of the sampling train.
Several items on the checklist require attention at this time.
If only one agency observer is present, the schedule below should be
followed.
For the first test, after determining that facility operations are as
specified, the observer will go to the sample site to observe the test team's
recording of the initial data. He need not observe the initial leak check,
since he will observe the leak check at the completion of the test. When the
observer is satisfied with the sample train preparation, he will allow the test
to be started. He will then observe the sampling of the first port and the
changeover to sampling of the second port. If he is satisfied with the perform-
ance of the test team, he will go to a point at a suitable distance from the
stack and read visible emissions for a 6-minute period.
He will then check facility operations. If the process and control equip-
ment are operating satisfactorily and the data are being recorded as specified,
he will again read visible emissions over a 6-minute period.
B-9
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The observer will then return to the sample site to observe completion of
the test, giving close attention to the final readings and the final leak
check. He will then observe transport of the sample train to the cleanup
area and recovery of the sample.
The Second Test
If the observer is satisfied with all sampling procedures in the first
test, he will spend most of the second test period in observing process opera-
tions and reading visible emissions. He may wish to spot check the sampling
operation and/or be present at the completion of the sampling. During the
second test he will make two 6-minute visible emission readings and will check
facility operations between readings. He should be satisfied that the data
being recorded are representative of the facility operations.
If the sample site is easily accessible the observer may wish to observe
the final data recording, final leak check, and transport of the sample train
to the cleanup area. In either case he should witness the recovery of the
second sample. A visual observation of particulate buildup on the filter and
in the acetone rinse from the first two tests can be correlated with the visi-
ble emission readings to determine the emphasis of observation for the final
test. This comparison of particulate collected will be valid only if the sample
volumes for both tests are approximately the same. If the particulate catch
on the filter and in the acetone rinse for the second test is consistent with
or greater than that indicated by the visible opacity readings for the first
test, then the observer should again place emphasis on surveillance of facility
operations. If the particulate catch for the second run appears lower than is
indicated by the visible opacity readings, he should stress the observation of
emission test procedures.
The Third Test
Regardless of the main emphasis, the observer must perform certain observa-
tions during the final test. He should again check all facility operations prior
to testing. He should make two 6-minute visible emission readings, with a check
of the facility operation in between. He will again witness sample recovery
and compare the apparent particulate catch with visible emission readings. He
should also check any suspected weak points or problem areas during this final
test.
B-10
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SAMPLE RECOVERY, TRANSPORT, AND ANALYSIS
Proper recovery of the sample is crucial to the compliance test. Most
test teams are not well-versed in the legal requirements for documentation
of sample recovery, sample transport, and sample analysis. It is imperative
that these tasks are done by standard procedures and that each step is well-
documented. Because the test report may ultimately be subject to the require-
ments of the Rules of Evidence, the observer should use a sample recovery
checklist to ensure that all tasks are performed properly (Table 5).
Sample Recovery and Transport
To reduce the possibility of invalidating the test results, the responsi-
ble person must carefully remove all of the samples from the sampling train
and place them in sealed, nonreactive, numbered containers. It is recommended
that the samples then be delivered to the laboratory for analysis on the same
day. If this is impractical, all samples should be placed in a carrying case
(preferably locked), in which they are protected from breakage, contamination,
loss, or deterioration.
The responsible person must mark the samples properly to provide positive
identification throughout the test and analysis procedures. The Rules of
Evidence require impeccable identification of samples, analysis of which may
be the basis for future evidence. Admission by a laboratory analyst that he
is not positive whether he analyzed sample No. 6 or sample No. 9, for example,
could destroy the validity of an entire compliance test report.
Positive identification also must be provided for the filters used in
any 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. If any other method of identifi-
cation is proposed, it must be a positive means of identification and must not
impair the function of the filter.
Finally, each container must be uniquely identified to preclude the possi-
bility of interchange. The number of each container is recorded on the analysis
data sheet associated with the sample throughout the test and analysis.
B-ll
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Samples are to be handled only by persons associated in some way with the
task of analysis. A good general rule is "the fewer hands the better", even
though a properly sealed sample may pass through a number of hands without
loss of integrity.
It is generally impractical for analyst to perform the field test. The
Rules of Evidence, however, require that a party be able to prove the chain of
custody of a sample. For this reason, each person who handles the sample must
document from whom he receives it and to whom he delivers it. This requirement
is best satisfied by having each recipient sign a standard chain of custody
sheet that is initiated during the sample recovery (Table 6).
Analysis
Potential sources of error in analysis lie in the sample, the analyzing
equipment, the analytical procedures, and documentation of results. Since
analysis is often performed at a laboratory distant from the test site, the
agency observer usually is not present at sample analysis. If he has any
question about the ability of the designated analyst to adhere to good practices
in analyzing and reporting data, the observer has two paths of recourse: he
may be present during analysis, or he may require that analysis be done by a
certified laboratory if one is available. The latter requirement, however,
usually is an unnecessary burden and should not be imposed as a general rule.
During the analysis any unused portions of the sample should be kept
intact and placed in a safe place until the final report is accepted.
Laboratory equipment, especially the analytical balance, should be calibrated
immediately before the sample weighing. The laboratory data and calculations
must be well-documented and the documents kept in such a manner that the
Agency can inspect the record of any^analysis upon request.
COMPLIANCE TEST REPORT
Upon completion of the compliance field test, the agency observer can
begin the final task of determining the representativeness of the compliance
test data. He will be required to write an observer's report for attachment
to the test team report. The facility operation data and the field check-
lists 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 must have been met. If the observer
B-12
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suspects a bias in the results, this bias should be noted. A bias that can
only produce emission values higher than the true emissions would not invali-
date the results if the plan is 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 compilation of the test re-
port; he is usually under the supervision of a senior engineer, who reviews
the report for content and technical accuracy. Uniformity of data reporting
will enhance the speed and efficiency of the agency's review. For this reason,
the agency should provide a report format and other guidelines for the test
team supervisor. A suggested format is presented in Figure 1 of the appendix.
The agency observer performs the first review of the test report. He
will check all calculations and written material for validity, noting any
errors and providing any necessary comments. Although the conclusions in the
observer's report do not constitute final authority, they should carry great
weight in the final decision concerning the representativeness of the test.
Because of 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 in Figure 2
of the appendix.
In addition to the determination of representativeness of the compliance
test, the observer will report all conditions under which the facility must
operate in the future to maintain their conditional compliance status. These
conditions are reported to the facility as conditions of continuing compliance
status.
These compliance test reports and the conditions of compliance acceptance
will provide any Agency inspector with sufficient data for conduction of all
future facility inspections.
CONCLUSIONS
The Agency must establish clear written guidelines for stack testing that
fully explain testing methodology and minimum data requirements and provide a
mechanism for obtaining all normal future facility operations and expected
B-13
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testing problems. The successful compliance test will require close
coordination between technical and legal staffs within the Agency, and ex-
tensive communication and coordination among the Agency observer, the testing
team, and the plant representatives.
The Agency observer is in a good position to assist the test team in ob-
taining valid compliance test results by advising them of any potential short-
comings that might compromise the test data. The observer should not direct,
interfere with, or intrude into the relationship of the plant representatives
and the test consultant.
The observer can play a key role by determining whether process operations
during the test are representative of normal operations and are consistent with
the accepted test protocol. He should use standard checklists whenever possible
to prevent omission of critical information or data that would be helpful in
final agency review of test results.
Observation of process operations during the compliance test will allow
the observer to formulate surveillance criteria for future plant inspections
to determine continuing compliance with emission standards and operating per-
mits.
The comments and reports developed by the observer should be well-
documented in the event that the Agency's decision concerning compliance is
contested.
B-14
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SLIDE 202-0 NOTES
OBSERVATON OF PERFORMANCE
TESTS
SLIDE 202-1
DETERMINE APPLICABLE
EMISSIONS REGULATIONS
o determine allowable pollutant
limitation
o define facility operation
o determine applicable test
method
SLIDE 202-2
OBTAIN ENTRY AND
COOPERATION
o establish contact with facility
o have facility submit a proposed
testing protocol including
facility operation and testing
procedure
B-15
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SLIDE 202-3 NOTES
EVALUATE TEST PROTOCOL
(DESIGN EXPERIMENT)
o review all existing permit data
and any previous agency contact
with facility
SLIDE 202-4
PRETEST SURVEY
o prior to test, have a meeting
with plant and testing personnel
to finalize testing protocol
o ensure all agreements and any
modifications or additions to
published procedures are writ-
ten and understood prior to test
SLIDE 202-5
PRETEST PREPARATION
o designate a contact person for
source, tester, and agency
o all questions, clarifications
and requests should only be made
between designated contact
personnel
o make it clear to facility and
tester when any phase needs
agency approval prior to
beginning or ending
B-17
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SLIDE 202-6 NOTES
SAMPLING
AGENCY RESPONSIBILITY
1. Facility Operation
2. Source Test Observation
3. Visible Emission Determination
SLIDE 202-7
SAMPLE CLEANUP
This is one of the most criti-
cal phases with Method 5. The
test normally only collects about
1/250,000 of the particulate
emitted. Since the total col-
lected mass is about 100 mg, any
error in sample recovery or
extraneous materials can have a
large affect.
SLIDE 202-8
SAMPLE TRANSPORT
The three main concerns in
sample transport are: 1) no
sample is lost, 2) the sample is
not contaminated by the sample
container, and 3) the sample is
not subject to conditions that
will eliminate or destroy part
of it (i.e., high temperature).
The sample integrity must be
maintained.
B-19
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SLIDE 202-9 NOTES
SAMPLE ANALYSIS
The agency generally does not
observe the sample analysis.
For this reason, it is suggested
that either an audit sample or
control sample be used whenever
practical.
SLIDE 202-10
fEST REPORT
Calculation errors are very
common. To help eliminate them
an ease of review, a standardized
testing report format, and stan-
dardized testing forms should be
used.
B-21
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SECTION C. ROLE, RESPONSIBILITIES AND BEHAVIOR
OF THE OBSERVER
Subject Page
1. Role, responsibilities and behavior of the observer C-3
2. Slides C-5
C-l
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ROLE, RESPONSIBILITIES AND BEHAVIOR OF THE OBSERVER
by
Thomas Clark
The agency observer plays a key role during the performance test program.
He is the official representative of the control agency. His role inludes:
1. preparing and planning the test;
2. observing process operations;
3. observing control equipment operations;
4. observing performance.testing methodology;
5. documenting and summarizing all activities during the
testing program; and
6. reviewing test report for completeness and auditing data
for accuracy.
RESPONSIBILITIES OF THE OBSERVER
In his role as official agency representative, the observer is responsible
for representing the interests of the agency during all phases of the performance
test. During the planning phase and in the pretest meeting, the observer will
specify all agency requirements with respect to test methodology, process and
control equipment operation and reporting requirements. The observer will make
decisions as necessary in each of these forementioned areas.
While observing on-site testing, the observer is responsible for the
validity of the tests. He must make decisions as to the representativeness of
process and control equipment operations, and determine if acceptable testing
methodology is being used.
Posttest responsibilities of the observer includes documenting in an ob-
server's summary report, all occurrences during field testing. The observer
must also review the test report for completeness and accuracy, and make rec-
ommendations as to the acceptability of the test report.
C-3
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BEHAVIOR OF THE OBSERVER
The overall objective of the performance test program is to achieve accu-
rate and reliable data. As the official representative of the agency, it is
the observer's responsibility to do all within his power to ensure that testing
the testing is completed successfully. Therefore, he must work cooperatively
with the source and the testing consultant. He must be specific and forthright
in his requests, and he must be respectful of the positions of the other par-
ties involved.
While observing on-site testing, the observer should adhere to the follow-
ing techniques.
Observing Facility Operations
1. Don't write on process charts and graphs
2. Don't turn knobs and dials
3. Don't collect unnecessary data or data that
was not agreed upon in the pretest meeting
without obtaining approval
Observing Testing Methodology
1. Don't touch or adjust test equipment
2. Don't question tester or interfere during
critical times of the test
3. Don't conceal unacceptable acts or procedures
to later use as justification to reject the
tests
C-4
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SLIDE 203-0 NOTES
ROLE OF THE OBSERVER
SLIDE 203-1
ROLE OF THE OBSERVER
The observer is the official representative of the agency.
1. Prepare and plan the test
2. Observe process operation
3. Observe control equipment operations
4. Observe testing methodology
5. Document all activities during testing program
6. Review test report and audit data
SLIDE 203-2
RESPONSIBILITIES OF THE OBSERVER
1. Specify Agency requirements.
2. Make decisions regarding:
test methodology
process and control equipment operation
reporting requirements
3. Determine representativeness of process and
control equipment operation.
4. Determine acceptability of testing methodology.
5. Compile summary report of test.
6. Review test report and make recommendations.
C-5
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SLIDE 203-3 NOTES
OBSERVER BEHAVIOR
1. The observer should do all within his power to see that
testing is completed successfully.
2. The observer should work cooperatively with the source
and the consultant.
3. The observer must be specific and forthright in his
requests.
4. The observer must be respectful of the positions of the
other parties involved.
SLIDE 203-4
OBSERVER TECHNIQUES
FACILITY OPERATIONS
1. Do not write on process charts and graphs.
2. Do not turn knobs and dials.
3. Do not collect unnecessary data.
SLIDE 203-5
OBSERVER TECHNIQUES
TESTING METHODOLOGY
1. Do not touch or adjust equipment.
2. Do not question tester or interfere during critical
times of the test.
3. Do not conceal unacceptable acts or procedures.
C-7
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SECTION D. ESTABLISHING TESTING PROTOCOL
Subject Page
1. U.S. EPA performance test guidelines (taken from the Model
Compliance Testing Protocol Manual) D-3
2. Slides D-17
D-l
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U.S. ENVIRONMENTAL PROTECTION AGENCY
PERFORMANCE TEST GUIDELINES
This document has been prepared for the purpose of ensuring and expediting
necessary information exchange relating to compliance testing for sources under
the Federal New Source Performance Standards for Stationary Sources [40 CFR
Part 60].
Every area in the United States is under jurisdiction of local, state
regional or state district offices which are a representative of the state, and
the Federal Regional Offices which are representatives of the Federal Environ-
mental Protection Agency (EPA). The "Notification of Plant Start Up" form
should be submitted to the Federal agency and proper State agency prior to
the plant start up date. In order to obtain official acceptance of any
source test results, contact must be established with the agency(s) having
jurisidiction. Facility operating conditions and test and analytical
methods for particulate and other regulated pollutants will be reviewed by
the agency prior to each test; a Compliance Test Protocol must be submitted
to the agency prior to each performance test.
The general guidelines to be used are published in the Federal Register.
The standard guidelines are, but not limited to, as follows:
60.8 Performance Tests
(a) Within 60 days after achieving the maximum production rate at
which the affected facility will be operated but no later than
180 days after initial startup of such facility and at such
other times as may be required by the Administrator under
section 114 of the Act, the owner or operator of such facility
shall conduct performance test(s) and furnish the Administrator
a written report of the results of such performance test(s).
D-3
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NOTIFICATION OF PLANT STARTUP
Agency USE ONLY
Source I.D. No.:
Source Name:_
State:
Location:.
Phone:
_County:_
.Mailing Address:.
Contact Person:
Anticipated Date of Startup:
Type of Industry:
Process Description:_
Mailing Address:.
phone:.
.Process Name:.
Products:
Raw Materials:
Fuels Burned:
Maximum:
Hourly:
Rate:
Maximum:
Hourly:
Rate:
Characteristics:
Average:.
Yearly: .
Rate:
Average:.
Yearly:
Rate:
Maximum:.
Hourly:
Rate:
Average:
Yearly:
Rate:
Type of Control Equipment:
Description of Control Equipment:
Maximum
Ib/hr
Averaq
tons/i
Pollutant:
.Control:.
.Equip-
ment
Efficiency:.
- Emission:
rate
.(estimate).
Emission:
stacks
Identification.
Diameter:-
(ft)
Height:-
(ft) -
-Flow:
rate
SCFM
Temp.
C
Is any of the above data considered confidential yes no
If yes; a written justification must be submitted with this form
detailing the reasons for request of this classification for
each item considered confidential.
D-4
-------
o
I
tn
AGENCY USE ONLY
Date Received
No. Assigned
Reviewer
COMPLIANCE TEST PROTOCOL
Pretest meeting date
Compliance test date(s).
I.
SOURCE INFORMATION
Name
Address
Person to contact
Telephone
II. TESTING FIRM INFORMATION
Name
Address
Person to contact
.Telephone
III. GAS STREAM INFORMATION. IDENTIFY ALL POLLUTANTS TO BE SAMPLED
1.
2.
3.
4.
5.
Pollutants
No. of
sampling points
Total time
per test
No of tests
(minimum of 3)
Test methods
-------
(b) Performance tests shall be conducted and data reduced in
accordance with the test methods and procedures contained in
each applicable subpart unless the Administrator (1) specifies
or approves, in specific cases, the use of a reference method
with minor changes in methodology, (2) approves the use of an
equivalent methods, (3) approves the use of an alternative method
the results of which he has determined to be adequate for indi-
cating whether a specific source is in compliance, or (4) waives
the requirement for performance tests because the ownder or
operator of a source has demonstrated by other means to the
Administrator's satisfaction that the affected facility is in
compliance with the Standard. Nothing in this paragraph shall
be construed to abrogate the Administrator's authority to require
testing under section 114 of the Act.
(c) Performance tests shall be conducted under such conditions as the
Administrator shall specify to the plant operator based on repre-
sentative performance of the affected facility. The owner or opera-
tor shall make available to the Administrator such records as may
be necessary to determine representative operating conditions to
be used while conducting performance tests. Operations during
periods of startup, shutdown and malfunction shall not constitute
representative conditions while conducting performance tests unless
otherwise specified in the applicable standard.
(d) The owner or operator of an affected facility shall provide the
Administrator 30 days prior notice of the performance test to
afford the Administrator the opportunity to have an observer present.
(e) The owner or operator of an affected facility shall provide, or
cause to be provided, performance testing facilities as follows:
(1) Sampling ports adequate for test methods applicable to
such facility.
(2) Safe sampling platform(s).
(3) Safe access to sampling platform(s).
(4) Utilities for sampling and testing equipment.
D-6
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(f) Each performance test shall consist of three separate runs using
the applicable test method. Each run shall be conducted for the
time and under the conditions specified in the applicable standard.
For the purpose of determining compliance with an applicable standard,
the arithmetic mean of results of the three runs shall apply. In
the event that a sample is accidentally lost or conditions occur
in which one of the three runs must be discontinued because of
forced shutdown, failure of an irreplaceable portion of the sample
train, extreme meteorological conditions, or other circumstances,
beyond the owner or operator's control, compliance may, upon the
Administrator's approval, be determined using the arithmetic mean
of the results of two runs.
SOURCE TEST PROCEDURES
A. The "Compliance Test Protocol" shall be completed by the testing firm
and/or company, and received by the Agency(s) of jurisdiction no later
than 30 calendar days prior to the proposed test date (60.8(d)).
B. After evaluating the completed "Compliance Test Protocol," and if
necessary, inspecting the test site, the Agency may require additional
conditions, including, but not limited to, the following.
General
1. A pretest meeting in addition to the normal on-site meeting just
prior to testing to resolve an acceptable "Compliance Test Protocol."
2. Correction of unsafe conditions.
3. Required pictures to be taken.
4. Postponement of sample date.
Sampling and Analytical Procedures
5. Additional tests due to adverse conditions such as interferences,
wide variation in feedstock, and nonsteady or cyclic processes.
6. Modification of the stack or duct to obtain acceptabe test condi-
tions.
7. Additional quality assurance procedures.
D-7
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8. Agency to observe the laboratory analysis of the samples.
9. Analysis of spiked samples.
10. Agency obtaining portions of liquid samples.
Facility Operations
12. The process will operate within the baseline conditions established
by the Agency during the compliance test.
13. The process operating parameter to be recorded during the compliance
test will be specified with intervals or recording.
14. Copies of operating logs and charts may be requested.
15. Calibration of process monitoring equipment may be required.
16. The air pollution control equipment will be operated in such a
manner as to be representative of future normal operations.
17. The air pollution control equipment operating parameters to be
recorded during the compliance test will be specified.
C. The agency will confirm the protocol in writing no less than ten (10)
calendar days prior to the proposed test date. If the agency requires
any modifications to the test and analytical methods and/or operational
parameters, or an additional pre-test meeting, the source and testing
firm will be contacted by telephone (followed by written confirmation)
no less than fifteen (15) calendar days prior to the proposed test date.
The source operator or tester shall notify the agency of any modifications
to their test of analysis and/or operational parameters, as defined in the
"Compliance Test Protocol" previously submitted.
D. Any agency representative may observe the field test procedures and obtain
copies of all field data. Agency personnel will not sign the plant release
or waiver form.
E. Prior to testing, calibration results of the various sampling train com-
ponents and operational parameters as specified by the "Compliance Test
Protocol" format and the Agency shall be available for inspection.
F. Emission data provided to, or otherwise obtained by, the Administrator
in accordance with the provisions of this part shall be available to
the public:
D-8
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(1) Upon a showing satisfactory to the Administrator by any
person that such records, reports, or information, or particu-
lar part thereof (other than emission data), if made public,
would divulge methods or processes entitled to protection as
trade secrets of such person, the Administrator shall consider
such records, reports, or information, or particular part
thereof, confidential in accordance with the provisions of
section 1905 of title 18 of the United States Code, except
that such records, reports, or information, or particular part
thereof, may be disclosed to other officers, employees, or
authorized representatives of the United States concerned with
carrying out the provisions of the Act or when relevant in any
proceeding under the Act; and
(2) Information received by the Administrator solely for the pur-
poses of §§60.5 and 60.6 shall not be disclosed if it is iden-
tified by the owner or operator as being a trade secret or com-
mercial or financial information which such owner or operator
considers confidential. Policy guidelines on "Confidentiality
of Business Information" is presented in the Federal Register,
Vol. 41, No. 171, Part IV - Wednesday, September 1, 1976.
G. The test results shall be submitted to the agency in the form of "Source
Sampling Report Format" to facilitate review. The report shall be certi-
fied by a minimum of the test team leader, person(s) responsible for
writing and/or reviewing the report, and a person with direct responsi-
bility of plant or process operations. The certification need only
include the portion of the report and data for which the representative
is directly responsible.
H. Acceptance of the compliance with the applicable standard(s) by the agency
is contingent on process and control equipment operation during the per-
formance test, and the future performance and maintenance of the process
and control equipment. The following information shall be submitted as
attachments:
IV. SAMPLING TRAIN INFORMATION
A detailed description of any sampling or sample recovery and
transport procedures which do not comply with the specified procedures
and justification for deviation.
V. LABORATORY ANALYSIS
A detailed description of any analytical procedure and/or equip-
ment which does not comply with the specified procedures and justi-
fication for deviation.
D-9
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VI. DATA SHEETS
A sample of all field data sheets to be used which do not con-
form to the data sheets presented in the appendix.
VII. DESCRIPTION OF PROCESS OPERATION
A description of process operations to include as a minimum
the following, (if known):
General Process
1. Process flow sheet.
2. Maximum rated capacity - as specified by manufacturers and
actual normal maximum operation.
3. Data normally monitored to ensure proper operation.
4. Data to be monitored and recorded during testing to ensure
representative operation.
5. Normal process operation in a 24-hour period, i.e., oxygen
lancing, shutdown, start up, cyclic operations and other load
shifts or times of increased emissions.
6. Feedstock compositions that tend to cause greatest individual
gaseous and parti oil ate emissions and the percent of annual
production attributed to these compositions. (Must be greater
than 5% of the annual average.)
7. Normal maintenance schedule for process.
Combustion Sources
8. Type of combustion source, i.e., tangential fired pulverized
coal boiler.
9. Maximum rated capacity for each fuel fired - as specified by
manufacturers.
10. Actual normal maximum sustained capacity for past and antici-
pated future operations.
11. Data monitored and recorded to ensure proper operation of
process and control equipment.
D-10
-------
12. Boiler efficiency and/or average Btu's heat input to produce
each pound of steam if applicable.
13. Type of fuel feed monitors and their last calibration date.
14. Maximum sulfur and ash content of fuel that will not be
exceeded on a monthly average by more than 10 percent for all
future operations when divided by the Btu content of fuel .
- percent sul fur by weight _
-
rrm+ont
content
per po(jnd Qr cubi(. foQt Qf
percent ash by weight
poun(j Qr cubic foQt Qf f(jel
15. For incinerators the primary chamber minimum gas temperature
and secondary chamber or afterburner gas temperature and resi-
dence time.
16. Normal operating procedures in a 24-hour period, i.e., soot
blowing, bottom ash removal, hopper ash removal, peak load or
sustained operation and manual or automatic operation.
VII. DESCRIPTION QF EMISSION CONTROL OPERATION
A description of emission control 'system to include as a mini-
mum the following, (if known):
1. Types and manufacturers of all control equipment.
2. All means of primary and secondary control and their operations
during testing.
3. Data to be monitored and recorded to ensure representative
operation during testing.
4. Minimum acceptable values of all control device parameters,
i.e., flows and pressures of liquids, voltage and amperage
of electrical input (secondary and primary), pressure drops
across the control system and normal cleaning cycle.
5. Preconditioning of gases prior' to control device.
6. Normal maintenance schedule on control equipment, i.e., clean-
ing of device, replacement of bags, replacement or addition of
catalyst, absorbing reagents or packing material, sealing of
leaks, and repair of damaged or worn parts.
. D-ll
-------
SOURCE SAMPLING REPORT FORMAT
Results of the performance test shall be submitted to the agency by the facility
representative within forty-five (45) days of the completion of the field work.
This report should include, but not be limited to, the following:
1. Format and information as show in Figure 1.
2. Certification by the test team leader that the sampling and analyti-
cal procedures, and data presented in the report are authentic and
accurate.
3. Certification by a responsible representative of the testing firm
(preferably by a professional engineer) that all the testing details
and conclusions are accurate and valid.
4. Certification on the process rate sheet by the facility representa-
tive of the facility operations during the performance test.
5. Data sheets are presented in Appendix B used and all data filled in
blanks when applicable. Other data sheets may be used but must be
approved by the agency prior to the field work.
6. All calculations must be made using the applicable equations as shown
in the Federal Register. An example calculation should be shown for
one run.
7. Final results must be presented in English and metric units and con-
tain two significant digits for each run. Values may be rounded off
to three significant digits after the calculation of each equation
and to two digits for the final results or all digits may be carried
in the computer and only rounded to two significant digits for the
final results. All rounding off of numbers will be performed in ac-
cordance with the ASTM 380-76 procedures.
D-12
-------
Cover
1. Plant name and location
2. Source sampled
3. Testing company or agency, name and address
Certification
1. Certification by team leader
2. Certification by reviewer (e.g., P.E.)
Introduction
1. Test purpose
2. Test location, type of process
3. Test dates
4. Pollutants tested
5. Observers' names (industry and agency)
6. Any other important background information
Summary of Results
1. Emission results
2. Process data, as related to determination of compliance
3. Allowable emissions
4. Visible emission summary
5. Discussion of errors, both real and apparent
Source Operation
1. Description of process and control devices
2. Process and control equipment flow diagram
3. Process data and results, with example calculations
4. Representativeness of raw materials and products
5. Any specially required operation demonstrated
Sampling and Analysis Procedures
1. Sampling port location and dimensioned cross-section
2. Sampling point description, including labeling system
3. Sampling train description
4. Description of sampling procedures that deviated
from standard methods
5. Description of analytical procedures that deviated
from standard methods
Figure 1. Source sampling report format,
D-13
-------
Figure 1. (continued)
Appendix
1. Complete results with example calculations
2. Raw field data (original, not computer printouts)
3. Laboratory report, with chain of custody
4. Raw production data, signed by plant official
5. Test log
6. Calibration procedures and results
7. Project participants and titles
8. Related correspondence
D-14
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VI. DATA SHEETS
A sample of all field data sheets to be used which do not con-
form to the data sheets presented.
VII. DESCRIPTION OF PROCESS OPERATION
A description of process operations to include as a minimum
the following, (if known):
General Process
1. Process flow sheet.
2. Maximum rated capacity - as specified by manufacturers and
actual normal maximum operation.
3. Data normally monitored to ensure proper operation.
4. Data to be monitored and recorded during testing to ensure
representative operation.
5. Normal process operation in a 24-hour period, i.e., oxygen
lancing, shutdown, start up, cyclic operations and other load
shifts or times of increased emissions.
6. Feedstock compositions that tend to cause greatest individual
gaseous and particulate emissions and the percent of annual
production attributed to these compositions. (Must be greater
than 5% of the annual average.)
7. Normal maintenance schedule for process.
Cpmbusti on Sourees
8. Type of combustion source, i.e., tangential fired pulverized
coal boiler.
9. Maximum rated capacity for each fuel fired - as specified by
manufacturers.
10. Actual normal maximum sustained capacity for past and antici-
pated future operations.
11. Data monitored and recorded to ensure proper operation of
process and control equipment.
D-15
-------
12. Boiler efficiency and/or average Btu's heat input to produce
each pound of steam if applicable.
13. Type of fuel feed monitors and their last calibration date.
14. Maximum sulfur and ash content of fuel that will not be
exceeded on a monthly average by more than 10 percent for all
future operations when divided by the Btu content of fuel.
rnnton4- - percent sulfur by weight _
content -
per pound Qr cubic foot Qf fuel
rnn4.on4. - _ percent ash by weight
content
foot of fuel
15. For incinerators the primary chamber minimum gas temperature
and secondary chamber or afterburner gas temperature and resi-
dence time.
16. Normal operating procedures in a 24-hour period, i.e., soot
blowing, bottom ash removal, hopper ash removal, peak load or
sustained operation and manual or automatic operation.
VII. DESCRIPTION OF EMISSION CONTROL OPERATION
A description of emission control system to include as a mini-
mum the following, (if known):
1. Types and manufacturers of all control equipment.
2. All means of primary and secondary control and their operations
during testing.
3. Data to be monitored and recorded to ensure representative
operation during testing.
4. Minimum acceptable values of all control device parameters,
i.e., flows and pressures of liquids, voltage and amperage
of electrical input (secondary and primary), pressure drops
across the control system and normal cleaning cycle.
5. Preconditioning of gases prior to control device.
6. Normal maintenance schedule on control equipment, i.e., clean-
ing of device, replacement of bags, replacement or addition of
catalyst, absorbing reagents or packing material, sealing of
leaks, and repair of damaged or worn parts.
D-16
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SLIDE 204-0 NOTES
ESTABLISHING TEST PROTOCOL
SLIDE 204-1
ADVANTAGES OF REQUESTING
TEST PROTOCOL
1. Ensures and expedites information exchange.
2. Provides maximum required information in a
standardized format.
3. Provides written plan of each phase of perfor-
mance test.
SLIDE 204-2
PERFORMANCE TEST GUIDELINES
INTRODUCTORY SECTION
Reviews regulations authorizing agency to
require performance tests.
PROCEDURES SECTION
Reviews agency administrative procedures.
D-17
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SLIDE 204-3 NOTES
PERFORMANCE TEST GUIDELINES
(cont)
PROTOCOL SECTION
(Specific Information)
1. source information
2. testing firm information
3. gas stream information
PROTOCOL SECTION
(Additional Information)
1. sample train information
2. analytical information
3. sample data sheets
4. process description
5. control equipment description
SLIDE 204-4
REPORTING REQUIREMENTS
Time allotted
Report format
Data validity certification
Round-off procedures
SLIDE 204-5
CONFIDENTIALITY OF DATA
THE OBSERVER SHOULD:
know all regulations, requirements and procedures.
inform the source of its rights.
Note: No emissions data is considered confidential.
SLIDE 204-6
FREEDOM OF INFORMATION
THE OBSERVER SHOULD:
know the regulations and requirements.
inform the source of liabilities.
D-19
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SECTION E. PLANT ENTRY AND PRETEST MEETING
Subject Page
1. The pretest meeting (taken from the Model Compliance Testing
Protocol Manual) E-3
2. Slides E-ll
E-l
-------
THE PRETEST MEETING
The following information contains a pretest meeting package, a pretest
agreement on continuing compliance package, and a pretest agreement on
facility operations package. The pretest meeting package consists of a pre-
test meeting checklist for recording pertinent information regarding the
plant, test team, and responsible agency representatives. A pretest plant
requirements and testing methodology form is also included for recording
additional quality assurance procedures, acceptability of sample site, and
necessary safety precautions. A pretest meeting ledger is included to docu-
ment attendance at the pretest meeting.
The pretest agreement on continuing compliance conditions package con-
tains a guide sheet for establishing process and control equipment operating
parameters during and after the compliance test. This package also contains
example allowable operating parameters for a power plant and an example data
sheet for recording operating parameters.
The pretest agreement on facility operation package contains a guide
sheet for establishing process parameters to be monitored and recorded, the
raw material to be processed during the test, and the feed rate and operating
cycle. Control equipment operation and maintenance are also covered by this
guide sheet.
E-3
-------
PRETEST MEETING CHECKLIST
Plant Name Date
Plant Address
Source to be Tested
Plant Representative Phone
Plant Manager Phone
Test Team Company Name
Team Representative Phone
Responsible Person Phone
Members of Title
Test Team
Agency(s)
Agency Representative Phone
Responsible Person , Phone
Agency Affi1i ati on
Observers and Tasks
E-4
-------
PRETEST MEETING PARTICIPANTS
Name Affiliation
E-5
-------
PRETEST PLANT REQUIREMENTS. AND TESTING METHODOLOGY
Plant Requirements;
Safety
Entrance
Other (Photo)
Sample Site
Acceptable
No. of Points reg'd.
Diagram in Protocol
Other
m
Sampling Methodology to be Used
Pollutant
Method
Remarks, Additional Quality Assurance, and/or Modifications
-------
PRETEST AGREEMENT OF CONTINUING COMPLIANCE CONDITIONS
Process
1) Process parameters that must be recorded and submitted to agency or
kept on file for later inspection
2) Percentage by which each process parameter can exceed the tested rate
and on what time weighted average
3) Future operating procedures
Control Equipment
4) Control equipment parameters that must be recorded and submitted to the
Agency or kept on file for later inspections
E-7
-------
5) Normal operating procedures
6) Normal maintenance schedule
7} Frequency of scheduled inspections by agency
Reviewed and approved by:
Date
Agency Faci 1 i ty
E-8
-------
PRETEST AGREEMENT ON FACILITY OPERATION
Process
1) Maximum process rate/capacity
2) Method of process weight or rate determination
3) Process parameters to be monitored and recorded, and their acceptable
limits to document process operation
4) Raw material feed and/or fuel acceptable analyzed values
5) Normal operating cycle or procedures
6) Portions of the operating cycle that will be represented by each run
E-9
-------
Control Equipment
7) Control equipment and effluent parameters to be monitored and recorded,
and their acceptable limits to document control equipment operations
8) Normal operating cycle (cleaning, dust removal etc.)
9) Normal maintenance schedule
10) Manner in which the control equipment will be operated
Reviewed and approved by:
Date
Agency Facility Tester
Was Facility provided agency checklists? yes no
Was Tester provided agency checklists? - yes ' no
Is any of the above information considered confidential?
If yes; was source notified to submit written justification for a confidential
classification on each item considered confidential
E-10
-------
SLIDE 205-0 NOTES
PLANT ENTRY AND
PRETEST MEETING
SLIDE 205-1
THE PRETEST MEETING
ATTENDEES
1. The Regulatory Agency
2. The Industry
3. The Test Consultant
SLIDE 205-2
PRETEST MEETING CHECKLIST
DESIGNATE RESPONSIBLE PERSONS
Plant Representative Phone _
Plant Manager Phone _
Test Team Company Name
Team Representative Phone
Responsible Person Phone.
Agency
Agency Representative Phone
Responsible Person Phone
E-ll
-------
SLIDE 205-3 NOTES
PRETEST PLANT REQUIREMENTS
AND TESTING METHODOLOGY
PLANT REQUIREMENTS
1. Safety
2. Entrance
3. Other
SAMPLING SITE
1. Acceptability
2. No. of points required
3. Diagram in protocol
SAMPLING METHODOLOGY
1. Pollutant
2. Method
3. Remarks, additional QA, modifications
SLIDE 205-4
PRETEST AGREEMENT ON FACILITY OPERATION
PROCESS
1. Maximum process rate
2. Method of process rate determination
3. Process parameters to be monitored and recorded
4. Acceptable composition of raw materials or fuel
5. Normal operating cycle
6. Portions of operating cycle to be included in each run.
E-13
-------
SLIDE 205-5 NOTES
PRETEST AGREEMENT ON FACILITY OPERATION
(cont)
CONTROL EQUIPMENT
1. Control equipment and effluent parameters to be
monitored and recorded
2. Normal operating cycle
3. Normal maintenance schedule
4. Control equipment operating procedure
REVIEW AND APPROVAL
1. Agency
2. Facility
3. Tester
SLIDE 205-6
PRETEST AGREEMENT OF
CONTINUING COMPLIANCE
PROCESS
1. Process parameters that must be submitted to the
agency or kept on file for inspection,
2. Percentage by which process operations can exceed
tested rate
3. Future operating procedures
CONTROL EQUIPMENT
1. Control equipment parameters that must be sub-
mitted to the agency or kept on file for inspection
2, Normal operating procedures
3. Normal maintenance schedule
4. Frequency of scheduled inspections
REVIEW AND APPROVAL
1. Agency
2. Facility
E-15
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SECTION F. OBSERVING THE TEST
Subject page
1. Observer's checklist package for EPA reference test methods and
continuous emission monitor certification (June, 1980) F-3
2. Observer's methods checklist (taken from Vol. Ill, QA Handbook) F-53
3. Slides .. ,,
r-bo
F-l
-------
INTRODUCTION
This package contains example checklists and data sheets
which can be used during observation of EPA reference method
tests and continuous emission monitor certification programs.
Contents of the package are divided into three sections. Section
I, Pretest Activities, contains the necessary forms to review the
protocol package and conduct the pretest meeting. The protocol
review form can be used as a worksheet to note testing related
topics to be discussed during the pretest meeting. The con-
tinuous emission monitor certification pretest checklist can be
used to plan the continuous monitor certification test program.
Facility operating parameters during the test and conditions of
continuing compliance should be discussed and agreed upon during
the pretest meeting. Data sheets are included for documenting
these parameters.
Section II, On-site Activities, contains field observation
checklists, control equipment operation forms, and a process data
form. The field observation checklists consist of a checklist
for sample site evaluation and checklists for EPA reference
Methods 1 through 8. These checklists can be used by the agency
observer to assist in evaluating the on-site performance of the
test team. Continuous emission monitor certification field
checklists are also included in this section and consists of a
F-3
-------
checklist for each continuous monitor performance specification
test.
The process data sheet is a multipurpose sheet for monitoring
process parameters during the test. This sheet should be modi-
fied as needed to suit each specific case. The control equip-
ment operation forms include examples of an electrostatic pre-
cipitator data sheet, a particulate scrubber data sheet, a fabric
filter data sheet/ and a centrifugal collector data sheet. These
forms are designed for recording the necessary control equipment
operating parameters during the compliance test.
Section III, Post-test Activities, contains an observer's
summary form and a source test report review form. The observer's
summary form is used to evaluate and summarize the source test
program. Any notable occurences for the process, control equip-
ment or source test should be documented on this form. The
source test report review form is used in evaluating the source
test report for completeness and accuracy.
F-4
-------
SECTION I
PRETEST ACTIVITIES
F-5
-------
Page of
PROTOCOL REVIEW FORM
Plant Source I.D. No.
Reviewer Date
I Source Information
Was information complete? If no; when will it be completed?
II Testing Firm Information
Was information complete? If no; when will it be completed?
Ill Gas Stream Information
Was information complete and acceptable? If no; list problem
When will it be corrected?
IV Sampling Train Information
Was a modification requested? If yes; give details of the
acceptance or rejection of the modification
V Laboratory Analysis
Was a modification requested? If yes; give details of the
acceptance or rejection of the modification
VI Data Sheets
Were alternative data sheets requested: If yes; list sheets
that were acceptable and nonacceptable and the reason for rejection
F-6
-------
Page of
VII Description of Process Operation
Was information complete and acceptable? If no; when will
data be completed?
List additional information requirements ^
VIII Description of Emission Control Operation
Was information complete and acceptable? If no: when will
data be completed?
List additional information requirements
F-7
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Page
of
PRETEST MEETING CHECKLIST
Plant name
Plant address
Source to be tested
Plant representative
Plant manager
Test team company name
Team representative
Responsible person
Members of
test team
Agency(s)
Agency representative
Responsible person
Agency
observers
Title
Date
Phone
Phone
Phone
Phone
Phone
Phone
Affiliation
and tasks
F-8
-------
PRETEST MEETING PARTICIPANTS
Name Affiliation
F-9
-------
PRETEST PLANT REQUIREMENTS AND TESTING METHODOLOGY
Plant Requirements:
Safety
Entrance
Other (Photo)
Sample Site
Acceptable
No. of points req'd.
Diagram in protocol
Other
Sampling Methodology to be Used
Pollutant
Method
Remarks, additional quality assurance, and/or modifications
-------
Page of
CONTINUOUS EMISSION MONITOR CERTIFICATION
PRE-TEST CHECKLIST
Plant Date
Address Unit
Process Description
I System Description
Monitor manufacturer
Model No. Serial No.
Type system extractive in-situ optical pathlength
If extractive, is samole conditioning system used?
Describe sample conditiong system
Pollutant(s) monitored
Type data tabulation system
Manufactured by
System span value Percent zero offset
Daily zero method
II Monitor Site and Orientation
Location of monitoring site (ie. before or after ESP, FGD, etc.)
Was monitor location stratified ? If not, how was non-strati-
fication determined
F-ll
-------
Page of
If stratified, what justification is used to accept this site as repre-
sentative
Cross-sectional dimensions of stack/duct at monitoring location ft;
shape
Is the monitor pathlength oriented in the plane of the nearest upstream
bend
Note: Include sketch of monitor location, including distances
to nearest upstream and downstream disturbances.
Ill Calibration Information
Type calibration system
Specify certified values for calibration sources
Does values of calibration source(s) meet requirements of the applicable
regulation? yes no
Are calibration sources traceable to NBS-SRM? yes no
If pressurized calibration gases are used, list gases and describe cali-
bration gas sampling and analysis methods
F-12
-------
Page of
Name and address of vendor(s) for gases listed above
Date gas cylinders will be certified
By whom
IV Performance Specification Test
List each performance specification test to be performed
Instrument Test
Operational test period start
Proposed test date
Reference method or test procedure to be used
List any modifications or soecial conditions to test procedures
Other information
F-13
-------
Page of
PRETEST AGREEMENT ON FACILITY OPERATION
Process
1) Maximum process rate/capacity
2) Method of process weight or rate determination
3) Process parameters to be monitored and recorded, and their acceptable
limits to document process operation
4) Raw material feed and/or fuel acceptable analyzed values
5) Normal operating cycle or procedures
6) Portions of the operating cycle that will be represented by each run
F-14
-------
Page of
Control Equipment
7) Control equipment and effluent parameters to be monitored and recorded,
and their acceptable limits to document control equipment operations
8) Normal operating cycle (cleaning, dust removal etc.)
9) Normal maintenance schedule
10) Manner in which the control equipment will be operated
Reviewed and approved by:
Date
Agency Facility Tester
Was Facility provided agency checklists? yes no
Was Tester provided agency checklists? yes no
Is any of the above information considered confidential?
If yes; was source notified to submit written justification for a confidential
classification on each item considered confidential
F-15
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Page of
PRETEST AGREEMENT OF CONTINUING COMPLIANCE CONDITIONS
Process
1) Process parameters that must be recorded and submitted to agency or
kept on file for later inspection
2) Percentage by which each process parameter can exceed the tested rate
and on what time weighted average
3) Future operating procedures
Control Equipment
4) Control equipment parameters that must be recorded and submitted to the
Agency or kept on file for later inspections
F-16
-------
5) Normal operating procedures
6) Normal maintenance schedule
7) Frequency of scheduled inspections by agency
Reviewed and approved by:
Date
Agency Facility
F-17
Page of
-------
SECTION II
ONSITE ACTIVITIES
F-18
-------
Page
of
FIELD OBSERVATION CHECKLIST
Plant
Observer
Run no.
Date
General Sampling Site
Stack/duct cross-section dimensions:
Material of construction
Internal appearance - Corroded
Insulation? Thickness
Nipple
I.D.
Straight run before ports
Straight run after ports
Drawing of sampling location:
Length
Equivalent dia.
Corroded Leaks
Caked part.
Lining
Thickness
Thichness
Flush w/inside wall
Cross-sectional dia.
Cross-sectional dia.
Minimum information required on drawing: stack/duct dimension, location and
description of major and minor disturbances, cross-sectional view showing
dimensions and port locations.
F-19
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Page of
METHOD 1 - SAMPLE AND VELOCITY TRAVERSE
Preliminary Procedural Checklist
Plant Run no.
Observer Date
Stack/duct type (e.g. circular, rectangular)
Stack/duct cross-sectional dimensions
Equivalent diameter (rectangular duct)
Nipple type (e.g. flush w/stack wall)
Nipple length I.D.
Distance from sampling site to nearest upstream disturbance
Number of stack diameters
Distance from sampling site to nearest downstream disturbance
Number of stack diameters
Number of sampling points per traverse from Federal Register
Number of sampling points to be used
Circular Stacks
Are traverse points located on two diameters?
Is the distance from the first traverse point to stack wall <1.0 in.?
Are there any modifications due to size of stack?
Verification of absence of cyclonic flow?
Rectangular Stacks
Grid configuration No. of traverse pts. ^_
Traverse points located at centroid of areas?
F-20
-------
Page
of
Plant
Observer
METHOD 2 - STACK GAS VELOCITY AND VOLUMETRIC FLOW RATE
Preliminary Procedural Checklist
Run no.
Date
Sampling train schematic drawing:
Modification to standard method
Verification of absence of cyclonic flow?
Type "S" pitot tube? Other
Const, mat'l.
Pitot tube connected to: Inclined manometer
Range Approx. scale length t
Pitot tube coefficient
Temperature gauge
or Magnehelic gauge
Divisions
Fluid type
Type
Attached to pitot tube?
Recent calibration of orifice meter - dry- gas meter? Pitot tubes?
Nozzles
Thermometers or thermocouples?
Magnehelic gauges?
Number of sampling points per traverse from Federal Register
Number of sampling points to be used
Length of sampling time per point desired
Time to be used
F-21
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Page
of
Plant
Observer
METHOD 3 - GAS ANALYSIS AND DRY MOLECULAR WEIGHT
Preliminary Procedural Checklist
Run no.
Date
Sampling .train schematic drawing:
Modifications to standard method
Method; Single point grab
Multi-point integrated
Probe type: Stainless steel
Single point integrated
Borosilicate glass.
Is there a filter used to remove particulate matter?
Type
Diaphragm
Type
Pump type: One-way squeeze
Is a condenser system used?
Flexible bag: Tedlar
Other
Mylar
Teflon
Other
Is a pressure gauge used?
Type
Are all connections tight and leak free?
Was sampling train leak checked?
Was sampling rate held constant?
(optional)
F-22
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Page 1 of 2
METHOD 4 - MOISTURE CONTENT
Preliminary Procedural Checklist
Plant
Observer
Run no.
Date
Procedure used: Reference
Reference Method
Approximate
Conducted simultaneously with pollutant emission test?
Apparatus
Probe: Stainless steel
Glass tubing
Heated to prevent water condensation?
Filter: In-stack Heated out-of-stack
Condenser
Description
Modifications
Impingers properly placed?
Impinger content: 1st
4th
Other
2nd
3rd
Modifications
Cooling system: Crushed ice
Metering system: Vacuum gauge
Dry gas meter
Modifications
Other
Pump
Thermometers
Barometer
Mercury
Aneroid
Other
Measurement Equipment
Graduated cylinder
Balance
F-23
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Page 2_ of 2
METHOD 4 (continued)
Procedure
Sampling time per point
Probe heater (if applicable) on? Temp.
Crushed ice in ice bath?
Leak-check? (optional) Leakage-rate
Sampling rate constant (within 10%)
All data properly recorded?
Post-test leak-check? (mandatory)
Leakage rate
Analysis - Impinger content
Method: Volumetric Gravimetric
Measurement of volume of water condensed: Graduated cylinder
Other
Measurement of silica gel: Balance Other
Color of silica gel? Condition
All analytical data properly recorded?
F-24
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Page 1 of 5
METHOD 5 - PARTICULATE EMISSIONS
Preliminary Procedural Checklist
Plant Run no.
Observer Date
Sampling train schematic drawing:
Apparatus
Probe nozzle: Stainless steel Glass
Design: Button-hook Elbow _Nozzle size
Clean?
Probe liner: Borosilicate Quartz Other
Clean? Heating system
Pi tot tube: Type S Other Properly attached to
probe? Modifications
Pi tot tube coefficient
Differential pressure gauge: 2 inclined manometers Other
Filter holder: Borosilicate glass Glass frit
Filter support Silicone Gasket
Other Clean?
F-25
-------
Page 2 of 5
METHOD 5 (continued)
Filter Heating System
Description
Condenser: Number of impingers Clean?
Contents: 1st 2nd 3rd 4th
Cooling system
Proper connections?
Modifications
Barometer: Mercury Aneroid Other
Gas density determination: Temp, sensors type
Pressure gauge Temp, sensor attached to probe?
Other
Procedure
Recent calibration: Pi tot tubes
Meter box Thermometers/thermocouples
Filter checked visually for irregularities?
Filters properly labeled? ;
Sampling site selected? Stack temp.
Average velocity head?
Pre-test leak check? (optional) Leakage?
Stack gas dry molecular weight?
Nozzle size properly selected?
Selection of sampling time?
All openings to sampling train plugged to prevent pre-test contamin-
ation?
Impingers properly assembled?
Filter properly centered?
F-26
-------
Page 3 of 5
METHOD 5 (continued)
Procedure (continued)
Type probe-liner: Glass Stainless steel Other
Silicon grease added to all ground glass joints?
Pitot tube lines checked for plugging or leaks?
Meter box leveled? Periodically?
Manometers zeroed?
Probe heat uniform along length of probe?
AH@ from most recent calibration -
Nomograph set-up properly?
Care taken to avoid scrapping nipple or stack wall?
Effective seal made around probe while in-stack?
Probe moved at proper time?
Nozzle and pitot tube parallel to stack wall at all times?
Filter changed during run?
Any particulate lost?
Data sheets complete and data properly recorded?
Nomograph setting changed when stack temp, changes significantly?
Velocity pressures and orifice pressure readings recorded accurately?
Post-test leak check performed? (Mandatory)
Leakage rate @ in. Hg.
Orsat analysis from stack Integrated
Fyrite combustion analysis Sample location
Bag system leak-checked?
F-27
-------
Page 4 of 5
METHOD 5 (continued)
Procedure (continued)
If data sheets cannot be copied, record:
Approximate stack temp. , Volume metered
First 8 AP readings:
Percent isokinetic calculated at end of each run?
Sample Recovery
Brushes: Nylon Bristle Other Clean?
Wash bottles: Glass Clean?
Storage containers: Borosilicate glass Other
Clean? Leak-free?
Petri-dishes: Glass Polyethylene
Other Clean?
Graduated cylinder/or balance: Subdivisions <2 ml? Other
Balance: Type
Plastic storage containers: Air-tight? Clean?
Probe allowed to cool sufficiently?
Cap placed over nozzle tip to prevent loss of particulate?
During sampling train disassembly: Are all openings capped?
;
Clean-up area: Description
Clean? Protected from wind?
Filters: Glass fiber Type
Silica gel: type (6 to 16 mesh)? New Used
Filter handling: Tweezers used?
Surgical gloves? Other
Any particulate spilled?
F-28
-------
Page 2 of 2
METHOD 6 (continued)
Procedure (continued)
Impinger contents: 1st: 15 ml of 80% isopropanol
2nd: 15 ml 3% H202 3rd: 15 ml 3% H202
Final impinger dry?
Probe heat at proper level?
Crushed ice around impingers?
Pre-test leak check at 10 in. Hg?
Leakage rate
Probe placed at proper sampling point?
Flow rate constant at approximately 1.0 liter/min.? (+_ 10%)
Data recorded at least every 5 minutes?
Post-test leak check at 10 in. Hg?
Leakage rate
Sample Recovery
System purged at least 15 minutes at test sampling rate?
Contents of impingers placed in polyethylene bottles?
Glassware rinsed with distilled water?
Liquid level marked?
Sample containers sealed and identified?
F-31
-------
Page _J of 2
METHOD 7 - DETERMINATION OF NITROGEN OXIDE EMISSIONS
Preliminary Procedural Checklist
Plant Run no.
Observer Date
Sampling train schematic diagram:
Apparatus
Probe: Borosilicate glass Other
Heated to prevent water condensation?
Filter: In-stack Out-of-stack
Collection flas.k: Capacity at least 2 liters?
Round bottom? Other
Flask valve: t-bore stopcock?
Temperature gauge: Dial Other
Vacuum line: Able to withstand 3 in. Hg vacuum?
Vacuum gauge: U-tube manometer
Divisions at least 0.1 in.?
Pump type? ,
Squeeze bulb: One-way Other
Barometer: Mercury Other
F-32
-------
Page 2 of 2
METHOD 7 (continued)
Reagents
Absorbing solution type?
Sampling
25 ml of absorbing solution placed in flask?
Flask valve stopper in purge position?
Sampling train properly assembled? Leak free?
Stopcock grease used? Type
Flask evacuated to 3 in. Hg pressure?
Leakage from manometer observation?
(e.g.) change in manometer of <_0.4 in. Hg/minute)
Initial volume of flask recorded?
Initial temperature of flask recorded?
Probe purged before sampling?
Sample collected properly?
Flask shaken for 5 minutes after collection and disassembly from train?
Oxygen introduced to flask? -Method used? _
Samples properly labeled, sealed, and stored for shipment?
F-33
-------
Page 1 of
METHOD 8 - SULFURIC ACID MIST AND SULFUR DIOXIDE EMISSIONS
Preliminary Procedural Checklist
Plant Run no.
Observer ' Date
Sampling train schematic diagram:
Apparatus
Probe nozzle: Stainless steel Glass
Design: Button-hook Elbow Nozzle size
Clean?
Probe liner: Borosilicate Quartz Clean?
Heating system
Pi tot tube: Type S Other
Properly attached to probe?
Modifications
Pitot tube coefficient
Differential pressure gauge: 2 inclined manometers
Other
Filter holder: Borosilicate glass . Glass frit
Filter support Silicone Gasket Other
Clean?
F-34
-------
Page 2 of 5
METHOD 8 (continued)
Apparatus (continued)
Filter heating system: (not used unless sampling for filterable
particulate matter)
Description
Condenser: Number of impingers Clean?
Contents: 1st* 2nd 3rd* 4th
Cooling system
Proper connections?
Modifications
Barometer: Mercury Aneroid Other
Gas density determination: Temp, sensor type
Pressure gauge
Temp, sensor attached to probe?
Other
Procedure
Recent calibration: Pitot tubes
Meter box Thermometers/thermocouples
Filter checked visually for irregularities?
Filters properly labeled?
Sampling site selected? Stack temp.?
Velocity head?
Pre-test leak check? (optional) Leakage?
Stack gas dry molecular weight?
Nozzle size properly selected?
Selection of sampling time?
*
Shall be Greenburg-Smith impingers with standard tips.
F-3b
-------
Page 3 Of
METHOD 8 (continued)
Procedure (continued)
All openings to sampling train plugged to prevent pre-test contamination?
Impingers properly assembled?
Filter properly centered?
Silicone grease added to all ground glass joints?
Pi tot tube lines checked for plugging and leaks?
Meter box leveled? . Periodically?
Manometers zeroed?
Probe heat uniform along length of probe?
AH@ from most recent calibration
Nomograph set-up properly?
Care taken to avoid scrapping nipple or stack wall?
Effective seal made around probe when in-stack?
Probe moved at proper time?
Nozzle & pi tot tube parallel to stack wall at all times?
Filter changed during run?
Any particulate lost?
Data sheets complete and data properly recorded?
Nomograph setting changed when stack temperature changes significantly?
Velocity pressure and orifice pressure readings recorded accurately?
Post-test leak check performed? (Mandatory)
Leakage rate @ in. Hg .
Orsat analysis from stack Integrated_
Fyrite combustion analysis Sample location
F-36
-------
Page 4 of 5
METHOD 8 (continued)
Procedure (continued)
Bag system leak-checked?
If data sheets cannot be copied, record:
Approximate stack temp. , Volume metered
First 8 AP readings:
Percent isokinetic calculated at end of each run?
Sample Recovery - Sulfuric Acid and Sulfur Dioxide
System purged at least 15 minutes at test sampling rate?
Contents of impingers placed in polyethylene bottles?
Glassware rinsed with distilled water? ' .
Liquid level marked?
Sample containers sealed and identified?
Sample Recovery - Particulate
Brushes: Nylon bristle Clean"? Other
Wash bottles: Glass Clean?
Storage containers: Borosilicate glass Other
Clean? Leak-free?
Petri-dishes: Glass Polyethylene
Other Clean?
Graduated cylinder/or balance:
Subdivisions <2 ml? Other
Balance: Type
Plastic storage containers:
Air-tight? Clean?
Probe allowed to cool sufficiently?
Cap placed over nozzle tip to prevent loss of particulate?
F-37
-------
Page
METHOD 8 (continued)
Sample Recovery (continued)
During sampling train disassembly: Are all openings capped?
Clean-up area: Description
Clean?
Filters: Glass fiber
Protected from wind?
______ Type
Silica gel: Type (6 to 16 mesh)?
New Used
Filter handling: Tweezers used?
Surgical gloves?
Other
Any particulate spilled?
Water: Distilled?
Stopcock grease: Acetone-insoluble?
Heat-stable silicone?
Other
Probe handling: Acetone rinse
Distilled water rinse ______
Isopropanol rinse
Particulate recovered from: Probe nozzle
Probe fitting Probe liner
Front half of filter holder
Blank: Acetone
Distilled water
Any visible particles on filter holder or inside probe?
Color of silica gel? -
Method of silica gel transfer?
All jars adequately labeled? _
Jars sealed tightly
Jars locked up?
Condition
Liquied level marked on jars?
F-38
-------
Page of
CONTINUOUS EMISSION MONITOR CERTIFICATION
OPACITY MONITOR FIELD CHECKLIST - PST 1
Plant Date
Address Unit
I. Optical Design Specifications
Were optical design specification tests performed on site, or was the
manufacturer's certification used?
Was peak spectral response between 500 and 600 nm?
actual value
Was response at wavelengths below 400 nm and above 700 nm less then 10
percent of peak response?
Was the mean spectral response between 500 and 600 nm?
actual value
Was the angle of view no greater than 5 degrees? actual
value
Was the angle of projection no greater than 5 degrees?
actual value
Did the vendor supply a spectral response curve to the facility for this
instrument?
II Calibration Error Tests Date
Filter type Path length used (if applicable)
Range Filter ID Optical density Opacity
Low
Mid
High
How many nonconsecutive readings were taken for each filter?
How was data tabulated?
F-39
-------
Page of
III Response Time Date
Value of high-range point Path length used (if applicable) _
How many upscale/downscale readings were taken?
How was the zero point computed?
IV 24 Hour Zero and Calibration Drift Tests
Date tests started Zero offset
How many drift tests were completed?
Were initial 24-hour readings taken after system was calibrated?
Was zero reading taken before cleaning and adjustment?
Were all drift readings taken at 24-hour intervals?
Were all subsequent 24-hour adjustments set to the same value as the
initial setting? If not, were any other manual adjustments made
at any time during the 168 h operational test period? If
adjustments were made, were they made only at 24 hour intervals?
If not, explain
Were zero adjustments made after the zero reading was taken, but before
the span reading?
Were span readings taken after cleaning and zero adjustments, but prior
to span adjustment?
Was automatic zero compensation used?
F-40
-------
Page of
Did automatic zero compensation exceed 4 percent? If so,
Explain procedures that followed ^
How many calibration drift tests were observed by agency personnel?
V Other
What is the equivalent diameter of the stack/duct at the exit?
Is the opacity value read at the monitoring site corrected for stack
exit equivalent diameter?
Name and affiliation of person conducting tests
Name of agency observer
F-41
-------
Page of
CONTINUOUS EMISSION MONITOR CERTIFICATION
S0?/N0 MONITOR FIELD CHECKLIST - PST 2
C- .A
Plant
Address
Date
Unit
Type monitor
I Calibration Error Tests
Will calibration error test be performed using calibration gases or cali
bration gas cells? -
Were triplicate reference method tests performed on each gas mixture
within 2 weeks of certification tests
Was each reference method test within 20 percent of the average results?
If calibration gas cells are used, how were the cells certified?
How many nonconsecutive readings were taken?
How was data tabulated?
II Response Time Date
Value of high-range point path length used (if applicable)
How many upscale/downscale readings were taken?
For extractive monitors, are gases introduced at the sample system inter-
face or as close to the sampling interface as possible?
If not explain
F-42
-------
Page of
III 2-Hour and 24-Hour Zero and Calibration Drift Tests
Date test started Zero offset
How many 2 h drift tests were completed?
How many 24 h drift tests were completed?
Were initial 24-hour readings taken after the system was calibrated?
Were zero readings taken before cleaning and adjustments?
Were all drift readings taken at the proper intervals?
Were all subsequent 24-hour adjustments set to the same value as the
initial setting? If not, were any other manual adjust-
ments made at any time during the 163 h operational test period?
If adjustments were made, were they made only at 24-hour intervals?
If not, explain
Were zero adjustments made after the zero reading was taken, but before
the span reading?
Were span readings taken after cleaning and zero adjustments, but prior
to span adjustment?
Was automatic zero compensation used?
Did automatic zero compensation exceed 4 percent? If so,
explain procedures that followed
Were all 2-hour drift readings taken without making adjustments after the
readings?
What visual output was used to obtain data from these drift tests?
F-43
-------
Page of
How many zero and calibration drift tests were.observed by agency per-
sonnel?
Explain any abnormalities about procedures or data
IV Field Test for Accuracy
If monitor system employs extractive sampling, is the probe tip for the
monitoring system and the probe tip for the reference method sampling
train located adjacent to each other in the stack?
If adjacent probe locations are impractical, attach sketch showing loca-
tion of each probe tip. Describe any suspected bias that could result
from having probes located in this arrangement
Was only 1 NOX test, consisting of three individual measurements, per-
formed in any 1 hour?
Were- individual measurements performed concurrently or within a 3 min.
period? .
Were a minimum of 9 NO tests run (27 individual measurements)?
Were a minimum of 9 SOp measurements made using the applicable reference
method?
Was more than 1 SO? measurement performed in any one hour?
Note: Use the applicable reference method checklist to check important
parameters during sampling.
F-44
-------
Name and affiliation of persons conducting tests,
Notes:
Name of agency observer
F-45
-------
Page Of
CONTINUOUS EMISSION MONITOR CERTIFICATION
C02/02 MONITOR FIELD CHECKLIST - PST 3
Plant Date
Address Unit
Type monitor
I Response Time
Value of high-range point
Path!ength used (if applicable)
How many upscale/downscale readings were taken?
For extractive monitors, are calibration gases introduced at the sample
system interface or as close to the sampling interface as possible?
If not, explain
II 2 Hour and 24 Hour Zero and Calibration Drift Tests
Date test started Zero offset
How many 2 h drift tests were completed?
How many 24 h drift tests were completed?
Were initial 24-hour readings taken after the system was calibrated?
Were zero readings taken before cleaning and adjustments?
Were all drift readings taken at the proper intervals?
Were all subsequent 24-h adjustments set to the same value as the initial
setting? If not, were any other manual adjustments made at
any time during the 168 h operational test period?
If adjustments were made, were they made only at 24-h intervals?
If not, explain
F-46
-------
Page of
II 2 Hour and 24 Hour Zero and Calibration Drift Tests (continued)
Were zero adjustments made after the zero reading was taken, but before
the span reading?
Were span readings taken after cleaning and zero adjustments, but prior
to span adjustment?
Was automatic zero compensation used?
Did automatic zero compensation exceed 4 percent? If so,
explain procedures that followed
Were all 2-hour drift readings taken without making adjustments after
the readings?
What visual output was used to obtain data from these drift tests?
How many zero and calibration drift tests were observed by agency per-
sonnel?
Explain any abnormalities about procedures or data
F-47
-------
PROCESS DATA DURING TEST
O
00
Unit
Run No.
Date
Parameter
Units
Data recording interval
Test start time
Recorded by
;
End
Time
Notes:
-------
FABRIC FILTER DATA SHEET - PARAMETERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE
Facility.
Monitor Name.
Boiler No..
.Test No. _
Design Efficiency.
.Test Date.
Recording; Interval3
Sampling Time
(minutes)
Clock Time
(24 hr. clock)
Representative
Design
Pressure Drop
Across
Baghousr
(in. H20)
Pressure Drop
Across
Compartment
(in. H2O)
1
o
3
*
4
:>
Temperature range of filter fabric
Fan damper position
Fan current (amps)
Cleaning cycle
Total no. of bags in operation
Design/Normal
During Test (flue gas temp.)
b
no.
no.
yes.
yes.
, number.
, number.
Are any bags blanked off?b
Are any bags leaking?
'Recording intervals 10 minutes. If a compartment is isolated sequentially for cleaning
throughout the test timing mechanisms, data readings should be synchronized with cleaning
cycle.
^This information is generally not available. It can be obtained during boiler shut-down prior
to or after testing; however, for many constant demand-type boilers, this is not possible.
F-49
-------
ELECTROSTATIC PRECIPITATOR DATA SHEET - PARAMETERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE
Facility
Recorded by
Design Efficiency
Boiler No.
Test No.
Test Date
Recording interval3
Sampling Time
(minutes)
-
Clock time
(24 hr. clock)
t
Representative
design
Operating voltage (kV)
Field number
1
2
3
4
Operating current (mA)
Field number
1
2
3
4
Soark-
Rate
(Sparks/
minute)
Rapper timing/sequence:
Hopper dust removal sequence:
Representative
During Test:_
Representative
During Test:
Recording intervals - 15-30 minutes.
F-50
-------
PARTICIPATE SCRUBBER DATA SHEET - PARAMETERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE
Facility.
Monitor Name.
Boiler No.
Test No. _
Design Efficiency.
.Test Date.
Recording Interval3
Sampling Time
(minutes)
0
Clock Time
(24 hr. clock)
Static Pressure
(in. H20)b
Inlet
Outlet
Representative
Design
Pressure Drop
Across Scrubber
(in. H20)
Water
Flow
Rate
(gl'm)
aRecording intervals 15-30 minutes.
blf direct reading of pressure drop is not available.
F-51
-------
CENTRIFUGAL COLLECTOR DATA SHEET - P A K A -METERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE'
Facility.
Monitor Name.
lloilcr \o..
Test No._
Design Efficiency
, Test Dale
Pressure drop across
collector, in. II-jO
Fan motor amperes
Design
During lest
beginning
Mid-Point
Knd
Is the collector scctionali/.cd with dumpers for control of Ap
No Yes
If yes. how were dampers positioned during test?.
Hopper ash removal sequence"
Representative _____^__
During test
F-52
-------
OBSERVER'S METHODS CHECKLISTS
(taken from Volume III, Quality Assurance Handbook)
F-53
-------
Revision No. 0
Date January 15, 1980
Page 10 of 12
METHOD 2
Sampling
Pitot tube, lines, and manometer assembled correctly?*
Pitot tube and components mounted in an interference free man-
ner?*
Differential pressure gauge has correct sensitivity?*
Differential pressure gauge leveled and zeroed?*
Pretest leak check?
(optional) Cyclonic flow checked? csf*s
Pitot tube parallel to stack walls?*
Static pressure measured? u£S Temperature measured?
Moisture content determined?
Orsat samples taken?
Method
If no explain:
Posttest leak check performed?*
Data recorded properly?
C/£S
(mandatory)
*Most significant items/parameters to be checked.
Figure 4.2 On- site measurements checklist.
F-54
-------
Section No. 3.2.4
Revision No. 0
Date January 15, 1980
Page 2 of 12
METHOD 3
Sampling ,
Method: single-point grab \S single-point integrated
multipoint integrated __ _
Is, a filter used to remove particulate matter?
* Sampling train leak checked? _ . .^»
*0rsat analyzer leak checked?
All connections tight and leak free?
Sampling port properly sealed?
Sampling rate held constant? \y
Sampling train purged?
Analysis
Molecular Weight Determination
Analyzer: Orsat S Fyrite Other
Fyrite:
Reagent at proper level and zeroed?*
Leak-free connection between analyzer and sample line?
Sampling line purged?*
Orsat:
Reagents at proper level?*
Analyzer level?
Leak checked?*
Sample analyzed within 8 h?*
Sample lines purged?*
Excess Air-Emission Rate Correction rO/ R-
Orsat analyzer leak checked?* Before After
Reagents at proper level?*
Sampling lines purged?*
Analysis repeated by drawing a new sample until the following
criteria are met?
CO,, - any three analyses differ by
2 a) £0.3% when CO- >4.0%
b) <0.2% when CO* £4.0%
any three analyses differ by
a) £0.3% when O9 <15.0%
b) £0.2% when O^ >_15.0%
CO - any three analyses differ by £0.3%
All readings averaged and reported to nearest 0.1%
*Most significant items/parameters to be checked.
Figure 4.1 On-site measurement checklist.
F-55
-------
Section No. 3.3.4
Revision No. 0
Date January 15, 1980
Page 2 of 10
METHOD 4
Procedure used: Reference \s Approximate
Reference Method
Conducted simultaneously with pollutant emission test?
Impingers properly placed?*
Impinger content: 1st /ot*iJ tf^O 2nd /*0/n/ O 3rd
4th loo* S*'/t'c44£/ Modifications
i^~
Cooling System; Crushed ice \S_ Other
Sampling time per point
Probe heater (if applicable) on? eqtgs Temp
Crushed ice in ice bath?
Leak check? (optional) _ ^^ Leakage rate O. O
Sampling rate constant (within 10%)?*
All data properly recorded?* _
Posttest leak check?* (mandatory)
Leakage rate* _ Q. O
Analysis - Impinger Content
Method: Volumetric _ \/ Gravimetric
Measurement of volume of water condensed:
Graduated cylinder _ (Aids _ Other
Measurement of silica gel: Balance \/ Other
Color of silica gel? jb£njt. . Condition
All analytical data properly recorded?
*Most significant items/parameters to be checked.
Figure 4.1 On-site measurement checklist
F-56
-------
Section No. 3.4.4
Revision No. 0
Date January 15, 3
Page 15 of 19
METHOD 5
Apparatus
Probe nozzle: stainless steel ^ glass
Button-hook jX elbow size
Clean?
Probe liner: borosilicate ^ quartz other
Clean?
Heating system*
Checked?
Pitot tube: Type S ^ other
Properly attached to probe?*
Modi fi c ati ons
Pitot tube coefficient
_ _ _
Differential pressure gauge; two inclined manometers
other _ _ sensitivity Q.QI - O
_ _ ^
Filter holder: borosilicate glass tx" _ glass frit
filter support _ silicone gasket _ other
Clean?
^
Condenser : number of impingers
Clean?
Contents 1st toon! HjQ 2nd 100 ml H±Q 3rd 4th Silita _ael
Cooling system
Proper connections?
Modifications
Barometer: mercury _ aneroid \^ other
_ _
Gas density determination : temperature sensor type />? er/no a.
pressure gauge t£Oi*/. - U--fube.
temperature sensor properly attached to probe?*
Procedure
Recent calibration: pi tot tubes* yX (/rme.r*sioNal O.hc.e.k.
meter box* tX^ thermometers/thermocouples*
Filters checked visually for irregularities?*
Filters properly labeled?* ues
Sampling site properly selected? t^cs ~
Nozzle size properly selected?*
Selection of sampling time?
All openings to sampling train plugged to prevent pretest con-
tamination? ^es
Impingers properly assembled? ues
Filter properly centered? . L,&s
Pitot tube lines checked for plugging or leaks?*ues
Meter box leveled? aes Periodically?
Manometers zeroed? ^e.
Figure 4.5 On-site measurements.
(continued)
F-57
-------
Section No. 3.4.4
Revision No. 0
Date January 15, 1980
Page 16 of 19
METHOD 5
Figure 4.5 (continued)
AH@ from most recent calibration
Nomograph setup properly?
Care taken to avoid scraping nipple or stack wall?*
Effective seal around probe when in-stack? fas
Probe moved at proper time? fas
Nozzle and pitot tube parallel to stack wall at all times?*
Filter changed during run?
Any particulate lost?
No
Data forms complete and data properly recorded?*
Nomograph setting changed when stack temp changed significantly?
Velocity pressure and orifice pressure readings recorded
accurately?*
Posttest leak check performed?*
Leakage rate o. £>/
(mandatory)
Or sat analysis
from stack
@ in. Hg
integrated
sample location
Fyrite combustion analysis
Bag system leakchecked?*
If data forms cannot be copied, record:
approximate stack temp 317 F volume metered
% isokinetic calculated at end of each run
S/ -f-t3
SAMPLE RECOVERY
Brushes:
Clean?
Wash bottles:
Clean?
nylon bristle
other
glass
Storage containers:
Clean?
borosilicate glass
other
Petri dishes: glass
Clean? Yes
_ Leakfree?
polyethylene
other
Graduated cylinder/or balance:
other
subdivisions <2.ml?*
Yes
Balance: type j-r/'a/e. k>e.drr\
Plastic storage containers:
Clean?
airtight?
Y&s.
Probe allowed to cool sufficiently?
Cap placed over nozzle tip to prevent loss of particulate?*
__, VJ5S . ,
During sampling train disassembly,are a^.1 openings capped?
Clean-up area description: Pouter J^/aN'f JLah
Clean? fes Protected from wind?
Filters:
Ves
type
glass fiber
Silica gel: type (6 to 16 mesh)? new?
Color? hlue. Condition?
EH
used?
#
(continued)
F-58
-------
Section No. 3.4.4
Revision No. 0
Date January 15, 1C?3
Page 17 of 19
METHOD 5
Figure 4.5 (continued)
Filter handling: tweezers used?
surgical gloves? other
Any particulate spilled?*
Water distilled?
Stopcock grease: acetone-insoluble?
heat-stable silicone? other
Probe handling: acetone rinse
distilled water rinse
Particulate recovery.from:probe nozzle Yes
probe fitting probe liner
front half of filter holder
Blank: acetone Ves distilled.water
Any visible particles on filter holder inside probe?:*
All 3ars adequately labeled? Vk.s Sealed tightly? Yes
Liquid level marked on jars?*
Locked up?
Acetone reagent: < 0.001% residue? mill kg oKgo.lte
-------
Section No. 3.5.4
Revision No. 0
Date May 1, 1979
Page 10 of 12
METHOD 6
Sampling
Bubbler and impinger contents properly selected, measured,
and placed in impinger?* \/_
Impinger Contents/Parameters*
1st: 15 ml of 80% isopropanol y
2nd: 15 ml of 3% H0O0
3rd: 15 ml of 3% H0 ,X_
Final impinger dry? tX
Probe heat at proper level? */
Crushed ice around impingers? \/
Pretest leak check at 250 mm (10 in.) Hg?
Leakage rate? Q.QO4
Probe placed at proper sampling point?
Flow rate constant at approximately 1.0 £/min?*
Posttest leak check at 250 mm (10 in.) Hg?*
Leakage rate? O. O&b JLJ t
Sample Recovery
System purged at least 15 min at test sampling rate?*
Contents of impingers placed in polyethylene bottles?
Fluid level marked?*
Sample containers sealed and identified?* >x
Most significant items/parameters to be checked.
Figure 4.4 On-site measurements
F-60
-------
Section No. 3.6.4
Revision No. 0
Date May 1, 1979
Page 10 of 11
METHOD 7
Sampling
Volume of 25 ml of absorbing solution placed in flask?
Flask valve stopper in purge position?
Sampling train properly assembled?
Leak free?* x Stopcock grease used? _ tX"
Type? _ £
Flask evacuated to 75 mm (3 in. ) Hg pressure? _ tX"
Leakage from manometer observation?* 0J /m i*J
(e.g., maximum change in manometer of £10 mm (0.4 in.)
Hg/min ) _ , _
Initial pressure of flask recorded?*
Initial temperature of flask recorded?
Probe purged before sampling? _
Sample collected properly?* tX
Flask shaken for 5 min after collection and disassembly
from train?* vX
Oxygen introduced to flask? /t/g Method used? _
Samples properly labeled and sealed and stored for shipment?
Sample Recovery
Samples allowed to remain in flasks for minimum of 16 h?*
Final flask temperature and pressure recorded?*
Sample transferred to leak-free polyethylene bottle? »X
Flask rinsed twice with 5-ml portions of distilled water
and rinse added to bottle containing sample? _ *^
pH adjusted to between 9 and 12?*
* Most significant items/parameters to be checked.
Figure 4.3. On-site measurements.
F-61
-------
Section No. 3.7.4
Revision No. 0
Date May 1, 1979
Page 16 of 18
METHOD 8
Sampling
Impingers properly assembled? .
Contents:* 1st #0 % JTA9 - /*6
2nd
3rd
4th 200v <*f " SfJ/e* *£/
Cooling system v '*'-' ^"J'"a-J~fA
-_ .._
Filter between 1st and 2nd impinger?
Proper connections?
*7*.W£SCJ- WW****wx^ wj-v**".* yrjr^r- ^
Silicone grease added to all ground-glass joints?
£Ji JL^WWIXW ^JU Wt»»^* fct^***^*** »*%* w.»_ 3 if * - f ^ i %
Pretest leak check? U*V (optional) Leakage"? ^^//
Pitot tube lines checked'for plugging and leaks? £**+>
Meter box leveled? C4**> Periodically? "
Manometers zeroed?* iJ+*>
Heat uniform along length of'probe?* _
AH@ from most recent calibration ^
Nomograph set up properly?
ivwiuw^J. t*^** h**- w» **f ^ "ir"~ ji * j-'^^ ' i i i 'j
Care taken to avoid scraping sample/port or stack wall?
Seal around'in-stack probe effective?
Probe moved at proper time?
ri.u.i->e uiuvcu a»- ^/j.w^/&*. v-j.".. /^^^ . i ^
Nozzle and Pitot tube parallel to'stack wall at all times?
Data forms c^mrl0*"^^ ^ai~a properly recorded? (Jt+J
Nomograph setting changed when^stack temperature/changes
significantly?
Oj.^ll.j.j.j.^a.i.i.^j.j s f,*^ r-i 3j^
Velocity pressures and orifice'pressure readings recorded
accurately? . #£+*. . r-
Posttest leak check performed?* tjiaJ (mandatory)
Leakage rate* 0. 0J <£t J/n >'fi>
Sampling Recovery
System purged at least 15 min at test sampling rate?*
Filter placed in 1st impinger contents? cStAJ
Ice removed before purging? M**S
Contents of impingers placed in'polyethylene bottles?
Glassware rinsed with distilled water? cj ,^>
Fluid level marked?*
Sample containers sealed and identified?*
Blanks obtained?* '
* Most significant items/parameters to be checked.
Figure 4.4. On-site measurements checklist.
F-62
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SLIDE 206-0 NOTES
OBSERVING THE TEST
SLIDE 206-1
OBSERVING THE TEST
1. Observer's attitude and behavior are very important.
2. Observer should perform duties quietly and thoroughly.
SLIDE 206-2
PREPARED CHECKLISTS
1. Provide a systematic method to check key
parameters.
2. Free observer to concentrate on observing
procedures.
F-63
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SLIDE 206-3 NOTES
CONDUCT PERFORMANCE AND SYSTEMS AUDITS
PERFORMANCE AUDIT
Quantitative evaluations of data quality
Examples:
1. critical orifice
2. audit samples for Methods 6 and 7
SYSTEMS AUDIT
An on-site qualitative inspection of total
measurement system
The audit includes:
1. set up and leak-check of sampling train
2. isokinetic sampling check
3. final leak-check
4. sample recovery
SLIDE 206-4
OBSERVE FACILITY OPERATIONS USING
STANDARDIZED DATA SHEETS
Assist observer in recording key data.
Provide data that is easily summarized.
SLIDE 206-5
RECORD VISIBLE EMISSIONS
Record visible emissions during each test.
Use standardized data sheets.
» Use procedures outlined in EPA Method 9 or
other procedures approved by the Agency.
SLIDE 206-6
EXIT INTERVIEW
» Conduct exit interview with plant and
test team.
» Request additional information if needed.
Critique test program.
F-65
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SECTION G. DETERMINING REPRESENTATIVE FACILITY OPERATIONS
Subject Page
1. Observing and establishing plant operating baseline conditions
during compliance emission tests G-3
2. Slides G-37
6-1
-------
OBSERVING AND ESTABLISHING PLANT OPERATING BASELINE CONDITIONS
DURING COMPLIANCE EMISSION TESTS
by Gary Saunders and Bill DeWees
The primary role of the agency observer during an emission test is to
certify that the test was conducted under "representative" conditions and that
the testing method was proper and in accordance with any pretest protocol that
had been established. A second, but equally important, function performed by
the agency observer is to develop an engineering profile of process and control
equipment operating conditions prior to and during the emission test. This
paper will focus on this latter aspect. (The agency observer will find detailed
information on observing, reviewing, and evaluating the performance of the emis-
sion testing itself in the references at the end of this paper.)
Even though the main purpose of observing the emission test is to verify
the representativeness of the test and that acceptable testing procedures .. .
were followed, the facility operation during the test should be of critical
interest to the agency from several other respects. For example, during the
initial compliance test the observer usually can determine the range of pro-
cess and control equipment parameters that the plant operator and equipment
supplier consider most optimum for achieving compliance with the applicable
emission standard. This information is useful not only for establishing repre-
sentative operating conditions during this test or pretest protocols for subse-
quent emission tests, but also in selecting or evaluating stipulations of
operating permits, and in assisting agency inspection personnel in evaluating
future performance and continuing compliance status. The overall process of
establishing a benchmark set of data on the facility operation is termed "base-
lining."
Establishing a baseline is, in its simplest meaning, documenting all -perti-
nent operating parameters as they relate to the emission characteristics of the
source; this includes both process and control equipment parameters. The base-
line provides a fixed point of operation or a narrow range of operating parame-
ters against which other determinations may be made. The concurrent emission
test provides a documented emission rate(s) that may be correlated with process
and control equipment operating characteristics derived during the test. The
baseline test as will be discussed is particularly useful for inspection person-
nel for subsequent routine inspections.
G-3
-------
The baseline may be used for several purposes. First, for existing sources,
baseline values may be obtained prior to a test to assist in the establishment
of representative operating conditions. The normal range of values may be
recorded during a period prior to a test and these values may be specified in
a test protocol to establish representative conditions or used as a starting
point in negotiating the test protocol with the plant. Comparison of compli-
ance test parameters with those specified in the protocol help establish whether
the process and control equipment were operating at representative conditions
as specified. Second, for new sources, the initial compliance test establishes
the values of operating parameters that correspond with measured emission rate
and a comparison against design values. This provides a fixed reference point
to compare future operating data against for establishing normal operating ranges.
Third, the values of the baseline parameters provide comparison data for evalua-
tion of routine inspection results. By knowing the effects of the various pro-
cess and control equipment operating parameters on emissions, comparison will
assist in evaluating the direction and magnitude of any changes in performance.
Fourth, documentation of the baseline data will assist in setting specific
ranges on important parameters for inclusion into an operating permit (if
required by the agency). Finally, the baseline test provides a fixed reference
point to compare long-term performance trends that are particularly of interest
in discussing continuous compliance aspects. Proper evaluation of data may
assist in establishing preventive maintenance schedules as well as provide an
indicator for any design or installation problems that may exist. In addition,
the rate at which the normal operating parameters move off from baseline values
may assist the agency in scheduling routine inspections and periodic compliance
tests.
The types of data that should be recorded is dependent upon site-specific
factors (i.e., the type of source or process, the product(s) produced, the con-
trol equipment installed). For that reason the agency observer and the inspector
(if different from the observer) should become aware of the site-specific factors
that affect the emissions, and take steps to obtain that data. In some instances
it will be difficult to separate and correlate all effects of the variations in
the process and control equipment parameters. However, by acquiring as complete
understanding as possible of the facility production process and its controls
prior to the test through review of permits and previous operational history
6-4
-------
and published technical information. The agency observer can frequently identify
key parameters which will have the most influence on emission levels. It is
strongly recommended that the baselining focus only on select parameters rather
than gathering all data indiscriminately. Collection of data which has no
significance can be inefficient and counter productive. Considerable effort is
resolved in recording and analyzing all process and control equipment data nor-
mally available at a facility. The inspector must be selective in which data
to collect to ease this burden. Also certain data may be of proprioritory
nature and considered confidential business data which will require special
handling and safe keeping. It is best not to incur this responsibility if
it can be avoided.
Although it is suggested that the agency collect all pertinent data, the
agency should be certain that 1) the data is needed and a change in its value
has an effect on the intended purpose of future data use and 2) the data is
accurate to the point that the recorded value has some meaning. Some instru-
ments have calibration factors attached, some instruments have no direct rela-
tionship but are used as mere indicators of some operational change and finally
many instruments either do not work or read incorrectly. When an operation and
maintenance program or permit to operate is issued based on a range of process
and control equipment parameters, the agency must be certain that the readings
are of true value or of a fixed relationship to a given operation. This may
require prior maintenance and calibration of the key parameter instrumentations
prior to the performance test and on a designated basis thereafter. It may
also require the installation of additional instrumentation.
During the baseline source test the agency observer must essentially con-
duct an inspection obtaining all the operating parameters for evaluation. (See
reference no. for conducting plant inspection.) The only major difference
between this and any routine inspection is the fact that emission testing is
occurring simultaneously to the inspection. Thus, the observer cannot spend
all his time observing the test as he has other responsibilities. Process
and control equipment parameters should be checked throughout the test; and
it is usually a good idea to obtain data for the week previous to and after
the stack test to demonstrate representative conditions during the test. This
may require 50 percent of the time with the process and control equipment with
the remainder split between Method 9 opacity observations and observing test
6-5
-------
procedures. It is advisable to have two agency persons on site when there is
not easy access between the sample site and control rooms. The use of the
field inspector responsible for that facility to perform the facility observa-
tion and visible emission readings is strongny recommended. This will enhance
the field inspectors knowledge and importance at that facility.
The remainder of this paper will discuss specific process and control
equipment operating conditions and measurement parameters which most often
affect the nature and amount of emissions. In a paper of this length it is
not possible to cover the subject in sufficient detail necessary to perform
an actual baselining. The reader is advised to carefully read the additional
technical guides and reports listed in the reference section. The information
presented below is intended to provide only an overview of the baselining pro-
cedure and introduce the reader to specific items that should be considered
in conducting a detailed plant inspection as part of the emission test verifi-
cation.
ESTABLISH REPRESENTATIVE CONDITIONS
As stated in Section 60.8(c) "Performance tests shall be conducted under
such conditions as the Administrator shall specify to the plant operator based
on representative performance of the affected facility." "The owner or operator
shall make available to the Administrator such records as may be necessary to
determine representative operating conditions to be used while conducting per-
formance tests." The agency must take full advantage of this requirement by
having the facility submit a written test protocol describing representative
process and control equipment operating parameters and mode of operation. If
the facility is told that their permit to op'erate, operation and maintenance
program and future agency inspections will be based on conditions recorded
during the performance test, their testing protocol would likely be more
detailed and realistic. It will also save the agency the time that would be
required to establish a basis to work from.
It is helpful if a standardized form can be sent to the facility that will
indicate the level at which the agency intends to baseline the facility. Figure
1 shows the minimum that would be agreed upon for future use of the data. Figure
2 shows a standardized use of data for a power plant. Figure 3 shows the mini-
mum items that must be agreed upon for the testing protocol. Figure 4 is a
standardized data form for agreement of a testing protocol for a power plant.
G-6
-------
PRETEST AGREEMENT OF CONTINUING COMPLIANCE CONDITIONS
Process
1) Process parameters that must be recorded and submitted to agency or
kept on file for later inspection
2) Percentage by which each process parameter can exceed the tested rate
and on what time weighted average
3) Future operating procedures
Control Equipment
4) Control equipment parameters that must be recorded and submitted to the
Agency or kept on file for later inspections
FIGURE 1
G-7
-------
5) Normal operating procedures
6) Normal maintenance schedule
7) Frequency of'scheduled inspections by agency
Reviewed and approved by:
Date
Agency Facility
FIGURE 1 (continued)
G-8
-------
ALLOWABLE OPERATING PARAMETERS FOR A POWER PLANT
Process: Applies only to sources without complete or proper continuous monitoring capability or to
sources that the continuous monitoring equipment is not operating properly for an 21 day
period.
Parameters
Allowable limits compared to average compliance test conditions
Time weighted basis
en
i
Steam production
Megawatt rate
Excess air
Fuel analysis:
Ash content
Sulfur content
110% of the average steam production tested rate
110% of the average megawatt tested rate
aZ% increase in oxygen content over the average tested excess
air value while operating at or about 90% of the average
steam production rate
An increase of 1.0% ash content above the average ash content
analysis of the test fuel
cAn increase of 0.25% sulfur content above the average sulfur
content analysis of the test fuel
A decrease of 0.50% sulfur content below the average sulfur
content analysis of the test fuel
8 hour average
recorded hourly
8 hour average
recorded hourly
1 hour average
recorded hourly
monthly average
collected daily
combined and ana-
lyzed weekly
monthly average
collected daily
combined and ana-
lyzed weekly
monthly average
collected daily
combined and ana-
lyzed weekly
Does not apply during changing load conditions.
3Ash content is the ash content divided by the heating value of the fuel.
Sulfur content is the sulfur content divided by the heating value of the fuel.
'Does not apply to flue gas desulfurization systems.
Applies only to coal fired boilers with electrostatic precipitators.
FIGURE 2
-------
ALLOWABLE OPERATING PARAMETERS FOR A POWER PLANT
Fabric filters - Torn bags must be replaced or blanked off whenever the facility exceeds the allowable
visible opacity for more than 2 hours in any 24 hours and/or every 120 days. Bags may be blanked off
up to 15% of the total bags as long as the facility meets the visible emission limits. All torn and
blanked off bags must be replaced every 12 months or when over 15% of the bags are blanked off, which-
ever is more restrictive. The agency must be notified under the following conditions if the boiler is
to be operated:
1) 30 days prior to all scheduled maintenance
2) Whenever the allowable visible opacity limit is exceeded for more than 2 hours in any 24 hours
3) If the facility plans on by-passing the baghouse for any reason.
Agency Inspections:
The agency will make at least one scheduled inspection every year to review the execution of the con-
ditions of the conditional compliance. The facility will be notified of the date of the first inspec-
tion in the conditional compliance letter from the agency. The facility will have all required data
available for inspection. The facility will then be notified after each scheduled and unscheduled in-
spection of the results of the inspection, any actions that must be taken by the facility and the date
of the next scheduled inspection. This does not waive the right of the agency to make as many unsched-
uled inspections as they deem necessary to ensure "good working operation" by the facility.
FIGURE 2 (continued)
-------
ALLOWABLE OPERATING PARAMETERS FOR A POWER PLANT
Fuel feed will operate on - Manual Automatic
Combustion air will operate on - Manual Automatic
Fly ash reinjection - Yes No
Soot blowing - Continuous Intermittent Maximum frequency
Bottom ash removal - Continuous Intermittent Maximum frequency
Control Equipment: (SIP)
Flue gas conditioning - No Yes Acceptable conditions
Fly ash removal - Continuous Intermittent Maximum frequency
Scheduled preventative maintenance
Electrostatic precipitator - A once-a-shift recording of all individual fields in the electrostatic
field is on or off. The agency must be notified under the following conditions if the boiler is
to be operated:
1) Complete outage of all fields
2) 50% or more outage for more than 24 hours of boiler usage
3) 25% or more outage for 48 hours of boiler usage
4) Any outage for more than 60 hours of boiler usage during any 30 day period
Scrubbing system - A once-a-shift recording of the scrubbing liquid to steam production rate ratio. The
agency must be notified under the following conditions if the boiler is to be operated:
1) Complete stoppage of liquid flow
2) 50% or less ratio of liquid to steam production for more than 24 hours of boiler usage
3) 80% or less ratio of liquid to steam production for more than 48 hours of steam production
4) 90% or less ratio for more than 60 hours of boiler usage in any 30 day period
FIGURE 2 (continued)
-------
PRETEST AGREEMENT ON FACILITY OPERATION
Process
1) Maximum process rate/capacity
2) Method of process weight or rate determination
3) Process parameters to be monitored and recorded, and their acceptable
limits to document process operation
4) Raw material feed and/or fuel acceptable analyzed values
5) Normal operating cycle or procedures
6) Portions of the operating cycle that will be represented by each run
FIGURE 3
G-12
-------
Control Equipment
7) Control equipment and effluent parameters to be monitored and recorded,
and their acceptable limits to document control equipment operations
8} Normal operating cycle (cleaning, dust removal etc.)
9) Normal maintenance schedule
10) Manner in which the control equipment will be operated
Reviewed and approved by:
Date
Agency Facility Tester
Was Facility provided agency checklists? yes no
Was Tester provided agency checklists? yes no
Is any of the above information considered confidential?
If yes; was source notified to submit written justification for a confidential
classification on each item considered confidential
FIGURE 3 (continued)
G-13
-------
FACILITY OPERATING PARAMETERS DURNG TEST PERIOD
FOR A POWER PLANT
Process
Designation of unit being tested_
Boiler nameplate capacity
Electric generator capacity
Firing type - Front wall
Boiler operation - Base load_
Opposed wall
_Pounds steam/h
jnegawatts
Vertical
Peak load
Tangential or corner_
Parameter
Acceptable limits
units
where gathered
Interval or recording
I
t'
-p.
Steam production
Megawatt rating
Fuel scales,
meter
Excess air
Ib steam/h
megawatts
Fuel sample - Wt per collection_
Fuel feed - Manual _____
Combustion air - Manual
Fly ash reinjection - No
Soot blowing - Continuous
Bottom ash removal - Continuous
Yes
Interval of collection^
Au toma ti c
Automatic
Intermittent
Intermittent
Location(s)_
Frequency_
Frequency_
FIGURE 4
-------
FACILITY OPERATING PARAMETERS
DURING TEST PERIOD FOR A POWER PLANT
Fuel
Fuel type Percentage
Coal ,
Oil
Gas
Other
Coal (classified by ASTMD 388-66)
Bituminous subbituminous anthracite lignite
Coal feed measurement and location
Automatic conveyor scale
Batch weighing - dumping hoppers
Other (describe) .
Location of scale
None
Liquid fossil fuel
Crude residual distillate
Liquid fuel feed measurement and location
Volumetric flow meter, make model
Other (describe)
Location of meter
None
Gaseous fossil fuel
Natural gas propane butane other
Gaseous fuel feed measurement and location
Volumetric flow meter, make model
Other (describe)
FIGURE 4 (.continued)
6-15
-------
FACILITY OPERATING PARAMETERS
DURING TEST PERIOD FOR A POWER PLANT
Location of meter
None
Other fuel (describe).
Other fuel feed measured by_
FUEL ANALYSIS
PROXIMATE ANALYSIS - As-fired solid and liquid fuels
Component % by weight
Typical Acceptable Range
Moisture
Ash
Volatile Matter
Fixed Carbon
Sulfur
Heat value, Btu/lb .
or ultimate analysis - which includes the proximate analysis plus the following
Nitrogen
Oxygen .
Hydrogen _
Carbon
FIGURE 4 (continued)
G-16
-------
FACILITY OPERATING PARAMETERS DURING TEST PERIOD FOR A POWER PLANT
Control Equipment
Parameter
Acceptable limits
Units
Inhere gathered Interval of recording
Flue gas conditioning - No Yes Explain
CD
,L Fly ash removal
Continuous Intermittent Frequency
~.j
Normal maintenance schedule
Conditions of Test Runs
Run 1
Run 2
Run 3
Other
FIGURE 4 (continued)
-------
To help ensure that the data is collected properly it is also helpful to
prepare standardized data forms as shown in Figures 5, 6, 7, 8, and 9. Since
this paper is unable to provide the required detail, it is suggested that the
agency either use a person knowledgeable with the specific type of process or
obtain the required reference material and/or training in plant inspection
procedures.
PROCESS PARAMETERS
The process parameters that may be monitored are as numerous as the types
of industry and, therefore, specific guidelines would require site specific
plans. However, process parameters generally fall into four general headings:
raw material inputs, production (output), fuels needed for the process and mode
of operation. Effluent characteristics may also be considered a process related
parameter but may be related more closely with the control equipment than the
process in some cases. The monitoring and recording of the facility operations
is the responsibility of the facility. The observer's responsibility is to
see that it is conducted in a proper manner and report any changes that need to
be made to the facility contact. The observer should never tamper with any
equipment or handle or mark on operating logs.
It is usually advisable during a baseline test to obtain process parameters
on a routine schedule of 1/2 hour intervals and to note any sudden changes that
occur during the test period. In specific, the observer is checking to see that
the process is operating as prescribed in the test protocol and to determine if
any significant shifts in process parameters occur during or between test runs.
If these shifts occur it is then the responsibility of the agency to determine
the magnitude of the effect on emissions and if it compromises the representa-
tiveness of the emission test. For example, in a recent test on a cement kiln,
the kiln speed was reduced for maintenance during a test run. The observer
did not report the reason for this decrease nor did the operator in his logs.
However, there had been an increase in opacity and ESP rapper spikes prior to
this reduction in kiln speed and feed rate. After several hours the production
rate was increased and the opacity gradually returned to the levels observed
prior to "malfunction" or operational problem. Unfortunately, one of the test
runs was conducted during this period without apparent indication in the reporting
G-18
-------
PROCESS DATA DURING TEST
Record the following data every 30 minutes during compliance test (SIP).
finish of each test and obtain copy of chart(s).
Mark chart at the start and
Parameter
Recording time
Steam load
Air load
Megawatt
co2
°2
Soot blowing
Bottom ash removal
Fly ash removal
Opacity
Units
24 h
Ib/h
Ib/h
megawatt
01
h
minutes
minutes
minutes
Values
Integrator factor
vo
Fuel feed - Manual
Combustion air - Manual
Fly ash reinjection - No_
Automatic_
Automatic
Yes
Locations
FIGURE 5
-------
FUEL INPUT DATA DURING TEST
Automatic weighing or metering
Counter (totalizer) Reading
Time Coal Oil Gas
End test
Begin test
Difference
Units fed during test
Counter conversion factor
Fuel per counter unit tons gal ft
3
Fuel fed during test tons gal ft
Fuel sampled during test
Number of samples
Total quantity of sample
Date of last calibration of
automatic metering device
Manual weighing or other procedure. Use this space for monitoring procedure
and calculations.
FIGURE 6
G-20
-------
Facility
Recorded by
Design Efficiency
ELECTROSTATIC PRECIPITATOR DATA SHEET - PARAMETERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE
Boiler No.
Test No.
Test Date
Recording interval*1
Sampling Time
(minutes)
Clock time
(24 hr. clock)
Operating voltage (kV)
Field number
1
i
Representative
design
2
3
4
Operating current (mA)
Field number
1
2
3
4
Soark-
Rate
(Sparks/
minute)
Rapper timing/sequence:
Hopper dust removal sequence:
Representative,
During Test:_
Representative_
During Test1..
Recording intervals - 15-30 minutes.
FIGURE 7
6-21
-------
PARTICULATE SCRUBBER DATA SHEET - PARAMETERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE
Facility.
Monitor Name.
Boiler No.
Test No._
Design Efficiency.
.Test Date.
Recording Interval"
Sampling Time
(minutes)
0
Clock Time
(24 hr. clock)
Static Pressure
(in. H20)b
Inlet
Outlet
Representative
Design
Pressure Drop
Across Scrubber
(in. H20)
Water
Flow
Rate
(gPIT>)
'Recording intervals 15-30 minutes.
blf direct reading of pressure drop is not available.
FIGURE 8
6-22
-------
FABRIC FILTER DATA SHEET - PARAMETERS
OF DESIGN AND OPERATION AFFECTING PERFORMANCE
Facility.
Monitor Name.
Boiler No..
.Test No._
Design Efficiency.
.Test Date.
Recording Interval*
Sampling Time
(minutes)
Clock Timr
(24 hr. clock)
Representative
Design
Pressure Drop
Across
Baghouse
(in. H20)
Pressure Drop
Across
Compartment
(in. H2O)
1
2
3
"
4
D
Temperature range of filter fabric
Fan damper position
Fan current (amps)
Cleaning cycle
Total no. of bags in operation
Design/Normal
During Test (flue gas temp.)
b
no.
no.
yes.
yes.
, number.
, number.
Are any bags blanked off?b
Are any bags leaking?1*
* Recording intervals 10 minutes. If a compartment is isolated sequentially for cleaning
throughout the test timing mechanisms, data readings should be synchronized with cleaning
cycle.
This information is generally not available. It can be obtained during boiler shut-down prior
to or after testing; however, for many constant demand-type boilers, this is not possible.
FIGURE 9
G-23
-------
of results (Figures 10, 11,.12, and 13). In addition, the test runs were con-
tinued the next day during a process change (from Type I to Type II cement)
and during the period of changeover the emission characteristics were in a
state of transition that had a significant effect on emissions and the opera-
ting characteristics of the ESP. Had sufficient documentation not been pro-
vided, agency personnel would probably be unable to piece together the cause of
the performance change (FiguresH and 15) and then the return to "normal" con-
ditions.
Raw material characteristics that should be monitored include the quantity
of all raw materials, chemical composition (including elemental analysis if
needed), the size distribution of the feed materials (if applicable), moisture
content, and any feed cycles that are present if the raw material feeds are
not continuous. All recycle loops should be included in the materials balance,
as the amount and type of materials recirculated generally will affect emission
rates. To the extent possible continuous strip chart recorders are valuable in
providing real-time data and should be used where available. Otherwise, visits
to process monitoring areas at a reasonable frequency is necessary to provide
adequate documentation.
The product characteristics should also be monitored including production
weight, chemical and physical characteristics, particle size, density (specific
or bulk), temperature and in the case of steam production, pressure. Although
many of the characteristics are typically not measured during the test, those
parameters that significantly affect performance should be measured for com-
parison with data obtained in the future. Care must be taken to protect the
confidentiality of this data, if required by the plant, for it is in these
areas that most sources are most sensitive about releasing data.
In those processes utilizing a fuel for heat input the fuel type and heat
content of the fuel should be specified. Other parameters that are commonly
of interest are the sulfur content of the fuel, the ash content (not applicable
to all fuels), and any chemical components that are included in the fuel that
might affect the performance characteristics of the process and/or control
equipment emission rate or emission characteristics.
The final process check is the mode of operation. M|my processes have
several modes for which they can be operated. The two general modes are auto-
matic and manual. However, there are many variations that would allow the
facility to divert pollutants, shut down auxiliary or cleaning systems, change
G-24
-------
SLURRY FEED AND INSUFFLATION DUST RATE FOR MAY 4, 1981
FIGURE 10
-------
OPACITY STRIP CHART FOR MAY 4, 1981
(0120 to 0520 h)
SD
I
FIGURE 11
-------
OPACITY STRIP CHART FOR MAY 4, 1981
(0640 to 1200 h)
FIGURE 12
-------
OPACITY STRIP CHART FOR MAY 5, 1981
(1040 to 1600 h)
CT3
I
I i
'
o
o
10
*>
3
CM
O
O
FIGURE 13
-------
OPACITY STRIP CHART FOR MAY 5, 1981 (1210 to 2400 h)
AND MAY 6, 1981 (0120 to 0240 h)
5
>.
O
o
*
o
FIGURE 14
-------
FIGURE 15
1200
1000
1 2 3 « 5
FIELDS
Secwtorjr current, ESP 10 recovery boMer
6
26. 1980.
1000
23456
Secondary current. ESP 10 recovery boiler, October 28, 1900.
COMPARISON OF BASELINE AND INSPECTION VALUES
FOR SECONDARY CURRENT
G-30
-------
pollutant reinjection systems, use manufacturer's personnel and not facility
personnel, or even extent the normal operating cycle. For many sources the
mode of operation is probably the most difficult parameter to determine repre-
sentative operations. A process flow chart should be reviewed with the facility
and discuss the options as to the manner in which the process can be operated.
Also if any of the processes are controlled manually during the test this must
be its normal mode of operation. No cleaning (i.e., soot blowing) or auxiliary
systems should be shut down unless they rarely operate during the normal opera-
tions. All pollutant reinjection (e.g., fly ash reinjection, insufflation)
systems should be in operation. Operational cycles that extend beyond their
normal time should not be considered representative.
CONTROL EQUIPMENT PARAMETERS
The establishment of baseline parameters for the control equipment is also
useful in determining operating characteristics and compliance capabilities
during future routine inspections. As explained in the process parameter sec-
tion, the mode of operation is important. Two types of control equipment are
particularly amenable to baselining: ESP's and Wet Scrubbers. Fabric filters
and mechanical collectors may also be baselined but in many cases operation
and maintenance play a major role in the long-term performance and there are
relatively few indicators that are truly useful in the sense of baseline para-
meters.
The emission test will provide the basic data common to all control equip-
ment, including gas volume, composition, and temperature, pollutant emission
rate, and an average opacity. In addition, for each control equipment category
the final disposition of the collected material should be determined (disposal
provisions). And, if a simultaneous inlet test is performed, the efficiency
of the control equipment may be determined. The specifics for each category
are discussed below.
FABRIC FILTERS
The fabric filter seems least amenable to the baseline concept because
there are few numeric parameters that easily relate to the performance. The
major factors influencing baghouse performance appear to be initial design,
maintenance of fabric filter components, and protection of fabric from attack
G-31
-------
by undesirable gas temperatures and/or gas compositions. However, some para-
meters may be measured or calculated to assist in the evaluation of performance
where large changes have occurred.
The two parameters most often determined ere the static pressure drop
and the air-to-cloth (A/C) ratio. Although changes in these values do occur,
they may not be significant from the standpoint of a final emission rate. They
may, however, place constraints on process operating conditions if there is a
significant change in these parameters. In addition, they may also indicate
a level of required and/or preventive maintenance to avoid sudden failures of
baghouse components. For example, an increase of the A/C ratio over baseline
conditions will usually result in an increased pressure drop and may change
cleaning cycle requirements as well as increasing maintenance requirements.
Whereas, a sudden decrease in the static pressure may indicate a bag failure
and a requirement for maintenance, (usually noted by an increase in opacity)
The pressure drop of most interest is that across the entire baghouse from
inlet to outlet. Multiple pressure drop indicators for multiple compartmented
baghouses are generally not of interest except as indicator of proper compart-
ment isolation during cleaning cycles. Otherwise, compartments tend to be
self-balancing for pressure drop and will automatically adjust gas flow in
each compartment accordingly. The static pressure drop should be measured
periodically throughout the test.
The frequency and cycle of the cleaning mechanism should be recorded. The
operation of the cleaning mechanisms should be confirmed and its affect on the
pressure drop and visible emissions recorded. There are several cleaning modes
available for reverse air and shaker baghouses and the effect on pressure drop
and emissions may be substantial if the cleaning cycle is changed. Pulse-jet
baghouses tend not to be a problem in this regard since they are usually on a
continuous cleaning cycle.
The fabric type should also be determined prior to or during the baseline
test because the fabric places constraints on gas temperature, gas composition,
and particulate compositions that may be passed through the fabric. Changes
in process operation or raw materials may damage bags if undesirable charac-
teristics or chemicals are present. In addition, changes in fabric may change
to a slight degree the performance of the baghouse in reducing emissions due
to structual differences in the fabric weave.
G-32
-------
If possible and if safety conditions permit an internal examination of
the baghouse is useful to pinpoint potential problem areas and to qualitatively
evaluate baghouse performance. Safe entry procedures must be used to avoid
contact with toxic substances, asphixiants, or explosive gas compostions. How-
ever, the recommended procedure is to observe the interior of the baghouse
from an open hatch without actually entering the equipment.
ELECTROSTATIC PRECIPITATORS
Electrostatic precipitators are, perhaps, the most amenable pieces of
control equipment for establishing baseline values. Through a combination of
parameters and knowledge of ESP operating characteristics it is possible to
estimate the performance of the ESP at any other time of interest after base-
line performance has been determined.
Electrical parameters for primary voltage, primary current, secondary
voltage and secondary current should be recorded periodically during the test.
These values when combined with plate area, gas flow rate, and physical size
of the ESP provide a number of useful parameters. In addition, trends within
the electrical data are useful in diagnosing the performance of the ESP. The
items of interest include an increase in secondary current from inlet to Qut-
let, an increase in power input from inlet to outlet, total power input, a
decrease in sparking from inlet to outlet, the actual superficial velocity
through the ESP (ft/sec), the gas treatment time, actual specific collection
area (SCA, ft2 of plate/1000 acfm), specific corona power (watts/1000 acfm),
and the power density (watts/ft2 of plate area). These provide the primary
indicators of performance when coupled with the baseline stack tests. Agency
personnel should confirm the operation of all rappers and the rapper frequency
and intensity from control board settings. In addition, agency personnel should
determine the size of the T/R (from specification plates on the T/R) and deter-
mine if the T/R control cabinet is in manual or automatic control mode.
In some cases it may be necessary to correlate resistivity of the dust
to process feed composition and/or operating characteristics. Chemical analysis
of the dust may be necessary to establish acceptable levels of chemical compon-
ents needed to obtain satisfactory performance of the ESP. Modification of
process operating conditions, process feed, or the addition of conditioning
agents may be suggested by the baseline criteria. However, when changes in
G-33
-------
these parameters occur ESP performance will typically shift. For those person-
nel responsible for inspecting ESP's, the baseline values provide a fixed point
of reference against which the inspection data may be compared. Figure 14 shows
a comparison between a baseline test and data obtained during the inspection
four months later. Performance had decreased significantly and is immediately
obvious when one of the major indicators of performance, secondary current, is
plotted. The trouble had occurred in the south chamber although the north
chamber was not up to its previous level during the inspection.
MECHANICAL COLLECTORS
The performance of the mechanical collector is very sensitive to particle
size distribution shifts around the 5 to 10y range as well as to the mechanical
condition of the collector. Pressure drop shifts across the mechanical collec-
t
tor are not very meaningful in correlating performance because the shifts in
pressure drop tend to be small. In addition, opacity-mass relationships are
not very useful since most mechanical collectors pass a large portion of light
scattering particles below 2y regardless of operation. The opacity will shift
only slightly with changes in performance unless an inlet particle size shift
occurs.
Baselining mechanical collectors involves calculating inlet velocity to
inertia! separators and examining the physical condition of mechanical collec-
tor for any signs of physical disturbance to the inertia! separation process.
This includes inleakage, damaged or plugged cones in multiclones or cyclones,
and excessive wear. These conditions will inhibit the performance capabilities
of the collector. Empirical relationships for collection efficiency, pressure
drop and gas volume may sometimes be developed to evaluate overall efficiency
but are dependent upon nonvarying particle size distributions.
WET SCRUBBERS
If the instrumentation is available, establishing baseline conditions can
be quite useful in evaluating the performance of wet scrubbers. Some key para-
meters may be defined and correlated to scrubber performance. The most common
indicators used are pressure drop, liquid-to-gas ratio (L/G in gal/1000 acfm
or 1/m3) and throat velocity in venturi scrubbers. In general, an increase
in these three values means improved performance. However, most scrubbers
have difficulty collecting particles in the 0.1 to 2.Op range due to a
G-34
-------
transition in collection mechanisms and thus, as part of the baseline test
a particle sizing test may be suitable.
Liquor quality and flow rates should be determined to all scrubber deli-
very points. Both dissolved and suspended solid levels should be determined
in water quality analysis as should any potential corrosive material to the
scrubber shell (pH, chlorides, and sulfates). The volumetric flow rates to
the scrubber, presaturator, sump, blow-down, make-up, and demister should be
determined to establish a material balance. The removal of the particulate
matter from the sump should be discussed. In some cases, the issue of water
quality and water flow have a major impact on performance of the scrubber parti-
cularly high temperature applications. What is to be avoided is a test scenario
where clean water is used during the test and at all other times recycled water
with elevated level of dissolved and suspended solids, established by equili-
brium conditions, is used. Unless clean water is to be used at all times
(once through type systems) the scrubber should be operated some period of
time before the baseline test to establish a representative baseline performance
value.
Physical components should be checked prior to a baseline test if safety
permits. These components include water distribution systems such as weirs
or spray nozzles, demister cleanliness and water coverage, and maintenance
capabilities of these systems. A scrubber depends upon good water and gas
distribution for proper operation and if proper coverage does not exist and
maintenance capabilities are not provided, then deterioration from baseline
values may be substantial and the agency should be alerted to potential problems.
FACILITY OPERATION DURING PERFORMANCE TEST
The previous discussions have dealt with the method of choosing the correct
operating parameter and acceptable values. It should be noted that during the
performance test that the process and air pollution equipment is either new or
is in its best maintained shape. Also, all operating parameters are probably
at the optimum point of an acceptable range. This is the main reason that the
facility should be required to have an operation and maintenance program to
keep the equipment and operating parameters at or near these conditions. This
set up of the equipment is generally referred to as "fine tuning." However,
on occasion the facility will cross over the line of fine tuning to a point of
G-35
-------
atypical conditions that can be or is only maintained during the short duration
of the performance test. Also procedures can be used to give reduced emission
rates for a short time period. Some examples are shutting off the power to an
ESP the night before the test and leaving the rappers on to clean the plates,
the use of auxiliary booster pumps to add more liquid flow to a wet scrubber,
having outside personnel set operating conditions with portable instrumentation
not usually available at the existing facility, and having additional personnel
operating the source in such a manner that emissions are reduced during each run
and then released between runs. Although these cases are not common, the faci-
lity should be informed that it will be operated by its own personnel and that
additional and outside personnel cannot make changes within 8 hours prior to
the test or during the testing period, lest the test be considered nonrepre-
sentative of normal operating conditions.
SUMMARY
Baseline testing allows the establishment of indicative parameters that
the agency may use for comparative purposes during inspections for permits,
and for comparing source to source performance. This documentation also allows
the agency to specify representative testing and operating conditions. It does
require a splitting of effort away from the actual stack test team observation.
However, the benefits that are produced far outweigh any inconvenience, if the
need ever arose, for full documentation of operating conditions that are diffi-
cult to reconstruct after-the-fact. Thus, during the emission test an agency
can obtain data useful in conducting future surveillance of plant compliance
in addition to helping determine the validity of the emission test results.
This paper may seem extreme in nature unless you considered that an ESP with
an 99.9 percent collection efficiency, shutdown for only four days will exceed
its annual emission rate. The need for continued compliance has become very
obvious and has be substantiated by recent reports.
G-36
-------
SLIDE 207-0 NOTES
OBSERVING AND ESTABLISHING
PLANT OPERATING BASELINE CONDITIONS
DURING PERFORMANCE TEST
SLIDE 207-1
PURPOSES OF DETERMINING
REPRESENTATIVE FACILITY OPERATION
1. Evaluate performance test
2. Establish operation and maintenance programs
3. Issue permit to operate
4. Reference point for future evaluations
SLIDE 207-2
BASELINE CONCEPT
Defn:
The documentation of all pertinent operating
parameters for both process and control equip-
ment operations to provide a narrow band of
operating parameters against which determina-
tions can be made.
G-37
-------
SLIDE 207-3 NOTES
FACILITY BASELINE
PROCESS STEPS
1. Have facility provide written test protocol.
2. Review protocol using agency staff knowledge on
specific industry and/or other information.
3. Make a pretest visit, check parameters, and finalize
protocol.
4. Observe testing to ensure representative facility
operation and properly recorded parameters.
SLIDE 207-4
AGREEMENTS ON TESTING PROTOCOL
PROCESS:
parameters to be monitored and recorded
acceptable values for each parameter
process samples to be taken and analyzed
mode of operation
instruments to be added and/or calibrated
SLIDE 207-5
(cent.)
CONTROL EQUIPMENT:
parameters to be monitored and recorded
acceptable values for each parameter
control equipment effluent samples to be
taken and analyzed
mode of operation
instruments to be added and/or calibrated
G-39
-------
SLIDE 207-6 NOTES
METHOD OF BASELINE ASSESSMENT
TEMPERATURE GAS VOLUME/VELOCITY
Thermocouple Pitot Tube
Thermometer Manometer
MOISTURE Tachometer (Fan RPM)
Wet Bulb/Dry Bulb Ammeter (Fan Current)
Psychometric Chart Manometer (Fan Static Press.)
GENERAL STATIC PRESSURE DROP
Stop Watch Manometer
Tape Measure GAS COMPOSITION
Pressure Gauge Fyrite, Orsat
Water Row
SLIDE 207-7
PROCESS OPERATION
Raw Materials
Fuel
Process Rate
Mode of Operation
SLIDE 207-8
PROCESS CONDITIONS
RAW MATERIALS EFFLUENT QUALITY
composition air volume
size distribution uncontrolled emission rate
moisture particle size distribution
feed cycles temperatures
FUEL condensables
heat input moisture
fuel quality opacity
sulfur content oxygen content
ash content PRODUCT QUALITY
special components moisture
PROCESS WEIGHT particle size
density (specific, bulk)
temperature
6-41
-------
SLIDE 207-9
NOTES
PROCESS MODE OF OPERATION
Manual or automatic operation
Cleaning and auxiliary systems
Pollutant reinfection
Normal period for process cycles
Diversion or circumvention of pollutants from air
pollution control equipment
Operation personnel
SLIDE 207-10
CONTROL EQUIPMENT CONDITIONS
GENERAL
temperature
air volume
collected pollutant
discharge rate
opacity
FABRIC FILTER
static pressure drop
air-to-cloth ratio
fabric type
cleaning system operation
internal conditions
ELECTROSTATIC
PRECIPITATOR
secondary current
power input
rapper operation
actual specific collection area
actual superficial velocity
power supply controller made
internal conditions
MECHANICAL
static pressure drop
inlet velocity
internal conditions
SLIDE 207-11
CONTROL EQUIPMENT
MODE OF OPERATION
Manual or automatic operation
Collected pollutant removal cycle
Cleaning cycle
Auxiliary or gas conditioning systems
6-43
-------
SLIDE 207-12 NOTES
RECORDING FACILITY OPERATION
The source should perform all data logging.
Use standardized data sheets for both the
process and control equipment data.
SLIDE 207-13
RESULTS OF FACILITY BASELINING
Performance test can be properly evaluated.
An operation and maintenance program can be
established.
Permit to operate can become an effective enforce-
ment tool.
Future inspections by agency can be more effective
in determining compliance and reasons for non-
compHance.
SLIDE 207-14
NOTE OF INTEREST
A 99 9% efficient ESP shut down for 4 days will
exceed one year's emissions at its rated efficiency.
G-45
-------
SECTION H. SOURCE TEST REPORT REQUIREMENTS AND REVIEW
Subject Page
1. Observer's summary form (taken from the Model Compliance Testing
Protocol manual) H-3
2. Source sampling report format H-6
3. General review guide for emission test reports H-9
4. Slides H-25
H-l
-------
1 of
Source I.D. No.
OBSERVER'S SUMMARY FORM
Source name
City and State
Type of process
Type of control equipment
NSPS regulation and effective date
Reference Method(s) and effective date(s)
Process Observation
Form no.
Observer Agency
Description of process and process operation during testing:
H-3
-------
Page 2 of 3
OBSERVER'S SUMMARY FORM (continued)
Control Equipment Observation
Form no.
Observer __^_ Agency
Description of control equipment and control equipment operation during
testing:
Source Test Observation
Form no.
Observer Agency
Description of any noteable occurances:
H-4
-------
Paqe 3 of 3
OBSERVER'S SUMMARY FORM (continued)
Visible Emission Observation
Form no.
Observer Agency
Reading ranged from to percent opacity
Maximum average for any test percent opacity
The source was/was not in compliance with the opacity reading of
at the time observations were made.
Was source operating representatively during any or all violation? (If
applicable) ^
Other Observations
List any items that may require attention in the future:
Process operation
Control equipment operation
Test team sampling procedures
Other
Prepared by Date
Reviewer Date
H-5
-------
SOURCE SAMPLING REPORT FORMAT
Results of the performance test shall be submitted to the agency by the facility
representative within forty-five (45) days of the completion of the field work.
This report should include, but not be limited to, the following:
1. Format and information as shown in Figure 1.
2. Certification by the test team leader that the sampling and analyti-
cal procedures, and data presented in the report are authentic and
accurate.
3. Certification by a responsible representative of the testing firm
(preferably by a professional engineer) that all the testing details
and conclusions are accurate and valid.
4. Certification on the process rate sheet by the facility representa-
tive of the facility operations during the performance test.
5. Data sheets found in Section F of this manual and any other data
sheets that meet the approval of the agency prior to use should be
used to record data. All applicable blanks should be filled in.
6. All calculations must be made using the applicable equations as shown
in the Federal Register. An example calculation should be shown for
one run.
7. Final results must be presented in English and metric units and con-
tain two significant digits for each run. Values may be rounded off
to three significant digits after the calculation of each equation
and to two digits for the final results or all digits may be carried
in the computer and only rounded to two significant digits for the
final results. All rounding off of numbers will be performed in ac-
cordance with the ASTM 380-76 procedures.
H-6
-------
Cover
1. Plant name and location
2. Source sampled
3. Testing company or agency, name and address
Certification
1. Certification by team leader
2. Certification by reviewer (e.g., P.E.)
Introduction
1. Test purpose
2. Test location, type of process
3. Test dates
4. Pollutants tested
5. Observers' names (industry and agency)
6. Any other important background information
Summary of Results
1. Emission results
2. Process data, as related to determination of compliance
3. Allowable emissions
4. Visible emission summary
5. Discussion of errors, both real and apparent
Source Operation
1. Description of process and control devices
2. Process and control equipment flow diagram
3. Process data and results, with example calculations
4. Representativeness of raw materials and products
5. Any specially required operation demonstrated
Sampling and Analysis Procedures
1. Sampling port location and dimensioned cross-section
2. Sampling point description, including labeling system
3. Sampling train description
4. Description of sampling procedures that deviated
from standard methods
5. Description of analytical procedures that deviated
from standard methods
Figure 1. Source sampling report format.
R-7
-------
Figure 1. (continued)
Appendix
1. Complete results with example calculations
2. Raw field data (original, not computer printouts)
3. Laboratory report, with chain of custody
4. Raw production data, signed by plant official
5. Test log
d. Calibration procedures and results
7. Project participants and titles
8. Related correspondence
H-8
-------
SOURCE TEST REPORT REVIEW FORM
PLANT SOURCE ID NO.
DATE REPORT RECEIVED RECEIVED FROM
REVIEWER DATE REVIEWED
REPORT CONTENTS
YES NO OK
Cover
1. Plant name and location
2. Source sampled
3. Testing company or agency,
name and address
Certification
1. Certification by team leader
2. Certification by reviewer .
(e.g., P.E.)
Introduction
1. Test purpose
2. Test location, type of process
3. Test dates _.
4. Pollutants tested
5. Observers' names (industry and
agency)
6. Any other important background
information
Summary of Results
1. Emissions results
2. Process data, as related to
determination of compliance
3. Allowable emissions
4. Visible emissions summary
5. Discussion of errors, both real
and apparent
H-9
-------
SOURCE TEST REPORT REVIEW FORM (Continued)
REPORT CONTENTS
Source Operation
1. Description of process and
control devices
2. Flow diagram
3. Process data and results, with
example calculations
4. Representativeness of raw
materials and products
5. Any specially required
operation demonstrated
Sampling Procedures
1. Sampling port location and
dimensioned cross section
2. Sampling point description,
including labeling system
3. Sampling train description
4. Description of sampling procedures
that deviated from standard methods
5. Description of analytical procedures
that deviated from standard methods
YES
NO OK
Appendix
1. Complete results with example
calculations
2. Raw field data (original, not
computer printouts)
3. Laboratory report, with chain of
custody
4. Raw production data, signed by
plant official
5. Test Log
6. Calibration procedures and
results
7. Project participants and titles
8. Related correspondence
H-10
-------
SOURCE TEST REPORT REVIEW FORM (Continued)
REPORT COMMENTS
Review Comments
Were calculations validated yes no
If yes, were any results greater than normal round off
errors yes no
Were any sampling or analytical procedures unacceptable
_y e s no
Were any process or control equipment operations
unacceptable yes no
List any unacceptable items_
List any additional items requested from the source or
tester after report reviewed yes no
List items and reason for request
This report is acceptable, unacceptable
give reason(s) for unacceptability
Comments reviewed by
H-ll
-------
IV. INSTRUCTIONS FOR PERFORMING THE EMISSION
TEST REPORT REVIEW
A. INTRODUCTION
Emission tests are conducted for a specific purpose and seldom address
all areas concerned with a detailed emission evaluation. Related data and
documentation such as process operation during the testing is seldom presented
in emission test reports. The primary purpose of the emission report review
is to evaluate the available data and to determine if the data can be used in
support of the specific project. Project data requirements should be estab-
lished before performing the emission test review. Data requirements differ
for standard setting, supporting existing standards, and screening studies.
Otherwise test data may be eliminated due to some minor deficiency unrelated
to the specific project data requirements.
Deficiencies in the report should be noted and properly explained. Recom-
mendations should be made for obtaining the desired information when the
report does not meet the established project requirements. Perform additional
visible emission observations, obtain a detailed process description, and
contact the state observer for additional data are examples of recommendations.
Important comments, observations, and determinations should be fully expressed
and explained to support the recommendations.
The following instructions describe the parameters used in performing the
emission test report review. If a section of this review is not applicable
(used) in the review procedure, the reviewer should write NOT APPLICABLE
across the entire page. Leave the instructions attached to the final review
so that any reader can use the review. The instructions are listed in chrono-
logical order for reference.
H-12
-------
B. REVIEW SUMMARY INSTRUCTIONS
This section is to briefly summarize the results of the report review.
Each phase of the emission measurement program should be addressed; specifi-
cally the purpose of the test, process operation, control equipment operation,
sampling and analytical procedures, and summary of results. Deficiencies
should be noted and specific recommendations and conclusions made.
Two pages have been provided for the review summary. Additional attach-
ments may have to be included for reports dealing with multiple pollutants or
sources.
Purpose of Test: State the purpose of the emission test. The following
are normal types of emission tests: compliance, control efficiency (manu-
facturer's guarantee), research, continuous monitor certification, etc.
Purpose of Review: Summarize what the data will be used for; such as in
the specific project, New Source Performance Standard background information.
Process Operation During Tests: Determine if process operations met
test requirements and summarize with conclusions. As a minimum, the report
should provide a process description and flow diagram and state whether the
process operated normally during the testing period. Summarize key process
data such as rated capacity, type of fuel used and other raw materials, and if
the process is cyclic, batch, or continuous.
Control Equipment Status During Testing: Summarize control equipment
data contained in the report and determine information necessary to complete
the specific project requirements. The report should ifentify the type,
manufacturer, and operating status of the control equipment during the test
period.
H-13
-------
Sampling and Analytical Procedures: Sampling and analytical procedures
should be adequately described. Sampling location, equipment, sample recov-
ery, analysis, calibrations, and quality assurance procedures should be
reviewed. Each step of the sampling and analytical procedures should be
properly documented. Generally, EPA reference and/or proposed methods should
have been used if applicable. If EPA reference methods were not used, evalu-
ate the test method used and compare to the applicable EPA reference method.
This comparison should be in detail and should determine if a bias in the
results is evident.
Sampling and analytical procedures for each pollutant should be evaluated
separately. This includes but is not limited to visible emissions, particle
size determinations, and process materials sampling.
Summary of Results: Summarize the emission data (average pollutant
concentration, visible emissions, particle size distribution, etc.) applicable
to the specific project. Extraneous data should not be included in this
summary. Note any bias (positive or negative) in the results due to sampling
or analytical procedures, process operation, etc. State why the results were
biased.
Recommendations and Conclusions: Specifically state how the data con-
tained in the report should be utilized in the project. Make concise recom-
mendations on how to improve or alleviate the data deficiencies. Conclusions
should address accuracy, precision, and reliability of the results. These
judgments should be discussed in the conclusions.
H-14
-------
C. REPORT DATA REVIEW INSTRUCTIONS
There are four sections to the review checklist: Introduction, Source
Operation, Test Procedures and Results, and Documentation. A separate page
has been provided for each section. The reviewer will have to use more than
one page for portions of the review if multiple pollutant sampling, several
test locations, and/or various process operating conditions are encountered.
For example, if a source was tested for sulfur dioxide and particulate at a
single location, use two separate pages for the Test Procedures and Results.
In addition, a blank form has been provided to encourage additional item
listing and review comments.
The reviewer should address each item by placing a check in the appropri-
ate column(s) or by indicating that this item is not applicable by writing
NA in the comments column.
The YES column should be checked if the report provides complete or
partial information requested for the item and the NO column if the informa-
tion was not provided. The OK column has been provided to indicate that the
data presented in the report for the specific item met project requirements.
All deficiencies or other observations should be entered in the comment
column. Every item will not be applicable to the general review requirements,
In this case, enter NA in the comment column for Not Applicable.
Project requirements should be established for each item in order to
effectively review the emission test report. The reviewer should consult
with the individual(s) for whom he is performing the review to establish the
specific project requirements. This approach is recommended to minimize
rejection of valid emission test reports/data due to report deficiencies not
applicable to the project goals.
H-15
-------
Following are some general guidelines and explanations for each section
of the Report Review:
C 1. INTRODUCTION
This section determines if the report includes who, what, when, where,
and why. All items in this section are self-explanatory.
C 2. SOURCE OPERATION
The emission test report should address the process and control equipment
status during the test period. Item 2 and 6 of this section refer to process
and control equipment monitoring. The emission test report should indicate
that the test team and/or monitor were aware of the process and control
equipment operating status. Statements in the report concerning normal
process operation, process upsets, or control equipment malfunctions during
testing are indications that process and control equipment monitoring were
performed during the testing. The raw materials input to the process should
be addressed. For example, the type of waste burned in an incinerator during
the tests should be described and compared to the normal type of waste burned
in the incinerator.
List any process, control equipment, or pollutant monitors mentioned in
the emission test report. Comments should be made concerning operation and
calibration status of the monitor.
C 3. TEST PROCEDURES AND RESULTS
Each page should address one type of pollutant and one sampling location.
This approach should be used to organize and clarify the comments for a
specific pollutant at a specific sampling location.
H-16
-------
The emission test report should address the items listed in this section
and the reviewer should be able to determine how each phase of the sampling
and analysis were performed. For example, if the sampling method requires
the sampling train to be purged, did the report mention this, along with how
long the train was purged? If the sample pH has to be adjusted during sample
recovery prior to analysis, did the report mention this was done?
Quality assurance procedures should be evident in the data presented if
not specifically addressed. Were audit samples used by the laboratory? If
samples were analyzed by another laboratory, were spike samples provided?
Was the dry gas meter calibration checked in the field? These are all examples
of quality assurance procedures. As a minimum, calibration requirements
specified by the test method should have been performed.
G 4. DOCUMENTATION
All field and analytical data used in the calculations should be recorded
on a data sheet. The reviewer should be able to perform the complete calcu-
lation procedure from the recorded data provided in the emission test report.
Any assumptions, such as the exhaust gas was assumed to be air with a molecular
weight of 29, should be specifically stated and validated.
All calibration procedures and data should have been provided in the
emission test report. Pre- and post-test calibrations required by the test
method should be available in the report.
D. SUMMARY DATA SHEET INSTRUCTIONS
This sheet has been provided to summarize the emission test report data.
Blank columns have been provided for the reviewer to summarize data of speci-
fic interest to the project. This could be visible emissions, particle size
data, or source stack conditions (percent moisture, stack temperature, etc.).
H-17
-------
SLIDE 208-0 NOTES
SOURCE TEST REPORT
REQUIREMENTS AND REVIEW
SLIDE 208-1
OBSERVER 'S SUMMARY REPORT
THE OBSERVER MUST DOCUMENT:
facility operation.
visible emission determination.
emission testing procedures.
other observations.
SLIDE 208-2
PERFORMANCE TEST REPORT
MINIMUM ACCEPTANCE CRITERIA
1. Certification by test team leader
2. Certification by reviewer (RE.)
3. Certification by facility representative
4. Legible data sheets
5. Calculations using equations from Federal Register
6. Example calculations for at least one run
7. Final results presented in English and metric units
and containing two significant digits
H-19
-------
SLIDE 208-3 NOTES
PERFORMANCE TEST REPORT FORMAT
1. Cover
2. Certification
3. Introduction
4. Sumary of Results
5. Source Operations
6. Sampling and Analytical Procedures
7. Appendix
SLIDE 208-4
REPORT REVIEW
PURPOSE
To evaluate and determine if data can be used in
decision making process.
REVIEW STRATEGY
1. Establish data requirements.
2. Use a written review package.
SLIDE 208-5
REPORT REVIEW PACKAGE
PARTI
Review Summary
PART II
Report Review
A. Introduction
B. Source Operation
C. Test Procedures and Results
D. Documentation
PART III
Summary Data Sheet
H-21
-------
SLIDE 208-6 NOTES
DATA REQUIREMENTS
Completeness
Accuracy
SLIDE 208-7
NOTIFICATION OF
COMPLIANCE STATUS
H-23
-------
SECTION I. NSPS DETERMINATION OF APPLICABILITY
Subject Page
1. New source performance standards determinations of
applicability (memo from Director, DSSE, to Directors of
Air and Hazardous Materials Division of Regions I, V, VII,
VIII, and IX, and Directors of Air and Waste Management
Division of Region II, III, IV, VI, and X, dated 1-27-82 1-3
1-1
-------
Code Reference
Question
Affected Deter-
regulation mination
Discussion
A- 3
A- 4
Letter to Ind.
State Bd. of
Health (July 3,
1973 - Suzuki)
Stauffer Chem.
Co., (July 31,
1973 - Wilson)
A- 7 Combustion
Engineering
(Beals, Region
IV, April 18,
1975)
A- 8 Santa Marina "
Refinery
(June 18, 1975
O'Connell-R.
IX)
60.14(e.)(2)
Would the replacement 60.2(h)
of mechanical dust
collectors with more
efficient electro-
static precipitators
bring a source with-
in the applicability
of NSPS?
Would an increase in
production rate of a
facility be considered
a change in the method
of operation?
May a boiler continue 60.11(d)
to operate should any
major unavoidable mal-
function occur in an
FGD system?
If modifications to 60.14
an existing facility
cause: (1) an in-
crease in emissions
of a pollutant; and
(2) an overall de-
crease in emission
of that pollutant
at the source, is
the facility subject
to NSPS?
No
Condi-
tional
Yes
No
This could not be considered a modi-
fication since there is no increase
in emissions.
An increase in production rate 1f
the design capacity of the facility
is not exceeded would not be consid-
ered a change in the method of op-
eration. However, an increase in
production rate above the design
capacity would be a change in the
method of operation.
However, it is clearly not the in-
tent of 60.11(d) to allow sources
to continue operating for any ap-
preciable length of time after mal-
functions are detected.
An overall decrease in emissions
from the source is not considered a
modification under 60.14(d).
Update - This determination was
based on the EPA definition of sta-
tionary source as a combination of
facilities. Using this definition,
NSPS did not apply when an existing
facility was modified such that net
emissions of any pollutant from the
entire plant (combination of facili-
ties) decreased. The U.S. Court of
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mlnatlon
Discussion
A- 9 Escanaba Paper
Mill (August 5,
1975, McDonald,
R-V)
A-ll Gleason, OGC,
to Carrol 1,
DSSE,
September 26,
1975
A-12 01 in Corp.
Sulfuric Acid
Plant
(October 8,
1975, Harrison,
(R-VI)
Does installation of
nozzles allowing
existing boilers to
burn No. 6 fuel oil
constitute a modifi-
cation?
Does modular control
of sources with in-
stallation phased
over an extended
time period meet
NSPS requirements?
Calculations indi-
cate that a process
modification will
probably not result
in an increase in
emissions, but this
is not certain. Are
performance tests
necessary?
60.14(e)(4) No
Sec. Ill, No
CAA.
60.2(h)
Yes
Appeals for Washington, D. C. in
ASARCO vs. EPA (January 27, 1978),
ruled the EPA definition must be
rejected as inconsistent with the
language of the Clean Air Act. If
modifications to an existing faci-
lity cause an increased in pollu-
tant emissions, the facility is
subject to NSPS, even if net emis-
sions at the plant decrease.
The facility is exempt under
60.14(e)(4) because this unit was
already burning #2 oil.
"EPA lacks affirmative authority to
permit operation of a source not in
total compliance with NSPS, unless
noncompliance is...beyond the source
owner's control."
Tests must be made before and after
the modification for emissions of
S02 and acid mist.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mlnation
Discussion
A-16
A-22
A-24
A-26
Memo (E. Reich
to Dave Kee)
October 15,
1976
Do NSPS apply to
sources reconstructed
after the proposal
date for the appli-
cable standard?
Memo (R. Wilson Is a new boiler in-
to I. Dickstein) stalled as an aux-
April 1, 1976
Memo (T.
Harrison to E.
Reich)
August 12, 1976
Revised
November 24,
1976
Letter to Clark
Oil & Refining
Corp. (T.
Voltaggio to
R. Bruggink)
August 27, 1976
60.15
Yes
60.5
No
iliary to an existing
boiler a modification
of an existing source,
bringing both the new
and old boilers under
NSPS?
Is a gas fired gene- 60.2(h)
rator which has been 60.1
modified to burn fuel
oil required to meet
NSPS only when burning
fuel oil?
No
Does the Tutwiler
method (UOP Method
9-59) adequately
demonstrate compliance
with S02 NSPS for the
Wood River Refinery?
60.8(b)
(4)
Yes
Reconstructed sources are bound by
the same applicability data as new
sources.
Only the new boiler would be subject
to NSPS.
NSPS apply to any stationary source
which contains an affected facility,
the construction or modification of
which is commenced after the date of
publication of the standard appli-
cable to that facility.
This determination does not mean
that the Tutwiler method is an ap-
proved equivalent or alternative
method for NSPS compliance.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation ruination
Discussion
A-27
Letter to Baker
& Daniels (T.
Voltaggio to J.
Carney)
August 26, 1976
A-38
Memo to R-IV
(E. Reich to
H. Bergman)
July 5, 1977
a) Will construction 60.2(h)
of a proposed sulfur
recovery facility con-
stitute modification
of a refinery?
b) Will construction
of a proposed sulfur
recovery facility at an
existing refinery con-
stitute construction of
a new sulfur recovery
plant under NSPS?
In determining whether 60.14
a modification has oc- (b)(l),
curred, does EPA or (b)(2),
the source have the (d)
burden of proving
whether or not emis-
sions from an existing
facility have in-
creased?
No The sulfur recovery facility will
not increase emissions from any af-
fected facility.
Condi- Proposed NSPS for sulfur recovery
tional plants were published in 41 FR
43866 on October 4, 1976. Should
construction commence after this
proposal date the facility would be
subject to NSPS.
Although 60.14(b)(l) indicates that
there is an initial burden on the
Agency to consider the emission fac-
tors in AP-42 to determine if there
is an increase in emissions, the bur-
den shifts to the source if AP-42 (or
another superior alternative emission
factor) fails to clearly indicate an
increase or decrease in emissions.
In the situation where the emission
level cannot be established clearly,
both the provisions of 60.14(d) and
60.14(b)(2) indicate that the bur-
den is on the source to demonstrate
to the Administrator's satisfaction
that the changed conditions do not
result in an increase in emissions.
You may proceed on the assumption
that, since emissions cannot be de-
termined clearly, there has been an
increase in emissions, and permit
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mination
Discussion
A-40
Memo to R-VI
(E. Reich to H.
Bergman)
July 19, 1977
A-42
Memo to R-IV
(E. Reich to
J. Uu)
September 29,
1977
a) Must EPA or the 60.11
source prove that a
malfunction has oc-
curred?
b) If a malfunction- 60.11(d)
ing source does not
expeditiously move
back into compliance,
is it still considered
to be in a state of
malfunction?
What procedure should 60.8(a)
be followed when an
affected facility has
not been performance
tested in the 180 day
period following start-
up due to shutdowns
caused by equipment
malfunction?
No
source documentation that there has
been no increase should the assump-
tion be disputed.
The source has the burden of proving
that a malfunction has occurred.
Such a source would be considered to
have moved from a state of malfunc-
tion to a state of noncompliance.
Consider issuing a 113(a) order re-
quiring the owner or operator to
notify the Administrator upon re-
startup (by telephone; to be fol-
lowed by confirmation in writing)
and also requiring a performance
test as soon as practicable there-
after but no later than 30 days
after restartup. If the facility
is unable to operate at the maximum
production rate for the initial per-
formance test, a subsequent perform-
ance test may be required when the
facility achieves maximum production
in order to assure compliance with
the standard.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mination
Discussion
A-50 Memo to R-VI
(E. Reich to
H. Bergman)
May 9, 1978
A-51 Letter to
Envirosphere
(W. Stevenson
to T. Carney)
May 22, 1978
M A-56 Memo to R-VIII
(E. Reich to
L. Vinson)
August 20, 1979
A-59 Memo (Reich to
Jacobs)
August 20, 1980
CO
Does conversion from 60.14
gas to coal, gas to (e)(4)
oil, or oil to coal in
a wet process Portland
cement kiln constitute
modification under
NSPS?
May source-specific 60.11(e)
opacity standards be
established under
NSPS?
May a source remove 60.13
continuous monitors (b), (e)
during performance
testing?
a) Where the per- 60.8
formanee standard is
stated in two signifi-
digits (e.g., 0.04
g/dscf), what pro-
cedures are to be ap-
plied by the region
in determining com-
pliance when the test
results are stated in
terms of three signifi-
cant digits?
No
Yes
No
A wet process port!and cement kiln
which switches from gas to oil, gas
to coal, or oil to coal, qualifies
for the exemption under 40 CFR
60.14(e)(4) because it has the capa-
bility to burn these alternative
fuels.
Under section 60.13(e), continuous
monitoring systems must be in con-
tinuous operation except for system
breakdowns, repairs, calibration
checks, and zero and span adjust-
ments. These exceptions do not in-
clude performance testing.
Legally, anything greater than 0.04
is a violation (e.g., 0.0401). How-
ever, most engineers tend to round
off results and therefore 0.044
would be reported as 0.04 and 0.045
would be reported as 0.05. A better
guide would be that anything showing
greater than a 10% excess is worth
considering for enforcement action.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mination
Discussion
b) What discretion do 60.8(b)
the regions and dele-
gated states have in
waiving testing re-
quirements? Can tests
be waived based on an
an agreement by the
source to conduct an-
nual leak checks or
other O&M practices?
c) Does the region 60.8(b)
have the authority to
allow the state to
waive the specific
stack test for the as-
phalt plant in
Geneva, NE?
Regions have authority to waive per-
formance tests or (in this case) a
retest providing they obtain assur-
ances from DSSE that the waiver is
consistent with national policy.
Delegated states cannot unilaterally
waive performance tests.
Yes Yes, see 59(b) above. As a policy
matter, stack tests should only be
waived in compelling circumstances.
In this case the question is whether
the stack test, already performed,
coupled with certain other actions,
can support a finding the standard
will be met, thus obviating the need
for a retest. These other actions
should include documentation by a
competent engineer that the cause
for any excess emissions has been
eliminated, and it can reasonably
be said that a retest would show
compliance.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulatlon urination
Discussion
D- 8 Northern 111.
Gas. Co. Plant,
Morris, 111.
(June 25,
(a) Would an abnormal
unavoidable short-term
peak operation of an
existing unit above its
1973 - Wilson) design capacity bring
the unit within the
applicability of NSPS?
60.40
(b) Is vaporized
naptha which is burned
in a new steam genera-
tor subject to NO
standards for gaseous
fossil fuel?
(c) Would a calcu-
lated value for NO
emissions based on
fuel and air rates of
of the boiler be ac-
ceptable to meet the
performance test or
the monitoring re-
quirements for a
steam generator?
60.44
60.46
60.45
No The applicability is based on the
maximum design capacity of the af-
fected facility, not the operating
rate. Furthermore, the standards
were not intended to cover abnormal
operations of any affected facility.
As indicated in 60.8(c), perform-
ance tests should only be conducted
under conditions of representative
performance (i.e., the conditions
under which the facility would op-
erate in a normal manner).
Yes Vaporized naptha is a gaseous fossil
fuel and thus, a unit burning this
fuel would be subject to standards
for NO applicable to gaseous fuels.
A
No/ EPA cannot presently accept a calcu-
Yes lated value for NO emission stan-
dards. Performance tests must be
conducted. However, this calcula-
tion approach may be used for con-
verting continuous monitor measure-
ments from ppm to Ib/mm Btu.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mination
Discussion
D-ll Babcock &
Mil cox
(August 2,
1973 - Wilson)
(a) Would the appli- 60.40
cation of refuse 60.2(h)
wastes, wood wastes,
bark, vegetation, ani-
mal or other waste by-
products as an alterna-
tive fuel for an exist-
ing fossil fuel-fired
steam generator con-
stitute a "modifica-
tion" to such
facility?
(b) Is a new steam Subparts
generating unit which D & E
has a design capacity
of more than 250 mm
Btu/h fossil fuel heat
input and is designed
to consume more than
50 tons per day of
solid waste subject to
either or both of the
standards for steam
generators and in-
cinerators?
No
Undeter-
mined
It is the interpretation of this of-
fice that the use of refuse waste as
an alternative fuel would not bring
an existing fossil fuel-fired steam
generator within the scope of appli-
cability of NSPS since refuse does
constitute fossil fuel as defined by
60.41(b).
This situation is presently under
review by EPA headquarters. Any
requests for determinations on this
subject must be forwarded to DSSE
for resolution. This issue relates
to new construction and is not a
modification issue, as in D-4.
Update - The steam generating unit
would be subject to both Subpart D
(or Da, if applicable) and Subpart
E.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation 'mination
Discussion
D-ll Babcock &
Wilcox
(August 2,
1973 - Wilson)
(c) Is the applicabi- 60.40
lity of NSPS based on
the normal operating
capacity of a steam
generator?
(d) Is the heat gen- 60.40
erated by waste by-
products cons i dered i n
calculating the heat
input to an appli-
cable steam generator?
(e) How would the 60.46(.b)
performance test be
conducted for a fossil
fuel-fired steam gen-
erator which burns
waste by-products as
supplemental fuel?
(f) Does the heat in- 60.40
put to steam generating
units include sensible
heat from combustion
air or fuels?
No The applicability is based on the
maximum design capacity of the af-
fected facility, not the operating
rate.
No Compliance is judged only on the
amount of heat and combustion ef-
fluents added by fossil fuel. The
performance test for determining
compliance must be conducted with no
interference from the turbine
exhaust gases.
Condi- Such unit would be required to fire
tional 100% fossil fuel during the perform-
ance test. The test should be con-
ducted at or above the normal steam
production rate, but preferably at
design capacity in order to avoid
the necessity of additional tests if
normal operating capacity is in-
creased.
No Only the gross heating value of the
fossil fuel is used to determine
heat input to steam generating
units.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mination
Discussion
to
D-23 Union Carbide
Corp. in South
Charleston,
W. Va
(February 4,
1974)
(g) Do waste by- 60.41(b)
products from petro-
chemical processes
constitute fossil
fuel?
(h) If gas turbine 60.40
exhaust gases are con-
sumed in a new or modi-
fied fossil fuel-fired
steam generator as com-
bustion air, would the
contribution from the
turbine exhaust gases
be added to the fossil
fuel combustion
(boiler) effluent in
determining compliance?
Does the installation 60.40
of two or more boilers,
each rated at < 250 mm
Btu/h but the sum of
which is > 250 mm
Btu/h, constitute con-
struction within the
meaning of NSPS?
No
No
No
It is the interpretation of this of-
fice that waste by-products such as
CO from FCC units are not fossil
fuels as defined by 60.41(b). The
definition covers only those fossil
fuels which are not waste materials.
Compliance is judged only on the
amount of heat and combustion ef-
fluents added by fossil fuel. The
performance test for determining
compliance must be conducted with no
interference from the turbine ex-
haust gases.
The affected facility is defined as
each unit (boiler) with a related
design capacity of more than 250 mm
Btu/h heat input of fossil fuel.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation nrination
Discussion
D-34 Dairyland Power (a) What degree of 60.8(c)
Co-op, Alma
Wisconsin Plant
(May 15, 1974,
Pratt, R-V)
sulfur content (maxi-
mum, minimum, inter-
mediate) in coal would
be considered repre-
sentative conditions
for a performance
test?
(b) Can EPA determine
violation of the S02
emissions over the
period of a year?
60.8(f)
(c) Can excess emis- 60.2(q)
sions caused by varia-
tions in sulfur content
of fuel be considered
a malfunction?
Condi- Performance testing while burning
tional coal with the maximum expected sul-
fur content would be required in
order to assure compliance under the
worst possible conditions.
No Current regulations determine viola-
tion of the emission standard by a
performance test which calls for 3
consecutive sampling runs of approxi-
mately 1 hour duration each. Thus
the regulations provide for an aver-
aging time of approximately 3 hours.
Each sampling run consists of twenty
minute samples taken at 30 minute
intervals.
No This situation could not be consid-
ered a "sudden and unavoidable
failure" since, under most circum-
stances, excess sulfur content is
forseeable based upon fuel analyses.
The technology exists to blend vari-
ous types of fuels in order to as-
sure compliance with the S0? stan-
dard. c
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mination
Discussion
D-38 Shell Oil
Company
(September 27,
1974, McDonald.
Region V)
Ol
D-63 Letter to
Environmental
Data Corp. (R.
Wilson to H.
Lord)
January 19,
1976
D-77 Letter to
Sirrine Co.
(T. Gibbs to H.
Stokes) May 16,
1977
(a) Can one sample 60.46(d) Yes
for S0?be as long as
70 minutes?
(b) What constitutes 60.46(d)
a complete sampling
run for S02?
(c) How is compliance 60.8(f)
determined?
May C02 continuous 60.45 Yes
monitoring equipment
be installed down-
stream of a wet lime-
stone scrubber de-
sulfurization unit?
What should be the
length of the peak
operating rate for
a boiler?
60.46(d) requires a minimum sampling
time of 20 minutes. It does not
specify a maximum time.
A complete sampling run requires two
samples taken at approximately 30
minute intervals. The total elapsed
time for one run under the condi-
tions suggested by the company would
be 170 minutes (70+30+70).
Each performance test for compliance
will require three separate runs.
Compliance will then be determined
on the basis of the arithmetic mean
of the three runs.
A 1% increase in the Fc factor is
required when limestone scrubbing is
utilized. The regulations will be
amended accordingly.
One to four hours.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation nvination
Discussion
D-79 Memo to R-V (E.
Reich to I.
Gross)
October 7, 1977
D-98 Memo (Reich to
Gardebring)
November 21,
1980
01
Is permanent derating
of steam generators
an acceptable method
of avoiding applicabi-
lity to NSPS, Subpart
D?
(a) Are ramping and 60.8(c)
soot blowing cycles
considered representa-
tive conditions for
coal-fired steam
generators?
Subpart D Yes
Soot
blowing-
Yes
Ramping-
No
(b) Under what cir-
cumstances can Method
17 be substituted for
Method 5, in perform-
ance testing?
40 CFR 60,
Appendix A
The derating must be accomplished
through a permanent physical change
to the affected facility which will
preclude it from operating at a ca-
pacity greater than the derated
value.
Soot blowing is a normal part of
every source operation, and it would
be artificial to cut the cycle off
during the performance test. Soot
blowing was considered in developing
Subpart D and in subsequent amend-
ments to that standard.
Ramping is not necessarily represen-
tative of source operation, particu-
larly in this case where the source
in question is base loaded. Addi-
tionally, there is little evidence
to support a contention that ramping
was considered in the original Sub-
part D testing data.
Method 17 can be used as an alterna-
tive to Method 5 at fossil fuel-
fired steam generators when (1) the
flue gas temperature at the sampling
location is consistently less than
or equal to 320 F and (2) the flue
gas at the sampling location is un-
saturated with water vapor. For
flue gases unsfaturated with water
vapor and having temperatures great-
er than 320 F, the acceptance of
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation urination
Discussion
F- 6 Letter to
Portland Cement
Assn. (W.
Johnson to C.
Schneeberger)
June 24, 1976
How do NSPS emissions 60.62(a)
standards apply to a (1), (2)
new operation involving
a 4 stage preheater with
a precalciner and,bypass
from which there are two
outlets for emissions?
Method 17 as an alternative to
Method 5 will be based on the demon-
stration that the particulate matter
concentration determined by Method
17 is greater than or equal to the
particulate matter concentration
that would be measured by Method 5
at a temperature of 320 F. If site
specific sampling logistics preclude
or compromise the use of Method 5,
requests for the alternative use of
Method 17 should be addressed to the
appropriate regional office.
With the bypass closed, the system
must meet the particulate emission
and opacity standards of 60.62(a).
With the bypass open, simultaneous
sampling at both outlets must yield
a combined particulate emissions
rate no greater than 0.30 Ib/ton of
feed and each emission point is
limited to a 20% opacity require-
ment.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mi nation
Discussion
I-11 Memo to R-VII
(E. Reich to E.
Stephenson)
March 21, 1977
O3
(a) If an existing 60.14
asphalt concrete plant (e)(4)
has an increase in
emissions due to the
recycling of asphalt
and there are np_ phy-
sical changes to the
plant necessary to
accommodate the use of
recycled asphalt ma-
terial, does the plant
become subject to
NSPS?
(b) If an existing 60.14
asphalt concrete plant
has an increase in
emissions due to the
recycling of asphalt,
and there are physi-
cal changes necessary
to the plant to ac-
commodate the use of
recycled asphalt ma-
terial, does the-plant
become subject to NSPS,
Subpart I?
(c) Must a plant
which is presently
covered by NSPS con-
tinue to meet NSPS
while recycling as-
phalt?
No
"The existing facility was designed
to accommodate that alternative use"
(recycled asphalt).
In this case the above exception
does no apply.
60.90
Yes
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mination
Discussion
1-12
Memo to R-X
(E. Reich to
R. Bauer)
September 28,
1978
0- 4
Memo (R. Duprey
to Norman
Edminston
February 27,
1976
(d) How should per-
formance tests be con-
ducted for a plant
which is recycling
asphalt?
Is one performance 60.3
test run performed on
an asphalt concrete
plant with an ap-
parently adequate
control device suf-
ficient to determine
compliance with NSPS,
Subpart I?
(a) Do NSPS cover 60.150
grit, scum, and waste
lime sludge burned in
the furnace along with
the sewage sludge?
(b) Do NSPS cover in- 60.150
cinerators used wholly
for the purpose of re-
activating lime sludge?
No
Yes
(c) Do NSPS require
intallation of a con-
tinuous monitoring de-
vice for monitoring,
recording, and storing
data on sewage sludge
charged to the furnace?
60.153(a)
(D
No
No
Performance tests should be con-
ducted while processing recycled ma-
terials in the normal manner at or
above normal production rate, but
preferably at design capacity.
The source should be required to
conduct performance tests in accord-
ance with the requirements of 40 CFR
60.8.
Flow rate measurements must be made
of all such inputs.
Where nonrecoverable waste lime is
combined with sewage sludge in a
sewage sludge incinerator, the stan-
dard is applicable.
The purpose of the monitoring device
is to measure sludge input to the
furnace during the compliance test.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mination
Discussion
Q- 1 Memo (D. Bell
to G. Stevens)
May 12, 1976
S- 1 Memo to Region
III (E. Reich
to S.
Wassersug)
January 19,
1978
0 AA-4 Memo to Region
VII (R.
Shigehara to
D. Durst)
August 3, 1978
GG-7 Memo (Reich to
Walker)
June 3, 1981
Do NSPS for zinc 60.171 Yes
smelters apply to
roasters at an
electrolytic zinc
smelter?
What is a reasonable Subpart S
percent of the time
to expect violations
of NSPS considering
all emission test
data?
Is an alternate 60.8(b) Yes
testing procedure ac-
ceptable for testing
2 new NUCOR steel
electric arc furnaces?
Can the analytic Subpart GG Yes
methods, ASTM - 60.335(a)
01945-64(1976), be (2)
used to determine
the nitrogen content
in natural gas and
fuel oil samples for
stationary gas tur-
bines?
A roaster is defined as any facility
in which a zinc sulfide ore concen-
trate charge is heated in the presence
of air to eliminate a significant por-
tion (more than 10%) of the sulfur
contained in the charge.
NSPS are expected to be met at all
times except during periods of
startup, shutdown, or malfunction.
We have the discretion, however, to
require a retest of a facility which
fails a compliance test due to what
appears to be random variability in
emissions.
The alternate testing method that
NUCOR steel suggested will be ac-
ceptable in this case.
Contact this office if details on
the alternate method are desired.
The Agency has reviewed and accepted
these analytic methods.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation mination
Discussion
WAV- Memo to Region (a) Can a waiver
1 VI (D. Costle under Section lll(j)
to A. Harrison) (l)(a) be issued to a
January 25, source which has been
1978 in operation?
lll(j)(l)
(a) CAA
(b) Should notice and lll(j)(l)
opportunity for public (a) CAA
hearing be given before
the Administrator de-
nies a request for
waiver under Section
No The prospective language of Section
Hl(j) clearly indicates that a
waiver request is to be filed before
operation commences.
Update - In Central Illinois Public
Service Company vs. EPA (March 23,
1979) the Seventh Circuit Court of.
Appeals concluded that lll(j) does
not require application prior to
startup of the source. "Even if
lll(j) was construed as impliedly
providing for pre-startup applica-
tion, such a provision would at most
be directory rather than mandatory
as startup per se has no substantive
significance to waiver eligibility."
No No source has the right to a waiver.
Therefore a source has no rights
which must be protected in the no-
tice and hearing process.
(continued)
-------
(continued)
Code Reference
Question
Affected Deter-
regulation ruination
Discussion
WAV- Memo to R-VI
2 (Reich to
Dutton)
June 11, 1979
May a nitric acid 60.70
plant receive an CAA 111
exemption from NSPS (j)(l)
while installing a
more energy-efficient
abatement system?
No NSPS for nitric acid plants only
permits the granting of exemptions
for use of an innovative technologi-
cal system or systems of continuous
emission reduction. N-ReN has not
proposed the use of an innovative
system (its eligibility for such a
waiver is also suspect) and the ni-
tric acid NSPS does not permit the
granting of an exemption based on a
source's financial situation.
INS
no
-------
SECTION J. AGENCY APPROVAL OF EQUIVALENT
AND ALTERNATIVE TEST METHODS
Subject Page
1. Use of the bias concept for alternative methods evaluation J-3
2. Approval of alternative and equivalent source test methods
applicable to enforcement of national emission standards J-10
3. Reference Methods 1 through 8 allowable options J-13
4. Slides J-31
J-l
-------
USE OF THE BIAS CONCEPT FOR ALTERNATIVE METHODS EVALUATION
by
William DeWees and Kirk Foster
When the EPA reference methods were first promulgated, the agency had the
foresight to know that under certain circumstances all specifications of the
performance test could not be met. Provisions were therefore devised to ac-
commodate these circumstances. These provisions are in the Federal Register
Title 40 Part 60.8(b) and stated as follows:
(b) Performance tests shall be conducted and data recorded in
accordance with the test methods and procedures contained in each
applicable subpart unless the Administrator (1) specifies or approves,
in specific cases, the use of a reference method with minor changes
in methodology, (2) approves the use of an equivalent method, (3) ap-
proves the use of an alternative method the results of which he has
determined to be adequate for indicating whether a specific source
is in compliance, or (4) waives the requirement for performance tests
because the owner or operator of a source has demonstrated by other
means to the Administrator's satisfaction that the affected facility
is in compliance with the standard. _ Nothing in this paragraph shall
be construed to abrogate the Administrator's authority to require
testing under section 114 of the Act.
To date, no source category has demonstrated compliance with the use of any type
of emissions control equipment or by any other means with enough certainty to
allow the use of a waiver. At present this essentially eliminates the use of
Option 4: The Waiver.
To have an equivalent method, written criteria and a comparison protocol
must be developed to demonstrate comparability with the reference method. EPA
has not developed the equivalency protocol. At present this eliminates Option 2
The Equivalent Method.
Allowance of minor modifications to the reference method and the approval
of an alternative method are the only two options used at present. Option 1,
Minor Modifications to the Reference Methods, are changes due to site specific
problems or as a result of circumstantial occurrences. These changes, to be
allowed, must meet at least one of the following criteria.
J-3
-------
Draft, 8/81
A. The effect will be insignificant on the final emission data
results; or
B. The change will accommodate a situation that is considered
unique and would apply only to the sample site for which it
is allowed.
An example of each case would be 1) allowing a sample run planned for two
hours but terminated four minutes before completion as a result of product
production shutdown to be considered valid and 2) allowing the facility to
skip one of the sampling points due to interference of a structural support
in the stack. The nature of these minor modifications allows approval at
any level by technically qualified agency personnel.
Presently, the only allowable option that could have national significance
is the approval of an alternative method. When industry requests the use of
an alternative method, an agency response is expected within a reasonable
time. The responsible agency generally does not have either the time or the
money to determine the exact correlation between the alternative method and
the reference method. For this reason, a procedure was needed to evaluate and
approve alternative methods without the time and expense to the agency for com-
parative testing research. Thus, as a practical means of saving both time and
money, the "bias concept" can be used to determine the acceptability of alter-
native methods. The bias concept has only one rule. When the bias (from prior
knowledge or comparative data) is determined to be insignificant or against
(deterrent) the initiating party or the party who bears the burden of proof, the
alternative method or procedure is acceptable for enforcement or compliance
testing. For NSPS this equates to agencynegative bias; industrypositive bias.
The direction of the bias or whether the alternative method would tend to
produce an increased or decreased emission measurement result can many times
be logically determined from prior knowledge. The magnitude of the bias is the
parameter that would take a research project to establish. However, when the
bias cannot be logically determined from prior knowledge, the source-must supply
comparative data if a quick response to the request is expected. Although the
the bias concept has only one rule, the application of that rule can be confusing.
Table 1 is a summary of the five cases of application for alternative methods or
procedures. The following discussions explain the acceptability for each of the
five cases for when industry is the initiating party or bears the burden of
proof and when the agency is the initiating party or bears the burden of proof.
J-4
-------
TABLE 1. SUMMARY OF THE BIAS CONCEPT FOR EVALUATING ALTERNATIVE METHODS
Types of alternative methods/procedures
requests
Facility performing test to
prove compliance or initiat-
ing request for alternative
methods
Agency performing test to prove violation
or requiring alternative methods
Case 1: Use of an alternative method
Acceptable if the alterna-
tive method produces values
equal to or greater than the
reference method
Acceptable if the alternative method pro-
duces values equal to or less than the
reference method
Case 2: Use of alternative procedures
allowed by reference methods to cor-
rect data that exceeds control limits
(i .e., under isokinetic)
Acceptable since they may
cause either no bias or a
high bias
Unacceptable. The procedure may be re-
versed to cause a low bias
Case 3: Use of alternative sample
train components and configurations
allowed by the Federal Register
(i.e., stainless steel probe liner
for Method 5 and elimination of IPA
impinger for Method 6 coupled with
Method 5)
Acceptable since this may
cause a high bias
Unacceptable. These modifications should
not be used if possible
Case 4: Use of QA Handbook, Volume III
alternative procedures for compliance
testing
Acceptable since some proce-
dures may cause a high bias
Acceptable for procedures that cause no
bias. In case of a high bias, the pro-
cedure must be reversed if possible or
not used
Case 5: Use of Federal Register and QA
procedures for certifying continuous
emission monitors
Whenever possible biasing or
adjustment techniques should
be avoided. If it becomes
necessary to use these pro-
cedures, the CEM's can be
certified if both sets of
data (corrected or uncor-
rected) meet the accuracy
specifications
Whenever possible biasing or adjustment
techniques should be avoided. If it be-
comes necessary to use these procedures,
the CEM's can be certified if both sets
of data (corrected or uncorrected) meet
the accuracy specifications
NOTE: The bias concept is not used to evaluate an alternative method or procedure when the reference method does
not produce representative emission results.
-------
-.art,
Important: The use of the bias concept for alternative methods should be
used only when the reference method provides representative results. If the
industry requests an alternative method because the reference method produces
false or nonrepresentative emission test results, the bias concept is not to
be applied in evaluating the alternative method.
CASE 1
To apply the bias concept, the purpose of the enforcement or performance
test must be understood. The EPA reference methods used in the support of
NSPS and NESHAPS are used to provide industry with a means of demonstrating
compliance with the applicable standard. It is important to note that the
performance of these tests is the responsibility of the industry and that
the test data are used by the industry to demonstrate compliance rather than
by the agency to prove violation. Therefore, when the industry requests an
alternative method, it is acceptable'if the alternative method produces emis-
sion test results equal to or greater than the reference method.
The alternative method must produce emission test results equal to or less
than the reference method when the agency:
a. requires the industry to use a specific alternative method,
b. performs or pays for the performance of the testing, and
c. proves the source is in violation with existing regulations.
CASE 2
Several alternative procedures had been routinely allowed between 1971
and 1977. As a result, when the revised version of Reference Methods 1 to 8
were promulgated on August 18, 1977, many of the alternative procedures were
incorporated into the methods. These alternative procedures were allowed
based on the bias concept and will produce emission test results equal to or
greater than the reference method procedures. The alternative procedures can
be grouped into two categories: data correcting techniques and methods varia-
tion procedures. . Two examples of the data correcting techniques are:
a. when the maximum allowable leak rate is exceeded at the maxi-
mum vacuum obtained during the test, the tester is allowed to
subtract a sample volume equal to the maximum leak rate for the
entire testing period (or void the test); and
J-6
-------
b. when the pretest and post-test dry gas meter calibration do not
agree within the allowable limit, the calibration factor that
yields the smallest sample volume is to be used.
Both procedures will produce emission test values equal to or greater than the
standard reference method procedures.
When industry is having the test performed to prove it can comply with
air pollution regulations, the use of any or all of the alternative procedures
in the EPA reference methods are acceptable.
When the agency is having the tests performed or must prove violation with
existing regulations, the alternative procedures should either not be allowed or
must be reversed to produce emission test values equal to or less than the ref-
erence method. In these examples, the agency would not subtract any sample value
from the leak rate; it would use the dry gas meter calibration factor that pro-
duces the greater sample volume. It is not advisable, however, for the agency to
use data correcting techniques to adjust data that do not meet the reference methods
allowable limits.
CASE 3
The second grouping of alternative procedures in the reference methods
is allowing sample train components and configurations to be changed, such as
using stainless steel for the probe liner materials for Method 5, eliminating
the IPA impinger for S02 determination when Methods 5 and 6 are performed simul-
taneously, and allowing the filter to be heated at any temperature less than
250°F for Method 5. All three procedures should produce emission test results
equal to or greater than the standard reference method procedures.
When industry is having the test performed to prove compliance these
procedures are acceptable. However, when the agency is having the test per-
formed or must prove violation, these procedures should not be used unless
the agency is sure that the effect is insignificant.
CASE 4
The Quality Assurance Handbook, Volume III, was patterned after the Federal
Register with its use of the bias concept for allowing several other alterna-
tive procedures for correcting data. The alternative procedures suggested
J-7
-------
- . a i (,, O/ O i
in Volume III provide emission values that will produce equal or greater
than true results. These alternative procedures were designed for compliance
testing by the facility only. The same rationale and techniques should be used
with the QA Handbook that were used in Cases 2 and 3 with the reference method
alternative procedures.
CASE 5
The main purpose of the EPA reference methods and Quality Assurance Hand-
book, Volume III is to provide a means of demonstrating compliance with Federal
regulations. In these cases the biasing and data adjustment techniques are
acceptable. Another purpose, which is increasing in use, is the certifica-
tion of the continuous emission monitors using the reference method results
as the true value results. In these cases the alternative procedures should
not be used when possible.
At times the data correcting techniques may have to be employed. When
the reference methods are used to check the relative accuracy of continuous
monitors, the results will have to be calculated using both pretest and post-
test calibration values since the tester has no way of knowing which is correct.
The relative accuracy should then be calculated by combining all the results
that produce the best relative accuracy and then the worst relative accuracy.
If the worst relative accuracy is in compliance with the standard then the mon-
itors would be certified. If the best relative accuracy does not comply then
the monitors would not be certified. If the best accuracy complies and the
worst accuracy does not comply then the agency will have to decide if the
monitors should be certified or not. The best way to avoid this dilemma is
to make calibration checks in the field.
In summary, the use of the bias concept for the evaluation of alternative
methods and procedures can be a useful tool. As with all tools, it works best
on the correct application. There are four applications for which its use is
not recommended.
1. Do not.use the bias concept when the reference method does not
provide the correct emission measurement value for the regulated
pollutant.
2. Minimize or eliminate the use of the bias concept when the ref-
erence method tests are used for the certification of continuous
emission monitors.
J-8
-------
3. Keep in mind that since the margin by which most industries
can comply with Federal regulations is small, an alternative
method with a large bias may not accomplish the intended goal
of demonstrating compliance or violation.
4. When the bias cannot be determined from prior knowledge or exist-
ing comparative data, the agency would have to deny the alterna-
tive method or the agency or industry would have to spend the time
and money necessary to provide the comparative data.
J-9
-------
SUBJECT:
FROM:
TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
Approval of Alternative and Equivalent Source Test DATE:
Methods Applicable to Enforcement of National
Emission Standards
B. J. Steigerwald, Director
Office of Air Quality Planning and Standards (MD-10)
Director, Enforcement Division, EPA Regions I - X
Director, Surveillance and Analysis Division, EPA Regions I
SEP 197$
- X
In the March 8, 1974, Federal Register, the definitions of "Equiva-
lent Method" and "Alternative Method" were added to 40 CFR 60 Standards
of Performance for New Stationary Sources. Similar provisions are con-
tained in 40 CFR 61, pertaining to hazardous pollutant standards. These
provisions provide a mechanism for approval of non- reference source test
methods.
The purpose of this memorandum is to set forth procedures which
clarify the responsibility for approval of alternative or equivalent
methods. Under these procedures the Regional Offices retain that
flexibility needed to meet EPA and State testing needs; OAQPS will
serve as a point of coordination and will retain approval authority
and provide technical assistance in cases where decisions could affect
uniform application of standards. The establishment of OAQPS as a focal
point for this authority, and the procedures outlined in this memorandum
have been discussed with and received concurrence from the Division of
Stationary Source Enforcement and the Office of Research and Development
programs which are involved in source test activities.
Purpose of Alternative Methods
The primary intent of the alternative method provisions is to accom-
modate two situations:
(1) The need to approve a method which would probably produce
results equivalent to reference method results but which
could not (due to lack of time, excessive cost, etc.) be
demonstrated as an equivalent method. Examples would be
substitute probe materials, differing sample train component
configurations, and procedural deviations. Approval may be
based on engineering evaluation or other relevant information.
(2) The need to approve less complex methods which, based upon
evaluation. or test data, produce results sufficiently
accurate to assure compliance in specific cases. One example
would be the case where an additional filter or wet collector
is added to the reference method sample train. Sub-isokinef>c
J-10
-------
sampling would be a second such example. In either case,
the results v.-ould not be equivalent to reference method
results, but would nevertheless assure compliance.
Neither of these needs can be readily accormiodated under the pro-
visions allowing "equivalent method(s)," since these require demonstra-
tion of a "consistent and quantitatively known relationship to the
reference method." In fact, demonstrating the equivalency of source
test methods is complex and not, as yet, adequately resolved. This is
discussed in further detail on page 3 of this memorandum.
Approval Authority
Approval of alternative methods may be desired in a number of
instances. These range from the case where an engineer must decide
in the field whether to approve use of less than the full number of
required sample points in a traverse (as might be desired due to
limited sample space), to the case where a State desires blanket
approval for use of an alternative method in carrying out delegated
authority for enforcement of federal standards.
The former case is one which would not seriously affect uniform
application of standards and approval authority is in the Regional
Offices. The latter case could result in a standard being applied
differently in different areas. Therefore, to insure uniformity and
technical quality in test methods used in the enforcement of national
standards, OAQPS will retain approval authority for cases where an
alternative method would effectively replace a reference method. While
precisely defining all requests which may fall in this category is not
possible, generally GAQPS approval will apply to all methods affecting
more than one source. In such cases, requests for approval should be
forwarded to the Director, Emission Standards and Engineering Division,
OAQPS. When such a request is received, ESED will perform a technical
review of the method.
This review will consider, for example, whether the method is
written in sufficient detail to assure acceptable precision and the
likely comparability of results, between the candidate method and the
reference method. The results of the review after appropriate
consultation and coordination with the Division of Stationary
Source Enforcement, will be provided to the respective Regional
Office, along with a decision on approvability. The decision will
constitute a strictly technical interpretation of the method and,
thereby, of the applicable standard. This interpretation is out-
side the scope of, and is not intended to duplicate or supersede
any Office of Enforcement decision which might otherwise be involved
in an enforcement action.
J-ll
-------
Generally, any basis for a negative decision will be clear and
will not likely be subject to serious dispute by the requesting agency.
However, in the case of a State test method where the question of
delegation of authority is involved, failure to approve an alternative
method could present a potential problem. Here the need to assure
that valid, supportable test methods necessary for enforcement of
national standards may come in conflict with the desire for uniform
Intrastate methods, or for preservation of longstanding local test
methods. When such cases occur, resolution will be needed on a case-
by-case basis. In this event, OAQPS will be available to assist the
Regional Offices in working with technical staff from the affected
agencies. Through a close working level relationship, resolution of
these problems should be possible.
Equivalency Criteria
As noted briefly above, the matter of equivalency is more com-
plicated than determining adequacy of an "alternative method" and
should be noted. Essentially, a determination of equivalency means
that the candidate method and the reference method produce the same
results under specified conditions. This assumes that the reference
method can be characterized exactly in terms of accuracy and precision
and that procedures are available which allow comparison of the two
methods. In fact, such procedures and information are not available
for field sampling aspects of source testing. Further these procedures
may be prohibitively expensive to apply in the field. Thus, for particu-
late matter, which is not an absolute quantity, and where the field
procedure constitutes the major portion of the method, equivalency may
be a mute issue. On the other hand, the analytical portion of methods
Involving identification"of specific compounds, such as fluoride or
beryllium, are more amenable to determination of equivalency.
The Office of Research and Development is currently involved in
standardizing reference methods and in considering equivalency
criteria. These are not available yet; however, requests for equiva-
lency determinations can be considered on a case-by-case basis. Such
requests should also be .directed to the Emission Standards and Engineering
Division which will coordinate the evaluation with appropriate Office of
Research and Development Laboratories. Generally, a determination of
equivalency will require, as a mini-uim, a detailed written method, results
of tests comparing the candidate i?.=thod against the reference method, and
results involving inter-comparison of the candidate method performed by
different laboratories and/or personnel.
cc:
Aubrey P. Altshuller
Doyle Borehers
John S. Nader
S. David Shearer
Roger Strelow
Edward F. Tuerk
Richard Wilson
Director, Air and Hazardous Materials Division, EPA Regions I - X
J-12
-------
REFERENCE METHODS 1 THROUGH 8 ALLOWABLE OPTIONS
by
Thomas Clark
INTRODUCTION
This document consists of a tabulation of the allowable options to
Reference Methods 1 through 8 as revised and published in the Federal Register,
Volume 42, No. 160, Thursday, August 18, 1977. Each option is listed along
with the party that has the prerogative to use the option and the expected
affect on the final test results.
In review, there are two major categories that changes or alterations to
the test methods may fit in. These categories are minor changes in the ref-
erence methods and changes in specific equipment or procedures. Minor changes
in the reference method should not necessarily affect the validity of the
results and it is recognized that alternative and equivalent methods exist.
Section 60.8 provides authority for the Administrator to specify or approve
1) equivalent methods, 2) alternative methods, and 3) minor changes in the
methodology of the reference methods. It should be clearly understood that
unless otherwise identified, all such methods and changes must have prior
approval of the Administrator. An owner employing such methods without ob-
taining prior approval does so at the risk of subsequent disapproval and
retesting with approved methods.
Within the reference methods, certain specific equipment or procedures
are recognized as being acceptable or potentially acceptable and are specifi-
cally identified in the methods. The items identified as acceptable options
may be used without approval but must be identified in the test report. The
potentially approvable options are cited as "subject to the approval of the
Administrator" or as "or equivalent". Such potentially approvable techniques
or alternatives may be used at the discretion of the owner without prior
approval. However, detailed descriptions for applying these potentially
approvable techniques or alternatives are not provided in the reference
methods. Also, the potentially approvable options are not necessarily accept-
able in all applications. Therefore, an owner electing to use such poten-
tially approvable techniques or alternatives is responsible for
J-13
-------
3.
Assuring that the techniques or alternatives are in fact
applicable and are properly executed;
Including a written description of the alternative method
in the test report (the written method must be clear and
must be capable of being performed without additional in-
struction and the degree of detail should be similar to
the detail contained in the reference methods); and
Providing any rationale or supporting data necessary to
show the validity of the alternative in the particular
application.
Failure to meet these requirements can result in the Administrator's dis-
approval of the alternative.
In the interest of clarity, the definition of the "Administrator" as
defined in Section 60.2 of subpart A consist of "any authorized representa-
tive or the Administrator of the Environmental Protection Agency". Authorized
representatives are EPA officials in EPA regional offices or state, local
and regional governmental officials who have been delegated the responsibil-
ity of enforcing regulations under 40 CFR 60. These officials in consulta-
tion with other staff members familiar with technical aspects of source test-
ing will render decisions regarding acceptable alternate test procedures.
METHOD 1 - SAMPLE AND VELOCITY TRAVERSE FOR STATIONARY SOURCES
Allowable options
1. Principle and applicability
1.2 Applicability
Sample site requirements for
new facilities
2. Procedure
2.3.1 Circular stacks
Use of a particulate traverse
which is not in the plane con-
taining the greatest expected
concentration
2.3.2 Rectangular stacks
Resolve problem of traverse
points too close to stack wall
Prerogati ves
administrator
tester
Affect on
final results
varies
equal or higher
administrator insignificant
J-14
-------
A11 owable opti ons
2.4 Verification of absence of
cyclone flow
Alternative methodology to per-
form accurate sample and
velocity traverses at a sample
site with cyclone flow
Prerogatives
tester
Affect on
final results
equal or higher
Subject to the approval of the Administrator.
"The method, procedure, or material substitution submitted to the agency by
the tester should give equal or higher emission results than the reference
method under the conditions of the performance test.
METHOD 2 - DETERMINATION OF STACK GAS VELOCITY AND VOLUMETRIC FLOW RATE
(TYPE S PITOT TUBE)
Allowable options
1. Principle and applicability
1.2 Applicability
Alternative procedures for
determining accurate-flow rate
when criteria of Method 1, Sec-
tion 2.1 are not met
2. Apparatus
Use of other apparatus for
determining flow rate that has
been demonstrated capable of
meeting specifications
2.1 Type S pitot tube
Use of standard type pi tot tube
Use of another point if final
traverse point is unsuitably
low to prove opening of stan-
dard pitot tube did not plug
during traverse
2.2 Differential pressure gauge
Use of a differential pressure
gauge of greater sensitivity
when conditions warrant
Prerogatives
Affect on
final results
tester
equal or higher
tester
1
equal or higher*
tester
tester
none
improved
tester
improved
J-15
-------
Allowable options
Void test results or employ
procedures to adjust measured
Ap values obtained from a
differential pressure gauge
which does not agree within 5%
of a gauge-oil manometer
2.3 Temperature gauge
Use of temperature gauge not
attached to pitot tube
2.4 Pressure probe and gauge
Use of standard or Type S pitot
tube for static pressure meas-
urement
2.6 Gas density determination
equipment
Use of method other than refer-
ence methods 3, 4, or 5 for
determining moisture or gas
density
3. Procedure
3.1 Performance of pretest leak
check
Use of leak check procedure for
pitot tube which differs from
specified procedure
3.6 Determine the stack gas dry
molecular weight
Use of methods other than ref-
ence method 3 for stacks with
interfering substances
3.7 Determination of moisture con-
tent by use of an equivalent
method
4. Calibration
4.1.2.2 Other than test section of
eight diameters downstream and
two diameters upstream for
pitot tube calibration when
flow is stable and parallel to
dust axis
Prerogati ves
tester
Affect on
final results
r
equal or higher*
tester
tester
insignificant
insignificant
tester
equal or higher
tester
tester
none
none'
tester'
tester
equal or higher
none'
tester
none
J-16
-------
Allowable options
4.2 Standard pitot tube
Standard pitot tube used as
part of an assembly for veloc-
ity traverse (interference
free)
4.3 Temperature gauges
Use of reference device other
than an NBS-calibrated thermo-
couple-potentiometer system
where temperature is above
450°C (761°F)
Invalidate or make adjustments
to test results if absolute
temperature is not within 1.5%
of calibration device
Prerogatives
tester
Affect on
final results
none
tester
insignificant
tester
insignificant
1
Subject to the approval of the Administrator.
>
"The method, procedure, or material substitution submitted to the Agency by
the tester should give equal or higher emission results than the reference
under the conditions of the performance test.
The method, procedure, or material substitution must meet the performance
criteria of the reference method under the condition of the performance test.
METHOD 3 - GAS ANALYSIS FOR CARBON DIOXIDE, OXYGEN, EXCESS AIR AND DRY
MOLECULAR WEIGHT
Allowable options
1. Principle and applicability
1.1 Principle
Use of either fyrite or orsat
analyzer for dry molecular
weight determination
1.2 Applicability
Use of other methods, described
in Section 1.2, or modifica-
tions to the described pro-
cedure
Prerogatives
Affect on
final results
tester
tester
insignificant
insignificant
J-17
-------
Allowable options
2. Apparatus
Using alternative sampling pro-
apparatus and systems that are
capable of obtaining a repre-
sentative sample and maintain-
ing a constant sampling rate
and are capable of yielding
acceptable results
2.1.1 Probe
Use of probe liners other
than stainless steel or boro-
silicate glass that is inert to
02» COa, and Nz and resistant
to temperature at sampling
conditions
3. Dry molecular weight determi-
nation
Sampling point located other
than at the centroid of the
cross section of the duct or at
a point closer to the wall than
1.00 m (3.3 ft)
3.1.2 Orsat analyzer
Pretest leak check
3.2.3 Sample volume
Collect a sample volume smaller
than 30A (1.00 ft3)
3.2.4 Orsat analyzer
Leak check of orsat analyzer
3.3.1 Multi-point, integrated
sampling
Less than eight traverse points
for circular ducts having diam-
eters less than 0.61 m (24 in.)
Less than nine traverse points
for rectangular stacks having
equivalent diameters less than
0.61 m (24 in.)
Less than twelve traverse
points for all other cases
Prerogatives
tester
Affect on
final results
none
tester
none
tester
none
tester
tester
tester
tester
tester
tester
none
none
insignificant
equal
equal
equal
J-18
-------
Allowable options
4. Excess air determination or
emission rate correction
factor determination
Use of fyrite analyzer for ex-
cess air or emission rate cor-
rection
Use of any of the three
approved procedures when not
specified in the standard
4.1.1 Sampling point located other
than at the centroid of the
cross-section of the duct or at
a point closer to the wall than
1.00 m (3.3 ft)
4.2.3 Sample volume
Collect sample at other than
constant rate
Collect sample volume smaller
than 3QSL (1.00 ft3)
4.3.1 Use of fewer sampling points
than specified in Section 3.3.1
6.2 Use of alternate method of cal-
culating excess air when in-
terferences are present
6.3 Procedures to include the con-
tent of argon in air when
determining dry molecular
weight to eliminate a negative
error of about 0.4%
Prerogatives
administrator
administrator
administrator
.1
testerj
tester
1
tester
tester
Affect on
final results
less accurate
varies
administrator equal or higher*
insignificant
insignificant
insignificant
none or improved'
insignificant
1
Subject to the approval of the Administrator.
"The method, procedure, or material substitution submitted to the Agency by
the tester should give equal or higher emission results than the reference
method under the conditions of the performance test.
The method, procedure, or material substitution must meet the performance
criteria of the reference method under the condition of the performance test.
J-19
-------
METHOD 4 - DETERMINATION OF MOISTURE CONTENT IN STACK GASES
Allowable options
1. Principle and applicability
1.2 Applicability
Use of other methods for
approximating moisture content
to aid in setting isokinetic
sampling rates
Use,of approximation method for
calculating emission rate
Use of alternate method for
determining moisture content in
saturated gas streams when psy-
chrbmetric chart or saturation
vapor pressure tables are not
applicable
2. Reference method
2.1.1 Probe
Use of probes constructed of
other metals or plastics when
stack conditions permit
2.1.2 Condenser
Modifications such as the use
of flexible connectors between
the impingers, using materials
other than glass, or using
flexible vacuum lines to con-
nect the filter holder to the
condenser
The use of any system that
cools the sample gas stream
and allows measurement of both
the water that has been con-
densed and the moisture leaving
the condenser, each to within
1 ml or Ig.
2.1.4 Metering system
Use of other metering systems
capable of maintaining a con-
stant sample rate and determi-
ning sample gas volume
Prerogati ves
Affect on
final results
tester
administrator
tester
none
insignificant
none or improved
tester
equal or higher*
tester
none
tester'
none
tester
insignificant
J-20
-------
Prerogati ves
tester1
tester
tester
Affect on
final results
equal or higher^
none
none or higher
Allowable options
2.2.1 The use of fewer points than
the minimum number specified
in Section 2.2.1 of the pro-
cedure
2.2.3 Performance of pretest leak
check
2.2.6 Void the test results or cor-
rect the sample volume as de-
scribed in Section 6.3 of
Method 5 if leakage rate ex-
ceeds the allowable rate
Subject to the approval of the Administrator.
2
The method, procedure, or material substitution submitted to the Agency by
the tester should give equal or higher emission results than the reference
method under the conditions of the performance test.
The method, procedure, or material substitution must meet the performance
criteria of the reference method under the condition of the performance test.
METHOD 5 - DETERMINATION OF PARTICIPATE EMISSIONS FROM STATIONARY SOURCES
Allowable options
2. Apparatus
2.1.1 Probe nozzle
Nozzle of design other than
button-hook or elbow
Nozzle constructed of materials
other than stainless steel or
glass
2.1.2 Probe liner
Exceeding maximum probe heat
temperature of 120 +14°C (248
+25 F) during sampling
Operating at a lower probe heat
temperature than 120 +14 C
(248 +25 F) during sampling
Use of borosilicate or quartz
glass liners at higher temper-
atures than specified for short
periods of time
Prerogati ves
administrator
administrator
administrator
tester
tester
Affect on
final results
none or less
varies
none or less
none or higher
none
J-21
-------
Allowable options
Use of metal probe liners such
as S-316 stainless steel,
Incology 825, or other corro-
sion resistant seamless tubing
2.1.5 Filter holder
Use of materials other than
borosilicate glass with a
glass frit filter support and
a silicone rubber gasket in
constructing filter holder
2.1.6 Filter heating system
Exceeding maximum temperature
of 120 +14°C (248 +25°F) dur-
ing sampling
Operating at a lower filter
temperature than 120 +14 C
(248 ±25°F) during sampling
2.1.7 Condenser
Condenser modifications such as
the use of flexible connectors
between the impingers, using
materials other than glass, or
using flexible vacuum lines to
connect the filter holder to
the condenser
The use of any system that
cools the sample gas stream
and allows measurement of both
the water that has been con-
densed and the moisture leav-
ing the condenser, each to
within 1 ml or Ig
2.1.8 Metering system
Use of other metering system
capable of maintaining sampling
rates within 1031 of isokinetic
and of determining sample vol-
umes to within 2%
2.1.10 Gas density determination
equipment
Using temperature sensor not
attached to probe assembly if
a difference of not more than
1% in the average velocity
measurement will be introduced
Prerogati yes
tester
Affect on
final results
none or higher
tester
1
equal'
administrator
tester
none or less
none or higher
tester
none
tester
none
tester'
equal
tester"
insignificant'
J-22
-------
Allowable options
2.2.2 Wash bottles
The use of polyethylene wash
bottles instead of glass
2.2.3 Glass sample storage containers
The use of polyethylene storage
containers instead of glass
2.2.4 Petri dishes
Use of petri dishes constructed
of materials other than glass
or polyethylene for filter
samples
3. Reagents
3.1.2 Silica gel
The use of desiccants other
than silica gel that are equiv-
alent or better
3.1.5 Stockcock grease
Use of stockcock grease other
than acetone-insoluble, heat-
stable silicon grease
3.3.2 Desiccant
Use of desiccants other than
indicating type, anhydrous
calcium sulfate
4. Procedure
4.1.1 Pretest preparation
Use of procedures other than
those described which account
for relative humidity effects
in preparation of ilters
4.1.2 Preliminary determinations
Selection of sampling site and
minimum number of sampling
points by means other than
Method 1
Selection of sampling time per
point that is less than the
specified minimum of 2 minutes
per point
Prerogatives
tester
tester
Affect on
final results
insignificant
insignificant
admininstrator equal
tester
tester
tester
none
2
none or higher
equal
tester
insignificant"
tester
administrator
equal or higher
equal or higher
J-23
-------
Allowable options
Sampling for shorter times at
each traverse point and ob-
taining smaller gas volumes
than specified for batch cycles
and other cyclic processes
4.1.3 Preparation of collection train
Use of a glass cyclone between
the probe and filter holder
when the total participate catch
is expected to exceed 100 mg or
when water droplets are present
in the stack gas
Pretest leak check
4.1.4
Performance of pretest leak
check
4.1.4.2 Leak checks during sample run
If leakage exceeds limits prior
to component change during the
test, correct sample volume or
void test
4.1.4.3 Posttest leak check
If leakage exceeds limits dur-
the mandatory posttest leak,
correct sample volume or void
test
4.1.5 Particulate train operation
Sampling at a rate that is not
within 10% of true isokinetic
sampling rate
Maintaining a filter tempera-
ture other than 120 +14°C
(248 +25 C) or other tempera-
ture specified by an applicable
subpart of the standard
Traversing the stack in a man-
ner other than specified in
Method 1
The use of two or more trains
in situations other than those
cited in Method 5
Prerogatives
administrator
Affect on
final results
/
equal or higher*
tester
insignificant
tester
tester
none
none or higher
tester
none or higher
administrator equal or higher'
administrator
equal or higher
administrator equal or higher*
tester
equal or higher*
J-24
-------
AT 1owable options
4.2 Sample recovery
The use of distilled water in-
stead of acetone for washing
probe, nozzle, and front half
of filter holder
4.3 Analysis
Method to correct the analyti-
cal data of Container No. 2
when leakage has occurred or
when voiding the test
5. Calibration
5.3 Metering system
Use of alternative procedures
such as orifice meter coeffi-
cients to calibrate the dry gas
meter for the posttest calibra-
tion
6. Calculations
6.12 If test standards are low in
comparison to the standards
and I is beyond the acceptable
range or, if I is less than 90%,
the results may be acceptable
Prerogatives
administrator
tester
Affect on
final results
none, improved or
higher2
equal or higher^
tester
equal
administrator equal or higher
1
Subject to the approval of the Administrator.
>
"The method, procedure, or material substitution submitted to the Agency by
the tester should give equal or higher emission results than the reference
method under the conditions of the performance test.
The method, procedure, or material substitution must meet the performance
criteria of the reference method under the condition of the performance test.
METHOD 6 - DETERMINATION OF SULFUR DIOXIDE EMISSIONS FROM STATIONARY SOURCES
Allowable options
1. Principle and applicability
1.2 Applicability
The selection and use of an
alternative method when free
ammonia is present
Prerogatives
tester
Affect on
final results
none, improved or
higher
J-25
-------
Allowable options
2. Apparatus
2.1 Sampling
Substituting sampling equipment
'described in Method 8, modified
to include a heated filter in
place of the midget impinger
equipment of Method 6
Determining SOz simultaneously
with particulate matter and
moisture content using Method 8
2.1.1 Probe
Use of probes constructed of
other than borosilicate glass
or stainless steel
2.1.2 Bubbler and impingers
Substitution of a midget
impinger in place of the midget
bubbler
The use of other collection
absorbers and flow rates
2.1.6 Drying tube
Use of other types of desic-
cants that are equivalent to
or better than silica gel
3. Reagents
3.1.1 Water
Omit the KMnOu test when high
concentrations of organic mat-
ter are not expected to be
present
4. Procedure
4.1.2 Leak check procedure
Leak check prior to sampling
run
Use of leak check procedure
other than published one
4.1.3 Sample collections
Purge sampling train with
unpurified ambient air
Prerogatives
Affect on
final results
tester
significant
tester
tester'
tester
tester'
tester'
equal
equal
equal or higher
equal
equal
analyst
insignificant
tester
tester
tester
none
insignificant
insignificant
J-26
-------
Allowable options
4.3 Sample analysis
If a noticeable amount of leak-
age has occurred, void sample
or mathematically correct final
results
Selection of method to correct
final results when leakage has
occurred
Prerogatives
tester
tester
Affect on
final results
insignificant
equal'
1
Subject to the approval of the Administrator.
The method, procedure, or material substitution must meet the performance
criteria of the reference method under the condition of the performance test.
METHOD 7 - DETERMINATION OF NITROGEN OXIDE EMISSIONS FROM STATIONARY SOURCES
Allowable options
2. Apparatus
2.1 Sampling
Use of the grab sampling sys-
tems or equipment capable of
measuring sample volume to
within +2% and collecting a
sufficient sample volume to
allow analytical reproducibil-
ity to within ±5%
3. Reagents
3.2.2 Water
Omit the KMnOi» test when high
concentrations of organic mat-
ter are not expected to be
present
4. Procedures
4.3 Analysis
If a noticeable amount of leak-
age has occurred, void sample
or mathematically correct final
results
Prerogati ves
Affect on
final results
tester
equal'
analyst
insignificant
tester
insignificant
J-27
-------
Allowable options
Selection of method to correct
final results when leakage has
occurred
Use of centrifugation instead
of filtration to remove solids
from the sample
Prerogatives
tester1
tester
1
Affect on
final results
equal3
insignificant
Subject to the approval of the Administrator.
The method, procedure, or material substitution must meet the performance
criteria of the reference method under the conditions of the performance test.
METHOD 8 - DETERMINATION OF SULFURIC ACID MIST AND SULFUR DIOXIDE EMISSIONS
FROM STATIONARY SOURCES
Allowable options
1. Principle and applicability
1.2 Applicability
The use of an alternate method
when interfering agents (free
ammonia, fluorides, dimethyl
aniline) are present
Determining filterable particu-
late matter along with S07 and
S02 J
2. Apparatus
2.1.1 Probe nozzle
Nozzle of design other than
button-hook or elbow
Nozzle constructed of materials
other than stainless steel or
glass
2.1.5 Filter holder
Use of gasket materials such as
Teflon or Viton to assemble
filter holder
Prerogatives
Affect on
final results
tester
tester
equal or higher
equal or higher'1
administrator
administrator
tester'
equal
^
equal or higher*1
equal'
J-28
-------
Allowable options
2.1.6 Impingers
Use of similar sample collec-
tion system in place of Green-
burg-Smith and modified impinger
system
2.1.7 Metering system
Use of other metering systems
capable of maintaining sampling
rates within 10% of isokinetic
and determining sample volumes
to within 2%
2.1.9 Gas density determination
equipment
Using temperature sensor not
attached to probe assembly, if
a difference of not more than
1% in the average velocity
measurement will be introduced
3. Reagents
3.1.3 Water
Omit the KMnOi» test when high
concentrations of organic
matter are not expected to be
present
4. Procedure
4.1.4 Pretest leak check procedure
Conducting a pretest leak check
4.1.5 Train operation
If leak check prior to component
change or at the conclusion of
the specified acceptable rate,
correct the final results or
void the test
Conducting post component change
leak check
Use of ambient air without
filtering to purge sample train
Prerogati ves
administrator
Affect on
final results
equal
tester'
equal
tester
insignificant
analyst
insignificant
tester
tester
none
equal or higher
tester
tester
none
insignificant
J-29
-------
Allowable options
4.1.6 Calculation of percent
isokinetic
Relax ioskinetic sampling rate
requirement where difficulty
in maintaining isokinetic rates
are experienced due to source
conditions
4.3 Analysis
If a noticeable amount of leak-
age has occurred, either void
sample or correct the final
results
Select method to correct final
results when a noticeable amount
of leakage has occurred
6. Calculations
6.3 Dry gas volume
If leak rate observed during
any mandatory leak checks ex-
ceeds the specified acceptable
rate, correct the volume met-
ered or invalidate test run
Prerogatives
Affect on
final results
administrator equal or higher'1
tester
tester
insignificant
equal'
tester
equal or higher
Subject to the approval of the Administrator.
The method, procedure, or material substitution submitted to the Agency by
the tester should give equal or higher emission results than the reference
method under the conditions of the performance test.
method, procedure, or material substitution must meet the performance
criteria of the reference method under the conditions of the performance test.
J-30
-------
SLIDE 251-0 NOTES
EQUIVALENT
AND
ALTERNATIVE
TEST METHODS APPROVAL
subpart60.8(a)
SLIDE 251-1
Defn: THE ADMINISTRATOR"
1. EPA Regional Officials
2. Officials of Other Agencies with NSPS Responsibility
Regional Agency
State Agency
Local Agency
SLIDE 251-2
ALLOWABLE ALTERNATIVES
FOR
THE ADMINISTRATOR
1. Approve minor changes to the reference test methods
2. Approve an equivalent method
3. Approve an alternative method which has been demonstrated
adequate for determining compliance at a specific source
4. Waive the requirement for performance testing
J-31
-------
SLIDE 251-3 NOTES
MINOR CHANGES TO
REFERENCE TEST METHOD
Minor changes are allowable with PRIOR approval of the
Administrator.
ACCEPTABLE OPTIONS
Administrator approval not required
option must be identified in test report
POTENTIALLY ACCEPTABLE OPTIONS
. cited as Or Equivalent or Subject To Approval of the Administrator
SLIDE 251-4
POTENTIALLY ACCEPTABLE OPTIONS
CRITERIA FOR USE
option must be applicable and properly
executed
include a detailed, written description of option
in test report
provide supporting data and rationale to show
validity of option in the specified application
SLIDE 251-5
LEVEL OF REVIEW
IMPACT LEVEL OF REVIEW
Site Specific State Agency
Regional EPA Regional Office
National EPA Headquarters
Note: The review and fmal decision must always be made at least at
the minimum affected level.
J-33
-------
SLIDE 251-6 NOTES
Defn: ALTERNATIVE METHOD
Any method for sampling and analyzing an
air pollutant which:
is not a reference or equivalent method
has been demonstrated to produce results
adequate for determination of compliance
Note: Send to EPA regional office for
review.
SLIDE 251-7
Defn: EQUIVALENT METHOD
Any method which has been demonstrated to
have a consistent and quantitative known relation-
ship to the reference method under specified
conditions
Note: Send to EPA regional office for
transfer to EPA Headquarters.
SLIDE 251-8
CRITERIA FOR AGENCY EVALUATION OF
MINOR MODIFICATION TO REFERENCE METHOD
1. Effect will be insignificant on final emission data
results.
2. Change will accommodate a situation that is
considered unique and would apply only to
sample site for which it is allowed.
Note: Review may be made at state level.
J-35
-------
SLIDE 251-9 NOTES
USE OF BIAS CONCEPT FOR ALTERNATIVE
PROCEDURES
all allowable alternative procedures in reference
method will provide emission results of equal or
greater value than standard procedures (bias
concept)
agency can use same bias concept technique
when evaluating alternative methods
SLIDE 251-10
BIAS CONCEPT RULE
When bias (from prior knowledge or comparative
data) is determined to be insignificant or against
(deterrent to) initiating party or party who bears the
proof of violation or compliance, alternative method or
procedure is acceptable for enforcement or compliance
testing purposes.
SLIDE 251-12
SIMPLIFIED EXPLANATION
1. When the source is attempting to prove com-
pliance, the bias concept must cause equal or
greater than true measured pollutant values.
2. When the agency is attempting to prove vio-
lation, the bias concept must cause equal or
lesser than true measured pollutant values.
0-37
-------
SLIDE 251-12 NOTES
IMPROPER USE OF BIAS CONCEPT
APPLICATIONS NOT RECOMMENDED
1. Do not use bias concept when reference method does
not provide correct emission measurement value for
regulated pollutant.
2. Minimize or eliminate use of bias concept when
reference method tests are used for certification of
continuous emission monitors.
SLIDE 251-13
(cont.)
3. Keep in mind that since margin by which most indus-
tries can comply with Federal regulations is small, an
alternative method with a large bias may not accomplish
intended goal of demonstrating compliance or violation.
4. When bias cannot be determined from prior knowledge
or existing comparative data, agency would have to
deny alternative method, or agency/industry would
have to spend time and money necessary to provide
comparative data.
J-39
-------
SECTION K. ENFORCEABILITY CRITERIA FOR DEVELOPMENT OF
COMPLIANCE TEST METHODS
Subject Page
1. Enforceability criteria for development of compliance test
methods K-3
2. Slides K-7
K-l
-------
ENFORCEABILITY CRITERIA FOR DEVELOPMENT OF
COMPLIANCE TEST METHODS
by
Kirk Foster and William DeWees
Introduction
For more than 10 years, State and Federal agencies have been making
compliance determinations from test data based on designated State methods or
U.S. Environmental Protection Agency (EPA) Reference Methods. In the early
1970s it was common practice for both industry and agencies to assume com-
pliance test data were accurate indicators of source compliance status. This
practice was acceptable because properly designed emission control systems
usually provided a comfortable margin of compliance, especially for State
Implementation Plan (SIP) standards. Variables such as facility operations
during testing and compliance test method error could be absorbed within this
margin of compliance.
Today, however, regulations are more stringent, the compliance margin is
smaller, and industry is more aware of the relationship between the test method
and the emission standard. To meet current responsibilities, agencies must
ensure that regulations and test methods keep abreast of current technology and
trends.
Developing and enforcing New Source Performance Standard (NSPS) regulations
have been the Federal government's largest long-term air pollution compliance
efforts. Industry challenges of NSPS regulations and performance test methods
have not been infrequent and have, in their own way, helped to strengthen the
method development process. Based on the collective experience of the NSPS
effort, useful criteria have evolved to assess the legal acceptability or en-
forceability of any new or revised test method proposed for compliance testing
purposes. This brief guideline sets forth some of the more important criteria
learned from this experience.
These criteria are offered as general guidance for control agency personnel
engaged in setting emission standards and in establishing rules and regulations
for implementing these standards. Since the compliance test method is an integral
K-3
-------
part of any emission standard and, in fact, is a major factor in determining the
level of a standard, the enforceability of the test method should be of prime
importance to a control agency.
Enforceability Criteria
The following 12 criteria are suggested to review or evaluate the accept-
ability of stationary source test methods and procedures for determining com-
pliance with applicable emission standards and regulations. Although the cri-
teria are rated to help allocate the attention and effort given to method devel-
opment with limited agency resources, all of them are important for maximum
enforceability. The list is not intended to be exhaustive and is offered as a
starting point in the agency's method development process. Other items may be
added as dictated by the individual needs and operating structure of the agency
and changing legal requirements.
Items 1 through 5 are essentially mandatory for an enforceable method.
Items 6 through 10 are necessary for an enforceable method, and Items 11 and
12 are highly beneficial.
1. The method must provide consistent, predictable measurement values
with sufficient accuracy and reliability for determining compliance.
2. The measured values must be reasonably related to the pollutant
emissions being regulated, either as a direct measurement or as a
quantitative indicator (surrogate) of the primary pollutant.
3. A written method and procedure must be available to explain the
methodology in sufficient detail to permit the regulated industry
to develop adequate testing capability and to conduct the required
tests in an acceptable manner.
4. Before being published as part of the final regulation, the methods
must be made available for public review and comment and preferably
subjected to some form of critical review by the scientific communi-
ty. Formal rulemaking procedures should be followed to the extent
warranted by the anticipated impact and significance of the regula-
tion.
5. A method providing a surrogate measurement of the pollutant being
regulated must be shown through sufficient comparison testing with
an accepted referee method to have a consistent relationship to
the measured values of the referee method under a variety of field-
testing conditions. The relationship does not have to be one-to-
one if the surrogate measurements can be shown to result in a less
stringent application of the standard.
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6. The method and testing equipment should be generally applicable to
the majority of the sources being regulated without substantial
modification of or deviation from the written procedures.
7. The testing equipment and all components should either be com-
mercially available at a reasonable cost as a complete system or
capable of being constructed from available plans and specifica-
tions. The cost of performing a compliance test using the method
should be reasonable, based on considerations such as the number
and frequency of tests required and the overall cost of the test
as compared to the source investment, operating costs, and profit
income, etc. (For most source categories, reasonable testing costs
for a complete test performed one time or no more than once per
year if there are no compliance problems would be in the range of
$5,000 to $25,000 depending on the size and type of plant.)
8. The test method and its analytical procedures should not be so
complex as to require a level of skill or experience for proper
application that is beyond the capability of the technical staff
of the majority of commercial testing firms offering compliance
testing services.
9. A clear-cut enforcement policy should be established for taking
into account measurement error in determining compliance with the
regulation. For measurement error to be considered, the accuracy
or precision of the method must be defined through collaborative
and/or comparison testing. The accuracy estimates should reflect
the worst-case error for the entire measurement system. This
worst-case would include errors in ancillary measurements such as
product output, raw material input, heat input, and other process
parameter measurements required to calculate emissions in units
of the standards.
10. Program responsibility should be assigned, and an appropriate
response mechanism established, for technically reviewing and
determining the acceptability of alternative test procedures pro-
posed by industry or State/local agencies with enforcement author-
ity. A group responsible for continued method review and needed
improvements and refinements based on field experience should be
designated, and its availability to provide further guidance and
assistance should be made known to the agency field enforcement
staff and industry and the testing services firms involved in com-
pliance test work.
11. To establish its accuracy and/or reproducibility and its specificity
and ruggedness under all anticipated field conditions, the method
should undergo sufficient evaluation testing before its wide-spread
use in compliance determinations.
12. To assure the validity of measurements made by persons attempting to
follow the written procedures who may not be fully familiar with the
methodology or have only a minimum level of training, adequate qual-
ity assurance procedures should be published as soon as possible
after the method is published.
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SLIDE 252-0 NOTES
ENFORCEABILITY CRITERIA FOR
DEVELOPMENT OF
COMPLIANCE TEST METHODS
SLIDE 252-1
MANDATORY CRITERIA
1. The method must provide consistent, predictable measure-
ment values with sufficient accuracy and reliability for
determining compliance.
2. Measured values must be reasonably related to pollutant
emissions being regulated.
3. A written method and procedure must be available to
explain the methodology in detail.
SLIDE 252-2
(cont.) MANDATORY CRITERIA
4 Methods must be made'available for public review and
comment and preferably subjected to critical review by the
scientific community.
5. A method providing a surrogate measurement of the
regulated pollutant must be shown through sufficient
comparison testing with an accepted referee method.
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SLIDE 252-3 NOTES
NECESSARY CRITERIA
1. The method and test equipment should be applicable to
the majority of sources being regulated without substantial
modification of, or deviation from, written procedures.
2. Compliance testing, as well as test equipment and com-
ponents, should be available at a reasonable cost.
3. The test method and analytical procedures should not be
beyond the capabilities of commercial testing firms.
SLIDE 252-4
(cont.) NECESSARY CRITERIA
4. A clear-cut enforcement policy should be established to
account for measurement error in determining compliance
with regulation.
5. Program responsibility should be assigned, and response
mechanism established, for technical review^ and deter-
mination of acceptable alternative test procedures.
SLIDE 252-5
HIGHLY BENEFICIAL CRITERIA
1. Before wide-spread use, the method should undergo
sufficient evaluation testing to establish its accuracy, repro-
ducibility, specificity and ruggedness under field conditions.
2. Quality assurance procedures should be published as
soon as possible after publishing the method to assure
validity of field measurements already attempted following
written procedures.
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SECTION L. SAFETY IN STACK TESTING
Subject Page
1. Stack sampling safety manual (prepared by Norman V. Steere &
Associates, Minneapolis, Minnesota) L-3
2. Slides L-85
L-l
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INTRODUCTION
Stack sampling and source evaluation can be carried out with fewer
interruptions and less total cost if equipment is not damaged and test
personnel are not injured or overexposed to environmental conditions.
Preventing damage, injury and overexposure requires advance planning and
preparation which should become an integral part of the methods and pro-
cedures for evaluating emission sources. Even though injury of personnel
is less likely to occur than damage to equipment, it is important to
protect both the equipment and the personnel so that tests can be
completed as scheduled.
There are four basic kinds of procedures that stack sampling groups
need to .develop for preventing injury to test personnel and damage to
test equipment.
1. Preliminary survey procedures
to identify potential hazards, such as heat, toxic gases,
high wi nds, etc.
2. Standard operating procedures
to control hazards normally encountered, or identified as
potential during preliminary surveys, such as climbing,
hoisting, storms, etc.
3. Personnel exposure monitoring procedures
to recognize or prevent overexposure to heat, cold, toxic
vapors, etc.
A. Emergency procedures
to fight fire, treat heat stroke, lower an injured person,
obtain emergency medical assistance, etc.
Standard procedures for preventing and controlling damage and injury are
fully as important as the standard test methods for stack sampling.
Supervisors of source testing personnel have both a moral and legal
obligation to protect employees from recognized hazards that are likely
to cause them serious physical harm. In order to protect employees,
supervisors must identify actual and potential hazards the employee may
encounter on the job, see that needed equipment is provided, establish
standard safety procedures, see that training is provided, and see that
standard procedures are followed. Employees are responsible for learning
standard safety procedures and using equipment correctly, and for pro-
tecting themselves and others who may be affected by stack sampling
operations.
There is no set of standards that covers all hazards to which test
personnel may be exposed, since source testing or evaluation is a
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relatively uncommon activity and one that is done under field conditions
while exposed to the weather and other uncontrollable or adverse condi-
tions. The lack of standards does not justify exposing personnel to
serious hazards with little or no protection or training, and it does
not justify employees disregarding standard procedures developed for
field testing.
In this brief safety manual there are references to standards
adopted by OSHA (the Occupational Safety and Health Administration),
even though these standards were originally developed for common and
routine activities, such as construction and manufacturing. The OSHA
standards are useful as guidelines, although they may not always be
appropriate as literal requirements for field testing, and although
they may not cover other serious hazards of field testing.
Recognition and control of potentially serious hazards take pre-
cedence over compliance with OSHA Standards alone. A safety program
limited to compliance with OSHA Standards without control of other recog-
nized hazards would not satisfy OSHA or provide adequate protection for
test employees. Cross-bracing and tieing-off of scaffolding are not
done to satisfy OSHA, but to prevent collapse or tipping of the
scaffolding. The laws of gravity and motion are always enforced,
uniformly and continuously, just as-the other laws of physics and chem-
istry are.
L-4
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CHAPTER 1
PREPARATION FOR STACK SAMPLING
Protection of stack sampling personnel should begin well before the
start of the sampling activities and even before preliminary surveys are
undertaken. Although stack sampling crews are usually equipped to work
safely in a wide variety of sampling situations, they may at times
encounter conditions for which they do not have adequate equipment or
protection.
Information from Plant Personnel
Before entering a plant, the stack sampling crew should know what
safety procedures and equipment the plant requires or recommends. By
ccntact with plant management or other plant personnel, it is important
to find out what kinds of hazards the stack sampling personnel may be
exposed to, so that special equipment can be obtained if needed to carry
out the sampling and protect the crew.
A copy of the plant safety manual or a list of safety rules may
help to identify specific safety measures recommended for protection
against hazards recognized at that plant. If the plant has special
safety equipment and emergency services available, it is important to
find out how to get help if and when it is needed.
If the plant has personnel in safety, industrial hygiene, engineering,
nursing or medical service, they may provide helpful information to
supplement what is obtained from plant management or what may be on file
from a previous survey. It will be particularly useful to find and talk
to someone who is knowledgable about the particular areas the crew will
be working in to ask about hazards which they may encounter there.
All information gathered for the crew, including names and phone
numbers, should be tabulated concisely and provided to crew members or
placed prominently with the stack sampling equipment.
Information from Outside Sources
If it is necessary to obtain additional information about serious
hazards and emergency problems, assistance may be available from the
fire department or the local office of the Occupational Safety and Health
Administration.
L-5
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Information from Site Visit and Observation
Some of the questions that may require observations at the sampling
site are, for example:
Will the weather or process conditions at the sampling
site require special clothing, equipment or supplies to
prevent serious overexposure to heat or cold?
Will noise conditions require special hearing protection
and communication equipment?
Will the heights require extra equipment for climbing
or hoisting?
Will possible chemical exposures require eye or respira-
tory protection other than the usual safety glasses and
filter masks?
If the plant site is large and complex and sampling activities will
be extensive, it may be helpful if site plans or process flow diagrams
can be obtained. If photographs can be taken on routine sampling or
preliminary surveys, they can be helpful in orienting replacement crew
members during future sampling operations.
If a preliminary survey is not conducted before routine stack
sampling, similar information should be gathered as necessary before
starting stack sampling operations.
Precautions at the Plant Site
When it becomes necessary to walk through plant areas, it ?s
important to follow designated aisles to avoid getting in the path of
moving equipment. Even within the proper walking areas crew members
must be especially alert for powered industrial trucks and fork lifts
which may travel the same aisles. These vehicles are fairly fast-
moving and may not be able to stop quickly. Drivers usually have a
limited view of the passageway and may not expect to encounter
pedestrians.
Crew members must also watch for swinging overhead cranes used
to carry materials since the operators may not be aware of or able to
see pedestrians.
Operators of gantry cranes also are not able to see someone in
a position near the crane rail, and anyone who gets caught in the
narrow clearance between such a crane and the supporting structure is
likely to be crushed.
L-6
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Extreme care should also be taken if It is necessary to pass
in front of a train in an industrial plant since some of them may
be remotely-control led and may not signal their movement. Seventy-
five feet of clearance is recommended for passing in front of even
a stopped train.
Additional precautions at the plant site should be based on the
types of hazards which may be encountered above, below or near the
sampling site. These include mechanical, electrical, chemical,
radiation, flammable, or thermal hazards.
Preparation of Equipment
Stack sampling equipment should be checked for safe operation
periodically. Electrical equipment should be checked as recommended
in Chapter 7-
Safety equipment should be checked to see that it is all avail-
able and in working order for each survey. Useful equipment may
include a compass, a camera, flashlights, lighting for reading instru-
ments in dark areas, a Wet Bulb Globe Thermometer, waste receptacles,
water for drinking and eye wash, and personal protective equipment.
Medical Examinations and First Aid Training
Routine physicals are recommended for stack sampling personnel
because of the physical stress of the wdrk and the possibility of
chemical exposure. The initial physical also develops the baseline
against which later physicals are to be compared. Without this baseline
test results may appear normal when they may actually represent the
result of overexposure to chemicals. Routine physicals should be given
every six months if there is daily or even weekly exposure. A more
thorough physical should be done on a yearly basis. Physicals should
include a general assessment of all the physical systems which are
subjected to exposure. Tests should include: hemoglobin packed cell
volume, complete blood count and differential, lung capacity, liver and
kidney function tests, a chest x-ray, and assessment of the heart,
starting with an EKG.
All stack sampling crews who do field work should have at least
two members trained In first aid to assure that one person is available
at all times. The first aid training offered by the Red Cross is good
basic training. However, a course specifically designed for an indus-
trial operation is more appropriate. CPR training should be included.
Preparation for Future Surveys
Unexpected events, equipment damage, injuries and accidents that
occur during stack sampling operations should be recorded for the
benefit of stack sampling personnel in future operations. This
L-7
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information and ideas for prevention should be shared by some means
such as a stack sampling newsletter, or should be incorporated into
later editions of this manual.
L-l
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CHAPTER 2
PRELIMINARY SURVEY PROCEDURES AT SAMPLING SITES
During the preliminary survey at a sampling site it is important to
determine what hazards may be present, what safety support may be
available from the plant, and what special protective equipment and
clothing will need to be provided for sampling personnel. Careful
evaluation of process and site conditions will be necessary to identify
equipment needed for protecting test personnel, monitor ing exposures,
facilitating tests, and communicating for routine testing and emergencies.
This chapter includes a general safety checklist and a discussion
of the information which needs to be gathered during the preliminary
survey. Specific safety checklists may have to be developed for diff-
erent types of industry and different types of sampling operations.
The major sections in the Safety Checklist are as follows:
A. Elevation
This section is for recording details about scaffolds and elevated
platforms used for sampling, about ladders and stairs, and about means
of bringing equipment to and from sampling ports. It should be noted
that no one is expected to climb any device that is unsafe.
B. Personal Protective Equipment
If the plant has rules on wearing of specific safety equipment this
section should record their requirements. This section should indicate
what additional personal protective equipment is needed for sampling
personnel. Since sampling personnel will frequently be closer to
emission sources for longer periods and under more adverse conditions
than plant personnel, sampling personnel will need more additional
protection.
If the plant has special protective equipment which they will loan
to sampling personnel, this information should be noted clearly. For
example, some plants have and will provide use of breathing air supply
equipment such as airline respirators. The plant may be able to provide
the familiarization needed for use of their equipment.
C. Special or Unusual Test Procedures
and Safety Precautions Necessary
Tests are often done under conditions in which production is high
L-9
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and emissions may be greatest. The person doing the pre-sampling survey
should determine or estimate the most extreme conditions that might
occur and alert sampling personnel so that they can be prepared. This
is also the section for alerting sampling personnel to any unusual plant
hazards, such as exposed high voltage lines or unexpected hazards, as
well as any unusual test conditions, such as high temperature or toxic
gas streams, flammable atmospheres, or other hazardous conditions.
D. Expos u re Hon i to r ? ng
If a plant has monitored employee exposure to certain specific
chemicals produced or used at the plant site this information could be
used to determine what respiratory protection is needed by sampling crews
and whether their exposures should be monitored.
E. Medical
This section provides for recording information needed to obtain
the best medical assistance available in the shortest possible time.
The most immediate source of trained medical assistance is likely to be
the plant nurse or doctor, and the plant should be asked where they
send or take their emergency cases for further emergency medical
assistance and treatment. If the plant does not have the facilities or
personnel for treatment of serious injuries or chemical exposures, they
will usually have experience with and can recommend the local hospital
with the most capable emergency room.
As part of the preparation for possible emergency medical treat-
ment, it is important to be sure of the procedure necessary to assure
treatment at the plant or at the hospital without any delay, and to
assure that there will be no delay of any necessary laboratory tests.
For example, is it necessary to have a purchase order, to establish
credit, to carry a Blue Cross card, or to have a physician's referral?
F. Fire and Rescue
This section seeks information on the availability and capability
of local Fire and Rescue services. While it is not very likely that
fire will occur in sampling equipment or facilities or that sampling
personnel will need rescue, it is desirable to know whether there is a
Fire Department and a Rescue Squad available and whether they are
practiced and equipped to provide emergency services that may be needed.
Under some extreme conditions or in remote locations, Fire and Rescue
services may not be able to reach the sampling site, so that sampling
personnel may need to have their own special rescue gear and training.
This section also asks for information on the location and travel
distance and time to the closest fire extinguishers of the correct type
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needed if fire occurs in test equipment or facilities or test chemicals.
The information can also be used to determine what type and number of
extinguishers need to be brought by the sampling team.
G. Emergency Signals
This section provides space for recording whether the plant has any
special emergency signals, such as for fire, tornado, or toxic gas leak.
If the plant monitors wind speed, wind direction, or other weather
conditions, such information could be valuable for protecting the
sampling operations and equipment.
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SAFETY CHECKLIST FOR PRELIMINARY SURVEY
(Space to enter date and identification of company and site.)
A. ELEVATION
Sampling will be from: temporary scaffolds ; fixed platforms^
Scaffolds; Number Heights
Height of sampling ports above scaffold platform
Height of railings of scaffolds above platform
Scaffolds cross-braced at every level (yes/no)
on one side on both
Scaffolds secured against toppling (yes/no)
by means of_
Scaffolds are erected on what levels
what surfaces
Pedestrian traffic below scaffold will generally consist of:
Plant personnel (yes/no)
Others (specify)
Barricades needed (yes/no)
Warning signs needed (yes/no)
Comments:
Fixed Platforms: Number Heights
Height of sampling ports above platform
Height of railings above platform
Openings Protected by
Toeboa rds
Fixed Pulleys (yes/no) ^
In working condition (yes/no)
Location
Comments
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Access to platforms by: Standard industrial stairs
Ships' ladders (steep stairs)
Fixed ladders
Portable ladders_
General condition of ladders
Rest stops Distance between
Cage on ladders
Climbing device Make
Comments:
B. PERSONAL PROTECTIVE EQUIPMENT Check if needed.
1. Safety glasses side shields
Face shields goggles hard hat
Safety shoes electrical hazard shoes
Life belt and safety blockj ladder climbing devices
Hearing protective devices
2. Respiratory protective equipment (see Sec D for details)
3. Body protection
Chemical protection gloves clothes
Heat resistant gloves garments
Other
C. SPECIAL OR UNUSUAL TEST PROCEDURES AND SAFETY PRECAUTIONS
L-13
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D. EXPOSURE MONITORING
Toxic or flammable gases, vapors, dusts contained in emmissions:
Toxic, corrosive, irritating or flammable materials in process
streams:
Respiratory protective equipment used by plant personnel:
Manufacturer and type
Respiratory protective equipment recommended for sampling personnel
For protection of personnel working at sampling port:
For protection of observer only at sampling port briefly:
Plant personnel are monitored for exposure to
Plant monitoring is by: Continuous monitor
Continuous monitor with alarm
Personnel monitoring
Periodically
Personal dosimeters
Monitoring recommended for sampling personnel
E. MEDICAL
Plant: First Aid available (yes/no) All shifts?
If available, give location of unit, telephone number, and
d i s tance
Staff: Nurse Doctor Other
Ambulance: On site On call Tel. No.
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Hospital with emergency room
Location Tel. No.
Provide a map or directions to reach hospital.
Emergency water available/flushing chemicals
Location
F. FIRE AND RESCUE
Fire Department: Name
Location
Tel. No./Emergency
Information
Self-Contained Breathing Equipment: Number
Manufacturer Type
Refill capability
Stokes stretcher?
Ladders, truck or snorkel can reach working height of
Rescue Service: Name Tel. No.
Stokes stretcher?
Gear available to lower injured person from height of
Special rescue equipment
Fire Extinguisher Rated
Class ABC
Distance from sampling sites
Distance from test trailer to
Distance frorji field laboratory
Horizontally to
Vertically to
G. EMERGENCY SIGNALS AND COMMUNICATION
If plant has coded or unusual alarms or several different types of
alarms, it would be helpful to obtain a short tape recording to
orient sampling personnel.
L-15
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Plant has: Fire Alarm Signal is_
Evacuation Alarm Signal is_
Tornado Alarm Signal is_
Gas or Leak Alarm Signal is
Plant monitors: Wind speed Wind direction Air temp.
Other weather conditions .
Locations of Telephones
Nearest to sampling site(s)
Nearest to test trailer
Nearest to field laboratory
L-16
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CHAPTER 3
WORKING AT HEIGHTS: SCAFFOLDS,
PLATFORMS, LADDERS, HOISTING
Responsibi1ities
Each employer is responsible for providing for his/her employees
a job and place of employment which are free from recognized hazards
that are likely to cause serious physical harm to his/her employees.
Since sampling crews cannot rely upon industrial plants to provide
safe working conditions for sampling personnel, the sampling supervisor
must identify plant hazards that may endanger his employees and do what
he can to protect them from these hazards. While the sampling organiza-
tion probably cannot effect any changes in the plant conditions, it can
try to assure that any sampling site construction does provide safe
working conditions. For example, if a platform must be built or a
railing cut for probe access, the sampling organization should provide
specifications for safety and for guarding any new openings with chain,
rope, or strong temporary railings. -Plant employees or scaffold con-
tractors may not know of the need for such things as A2-inch high
guard railings, toeboards, secured straight-run ladders, or tieing off
scaffolds.
Sampling crews also have a responsibility not to endanger plant
employees or property with sampling operations, or set-ups and take-
downs. For example, the sampling team may need to rope off or barricade
areas where tools or equipment are being hoisted or may fall.
Employers performing sampling under Federal contracts have a
contractual responsibility to comply with Federal safety regulations,
including OSHA Standards. EPA personnel monitoring stack sampling
operations have a responsibility to see that the sampling is done
according to the contract and is carried out in a reasonably safe
manner. EPA project personnel can advise the contractor informally if
reasonable safety precautions are not being followed, although formal
action can be taken only by EPA contracting officers.
Working at Heights
Although the most common hazard of working at heights is that of
equipment or personnel falling off the platform, there are some less
common hazards that should be considered.
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Working at heights with grounded electrical equipment exposes
sampling personnel to increased danger from lightning. Personnel
should be alert to approaching storms since lightning may strike in
advance of a storm. A portable radio can be used to monitor weather
reports, and static interferences may signal lightning discharges in
the vicinity.
Visibility seems to be a requirement for effective sampling
operations. Snow, rain and dust storms may impair visibility so much
that sampling operations will need to be stopped. Such storms many
also interfere with verbal communication between sampling personnel.
Since sampling operations at heights introduce a time separation
between personnel at different levels, there may be situations where
personnel need to have some emergency equipment at the working eleva-
tion. For example, a supply of emergency water is needed on the plat-
form if personnel can splash corrosive chemicals in their eyes or on
their skin. Some small adhesive bandages may be needed, to keep blood
from dripping, and personnel may need emergency lighting in case of
power failure during night operations.
If the sampling environment presents the unusual hazard of release
of high concentrations of deadly gases, such as hydrogen sulfide,
personnel on the platform may need self-contained breathing apparatus
for safe escape. Special respirators will be needed for protection if
there is exposure to irritating gases and vapors.
In Chapter 3 the needs for routine and emergency communications
are discussed. An additional possibility for improving communication
capabilities would be to incorporate signal wires with probe umbilicals
if test equipment is not going to be operated on the sampling platform.
A simple signalling system would allow the person at the equipment to
signal when the probe is to be moved and what position the probe is to
be at. Whistles, buzzers, or hand and flashlight signals may also be
used.
If there is frequent need to walk or work near the edge of roofs
or other elevated surfaces, tightly-strung rope or cable at A2 inches
height can be used to provide a temporary guard railing to prevent
falls. If rope.or cable is used as a railing, it should have less than
6 inches of sway under a 200 pound force, and no more than 3 inches of
sag between supports. Vertical supports should not exceed eight foot
intervals if the rope or cable is to provide good protection for opera-
tions carried on regularly and close to the railing.
On some high surfaces it may be desirable to provide a temporary
guard railing or rope even if sampling personnel do not plan to work
near the edge. Need for such a safety guard railing or rope is greater
if the surface slopes or is rough or slippery; a mid-line may also be
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needed to provide protection in case someone slips or slides under
the k2 inch high guard railing or rope.
Under some extreme conditions where guard rails or guard ropes
cannot be provided or where work is well above or beyond fixed guard
rails, and where fall distances could cause serious injuries, personnel
should wear safety belts or harnesses connected to well-rigged safety
lines. Such safety lines should be equipped with shock-absorbing
devices so that in case of falls there is minimum injury from the
sudden stop at the end of the line.
Although guard railings are usually recommended for walking and
working surfaces four feet above another level, there are some situa-
tions where the exposure to falling is infrequent and the risk does not
seem to justify the expense and hazards of erecting a temporary railing.
For example, consider a one-story flat roof where sampling operations
are twelve feet or more from the edge. Although sampling personnel can
approach the edge, they are working far enough away that even if they
fell on the roof they would not be likely to fall over the edge. During
set-up and take-down operations when they are hoisting equipment over
the edge of the one story roof, the hazard of the height is so obvious
and attention is generally so great that personnel are not likely to
fall over the edge. However, if extra attention alone does not seem
to provide great enough safety, some additional protection will be
needed that does not interfere with hoisting operations or create
greater hazards during its installation.
If the wind is blowing or gusting at 25 miles per hour or more,
climbing and hoisting should be stopped to prevent falls. If the wind
speed exceeds 30 miles per hour, sampling operations should be dis-
continued and sampling personnel should come down off of elevated
platforms. If equipment is blowing off "the platform, the wind speed
is obviously too great. When the botton of a flag is blowing straight
out, wind speed is 25 mph or greater.
Wind speeds can be measured inexpensively with a portable wind
speed indicator, or can be estimated from the following table of wind
speed and effects.
If ladders, stairs and platforms are covered with ice or are icing
up from a freezing rain, there should be no climbing or work at
elevations.
If hand-held tools are used beyond the edge of the working plat-
form, such as to remove plugs from sampling ports, it is advisable to
take special care to prevent the tool and the plug from falling. In
some situations it may be desirable to tie the tool to the platform or
other superstructure. For example, a tie line should definitely be
attached to any wrench used to loosen a tight plug in a sampling port,
anticipating that the wrench may slip.
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Miles
per hour
8-12
13-18
19-24
25-31
32-38
(Sources:
Wind Speed and Effects
Gentle Breeze
Moderate Breeze
Fresh Breeze
Strong Breeze
Moderate Gale
Wind extends light flag; leaves
and small twigs in constant motion
Loose paper and dust blown about
Small trees sway; white caps form on
fresh water
Large branches and whole trees move;
wind whistles in wires; flag flutters
vigorously
Flag whips wildly; loose objects may
be lifted from the ground; difficult
to walk against the wind
W. N. Witheredge in Industrial Hygiene and Toxicology
Vol. 1, John Wil.ey, New York 1958 and G. L. Cantylaar,
Your Guide to the Weather, Barnes £ Noble, New York
1964.)
Ladders and Climbing
Portable ladders have a tendency to fall back away from the
building if they are too steep and to slide sideways when people get
on or off at the top of the ladder. Ladders tend to slip away from the
building at the bottom of the ladder if they are not at the correct angle
of if the ladder shoes slide on the supporting surface. Anti-skid
ladder safety shoes are helpful and ladders are reasonably stable if
they are at the right angle. Place the bottom of the ladder one foot
away from the building for every four feet of ladder elevation up to
the point of support.
It is good practice to secure or tie off the top of ladders which
are going to be used more than once or twice. The tie-off should limit
movement of the top of the ladder and secure the ladder from sliding,
falling down, and tipping out.
When setting up a portable ladder, the tops should extend above the
roof, parapet, or platform at least k2 inches for support while getting
off and on the ladder. Ladders should be positioned so there is climb-
ing room (about 30 inches minimum), and so that there are no obstruc-
tions behind the ladder that will interfere with free use of hands and
feet on ladder rungs or that will be in a position to be mistaken for
ladder rungs.
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Portable scaffolds need to be secured to minimize horizontal
movement and to prevent scaffolds from tipping over due to wind, load,
or working stresses. Scaffolds over twenty feet high should be secured
or tied off. Scaffolds taller than forty feet high should be secured
every twenty feet.
Scaffolds with built-in ladder sections should be erected so that
all the ladder sections are in a straight run. This will facilitate
use of the ladder and prevent injuries which may occur if personnel
are unaware of or forget shifts in the position of ladder sections.
Fixed ladders should be securely fastened to the structure. All
ladders should be in good repair without any cracks or weakening
damage. All rungs or cleats should be sound, securely fastened to the
rails, and evenly spaced. If rungs are not evenly spaced the ladder
will be hazardous to climb. An even climbing rhythm depends on even
spacing of rungs, and uneven spacing requires extra attention to prevent
misstep.
Safe climbing requires both hands free for gripping the rungs of
the ladder. Nothing should be carried in the hands while climbing. If
tools and small equipment cannot be hoisted, they should be carried up
ladders only in backpacks, shoulder-straps or belts. Care should be
taken to prevent tools or equipment in backpacks or pockets from
becoming dislodged and falling, and to prevent tools or equipment from
catchning on a rung or rail and throwing the climber off balance
Climbing and descending should be done facing the ladder. The
foot should be placed on the rung so that the front edge of the heel is
against the rung to prevent slipping, particularly during inclement
weather or on oily or slippery rungs. The hands should grasp the rungs
firmly, rather than the rails. Gripping the rungs for climbing, as
firefighters are trained to do, provides greater control and less
chance of slipping than gripping the side rails of a ladder.
Climbiers should wear sturdy well-fitted gloves, sturdy boots in
good repair, and clothing that is not so loose that it may catch in
ladders.
Portable metal ladders should not be used where the ladder or
person on the ladder may come into contact with electric circuits.
Scaffolding and Platforms
Working platforms and elevated walkways need to be provided with
guard railings high enough (k2 inches is standard) to prevent workers
from falling off the elevated surfaces and from falling over the rail-
ings. Midrails are standard to prevent workers from falling under
the guard rai1 ings.
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The performance standard for railings is a 200 pound force applied
in any direction at any point on the top rail. If you decide to test
the railings do NOT do it with your body. If the rail appears too weak
to support you if you fall against it, do something to strengthen or
replace or supplement the railing before sampling.
If sections of guard railings must be removed for probe access to
sampling ports, there should be some alternative guarding of the
opening in the railing. One alternative would be a temporary railing
above and below the path of the sampling train, and another would be a
railing out beyond the opening.
If there are openings in railings around areas used for sampling
operations, for hoisting, stairs, or ladders, it will generally'be
desirable to close the openings with a snap chain, rope or other
temporary barrier to falling. Since sampling operations often must be
carried out in locations not designed for protection of work operations,
existing railings may need to be augmented and temporary protection of
openings may need to be added to prevent falls.
Working surfaces of elevated platforms should obviously be strong
enough to support personnel and equipment, and constructed so that the
boards do not slide off the scaffold or supports. If planks must over-
lap, they should overlap at least 12 inches or be nailed down or
secured against movement. At elevations or locations where high winds
may occur, it is advisable to secure all plywood and planking against
wind forces which may move or lift them.
Secure footing without tripping hazards is essential in elevated
locations. Tape, tools and small objects should be stored so that
they do not clutter the work platform. Umbilicals and wires should be
run so that they are kept out of the working path. If it is impossi-
ble to avoid uneven platforms or tripping hazards, they should at
least be minimized and marked to help reduce their danger.
Open-grating platforms used for stack sampling should be floored
with plywood to prevent small tools and parts from falling through the
grating onto persons or equipment.
Toeboards should generally be provided as curbs around the edges of
working platforms to prevent equipment, small tools and other gear from
being pushed or kicked over the edge. Toeboards are not required if
personnel cannot pass beneath the open sides of the platform, or if
there is no equipment below which could be damaged by falling material.
However, even though toeboards may not be required, small objects such
as metal parts can fall off a platform or scaffold between the scaffold
and the stack, and may bounce and hit a person or equipment.
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Toeboards should be four inches nominal in vertical height from the
top edge to the top of the working surface. Lumber that is 1" x A" or
2" x V nominal could be used for toeboards.
Preventing the falling of tools and equipment and hardware is
important since the impact on a person below could be fatal. Tool
belts might be useful where toeboards or solid flooring cannot be pro-
vided.
Roping off areas below sampling operations and hoisting operations'
(the "impact zone") will help avoid possible injuries.
Scaffold Erection
In earlier sections of this chapter we described the need for
supporting or tieing off scaffolding to prevent it from swaying or
tipping over, and the need for standard height railings and toeboards
and solid work surfaces. We also referred to the desirability of
fastening work platforms to the scaffold, or to cleating planks so they
cannot slide off the scaffold. In addition to these precautions, you
should mention to scaffold erectors that planks fit better if the
scaffold is erected so the cross-section is rectangular; the diagonal
distances between legs should be just about equal. Cross-braces also
serve an important function of keeping scaffolds up, and most sections
of scaffolding should have the cross-braces connected and the connec-
tions should be secured to keep the braces in place.
Scaffolds should be erected on solid footings to avoid sinking
into the ground or poking holes in a roof. If the scaffold is erected
where it may be struck by vehicles, barricades and signs will be needed.
Some sampling contractors have found a definite advantage in
having their scaffolding erected by one or two scaffold contractors who
have shown dependable performance. The sampling contractor apparently^
saves time and money by having a known and reputable firm erect their
scaffolding, even over travel distances greater than 100 miles.
A visual check should include the following items:
1. Are the feet stable and firm?
2. Is there a permanent access ladder either
a. built-in and continuous; or
b. temporary ladder lashed firmly?
3. Are all other connections firm either with pins or bolts or
nested?
4. Are there secure cross braces to prevent torque?
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5. Are the scaffold platforms of at least two 2 x 12 planks wide
or their equivalent?
"6. Are the scaffold platforms secured against teetering or the
wind?
7. Are there 42" guardrails with midrails or does the cross bracing
give equivalent protection?
8. Are there toe boards of sufficient height to prevent tools and
equipment from falling? (V or more)
Hoisting
In addition to the need for hoisting equipment up to sampling sites
during set-ups and lowering it after the tests, there is a need for some
routine and safe methods for hoisting replacement probes and other
supplies during the sampling operations. If the usual method is to
lower over a pulley or over the edge of the platform, loss of your grip
may mean loss of the equipment parts. Looping the control end of the
rope around the scaffold or platform railing can provide an effective
brake for lowering heavy equipment by improved control of the rate of
descent.
The basic needs for hoisting and lowering stack sampling equipment
to and from the sampling site safely and uneventfully are: rope, gloves,
a clear path, a pulley, support for the pulley, a method of attaching
the load, and some method of stopping or controlling the rate of descent.
Clear path
The Preliminary Survey should determine whether a clear path for
hoisting is available or if it can be provided economically. If there
is no clear path for movement of equipment up to the sampling site,
directly or in stages, the equipment may be damaged or may have to be
moved with great difficulty.
Hoisting Procedures
Before lifting any loads, the hoisting area should be roped off or
marked to warn passersby, and access limited to the crew members doing
the hoisting or guiding the load. The rope or signs can be removed
either when the hoisting has been completed and there is no danger of
tools or equipment falling, or after the sampling is completed.
No one should be directly under a load being hoisted, even if
block and tackle are being used.
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If possible, loads should be lifted straight up and the hook and
line should be directly above the load before it is lifted. Pulling
a load sideways as it Is being lifted may cause it to swing into some-
thing and cause damage to the load.
To keep loads from swinging or blowing while they are being
hoisted, a tail line or guide line is recommended for control by the
crew member on the lower level at the hoisting site.
Leather-palm gloves should always be worn to handle the hoisting
lines, and gloves should be worn when handling the load.
Stopping and Controlling the Rate of Descent
Stopping a load at the top when one person is hoisting from the
top can be managed by taking a doubled length of line above your grip
and passing it around a post and tying two half-hitches with the
doubled line. This will allow one person to hoist and secure the load,
swing the load onto the platform and then slip the knot loose by pull-
ing on the slack end of the line.
Controlling the rate of descent of a load can be managed by use of
a block and tackle, or by passing a loop of the rope around a post or
something shaped like a capstan or a mushroom. Back pressure on the
slack end of a line around a post or capstan will increase the friction
on the rope and allow good control of rate of descent with less stress
on the sampling crew. A capstan-like device has the advantage that
you can throw a loop in the rope and over the capstan easier than loop-
ing the entire length of the rope around an endless post or railing.
Pulley and Support
Although use of ropes without pulleys has been common in stack
sampling work, hoisting difficulty and damage to equipment has also
been common. Use of a pulley is recommended for hoisting. Pulleys
and rigging should be standard equipment for stack sampling crews.
Block and tackle may be available in local hardware stores either as
parts or assembled, but it is more convenient to purchase the equip-
ment in advance. At some sites the only path or the most convenient
hoisting path may be the inside of the ladder cage. If the ladder
cage extends k2" above the platform as it should, the top of the
ladder cage may be strong enough to support a bracket for the pulley
and the weight of the loads of equipment. If the ladder cage does
not extend high enough to provide pulley support and a path, a frame
could be rigged to support the pulley above the cage, preferably with
sufficient headroom to allow use of the cage while the frame is in
place.
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Sites over 50 feet high and those which are sampled regularly
should have a pulley support installed. Some companies have gallows
frames and pulleys installed permanently. Condition of frames and
supports should be checked before using them.
Load Support and Direction
Loads to be hoisted should have connections for hoisting lines,
or should be supported in slings or lashed so the load will not shift
or drop during hoisting.
Slings and Attaching Loads for Hoisting
When hoisting probes or other equipment without specific attach-
ment points, it Is safer to provide a separate sling or binding rope
than to use the hoisting rope to wrap or tie the load. Hoisting ropes
should have hooks for attaching loads.
The most commonly used sling is composed of two lengths of rope
with a galvanized eye spliced in each end of each rope. To use the
sling, a length of rope is passed under each end of the load and the
four eyes are hooked onto the tackle hook of the hoisting line and the
safety catch is closed.
Hooks
All hooks used for hoisting should have safety catches to prevent
the load from slipping out of the hook. The support line or sling is
prevented from coming out of the hood until the catch is released.
As a rule of thumb, the load in tons that can be carried safely
by a hook is equal to the square of the diameter of the eye. As a
rough estimate a hook with a one inch diameter eye could carry a one
ton load safely.
If a shackle or clevis is used in the sling, the safe load in
tons is the diameter of the pin in 1/4-inches squared and divided by
three. For example, a half-inch diameter clevis pin is two quarter-
inches, and two squared and divided by three is 2x2 1 _1_ tons.
3 = ' 3
These rules of thumb are not suggested as a substitute for
accurate tables and reference material from the manufacturer, but may
be useful as a safety check while in the field.
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Block and Tackle
Block and tackle provide a means of gaining a mechanical advan-
tage for lifting equipment to stack sampling sites. If heavy loads
need to be lifted or controlled carefully, particularly on long lifts,
the job can be done with less stress on the crew by use of block and
tackle. The cost of the reduction in stress is the added time to pull
twice or three times the length of rope that is needed with use of a
single pulley.
Rigging block and tackle is done by placing the blocks close
together in the same relative position as they will be used, and
threading the end of the coiled rope through the pulleys to the connec-
tion point. Then the blocks can be pulled apart as needed without
kinking or tangling the line.
Obviously you need rope strong enough to support the load lifted,
and large enough in diameter to allow a firm grip, such as 3/^-inch
rope. Rotten, frayed or severely worn rope should not be used.
The safe load for manila rope one inch in diameter or less can be
estimated by squaring the diameter of the rope in inches, with the
product the load in tons. For example, a 1" rope could carry a safe
load of one ton, and a 1/2" rope could carry a safe load of 1A ton.
Sisal rope can carry only one-third the safe load of manila rope.
Sturdy gloves are needed to provide hand protection and a secure
grip on the rope. Leather-palm gloves seem to be effective, and con-
sidered a necessity by many sampling personnel.
Care of Rope
Care should be taken to avoid kinking rope, getting it wet, or
dragging it in the dirt. If rope gets dirty, it should be hosed off
and then loosely coiled to dry. If rope must be passed over sharp
corners or edges, they should be padded or protected with chafing gear
to prevent damage.
If block and tackle are used, the recommended storage procedure
is: pull the blocks together, coil the rope, store the coiled rope
with the end on the bottom and the block and tackle on the top. With
this procedure, the block and tackle are ready to use without tangling
or kinking of the rope.
Rope should be inspected for wear, breaks or other defects prior
to each use, or after each use to save time when the rope is needed.
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Manila and sisal rope should be replaced every year, if they are used
often or subjected to inclement weather.
Elevators and Hanlifts
Passenger elevators are usually well maintained and regularly in-
spected where the passenger load and frequency of use is great, such as
in office and commercial buildings. However, small industrial elevators
and hoists may be poorly maintained and seldom used regularly. If a
hoist or small elevator is going to be used for access to tall stacks,
the sampling crew should test the operation and alarms, and check out the
escape routes.
If the hoist or elevator seems to be unreliable based on preliminary
survey information or tests, the crew should see what maintenance or
emergency assistance can be provided. If alarms do not work or phones are
not reliable, the crew should carry a radio or other signaling device so
that assistance can be called if the hoist or elevator stops between
landings. If escape may be necessary and feasible, find out what is needed
to get out of the car and what is needed to get to a safe route to the
ground.
Manlifts are vertical conveyor belts for moving people from floor to
floor- in less space and time than required by stairs. Manlifts are old
fashioned, dangerous and not designed to move equipment or freight. Man-
lifts are constructed of a continuous belt with steps every 16 feet or
so and handholds 48 to 56 inches above each step. A continuous fixed
ladder without cage accessible from both the up and down side of the
manlift should be provided. A control rope or ride should be accessible
from any step on the manlift to stop the belt and apply the brakes. At
the top of the manlift there are supposed to be two separate automatic
devices which cut off the power and set the brake if the person does not
step off the manlift at the top platform. At the platform there should
be a grab bar to permit the rider to swing free and on to the top landing
if the emergency stops fail to operate at the top of the manlift.
Before riding a manlift check to see if (1) the emergency stop at
the top of the manlift is operative, (2) the emergency rope or rod along
the manlift's vertical surface is operable, (3) there is a permanent ladder
accessible to the up and down run, (k) the underside of the floors or
platforms on the up side have cone shaped guards to guide the ascending
person through the floor opening, (5) there is sufficient illumination to
see the platforms and stops, (6) there are instructions posted on each
landing, (7) the belt has not been spliced and does not show wear, and
(8) the top landing has a sign designating it as the top landing and to
get off.
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To ride a manlift: (1) face belt and put both feet squarely on
step, (2) hold handgrips firmly with both hands, (3) never carry tools
or objects in hands or protruding from pockets as they may catch on
floor openings, and (k) do not leap to catch a step that has passed the
floor landing. If there is any other way to reach the top ignore the
manli ft.
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CHAPTER 4
COMMUNICATION TECHNIQUES FOR ROUTINE
TESTING AND EMERGENCIES
Needs for Communication
Rapid and effective communication is needed between members of
sampling teams to help assure that the testing follows the established
schedule,and to correlate data recorded with the sampling activity and
the position of the probe. If shouts are not heard or gestures are
misunderstood, the test results may not be accurate, so there is a need
for audible and clear communication for routine testing.
During setup and breakdown there may be hoisting or lowering
operations that are not routine or that are carried out or assisted by
another contractor. For these infrequent operations (relative to
sampling) and for effective cooperation between people who may not work
together regularly, there is need for audible communication and visual
communication that is clear, rapid,-and not likely to be misunderstood.
If there is a plant emergency, such as a fire, tornado warning, or
unexpected release of toxic chemicals, it is imperative that sampling
personnel know the signals, and that they know what to do and can do it
promptly and correctly. If there is an emergency in the sampling
operations, such as observation of lightning or high winds, or damage to
equipment or injury to personnel, the sampling personnel need to have
some means of signalling the emergency and calling for the kind of
emergency help needed.
Types of Communication Systems
If plant noise is not too great and winds are not too high, and if
the vertical and horizontal distances are not too great, it may be
possible to communicate effectively by means of shouts and gestures.
However, this means of communication is easily interfered with by equip-
ment noise, passing trains and other vehicles, and the distractions of
the work.
Each sampling team can use their own system of hand signals to
indicate common messages such as temperature, move the probe, and so
forth. As a better means of signalling for attention to visual signals
than shouting, various inexpensive whistles, horns or bells can be used.
Team members can carry or wear the same type of whistle or other device,
or each can have a device with a distinctive pitch.
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Where distances or ambient noise levels are too great for a hand
bell or mouth-powered whistle or horn to carry clearly, there are Halon-
powered hand-held horns that can be used effectively.
Telephones provide a more rapid and effective means of communicating
than hand signals. However, there are expenses and difficulties
associated with stringing telephone wires.
Radio communication between sampling team members provides many
advantages, both for carrying out routine monitoring tasks and for
relieving some of the monotony of the monitoring. Radio communication
also is very effective for conveying special directions during setup
and breakdown, and for describing emergencies and the type of help
needed. In addition to radios for communication between team members,
it may be possible and is certainly desirable to borrow a radio from the
plant to be able to communicate directly with them in case of any
emergency. In addition to the two-way radios, it may be very helpful
to have a portable receiver to monitor local stations for weather reports
and for static which may indicate approaching storms.
Consider possible interference which may prevent uninterrupted use
of radio equipment provided by the sampling team or the plant. CB radio
channels are not likely to serve the needs of the sampling team, and CB
broadcasts may interfere with other channels. Equipment should be
checked out to be sure it can be relied upon.
Special Problems
Stack sampling personnel have been trapped in elevators and have
been unable to get help for several hours because telephone and alarm
systems have been out of order, and because no one noticed the team
missing. Before using plant elevators the team should be sure any
telephone is working and answered, and that the alarm system is working
and will summon needed assistance. As a back-up,team members should
keep in touch so that someone missing will b$ noticed within a short
time.
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CHAPTER 5
WORKING IN HOSTILE ENVIRONMENTS
One of the first things that is done on every commercial airplane
flight is an audible and visual review of emergency procedures to be
followed by passengers in case there is loss of cabin pressure or
emergency landing. The review of procedures for instruction of passen-
gers gets to be routine if you fly often, and seems to be unnecessary
preparation for emergencies that never happen, oxygen deficiency, fire,
or sudden impact. However, if any of these emergencies do occur, they
will be 1ife-threaten ing very suddenly!
While stack sampling personnel seldom encounter life-threatening
emergencies, routine difficulties and boredom being more common, stack
sampling operations are frequently conducted in environments which are
hostile or which may become hostile unexpectedly. Hazards outside of
buildings include temperature extremes, wind, electrical storms, and
releases of chemicals from process or control equipment. Hazards
inside of buildings include temperature extremes, noise, dust, and
releases of chemicals from process equipment.
Other chapters discuss emergency procedures for high winds, fire,
electrical storms, and overexposure to heat and cold, and some con-
ditions under which sampling outside should not be started or continued,
such as freezing rain.
If sampling operations take place inside a process building or some
other area in which there may be high ambient concentrations of toxic
gases or possibility of release of large quantities of toxic or
asphyxiating gases, sampling personnel should be able to escape if their
respirators fail or there is a release of hazardous gases.
If there is a possibility of a hazardous gas emergency in any
inside sampling location more than 75 feet travel distance from outside
air, each person should have an emergency escape device that will pro-
vide a respirable atmosphere sufficient for escape. Finding out whether
there has ever been a hazardous gas emergency in the plant, or whether
there is a reasonable possibility of one, should be a part of the
Preliminary Survey.
Each sampling crew that may encounter oxygen-deficient or extremely
contaminated atmospheres should be equipped with two self-contained
breathing masks for each person. Training is necessary for rapid, safe
and effective use of tne breathing apparatus.
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Each crew member entering a hostile environment should carry a
small, portable alarm device for signalling a serious emergency and
cal1 ing for help.
Under some circumstances where sampling personnel may encounter
dangers where immediate rescue is necessary for life safety, a harness,
life-line and attendant should be provided. Examples of such dangers
are: floating-roof tanks where the contents will not float a human
body (eg. gasoline); unguarded sloping roofs; elevated horizontal ducts;
and sampling sites where wind speeds may be extreme. A CO -inflatable
life jacket may be needed for work where a bulky life jacket would
interfere with sampling activities.
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CHAPTER 6
WORKING IN HOT AND COLD CONDITIONS
Hot Conditions
Overexposure to heat from work stress, ambient temperature and
radiant heat can cause a variety of ill-effects on humans, ranging from
cramps to collapse to possible death. Employees need to assess the
exposure and recognize the signs and symptoms of heat stress so they
can take preventive measures. Drinking water, salt, protective clothing
and regular rest breaks in a cool area need to be available and used to
prevent serious effects of overexposures. The effects of heat stress
can be so serious that the major effects are described briefly in the
next three paragraphs, and described in detail in a later section of
this chapter, with symptoms and treatment.
Heat cramps are muscle spasms caused by depletion of salt, exces-
sive sweating without replacement of the salt lost. Under extreme
exposures, salt loss may be as much as 6 to 8 teaspoonfuls in one day.
Heat exhaustion can result from excess loss of water and salt, and
affected persons may collapse from dehydration or inadequate circulation.
There is heavy sweating, little or no increase in body temperature, and
a rapid pulse, up to 150 beats per minute.
Heat stroke is an extreme failure of the body thermoregulation
system, with hot dry skin, flushed face, rapid and bounding pulse, and
high body temperature greater than 105° F. Continuous exposure to
extreme heat for as little as three hours can produce heat stroke.
Brain disorders may range from headache to delirium to unconsciousness.
Rapid cooling is urgent to prevent death.
Climbing ladders and stairs is heavy work that generates consider-
able metabolic heat. Heat stress as discussed in this chapter is not
likely to occur unless there is medium or heavy work.
Other factors that may magnify harmful effects of heat exposure
are chemical exposures, altitude, inadequate acclimatization, fatigue,
lack of sleep, consumption of alcohol, inadequate nutrition, cardiac
and respiratory conditions, and taking certain medications. Toxic
substances such as carbon monoxide have a synergistic effect so that
heat stress effects will occur at lower temperatures than expected, if
there are toxic exposures at the same time as heat exposures.
In order to assess the heat stress presented at sampling sites by
ambient conditions, we recommend that the Wet Bulb Globe Temperature
(WBGT) be determined during the Preliminary Survey, and confirmed during
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initial set up. If the WBGT is above 80° F or the wet-bulk temperature
is above 85° F, there is going to be sufficient heat stress to take
other steps to measure heat stress, body temperatures, and weight loss,
and to assess methods of reducing heat stress.
Some of the methods of reducing heat stress are rest periods in
cool areas, providing block and tackle for hoisting, providing cooling
fans or reflective clothing, or scheduling set-up work during a cooler
period of the day. Methods of reducing heat transfer to sampling
personnel include the following:
Reduce solar load (if sampling is done outdoors)
Wear light-colored clothing and headcovering (e.g. hard hat)
Cover as much exposed skin as possible
Provide shade if possible
Reduce conductive and radiant heat load from stacks
Provide insulating material on hot surfaces
Provide reflective surface to shield personnel
Improve convective heat load factors
Wear loose-fitting or limited clothing and promote evaporation
if ambient temperatures are below 100° F (37.8° C)
Cover the body as much as possible if the ambient air
temperatures are higher than 100° F (37-8° C).
At sampling sites where the heat stress may be severe, such as at
kilns or in desert areas, it will be advisable to equip sampling teams
with an oral medical thermometer. It may be necessary to keep the thermom-
eter in the ice chest or other cool area to keep the thermometer from
reaching temperatures above 100° F.
If personnel begin to have symptoms or show signs of heat stress, the
thermometer will be very useful in assessing the problem. Oral temperature
information and the signs and symptoms will help identify the degree of
heat stress before the problem becomes so severe that the affected person
cannot be brought down from elevated worksites without being lowered in a
Stokes Stretcher. Recovery of a seriously affected person is directly re-
lated to the severity of the symptoms when removed from the heat stress,
and the availability and vigorousness of the first aid treatment. If the
oral temperature exceeds 100° F as result of heat stress, the exposed
person should definitely be removed from further heat and work stress for
at least 2k hours.
Recovery of a person showing signs of extreme heat stress may also
depend on whether the affected person receives the needed medical aid
promptly.
Core body temperatures are a more accurate measure of the effects
of heat stress and are usually at least 1.0 degree F higher than oral
temperatures. Definitive first aid and medical treatment will use
rectal thermometers to measure core body temperatures. If a sampling
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team is going to work at a site remote from medical or paramedical
assistance, the team's first aid kit should include a rectal thermometer.
Any time a sampling team is going to be working more than three
miles or ten minutes from a source of medical assistance (infirmary,
clinic or hospital) it is necessary that one or more persons on the team
be trained in first aid. (It is desirable for all sampling personnel
to have had first aid training.)
Preventive Measures
If an employee is not exposed to a hot environment on a daily basis
the employee will not become acclimated to the hot environment and
sweating will be more profuse and will contain a higher percentage of
salts than is common with acclimatized workers. Thirst cannot be relied
upon to assure sufficient fluid intake.
In hot environments where heat stress may be severe, the following
recommendations should be considered for the protection of sampling
personnel:
(a) A minimum of 2 gallons of special fluid is recommended per
person. The fluid can be 0.1% salted and iced drinking
water, commercial products, special formulas (listed in
Appendix), or salt tablets and iced water.
(b) One break each hour to drink the salted water is recommended
unless the water with salt is available at the sampling
sites.
(c) Breaks to an air-conditioned or cool area will reduce the
heart rate and allow for a greater margin of safety in
preventing heat stress conditions.
(d) Weighing each exposed person before and after working in the
hot environment is recommended; weight loss will indicate
dehydration and the urgent need to drink more 0.1% salted
water or special fluids.
(e) Employees should be trained in recognition of the signs and
symptoms of heat stress.
(f) It is imperative that treatment begin immediately when
symptoms and signs of severe heat stress are present,
regardless of WBGT.
(g) Wear head covering and loose-fitting, absorbent clothing,
preferably cotton, to assist evaporation.
(h) If possible, schedule strenuous work and hot work in cooler
part of the day or year.
L-36
-------
Temperature Extremes
1. Heat Stroke (Sunstroke)
Serious medical emergency of major magnitude: Is uniformly fatal
unless treated promptly and adequately (vigorously).
Symptoms
(a) Skin is hot and dry, red, mottled, or cyanotic (gray to blue)
(b) Body core temperature 106° F and rising, oral temperatures of
105° F and rising.
(c) Heart bounding and rapid
(d) The worker may become confused, delerious, unconscious or
comatose, either slowly or rapidly.
Treatment
It is essential that treatment begin immediately. Rapid cooling of
the body is imperative.
(a) Saturate the worker's clothes with ice water. Do not protect
worker from any wind available. Shade from sun and any other
heat source.
(b) Evacuate to ground level, or if evacuation is delayed initiate
additional treatment before reaching ground level.
(c) Immerse in chMled water and massage the body vigorously, or
(d) If immersion is impossible, wrap the unclothed body in wet
sheets and fan vigorously with cool dry air, or
(e) If immersion or wrapping in sheets is not feasible, then soak
the worker's clothing with ice water and fan vigorously (use
an electric fan if available).
(f) Monitor body temperature to prevent the oral temperature from
dropping below 100° F. Continue to monitor body temperature
to detect either a continued drop or a rise.
(g) Treat for shock if present by elevating feet, legs, lower
torso or by placing on a plank with the foot end of the plank
or Stokes Stretcher elevated 12" - 2k" approximately. Wrap
in warm blankets if body temperature is down.
L-37
-------
(h) Transport to nearest hospital preferably by ambulance, van,
or accompanied in back of pickup truck in Stokes Stretcher
with feet elevated at least 6".
Complications may include: Kidney failure, liver failure, blood
disorders, impairment of the muscles of the heart, and permanent
brain damage. The complications are in part consequences of
prolonged high body core temperature and in part the result of
oxygen starvation of the tissues if shock is severe or prolonged.
Loss of consciousness accompanied by cyanotic (gray-blue) skin will
appear to be shock, but if the body temperature is elevated the
symptoms are from the heat stroke. If the body temperature is
elevated (\0k° F or above orally) but sweating is occurring, the
condition is probably the stage before heat stroke and the person
should be treated as vigorously as if suffering heat stroke.
2. Heat Exhaustion
Recovery is assured within one to five days if treated. If
untreated heat exhaustion usually will progress into heat stroke.
Symptoms
May appear during work or during res.t periods:
(a) Skinclammy and moist, pale, muddy or flushed.
(b) Body core temperature 99.5101° F oral temperature can be
below the normal 98.6° F.
(c) Heartthe pulse may be weak with the blood pressure low,
causing fainting, especially upon standing after sitting.
(d) Brainwill be rational, may have headache.
(e) General symptomsextreme fatigue, weakness, giddiness,
nausea. Any one or all may be present.
Treatment .
(a) Protect from sun and other heat sources.
(b) 0.]% salt water to replenish both the salt and fluids lost
from sweating, or
(c) Cold water to drink and pour over face and head.
(d) Evacuate to cool, preferably air conditioned, room.
L-38
-------
(e) Salt and water must be replaced In the body. Give salt
tablets with water or dissolve the salt tablets in the water.
(f) Transport to definitive medical care.
3. Heat Cramps
Heat cramps are caused by working in a hot environment and not
replacing the salt being lost by sweating. Salt replacement is
equally important with liquid replacement.
Symptoms
Spasms (cramps) of the skeletal muscles.
Treatment
(a) Drink 0.1% salted water.
(b) Transport to nearest doctor for saline I.V., if symptoms are
not relieved with the salted water or if the spasms are severe
and multiple.
L-39
-------
CHILL FACTOR
Wind in
m.p. h.
Calm
5
10
15
20
25
30
35
40
45
50
32
Local Temperature in Degrees Fahrenheit
23
14
5
-4
-13
-22
-31
Equivalent Temperature (Wind Plus Local Temperature)
32
29
18
13
7
3
1
-1
-3
-3
-4
23
20
7
-1
-6
-10
-13
-15
-!7
-18
-18
Little->
Danger
for Those
Properly
Clothed
14
10
-4
-13
-19
-24
-27
-29
-31
-32
-33
5
1
-15
-25
-32
-37
-41
-43
-45
-46
-47
-4
-9
-26
-37
-44
-50
-54
-57
-59
-61
-62
Considerable >
Danger
-13
-18
-37
-49
-57
-64
-68
-71
-74
-75
-76
Ext re
Dange
-22
-28
-48
-61
-70
-77
-82
-85
-87
-89
-91
-31
-37
-59
-73
-83
-90
-97
-99
-102
-104
-105
, ^
me *r
r
-40
-40
-47
-70
-88
-98
-104
-109
-113
-116
-118
-120
L-40
-------
Cold
Although stack samplers may not be exposed to extreme cold conditions
for prolonged periods, there are several different kinds of cold injuries
which can occur, even at temperatures above freezing. This section
describes exposure conditions which may cause cold injuries, and methods
to prevent or care for such injuries.
Local Cold Injuries
Chilblains can result from prolonged exposures of bare skin to
temperatures in the low sixties or below. The injury usually affects
the extremities as a chronic injury of the skin and peripheral capillary
circulation. Protecting the skin against exposure to cold for prolonged
periods is the method for prevention and for treatment of chilblains.
Immersion foot results from wet cooling of the extremities. Although
more common in wet feet exposed over hours or days at temperatures
slightly above freezing, it can occur at higher temperatures if wet feet
are exposed to cooling over prolonged periods. Prevention depends on
dry shoes and socks, and limited exposures with wet feet. Severe ex-
posures will require emergency treatment.
Frostbite can affect hands, feet, ears, and exposed parts of the
face, and the severity of the frostbite can range from incipient frost-
bite to superficial, to deep frostbite. Incipient frostbite, or frost
nip, appears as a sudden blanching or whiteness of the skin, and often
is not noticed by the person affected because it comes on slowly and is
painless. If identified early, incipient frostbite can be treated
effectively by warm hands or breath or by holding the nipped fingers
in the armpits. No type of frostbite should be rubbed, and snow should
not be used to rub frostbite.
Superficial frostbite causes the skin to have a white, waxy
appearance and firm touch, with the tissue beneath soft and resilient.
Treatment is protection from the cold and steady and careful rewarming
of the frostbitten area. Do not rub any frostbitten area.
Deep frostbite usually involves the hands and feet, and is an
extremely serious injury. Tissues are pale, cold, and solid, and
emergency medical treatment is urgent. The injured person must be
kept dry, given external warming, and watched to see if cardiopulmonary
rescuscitation is necessary. Emergency medical treatment will be
rapid rewarming in a warm water bath that does not exceed 105° F.
Systemic Hypothermia
Severe and general body cooling, known as systemic hypothermia,
can occur at temperatures well above freezing by exposure to low or
L-41
-------
rapidly dropping temperatures, or cold moisture, or to snow and ice.
Fatigue, exertion, and hunger are contributing factors.
Generalized body cooling can progress through five stages:
shivering; apathy, sleepiness, 1istlessness, and indifference; uncon-
sciousness, with slow respiratory rate and very slow pulse rate;
freezing of the extremities; and death. Sustained shivering begins
when the body core temperature falls below 95° F. With continued
cooling there will be stumbling, fumbling, clumsiness, slow reactions,
mental confusion, and difficulty in speaking. If the cold conditions
are extremely severe, death may occur within two hours of the first
symptoms. Emergency treatment of hypothermia requires moving the
person out of the wind, replacing wet clothing and providing external
heat in any way possible, because the person is unable to generate
sufficient body heat. Warm liquids and nourishing food should be pro-
vided if the person is conscious. A warm bath with the water kept
between- 105° F and 110° F is the most effective" way of warming a
victim of hypothermia. However, since hypothermia is such a severe
emergency, emergency medical treatment is needed promptly.
Wind Chill
The two important factors which contribute to cold injuries are
the temperature of the environment and the velocity of the wind.
Thermal conductivity of the environment is the mechanism that allows
for the effects of the extreme cold. The most common conductors of
cold to stack samplers are moisture, such as wet hands, and metal, such
as ladders and railings. Still air is a very poor conductor, but in-
creased velocity increases the wind-chill factor. Stack sampling opera-
tions should not generally be conducted when the wind-chill temperature
is below -20° F.
L-42
-------
CHAPTER 7
ELECTRICAL HAZARDS AND CONTROL MEASURES
Electrical shocks and fires are associated with defective wiring
that causes short circuits or ground faults. Insulation may fail due
to misuse, overloading, aging or attack by hostile environments
(chemical atmospheres). Static electricity may cause a fire or explo-
sion in the presence of flammable vapors or finely divided particles
such as dry fibers or dusts.
Ejffects of current on the body
The figures mentioned below are average figures for males. The
corresponding figures for females are 66% of those cited for males.
Perception or Reaction Current
The value at which a slight tingle is noticed is about 1.1 milli-
amperes or thousandths of an ampere. Although a slight tingle is not
dangerous, the startling effect might bring about an involuntary
reaction which could lead to an accident. Suppose the contact is made
by an individual who is working on a ladder or other elevated work site.
Let Go Current
The maximum value of current which still allows the individual to
release his hold on the electrical conductor is 15 mi 11iamperes. Values
above this level become hazardous because the individual is in effect
frozen to the conductor and his muscles aVe unable to respond to his
message to them to release the hold. Any direct contact with this
individual will then result in having the would-be rescuers similarly
frozen. Switching the current off or otherwise disconnecting the
conductor is the best method of releasing the person.
Lethal Currents
A value of approximately 18 mi 11iamperes through the chest cavity
will cause the muscles to contract and stop the individual from
breathing, bringing about death due to asphyxiation. Muscular contrac-
tions brought about by electric shock may be so violent as to break
bones.
L-43
-------
Ventricular fibrillation, a condition where the heart is uselessly
pulsing but not circulating any blood, can result from a shock when the
current in mi 11iamperes = 116 where t = contact time in seconds.
Currents above fibrillation values may stop the heart completely,
burn body tissues or damage the nervous system.
Summarizing and tabulating:
1 - 8 mi 11iamperes very slight shock
8-15 painful shockcan let go
15-20 painful shockcannot let go
20 - 25 painful, severe muscular contraction,
breathing difficulty
50 - 100 ventricular fibrillation possible
100 - 200 ventricular fibrillation certain
200 and over severe burns, severe muscular
contraction, chest muscles clamp
Jieart and stop it during shock.
The severity of an electrical shock will depend on the path through
the body and will increase as the voltage increases, with increasing
moisture at the contact point, with increased pressure at the contact
point and with an increase in the contact area.
Fuses primarily protect electrical components from excessive
current flow and thus prevent fire and equipment damage. But fuses do
not protect against shock since they must be large enough to carry the
load current which is normally 1000 times greater than the 15 or 20
milliamps that will bring problems to humans.
Preventive Measures
In order to minimize the problems of electrical origin, the
following procedures should be employed.
1. Use grounded electrical equipment whenever possible, or use
double-insulated equipment. Some experienced stack test
crews run separate grounds as supplemental protection in
case the plant electrical system does not provide an
effective grounding circuit. Metal cases or frames of
sampling equipment should be grounded to prevent shock if
probe heater wires short out to the equipment.
2. In areas where flammable vapors or dusts are present, use the
proper explosion-proof equipment and enclosures.
3. When necessary, equipment may be purged with an inert gas or
pressurized with air so that all leakage is outward. This
L-44
-------
will prevent the explosive atmosphere from entering the
enclosure with the potential arcing device or ignition
source.
*». Intrinsically safe circuitry may be employed. This defines a
class of device where failure of any component, by any means,
will not generate sufficient energy to ignite the explosive
atmosphere.
5. Use of a Ground Fault Interrupter (GFl) will automatically
disconnect a circuit from the line in a few milliseconds
when a preset current value is exceeded, e.g. 5 mi 11iamperes.
The GFl, which is placed between the source and the load,
compares the current in the two conductors. As long as they
are in balance, the current continues to flow. When there
is an unbalanced condition brought about by a leakage path
to ground through faulty insulation or through a human
(causing shock) the circuit is automatically broken. It
should be realized that GFI's do not protect against line to
line contacts. When used with long extension cords, there
may be nuisance tripping due to ground leakage through the
conductor insulation.
Many electrical problems occur at the cord-receptacle interface.
Addressing that problem, the National Electrical Manufacturers Associa-
tion (NEMA) has developed standards to minimize the chance for accidents
Connecting parts for 15 A - 125 V will not fit 20 A - 220 V ratings,
and encapsulated or dead front plugs and receptacles are replacing the
older style units.
All electrical equipment and power tools should be examined and
tested each time they are being prepared for shipment to a test site.
A specific check list should be prepared for each item and used to
conduct the tests. The reference for electrical equipment is the
National Electrical Code prepared by the National Fire Protection
Association.
All portable electric tools, power and light extension cords,
adaptors and multiple outlet boxes should be examined to see if the
insulation has been damaged, if conductors are exposed, or if connec-
tions are loose. Grounding circuits should be checked for continuity,
and grounding pins and connections should be undamaged. Damaged cords
should be replaced, not spliced or taped. Check closely for damage to
cords where they enter plugs or equipment, at the point where flexing
and other stress may cause damage to insulation.
In order to avoid startling or painful shocks on electrostatic
precipitators, it is essential to ground the metal parts of the probe
and sampling equipment.
L-45
-------
Static Electricity
Static electricity is electrical energy which accumulates on the
surface of a non-conducting material or an insulated conductor. The
hazard is a spark which may form when this energy discharges to ground.
A static charge may be formed whenever particles make and break contact
as in a moving airstream. Pouring of liquids with splashing may gener-
ate static as may a rapidly moving belt or web. Bonding or tying the
component parts of a system together and then grounding will help
dissipate the charge as it is formed.
Dangerous accumulations of static electricity may be prevented or
controlled by humidification or by ionization of the air to make it a
conductor of electricity. Proper grounding will conduct the static
charge away before it has a chance to build up sufficiently to cause
a spark.
Static charges generated by the human body are normally conducted
away through clothing and shoes. Where volatile flammable liquids and
gases are used, workers should not wear rubber soled footwear (which
insulates them). In some areas, it may be advisable for them to wear
special conductive shoes or straps and to stand on grounded metal plates
or conductive floors.
L-46
-------
CHAPTER 8
FLAMMABLE HAZARDS AND CONTROL MEASURES
Gases, vapors and liquids that can be easily ignited and burn with
extreme rapidity are called "Flammable." Such materials are used for
cleaning and as reagents in some source testing methods, and may be
encountered in some process streams, emissions, and industrial environ-
ments. While flammable hazards may be minor or under control most of
the time, it is important to recognize the hazards and understand the
importance of all the precautionary measures that can be taken.
Flaming Combustion
Flaming combustion or fire results when a flammable concentration
of fuel is present in an oxidizing atmosphere such as normal air and
there is a source of ignition. In the normal atmosphere, there are two
basic precautions that can be taken to prevent fire and explosion: (1)
prevent the introduction or accumulation of sufficient flammable
material to provide the fuel for a f-ire; (2) eliminate or prevent the
introduction of any source of ignition which can set the fuel on fire.
Fires and explosions have been rare in source sampling because
flammable concentrations of gas and vapor have not been common, and
because ignition sources have generally been kept out of flammable
concentrations of gas and vapor. Let's consider what has been done
and what you may need to do.
Ignition Control
The most frequent method of controlling ignition sources is to
prohibit smoking in areas where there may be combustible materials or
flammable gases or vapors. If the sampling site is posted "No Smoking,"
or if the facility has a No Smoking rule, there should be no smoking
except in designated areas. Sampling personnel may invoke their own No
Smoking rule if necessary to prevent contamination of samples or
ignition of acetone, sampling equipment or test atmospheres. No Smoking
safety regulations should apply to all persons within the area being
protected.
Since most sampling equipment uses electricity for heating,
lighting, switching and power, there are many ignition sources available.
If sampling equipment has to be used in flammable atmospheres, it will
be necessary to provide explosion-proof equipment or take special
measures to enclose and purge the equipment to exclude flammable vapors.
The purge can be nitrogen or air fed from an area without flammable
vapors.
L-47
-------
Flammable Concentrations
Combustible vapors and gases will not catch fire unless they are
In the right concentrationin the flammable range. The flammable range
Includes concentrations from the lower limit of flammability to the
upperJimit, In air with the normal concentration of oxygen. Table 1
shows the flammable limits for some common gases. All of the gases
listed are considered flammable gases except anhydrous ammonia.
Organic liquids can be heated to temperatures which cause enough
evaporation to produce a flammable concentration of vapors. The
temperature required to produce vapor concentrations at the lower limit
of flammability Is called the flash point temperature.
Liquids which have flash point temperatures below 100° F (37.8° C)
are defined as Flammable liquids by DOT and OOL.
There is concern about safe storage and handling of flammable
liquids because at common ambient temperatures a spilled liquid will
rapidly generate a flammable concentration of vapors. If the spill is
large enough so that the flammable concentration of vapors can reach an
Ignition source before dissipating, there is likely to be a flash fire
or explosion. .
Combustible liquids have flashpoints at or above 100° F (37.8° C).
Such liquids can present serious fire hazards if the liquids are heated
above their flashpoint temperatures, or if the liquids are sprayed or
atomized, or evaporated by spills on clothing or other porous materials.
Some common flammable and combustible liquids are listed in Table 2
with their flash point temperatures, autolgnition temperatures and
flammable limits in air.
L-48
-------
Table 1 Flammable Limits for Some Flammable Gases
Gas Lower Upper Ignition Temperature
Acetylene
1, 3-Butadiene
Butane
Cyanogen
Methane
Propane
Hydrogen
Carbon Monoxide
2.5
2.0
1.9
6.6
5.0
2.2
4.0
12.5
100
12.0
8.5
32
15.0
9.5
75
74
581°F
788
761
1004
842
752
1128
Table 2 Fire Hazard Information on Some Flammable Liquids
Liquid Flash Flammable Limits Ignition Temperature
Point Lower Upper
"F
Acetone -4
Benzene 2
Dioxane 54
Ethyl ether -49
Ethyl alcohol 55
Methyl alcohol 52
Isopropyl
alcohol 53
Isopentane -60
Toluene 40
Xylenes 81-90
2.6
1.4
2.0
1.9
3.3
6.7
2.0
1.4
1.2
1.1
12.8
7.1
22
36.0
19
36
12
7.6
7.1
6.0-7.0
0 p
1000
1044
356
320
689
725
750
788
896
281-292
L-49
-------
0 0 PER AT
APPROVED TYPE OF EXTINGUISHER
KIND OF FIRE
FOAM: Don't Play Stream Into thi Burning
Liquid. Allow Foem to Fall Lightly on Fira.
DECIDE THE
CLASS OF
FIRE YOU ARE
FIGHTING. .
. . .THEN
CHECK THE
COLUMNS
TO THE
RIGHT OF
THAT
CLASS
MATCH UP PROPER EXTINGUISHER WITH CLASS OF FIRE SHOWN AT LEFT
ROINARY
)RY
CHEMICAL
GAS
CART-
RIDGE
Water Ex
palled by
Carbon
Dioxide
Gas
MULTI-
PURPOSE
DRY
CHEMICAL
PUMP
TANK
Plain
Water
CARBON
DIOXIDE
Carbon
Dioxide
Gat Under
Pressure
SODA
ACID
Bicarbonate
of Soda
Solution
and Sul-
phuric Acid
FOAM
Solution of
Aluminum
Sulphate
and Bicar-
bonate of
Soda
CLASS A FIRES
CARBON DIOXIDE: Direct Discharge as
dose to
Fire as Pos-
. First
at Edge of
Flames
and Gredu-
ally For-
C ward and
USE THESE
EXTINGUISHERS
ORDINARY
COMBUSTIBLES
WOOD
PAPER
CLOTH
ETC.
SODA-ACID, GAS CARTRIDGE: Direct
Stream at Base of Flame
CLASS B FIRES
USE THESE
EXTINGUISHERS
*
FLAMMABLE
LIQUIDS, GREASE
GASOLINE
PAINTS
OILS. ETC.
PUMP TANK: Place Foot on Footrest and
Direct Stream at Bese of Flames
CLASS C FIRES
USE THESE
EXTINGUISHERS
DRY CHEMICAL: Direct at the Bese of the
Flames. In the Case of Class A Fires. Follow
Up by
Directing
the Dry
Chemicals
at Remain-
ing Material
lt That is
Burning
ELECTRICAL
EQUIPMENT
> MOTORS
SWITCHES
ETC.
NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH
-------
CHAPTER 9
CHEMICAL HAZARDS
Stack sampling crews have three major sources of exposure to
chemical hazards on the job: chemicals used in test procedures;
chemicals in the effluent and process streams being sampled; and
chemicals used or processed or generated in the plant being monitored.
This chapter described the hazards of chemicals commonly used
for stack sample analysis, and defines common terms which are used to
describe chemical hazards and which may appear on container labels.
Federal shipping regulations are described, including the limitations
on shipments by various modes of transportation.
As an aid to assess the hazards of exposure to stack gases and
process streams, and other chemicals that may be encountered, an
Appendix has been provided with information on some 400 industrial
chemicals for which inhalation exposure limits have been established.
The Appendix lists the substances, whether they are readily absorbed
through the skin, their health hazards, exposure limits adopted by
OSHA, whether the limit is a Ceiling value instead of an eight-hour
time-weighted-average limit, and levels above which exposures are
considered to be Serious violations of OSHA Standards
Hazards of Skin Contact with Chemicals
Chemicals in contact with the skin may have no effect, may irritate
or destroy tissue, or may sensitize or penetrate the skin. For example,
acetone, hydrochloric acid, toluene, and dilute hydrogen peroxide will
irritate the skin if there is repeated or prolonged contact. Irrita-
tion will be more severe on more delicate tissues such as the eyes.
Some chemicals can cause sensitization of the skin and subsequent
allergic reactions; formaldehyde, toluene di-isocyanate, and some epoxy
resin system components are examples of chemicals which can sensitize
some people. Nitric acid, sodium hydroxide, and sulfuric acid in con-
tact with the body will be corrosive and cause destruction of tissue.
If emergency water is available immediately in sufficient quantity,
flushing chemical spills from the body may prevent serious damage.
Personal protective equipment and safe procedures are useful in pre-
venting chemical splashes and reducing the need for emergency water.
Benzene and phenol can both penetrate unbroken skin, but with
different results. Benzene can over a period of time cause severe and
even fatal blood diseases, including leukemia. Phenol is rapidly
absorbed through the skin, affects the central nervous system, and
L-51
-------
contact with as little as 64 square inches of skin can cause death
within 30 minutes.
If phenol contacts the skin, flushing for 20 minutes with WATER
is essential. Do NOT flush with alcohol, unless it is possible to
do so in a way that prevents spreading the phenol! Washing phenol
with alcohol usually dissolves and spreads the phenol over a greater
area of skin and increases the absorption.
Inhalation Hazards
Inhalation of chemical gases, vapors or particles can have
immediate effects from acute exposures to relatively high concentra-
tions, or delayed effects from chronic exposures to relatively low
concentrations. Acute effects include asphyxiation, irritation, nar-
cosis,S various systemic effects. Asphyxiation may be simple asphyxia-
tion from oxygen deffciency in an enclosed space or pit, or chemical
asphyxiation from gases such as carbon monoxide. Irritation may
occur in the upper respiratory tract or in the bronchi and lungs, and
some acute exposures can have serious delayed effects, including death.
High concentrations of nitrogen oxides from nitric acid or other
sources (200-700 ppm) can have serious delayed effects or cause death
after as long as 2k hours.
Narcosis can occur from inhalation exposures to vapors of many
solvents, including toluene and high concentrations of acetone.
Effects of narcosis can range from headache through incoordination to
unconsciousness, and in extreme cases to death.
Chronic exposures for long times to low concentrations may produce
noticeable effects or delayed effects, often difficult to associate
with the exposure. Inhalation of mercury vapor at concentrations over
0.1 milligrams per cubic meter(mg/m3) are 1ikely in time to produce a
mercury poisoning with symptoms such as a metallic taste in the mouth,
and signs such as intention tremors and other neurological and
psychological changes. Continuing exposure to some chemicals can pro-
duce subtle and disabling effects on various body systems, including
sterility, birth defects, and cancer. Some common chemicals such as
vinyl chloride and benzene have been shown to cause an increased
incidence of cancer in exposed workers, with the cancers developing as
much as fifteen years after the exposure. (In most cases the
exposures have been extended over a period of many months or years.)
Ingestion and Injection of Chemicals
Chemicals may enter the body unintentionally through ingestion if
chemicals are brought to the mouth on unwashed hands or in contaminated
L-52
-------
food or beverage containers. Chemicals are not likely to be injected
in an industrial plant unless a high-pressure line breaks or an
extreme high-pressure jet is encountered.
Label ing Terms
"Corrosive" is the term used by the Manufacturing Chemists
Association and the Department of Transportation to identify chem-icals
which will cause destruction of living tissue.
"Irritant" is the term used for chemicals which will produce
observable ill effects less severe than destruction of tissue, an
inflammatory reaction.
"Poison" is the term used for certain regulated materials which
will cause death at doses of 50 milligrams or less per body weight in
kilograms. The dose likely to cause poisoning death of a 70 kilogram
person (about 1^5 pounds) would be one teaspoon or less of a material
classified as a Poison. DOT would also classify as Poison any material
which would cause death in half or more of an animal test population
with skin contact of 200 mg/kg or less, or breathing concentration of
200 ppm or 2 mg/liter for one hour. The Manufacturing Chemists
Association defines "highly toxic substance" in the same terms.
"Toxic substances" are not regulated by DOT but are defined by
MCA as those materials having a median lethal dose from 50 to 500 mg/kg
body weight orally, from 200 to 2000 mg/kg by skin absorption, and from
200 to 2000 ppm or 2 mg/1 to 200 mg/1 by inhalation. Toxic chemicals
would be likely to cause death in a 70 kg person if the oral dose were
between one teaspoon and one ounce.
"Flammable Liquid" and "Flammable Gas" are terms used for liquids
with closed-cup flash point temperatures at or below 100°F (37.8°C) and
for flammable gases such as propane, hydrogen, acetylene, and methane.
"Oxidizers" are defined by DOT as substances such as chlorates
peroxides or nitrates that yield oxygen readily to stimulate the com-
bustion of organic matter. Oxygen is now classified by DOT as an
Oxidizer.
"Compressed Gas" labels are required by DOT for cylinders that are
not otherwise labeled.
Since the fatal crash of a cargo plane in Boston as a result of
breakage of an improperly packaged shipment of nitric acid, there has
been increasing restriction on air shipment of hazardous materials.
Other transportation incidents have led to serious restrictions on other
modes of transportation for hazardous chemicals. DOT places legal
responsibility for compliance with hazardous materials shipping
L-53
-------
regulations on every person who packs or ships hazardous materials,
and requires mandatory training for compliance.
The basic restrictions on shipment of hazardous materials are
these:
Do not mail hazardous materials
Do not carry any hazardous chemicals on plane trips, in either
personal or checked baggage. (Fines for honcompliance have reached
$15,000.)
Use only UPS or Federal Express to ship hazardous chemicals, to
avoid passenger-carrying vehicles and planes.
Prepare shipping papers as required for any shipment or transpor-
tation of hazardous chemicals. (See Appendix for sample of shipping
paper; see CFR kS for details of packaging, shipping papers, labeling
and placarding.)
L-54
-------
CHEMICAL
Acetic Acid
HEALTH HAZARD
Liquid and vapors are corrosive in direct relation to
concentration. Irritating to nose, throat, lungs, and
skin. First Aid: Flush well with water then treat as
a thermal burn. Decontaminate clothing.
FIRE HAZARD
Combustible. Flash point 109°F (A3°C), LEL k%t.
Ignition temperature 975°F (S2k°C). AVOID: storing
with oxidizers, or temperatures below 63°F (for glacial)
Corrosive to metals.
Acetone
HEALTH HAZARD
Irritating to nose, throat, and skin. Causes narcosis
at high concentrations. FIRST AID: flush eyes/skin
with water then treat as thermal burn.
FIRE HAZARD
Extremely Flammable Liquid. Flash point -VF (-20°C),
LEL 2.6%, Ignition temperature 1000°F (538°C). Avoid
all sources of ignition. Provide ventilation to
prevent flammable concentrations.
Benzene
HEALTH HAZARD
Toxic and can cause leukemia. Readily absorbed through
skin, eyes, and respiratory tract. Affects central
nervous system. Causes narcosis. Repeated inhalation
of less than lOppm can cause liver, kidney, and bone^
marrow damage. Can cause aplastic anemia and leukemia.
Provide ventilation to limit exposures to less than
1 ppm. FIRST AID: Flush with water 15 minutes for
accidental contact to eyes and skin.
FIRE HAZARD
Extremely Flammable Liquid. Flash point 2°F (-17°C),
LEL ].k%, Ignition temperature 10W*F (562°C). AVOID:
All sources of ignition and vaporizing in enclosed
space. Reacts vigorously with oxidizers.
Fuming Sulfuric
Acid
HEALTH HAZARD
Rapidly destructive to body tissue. Will cause 3rd
degree burns. Eye damage may result in blindness.
Inhalation may be fatal from spasm of the .larynx
L-55
-------
CHEMICAL
Fuming Sulfuric
Acid (Continued)
HEALTH HAZARD (CONTINUED)
usually within 30 minutes. May cause lung tissue damage
with edema. 3mg/M3 causes choking in uninitiated.
Exposure above Img/M^ for 8hrs. will cause lung damage
and in higher concentrations death. Provide ventilation
to limit inhalation. FIRST AID: Immediately flush with
copious amounts of water at least 15 minutes. Remove
clothing under shower and decontaminate. Treat residual
chemical burn as thermal burn.
FIRE HAZARD
Reacts violently with metals and organics.
Hydrochloric
Acid
HEALTH HAZARD
Highly toxic. Vapers are highly irritating to eyes, skin,
nose, and lungs, causing severe damage. May cause
bronchitis, pneumonia, or edema of lungs. Exposure to
concentrations of 0.13 to 0.2$ can be lethal to humans
in a few minutes. Provide ventilation to limit exposure.
FIRST AID: Flush immediately with copious amounts of
water at least for 15 minutes. Then treat as thermal burn.
Decontaminate clothing before reuse.
FIRE HAZARD
Will react with metals, producing Hydrogen.
storing with metals.
AVOID:
Hydrogen
Peroxide
HEALTH HAZARD
Irritating to eyes, skin, nose, and lungs. FIRST AID:
Flush with copious amounts of water immediately and for
at least 15 minutes. Then treat as thermal burn.
Decontaminate clothing before reuse.
Nitric Acid
HEALTH HAZARD
Highly corrosive to eyes, skin, nose,
cause bronchitis, pneumonia or edema.
and lungs. Vapors
Reaction to in-
halation may be delayed as long as 30 hours and still be
fatal. Provide ventilation to limit exposures. FIRST
AID: Flush eyes and skin immediately with copious amounts
of water at least 15 minutes. Then treat as thermal burn.
Decontaminate clothing before reuse.
L-56
-------
CHEMICAL
Nitric Acid
(Continued)
FIRE HAZARD
Strong oxldizer. Hazardous reactions occur if mixed
with organic materials, including solvents. Provide
ventilation to limit exposures.
Phenol
HEALTH HAZARD
Highly toxic. Absorption thru intact skin is very
rapid. Symptoms may appear within 15 minutes with
death in 30 minutes involving the central nervous
system from a solution spill covering as little as
64 sq. inches of skin. Where death is delayed, damage
is caused to the liver, kidneys, spleen, and lungs.
Pulmonary edema may occur. FIRST AID: Flush skin
and eyes with copious amounts of water IMMEDIATELY
and for at least 15 minutes while removing
contaminated clothing. For INHALATION: remove from
exposure, wash from skin, give artificial respiration
if needed.
CAUTION: Do NOT flush with alcohol.
FIRE HAZARD
Combustible liquid.
ignition temperature
Flash point
1319°F (715°C).
175°F
(79°C);
Phenoldisulfonic
Acid
HEALTH HAZARD
Irritant. Flush well with water
eye contact.
in case of skin or
Sodium Hydroxide
HEALTH HAZARD
Causes severe damage to eye tissue, and skin.
Inhalation causes irritation to nose, throat, and
lungs. FIRST AID: Flush eyes and skin with copious
amounts of water for 15-30 minutes. Then treat chemical
burn to skin as thermal burn. Burn to eyes require
additional treatment by a physician, preferable by
an eye specialist.
FIRE HAZARD
Reacts exothermally with limited amounts of water.
1-57
-------
CHEMICAL
Toluene HEALTH HAZARD
Readily absorbed thru skin. Causes narcosis.
If contaminated with benzerfe,symptoms of benzene
exposure will be directly related to extent of
contamination. FIRST AID: Flush eyes and skin
with water. Fresh air for narcosis.
FIRE HAZARD
Flammable liquid. Flash point AO°F (^°C),LEL
1.17%. Ignition temperature 997°F (536°C).
L-58
-------
DOT Hazardous Materials Regulations
Maximum Net Quantity in
One Package
Chemical
Acetic Acid
Acetone
Benzene
Hydrochloric Acid
Hydrogen Peroxide
8-40%
Nitric Acid
Phenol
Proper shipping name
Hazard Class
and
Hazard Label
Corrosive Material
Flammable Liquid
Flammable Liquid
Corrosive Material
Oxidizer
Oxidizer
Corrosive Material
Poison B
Passenger-
Carrying
Aircraft
1 qt.
1 qt.
1 qt.
1 qt.
1 qt.
Forbidden
Forbidden
50 Ibs.
Cargo Only
Aircraft
1 gal
1 gal
1 gal
10 gal
1 gal
Forbidden
5 Pints
250 Ibs
is "Carbolic Acid"
SuIfuric Acid, Fuming
Proper shipping name
is "Oleum"
Sodium Hydroxide
Dry, solid, flake,
bead or granular
Liquid or Solution
Toluene
Corrosive Material
Corrosive Material
Corrosive Material
Flammable Liquid
Forbidden
25 Ibs.
1 qt.
1 qt.
5 Pints
200 Ibs,
1 gal,
1 gal
Name and hazard class of material must be shown on shipping papers. Specif!
cation packaging must be used.
L-59
-------
CHAPTER 10
PERSONAL PROTECTIVE EQUIPMENT
Personal protective equipment is important because it provides
an immediate barrier between stack sampling personnel and potentially
hazardous materials and conditions.
Although personal protective equipment is used because it is
usually not possible to confine all hazardous materials and guard
against all energy sources, it provides only limited protection.
This chapter outlines the needs for and limitations of head, eye,
hearing, respiratory, and foot protection
Head Protection
Safety (hard) hats should be used during stack sampling activities
whenever there is the possibility of impact from falling objects. The
impact energy rating of a hard hat is kO foot pounds. Since a hard hat
alone may not provide sufficient protection against the impact of falling
objects, it is essential that the area under a suspended load or an
overhead operation be kept free of personnel by the erection of barri-
cades and the placement of signs.
Hard hats with a complete brim offer better protection than those
with a brim in front only. Hats can be equipped with neck straps to
keep -the hat in place in the wind or when bending over. They can also
be equipped with winter liners for protection against cold or radiant
heat.
It is important to maintain the maximum protection of hard hats
by protecting the structural integrity of the shell. Hats should
not be stored in the sun or in high temperature areas because they
may become brittle. They must not be modified with holes or notches.
The shell should be discarded if it becomes broken, punctured or
brittle.
It is also important to insure the correct adjustment of the
suspension strap to provide proper clearance between the shell and
the wearer's head. Reduction of the manufacturer's recommended
clearance will reduce the energy absorbing capacity of the hat.
More information on hard hats is available from vendors or from
"Safety Requirements for Industrial Head Protection" ANSI Z 89-1 - 1969-
L-60
-------
Eye Protection
Safety glasses should be the minimum eye protection worn by
stack sampling personnel, to protect against frontal impact from
flying and falling particles. Safety glasses which meet OSHA/ANSI
standards for industrial eye protection will withstand the impact
equivalent to a 2.4 ounce steel ball dropped 50 inches. Standard
safety frames will keep the lenses in the frames. Normal eyewear
without safety frames and industrial quality lenses are thinner and
will not withstand nearly as much impact. Side shields are recom-
mended to provide side protection. Cover goggles provide additional
protection and should be used for dusty areas, overhead work, handl-
ing corrosive or irritating chemicals. Face shields offer more
protection and may be cooler for some operations.
Hearing Protection
Hearing protection may be necessary at some test sites to
prevent hearing loss. Long term exposure to high levels of sound
can cause permanent loss of hearing in many frequency ranges as a
result of nerve damage. Even short exposures can cause temporary
loss of hearing ability.
A simple test for the need for hearing protection is to try
speaking to a person standing beside you. If y6u have to shout to
communicate, you need ear protection devices to reduce the amount of
sound reaching your ears. Although hearing protectors reduce the
sound level in many frequency ranges, they actually improve speech
communication by reducing the interference caused by other sounds.
Earmuff hearing protectors generally provide the most effective
protection. They fit over the ears and are held in place by a head
band, which can be attached to a hard hat if the hat has an attachment
provision. If glasses, sideburns or long hair prevent effective use
of earmuff protectors, the next best protection is a set of the best
fitting and most efficient molded earplugs available. Some of these
are "universal" (one size fits all) while others must be fitted to
the user. The least effective but most readily available and cheapest
protectors consist of a small wad of synthetic fibers which is shaped
as it is inserted into the ear canal. Extra plugs are recommended,
especially in remote locations where replacement may be difficult.
The actual noise attenuation offered under working conditions
by ear protection devices is only about 33 to 60 percent as effective
as claimed by the manufacturer. Ratings are based on tests in which
the ear protectors are fitted perfectly; however, normal work activi-
ties usually prevent a perfect fit and there is some leakage of sound.
L-61
-------
Respiratory Protection
Respiratory protection is needed for many stack sampling operations,
and it requires planning in advance. Respiratory protection must be
selected that will provide adequate protection for stack sampling person-
nel, personnel must be given special physical examinations and training,
and equipment must be maintained.
A physical examination prior to wearing respiratory protection is
essential to determine whether an individual can wear a respirator. The
physical can be part of an annual or special examination. The physical
should include an assessment of the individual's general health, the
cardiovascular system and the respiratory system. The assessment should
include at least an EKG at rest and at exercise; blood tests, including
liver and kidney function, chest X-ray; and vital capacity, functional
volume capacity, exhaled air first minute and exhaled air middle quarter
of test. Any abnormality or potential problems should preclude the
wearing of respiratory protection.
There are two basic types of respiratory protection: air supplying,
and air purifying. The air purifying types, with filters and canisters,
are limited to relatively low concentrations of contaminants and those
with warning properties that will signal when the filter or canister no
longer is functioning. The air purifying filter and canister masks must
NOT be used in oxygen-deficient atmospheres because they do not provide
any oxygen. Atmospheres with less than ]6% oxygen will not support com-
bustion, and they can be dangerous if exertion is great. Oxygen concentra-
tions below ]2% become life threatening, and persons entering a seriously
oxygen-deficient atmosphere will be overcome so rapidly that they will not
be able to escape.
Air purifying respirators will be labeled with the particulate or
vapor or gas for which they have been rated by MESA or NIOSH. In general,
they will not provide protection at concentrations of contaminant greater
than ]%, and it is recommended that they not be relied upon in concentra-
tions greater than ten times the PEL listed. Unopened cartridges should
be replaced before their expiration date; opened cartridges should be re-
placed immediately
Air supplying respirators include airline respirators, and self-
contained breathing apparatus (SCBA). Only SCBA are safe to use in
atmospheres which are immediately dangerous to life, including oxygen-
deficient atmospheres. Current standards for SCBA require a positive
pressure demand system which supplies air to the facepiece or hood con-
tinuously to maintain the inside pressure higher than that of the
surrounding atmosphere. The demand mode supplies additional air for
breathing during the inhalation, while the mask maintains positive pressure
inside the face piece.
L-62
-------
The fit of respirator facepieces is crucial to the satisfactory
performance of the respirator. Without a tight seal, the facepiece will
allow contaminated air from the surrounding atmosphere to enter the
respiratory tract. The seal of a facepiece can be checked with amyl
acetate while moving the head from side to side, up and down, and bending
the body, lifting and under stress such as a treadmill. If the olfactory
threshold for amyl acetdte is high, a smoke tube should be used.
Training should include the limitations and performance of respira-
tors, and an opportunity to wear the system in an uncontaminated atmos-
phere to appreciate its unique characteristics, and to identify possible
latent claustrophobia which could be life-threatening if the mask were
removed in a toxic atmosphere. Training should also include a period of
use in a simulated emergency, and training should be updated with refresher
courses at least every two years.
Standard operating procedures should be written whenever respirators
are to be used, and the procedure should include the hazards that may be
encountered and countermeasures, respirator selection, fit, use and care.
All respirators should be inspected for wear and cleaned after each
use, or monthly. Any necessary repairs should be made prior to storage
in a sealed container.
Foot Protection
Safety shoes with protective metal toe caps are highly recommended
for stack sampling personnel, and they may also be required by plant
rules.
These shoes come in three classifications depending upon the amount
of protection they provide the toes:
No. 30 - withstand 1000 pounds of compression and 30
foot pounds of impact
No. 50 - withstand 1750 pounds of compression and 50 foot
pounds of impact
No. 75 - withstand 2500 pounds of compression and 75 foot
pounds of impact
Steel mills and some other industries with heavy equipment and
serious foot hazards often require employees and visitors to wear shoes
with special protection for the top of the foot, (the metatarsal arch)
as well as the toes. Visitors with regular safety shoes usually are
required to put on metatarsal protectors to comply with plant rules.
Although such metatarsal protectors should be worn while on the plant
flpor in this type of operation, they are a hazard to climbing. Stack
sampling personnel should plan to leave the metatarsal protection at
the bottom of any ladder that has to be climbed. It may be advisable
to inform plant safety personnel of the importance of adapting their
rules to this special situation.
L-63
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
ABATE
ACCTAUCHYOe
ACETIC ACID
ACETIC ANHYDRIDE
ACETONE
ACETONITRILE
2-ACrTYLAMIHOFLOURENE
ACETYLCNE
ACETYLENE TETRABRONIDE
ACROLEIN
ACKYUNIOE SKIN
ACRYLONITRILE SKIN
AURIN SKIN
ALLYL ALCOHOL SKIN
ALLYL CHLORIDE
ALLYL 6LYCIOVL ETHER (ACE) SKIN
ALLYL morn. OISULFIOE
ALPHA-CHLOROACETOPHEHOHE
ALPHA-METHYL STYRENE
ALPHA-NAPHTHYLAMINE
ALUNDUM (A123)
4-AMINOOIPHENYL SKIN
2-AHINOmiOINE
AMMONIA
ANNONIUN CHLORIDE
AMMONIUM SULFAMATE
N-AHVL ACETATE
AHVL ACETATE-SEC
ANILINE SKIN
ANISIOINE (0-P 1 SOBERS )
ANTIMONY t COMPOUNDS (! Sb)
AHTU (ALPHA NAPHTHYL THIOUREA)
HEALTH HAZARD
PRINCIPAL EFFECTS
OR BASIS/PEL
CHOLINESTERASE INHIBITION
HARKED IRRITATION-EYE, NOSE, THROAT, SKIN
HARKED IRRITATION-EYE, NOSE. THROAT. SKIN
HARKED IRRITATION-EYE. NOSE, THROAT, SKIN
MILD IRRITATION-EYE. NOSE. THROAT/NARCOSIS
MILD IRRITATION-EYE. NOSE. THROAT/ACUTE
TOXICITY (CYANOSIS)
CANCER
SIMPLE ASPHYXIATION
CUMULATIVE LIVER ( LUN6 DAMAGE
MARKED IRRITATION-EYE, NOSE, THROAT,
LUNGS. SKIN
ACUTE SYSTEMIC TOXICITY (CMS)
MODERATE IRRITATION-EYE. NOSE, THROAT/
ACUTE TOXICITY (CYANOSIS)
CUMULATIVE LIVER OAHACE/SUSPECT CARCINOGEN
MARKED IRRITATION-EYE, NOSE. THROAT.
SKIN/CUMULATIVE EYE DAMAGE
MARKED IRRITATION-EYE. HOSE, THROAT,
SKIN/CUMULATIVE LIVER DAMAGE
MARKED IRRITATION-EYE. NOSE. THROAT.
SKIN/CONTACT ALLERGY SKIN
MARKED IRRITATION-EYE. NOSE. THROAT
HARKED IRRITATION-EYE. NOSE, THROAT,
LUNGS, SKIN
MODERATE IRRITATION-EYE. NOSE, THROAT
CANCER-BLADDER
"INERT' PARTICIPATE (ACCUMULATION IN LUNGS)
CANCER
CUMULATIVE TOXICITY/INCREASED BLOOD
PRESSURE
MARKED IRRITATION-EYE. NOSE. THROAT, LUNGS
MILD IRRITATION-EYE, NOSE. THROAT
MILD IRRITATION-EYE, NOSE. THROAT
MODERATE IRRITATION-EYE. NOSE. THROAT
MODERATE IRRITATION-EYE. NOSE. THROAT
HETHEMOGLOBIN FORMATION/ACUTE TOXIC
(SYSTEMIC) EFFECTS
HETHEHOGLOBIN FORMATION/CUMULATIVE
TOXICITY
CUMULATIVE LIVER AND HEART DAMAGE
CUMULATIVE ENDOCRINE (THYROID AND
PERMISSIBLE
EXPOSURE LIMIT
(PEL)XOSHA
PPM MG/M3
NONE
200
10
5
1000
to
STD
NONE
1
O.I
-
20
-
2
1
10
2
0.05
100
STD
NONE
STD
0.5
50
NONE
-
100
125
5
-
-
NONE
360
25
20
2*00
70
I9I0.10U
NONE
14
0.25
0.3
*5
0.25
S
3
45
CEILING
12
0.3
480
CEILING .
1910.1004
NONE
1910.1011
2
35
NONE
15
525
650
19
0.5
0.5
0.3
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S-ABOVE 30MG/H3
S
S-ABOVE 3XPEL
S-ABOVE 5 PPM
S-ABOVE 3XPEL
S
S-ABOVE 1.0*
S-ABOVE 5000 PPM
S
S
S
S
S
S
S
S
S
S
S-ABOVE CEILING
S-ABOVE I.Ot
S-ABOVE O.I*
S-ABOVE 3XPEL
S-ABOVE 2JOPPM
S-ABOVE 2XPEL
S-ABOVE 2XPEL
S-ABOVE .2XPEL
S-ABOVE 3XPEL
S
S
ARGON
ADRENAL) DAMAGE
SIMPLE ASPHYXIATION
NONE
NONE
L-64
S-IF OXYGEN IS LESS
THAN 18* BY VOL
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
ARSENIC I COMPOUNDS (a* Ai)
ARSINE
ASBESTOS (ALL FORMS)
ASPHALT (PETROLEUM) FUMES
AZINPHOS METHYL SKIN
BARIUM (SOLUBLE COMPOUNDS)
8AYGON (PROPOXUR)
BENZENE SKIN
BENZIOINE SKIN
BENZOYL PEROXIDE
BENZYL CHLORIDE
BERYLLIUM AND COMPOUNDS
BETA-NAPMTHYLANINE
BETA-PROP IOLACTOHE
BIPHENYL (OIPHENYL)
BIS-CHLOROHETHYL ETHER
BISMUTH TELLURIOE
BISMUTH TELLURIOE (S«-OOP£0)
BORATES, TETRA, SODIUM SALT,
ANHYORATE
BORATES, TETRA, SODIUM SALT,
DECAHYDRATE
BORATES. TETRA. SODIUM SALT,
PENTAHYORATE
BORON OXIDE
BORON TRI BROMIDE
BORON TRI FLUORIDE
BROMINE
BROMINE PENTAFLUORIOE
BROMOFORM SKIN
BUTADIENE (1 J-BUTAOIENE)
BUTANE
2-BUTANONE (MEK)
2-BUTOXYETHANOL SKIN
N-BUTYL ACETATE
BUTYL ACETATE-SEC
BUTYL ACETATE-TERT
HEALTH HAZARD
PRINCIPAL EFFECTS
OR BASIS/PEL
CUMULATIVE SYSTEMIC POISON/
SUSPECT CARCINOGEN
ACUTE SYSTEMIC TOXICITY
ASBESTOS IS/CANCER
SUSPECT CARCINOGEN
CHOLINESTERASE INHIBITION
CUMULATIVE HEART, LUNG I BRAIN DAMAGE
CHOLINESTERASE INHIBITION
CUMULATIVE BONE HARROW DAMAGE/
UUKEHOCEN
CANCER OF BLADDER
MODERATE IRRITATION-EYE, NOSE, THROAT/
SUSPECT CARCINOGEN
MARKED IRRITATION-EYE, NOSE. THROAT/
SUSPECT CARCINOGEN
CUMULATIVE LUNG DAMAGE (BERYLLIOSIS)/
SUSPECT CARCINOGEN
CANCER-BLADDER
ACUTE SYSTEMIC TOXICITY (H 1 GH) /CANCER
MODERATE IRRITATION-EYE, NOSE, THROAT. LUNGS
CANCER (LUNG)
"INERT" P ARTICULATE (ACCUMULATION IN LUNGS)
CUMULATIVE LUNG DAMAGE
MODERATE IRRITATION-EYE, NOSE, THROAT, SKIN
MODERATE IRRITATION-EYE, NOSE, THROAT, SKIN
MODERATE IRRITATION-EYE, NOSE. THROAT. SKIN
"INERT PARTICULATE (ACCUMULATION IN LUNGS)
MARKED IRRITATION-EYE, NOSE, THROAT, LUNGS
ACUTE AND CHRONIC LUNG IRRITATION
(PNEUMONIA)
MARKED IRRITATION-EYE, NOSE, THROAT, LUNGS
MARKED IRRITATION-EYE. NOSE. THROAT, LUNGS
MARKED IRRITATION-EYE. NOSE, THROAT/
CUMULATIVE LIVER DAMAGE
MODERATE IRRITATION-EYE, NOSE, THROAT
NARCOSIS
MILD IRRITATION-EYE, NOSE, THROAT/NARCOSIS
MILD IRRITATION-EYE, NOSE, THROAT/
CUMULATIVE XBC 4 KIDNEY DAMAGE
MODERATE IRRITATION-EYE, NOSE. THROAT,
LUNGS (UPPER)
MODERATE IRRITATION-EYE, NOSE, THROAT,
LUNGS (UPPER)
MODERATE IRRITATION-EYE, NOSE, THROAT,
LUNGS (UPPER)
PERMISSIBLE
EXPOSURE LIMIT
(PELl/OSHA
PPM HG/M3
-
0.05
STD
NONE
-
-
NONE
1
STO
STO
-
1
-
STO
STD
0.2
STD
NONE
NONE
NONE
NONE
NONE
-
0.5
0.2
1910.1001
NONE
0.2
0.5
NONE
3
1910.1028
1910.1010
5
5
0.002
1910-1009
1910-1013
1
1910.1008
NONE
NONE
NONE
NONE
NONE
IS
NONE NONE
1 3
CEILING
O.I
NONE
0.5
1000
NONE
200
50
ISO
200
200
0.7
NONE
5
2200
NONE
590
2
-------
UAOILY
MSORKO
THROUGH
SUBSTANCE SKIM
BUTYL ALCOHOL-SEC
N-BUTYL ALCOHOL SKIN
BUTYL ALCOHOL-TERT
SUTYL CHROMATE-TERT SKIN
(AS Crtj)
N-BUTYL CLYCIOYL ETHER (BGE)
BUTYL LACTATE
BUTYL MERCAPTAN
P-TERT-BUTYL TOLUENE
BUTYLAMINC SKIN
CAOMIUH (METAL OUST ( SOLUBLE
SALTS)
CAONIUN OXIDE (FUME)
CALCIUM ARSENATE (as As)
CALCIUM CARBONATE
CALCIUM CYANAMIOE
CALCIUM HYDROXIDE
CALCIUM OXIDE
CAMPHOR (SYNTHETIC)
CAPROLACTAM DUST
CAPROLACTAM VAPOR
CAPTAFOL (DIFOLATAN) SKIN
CAPTAN
CAR8ARYL (SCVIN)
CARBOFURAN
CARBON BLACK
CARBON DIOXIDE
CARBON OISULFIOE SKIN
CARBON MONOXIDE
CARBON TETRABROHIOE
CARBON TETRACHLORIOE SKIN
CATECHOL (PYROCATECHOL)
CELLULOSE (PAPER FIBER)
CESIUM HYDROXIDE
CHLOROANE SKIN
CHLORINATED CAMPHENE SKIN
HEALTH HAZARD
PRINCIPAL EFFECTS
OR BASIS/PEL
MODERATE IRRITATION-EYE. HOSE. THROAT/
NARCOSIS
MODERATE IRRITATION-EYE. NOSE, THROAT
MODERATE IRRITATION-EYE. NOSE. THROAT
HARKED IRRITATION-EYE. NOSE. THROAT, SKIN/
SUSPECT CARCINOGEN (CrOj BASIS)
MILD IRRITATION-EYE. NOSE, THROAT, SKIN
MODERATE IRRITATION-EYE. NOSE, THROAT.
LUNGS
OOOR/MOOCRATE IRRITATION-EYE. NOSE THROAT
CUMULATIVE LIVER. KIDNEY, CMS DAMAGE
MARKED IRRITATION-EYE. NOSE, THROAT,
LUNGS. SKIN
CUMULATIVE KIDNEY ( LUNG DAMAGE/
SUSPECT CARCINOGEN
CUMULATIVE KIDNEY I LUNG DAMAGE/
SUSPECT CARCINOGEN
CUMULATIVE SYSTEMIC ARSENIC POISONING/
SUSPECT CARCINOGEN
"INERT" PARTICULAR (ACCUMULATION IN LUNGS)
MODERATE IRRITATION-EYE, NOSE. THROAT. SKIN
NARKED IRRITATION-EYE, NOSE, THROAT, SKIN
HARKED IRRITATION-EYE. NOSE, THROAT. SKIN
MODERATE IRRITATION-EYE, NOSE, THROAT/
ACUTE TOXIC ITT
MILD IRRITATION-EYE. NOSE, THROAT, SKIN
MILD IRRITATION-EYE, NOSE, THROAT, SKIN
RESPIRATORY SENSITIZATION (ASTHMA)/
PHOTOTOXIC DERMATITIS
CUMULATIVE SYSTEMIC TOXICITY/
POTENTIAL HUTAGEN
CHOLINESTERASE INHIBITION/
CUMULATIVE LIVER DAMAGE
CHOLINESTERASE INHIBITION
CUMULATIVE HEART DAMAGE/SUSPECT CARCINOGEN
SIMPLE ASPHYXIATION
CUMULATIVE CNS DAMAGE
CHEMICAL ANOXIA AND ASPHYXIATION
ACUTE AND CHRONIC TOXIC EFFECTS ON LUNGS,
LIVER, AND KIDNEYS
CUMULATIVE LIVER DAMAGE/SUSPECT CARCINOGEN
CUMULATIVE LIVER, KIDNEY « SKIN DAMAGE
"INERT" P ARTICULATE (ACCUMULATION IN LUNGS)
MILD IRRITATION-EYES, NOSE, THROAT, SKIN
CUMULATIVE LIVER DAMAGE/SUSPECT CARCINOGEN
CUMULATIVE LIVER DAMAGE
PERMISSIBLE
EXPOSURE LIMIT
(PEL)/OSHA
PPM MG/M3
150
100
100
CEILING
SO
NONE
10
10
f.50
300
300
0.1
270
NONE
35
60
5 15
CEILING
-
-
-
NONE
NONE
NONE
-
2
NONE
NONE
NONE
NONE
-
NONE
-
5000
20
SO
NONE
10
NONE
NONE
NONE
-
.
0.2
O.I
1
NONE
NONE
NONE
5
12
NONE
NONE
NONE
NONE
5
NONE
3.5
9000
60
55
NONE
65
NONE
NONE
NONE
0.5
0.5
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S-ABOVE 2XPEL
S
S-ABOVE 2XPEL
S
S-ABOVE 2XPEL
S-ABOVE 5"M;
25 MG/M3
S
S
S
S
S
S
S
S
S
S
S-ABOVE 2MG/H3
S-ABOVE 10PPH:
W> NG/M3
S
S-ABOVE 5 MG/M3
S
S-ABOVE 0.2 HG/M3
S
S-ABOVE 10XPEL
S
S-ABOVE 1.5XPEL
S-ABOVE 0.1 PPM;
1 . k MG/M3
S
S-ABOVE 5PPM;
20 MG/M3
S
S
L-66
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
CHLORINATED OIPHENVL OXIDE
CHLORINE
CHLORINE DIOXIDE
CHLORINE TRI FLUOR IDE
CHLOROACETALDEHYDE
CHLOR06ENZENC
0-CHLOROBENZYLIOENE SKIN
MALONONITRILE
CHLOROBROHOMCTHANE
CHLOROOIFLUOROHETHANE (F22)
CHLOROOIPHENYL (kZt Ci) SKIN
CHLOROO 1 PHENYL (5** C 1 ) SKIN
CHLOROFORM
1 -CHLORO- 1 -N 1 TROPROPANE
CHLOROPICRIN
CHLOROPRENE-8ETA SKIN
CHLOROPYRIFOS (OURSBAN) SKIN
0-CHLOROSTYRENE
0-CHLOROTOLUENE
2-CHLORO-6-(TR 1 CHLOROMETHYl)
PYRIDINE
CHROMATES, CERTAIN INSOL. FORMS
CHRONIC AC 10 1 CHROHATES
CHROMIUM, SOL. CHROMATES SALTS
CLOP IDOL (COYOEN)
COAL TAR PITCH VOLATILE*
COBALT, METAL. FUHE t DUST
COPPER DUSTS (MISTS
COPPER FUHE
CORUNDUM (AL203)
COTTON DUST (RAW)
CRA6 HERBICIDE (SESONE)
CRESOL (ALL ISOMERS) SKIN
CROTONALOEHYOE
CRUFOMATE (RUELENE)
CUMENE SKIN
CYANAMIOE
CYANIDES (as Cn) SKIN
HEALTH HAZARD
PRINCIPAL EFFECTS
OR BASIS/PEL
CUMULATIVE LIVER DAMAGE
CUMULATIVE LUNG OAMAGE/t ACUTE TOXICITY
MARKED IRRITATION-EYE. NOSE. THROAT, LUNGS
MARKED IRRITATION-EYE. NOSE. THROAT, LUNGS
MARKED IRRITATION-EYES, NOSE. THROAT,
LUH6S. SKIN
NARCOSIS/CUMULATIVE SYSTEMIC TOXICITY
MARKED IRRITATION-EYES, NOSE, THROAT, SKIN
CUMULATIVE HEART, LIVER. KIDNEY DAMAGE
CUMULATIVE LIVER DAMAGE/CHLORACNE (SKIN)
CUMULATIVE LIVER DAMAGE/CHLORACNE/
SUSPECT CARCINOGEN
NARCOSIS/CUMULATIVE LIVER AND KIDNEY
DAMAGE/SUSPECT CARCINOGEN
MODERATE IRRITATION-EYE. NOSE. THROAT, SKIN
HARKED IRRITATION-EYES. NOSE. THROAT
NARCOSIS/ACUTE TOXIC 'EFFECTS ON KIDNEY.
LIVER. LUNGS
CHOLINESTERASE INHIBITION
CUMULATIVE LIVER * KIDNEY DAMAGE
NARCOSIS
CUMULATIVE LUNG DAMAGE/SUSPECT CARCINOGEN
CUMULATIVE LUNG DAMAGE/SUSPECT CARCINOGEN
CUMULATIVE LUNG DAMAGE/SUSPECT CARCINOGEN
"INERT" PARTICULATE (ACCUMULATION IN LUNGS)
CUMULATIVE LUNG CHANGES/SUSPECT CARCINOGEN
CUMULATIVE LUNG CHANGES (ASTHMA)
MILD IRRITATION-EYES, NOSE. THROAT, SKIN
MILD IRRITATION-EYE. NOSE, THROAT
"INERT" PARTICULATE (ACCUMULATION IN LUNGS)
CUMULATIVE LUNG DAMAGE (BYSSINOSIS)
CUMULATIVE LIVER DAMAGE
MARKED IRRITATION-SKIN/ACUTE TOXICITY (CNS)
MARKED IRRITATION-EYES, NOSE. THROAT, LUNGS
CHOLINESTERASE INHIBITION
NARCOSIS
MARKED IRRITATION-EYES, NOSE, THROAT, SKIN/
ACUTE TOXICITY
MILD IRRITATION-EYES, NOSE. THROAT
PERMISSIBLE
EXPOSURE LIMIT
(PED/OSHA
PPM MG/M3
0.5
1 3
0.1 0.3
0.1 Q.k
CEILING
1 3
CEILING
75 350
0.05 0.4
200 1050
NONE NONE
1
0.5
50 240
CEILING
20 100
O.I 0.7
25 30
NONE NONE
NONE NONE
NONE NONE
NONE NONE
1
O.I
0.5
NONE NONE
0.2
O.I
1
O.I
NONE NONE
1
15
5 22
2 6
NONE NONE
50 2*5
NONE NONE
5
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S
S
S
S
S
S-ABOVE 2XPEL
S
S
S-ABOVE 10500
MG/M3
S
S
S
S-ABOVE 3XPEL
S
S-ABOVE 3XPEL
S-ABOVE 2 MG/H3
S-ABOVE 100PPM;
570 MG/M3
S-ABOVE 150PPN;
750 MG/M3
S-ABOVE 30 MG/M3
S
S
S
S-ABOVE 30 MG/M3
S
S
S-ABOVE 2XPEL
S-ABOVE itXPEL
S
S
S
S
S-ABOVE 2XPEL
S-ABOVE 2MG/M3
L-67
S-ABOVE 2XPEL
-------
MAOILY
ABSORBED HEALTH HAZARD
THKOUCM PHI MCI PAL EFFECTS
PERMISSIBLE HAZARD OF
EXPOSURE LI HIT EXPOSURE
(PED/OSHA ABOVE PEL
SUBSTANCE SKIN
CYAN06EN
CYCLOHEXANE
CYCLOHEXANOL
CYCLOHEXANONE
CYCLOHEXENC
CYCLOHEXYLAHINE SKIN
CYCLOPENTAOIENE
2, *-0(2. *-0 1 CHLOROPHENOXY
-ACETIC ACID)
DOT SKIN
OECASORAHC SKIN
OEMETON(SYSTOX) SKIN
OI-SCC. OCTYL PHTHALATt
OIACETONE ALCOHOL
OIAZINON SKIN
oiAzoMETHANE
OI80RANC
OIBROM
1,2-OIBROMOETHANE SKIN
(ETHYUNCOIMONIOC)
OIBUTVL PHOSPHATE
2-N-OIBUTYLAHINOETHANOL SKIN
OI8UTYLPHTHALATE
l.l-DICHLORO-l-NITROETHANE
1 ,3-OICHlORO-5.5-OIMETHYL
HYOANTOIN
OICHLOROACETYLENE
o-oiCHLOROBENZENE
P-OICHLOROBENZENE
3.3-OICHLOMBENZIOINE SKIN
0 1 CHLOROO 1 FlUORONETHAHE
I.I-DICHLOMETHANE
1.2-OICm.OROETHANE (ETHYLENE
OICHLORIOE)
oicHioftorom. ETHER SKIN
1.2 OICHLOROETMYLENE
OICHLOROHONOFLUOROMETHANE (F2I)
0 1 CHLOROTETRAFLUOROETHANE
OICHLORVOS (OOVP) SKIN.
OR SAS IS/PEL
MODERATE IRRITATION-EYES, NOSE. THROAT/
ACUTE TOXICITY (CYANOSIS)
MODERATE IRRITATION-EYES. NOSE. THROAT/
MARCOS IS
MILD IRRITATION-EYES. NOSE. THROAT/
CUMULATIVE LIVER ( KIDNEY DAMAGE
HARKED IRRITATION-EYES, NOSE, THROAT/
CUMULATIVE LIVER ( KIDNEY DAMAGE
MODERATE IRRITATION-EYES, NOSE, THROAT/
CUMULATIVE SYSTEMIC TOXICITY
NARKED IRRITATION-EYES, NOSE, THROAT, SKIN/
SUSPECT CARCINOGEN
MODERATE IRRITATION-EYES. NOSE. THROAT
ACUTE SYSTEMIC TOXICITY
CUMULATIVE TQXICITY/SUSPECT CARCINOGEN
ACUTE CHS TOXICITY
CHOUNESTERASE INHIBITION
MODERATE IRRITATION-EYES, NOSE. THROAT
CHOUNESTERASE INHIBITION
MARKED EOEMA-LUNCS/SUSPECT CARCINOGEN
MARKED EDEMA-LUNGS/ACUTE CNS TOXIN
CHOLINESTERASE INHIBITION
SUSPECT CARCINOGEN
MILD IRRITATION-EYES. NOSE, THROAT,
LUNGS (UPPER)
CHOLINESTERASE INHIBITION
(ACCUMULATION IN LUNGS)
ACUTE SYSTEMIC TOXICITY (LUNGS. HEART,
LIVER, KIDNEYS)
MARKED IRRITATION-EYE. NOSE. THROAT,
LUNGS (UPPER)
CUMULATIVE CNS TOXIN; DISABLING .NAUSEA
MARKED IRRITATION-EYE. NOSE, THROAT
CUMULATIVE SYSTEMIC TOXICITY
CANCER (BLADDER)
(ACCUMULATION IN LUNGS)
CUMULATIVE LIVER DAMAGE
CUMULATIVE LIVER DAMAGE
HARKED IRRITATION-EYE, NOSE. THROAT. LUNGS
NARCOSIS
CHOLINESTERASE INHIBITION
L-68
PPM MC/M3
NONE NONE
300 1050
SO 200
50 200
300 1015
NONE NONE
75 200
10
1
0.05 0.3
O.I
5
50 2*0
HONE NONE
0.2 O.k
O.I O.I
3
20 US
1 5
NONE NONE
5
10 60
CEILING
0.2
NONE NONE
50 300
CEILING
75 *50
STO 1910.1007
1000 >»950
100 <)00
50 200
15 90
CEILING
200 790
1000 «00
1000 7000
1
S-SEHIOUS
S -ABOVE 10PPM;
20 MG/M3
S-ABOVE 2XPEL
S-A80VE 2XPEL
S
S-ABOVE 2XPEL
S-ABOVE IOPPM;
1(0 MG/H3
S-ABOVE 2XPEL
S-ABOVt 3XPEL
S
S
S
S-ABOVE 2XPEL
S-ABOVE O.I MG/M3
S
S
S-ABOVE 2XPEL
S
S-ABOVE 6PPM;
43 MG/M3
S
S-ABOVE 3XPEL
S
S
S
S
S-ABOVE 3XPEL
S
S
S-ABOVE 3XPEL
S-ABOVE 3XPEL
S-ABOVE 3XPEL
S-ABOVE 2XPEL
-------
READILY
ABSORBED HEALTH HAZARD
THROUGH PRINCIPAL EFFECTS
SUBSTANCE SKIN OR BASIS/PEL
DICROTOPHOS (BIORIN)
DICYCLOFENTAOIENE
0 1 CYCLOPENTAO 1 ENYL- 1 RON
OIELORIN
DIETHYLAHINE
0 1 ETHYLAH 1 NDETHANOL
DIETHYLENE TRIAMINE
OIETHYLPHTHALATE
0 1 FLUOROO 1 BROMOMETHANE
DIGLYCIOYL ETHER (OGE)
OIISOBUTYL KETONE
OIISOPRQPYLAHINE
DIMETHYL ACETAMIOE
4-01 METHYL AMINOAZOBENZENE
01 METHYL SULFATE
OIHETHYLAMINE
OIHETHYLANILINE
OIMETHYLFORMAMIOE
l.l-OIHETHYUIYORAZINE
OIMETHYLPHTHALATE
OINITRO-0*CRESOL
3 , 5-0 1 N 1 TRO-0-TOLUAM I OE
(ZOALENE)
0'^TR|B|MZENE (ALL
DINITROTOLUENE
OIOXANE-TECHNICAL GRADE
OIOXATHION (OELVAR)
OIPHENYLAMINE
OIPROPYLENE GLYCOL METHYL
ETHER
OIOJUAT
DISULFURAM
OISYSTON
2,6-OITERT-BUTYL-P-CRESOL
OYFONATE
EMERY
ENOOSULFAN (THIOOAN)
ENORIN
EPICHLORHYORIN
EPN
SKIN CHOLINESTERASE INHIBITION
MILD IRRITATION-EYE. NOSE, THROAT/
CUMULATIVE LIVER t KIDNEY DAMAGE
SKIN CUMULATIVE LIVER DAMAGE/SUSPECT CARCINOGEN
MARKED IRRITATION-EYE. NOSE. THROAT,
LUNGS, SKIN
SKIN MARKED IRRITATION-EYE. NOSE, THROAT
SKIN MARKED IRRITATION-EYE, NOSE. THROAT. LUNGS,
SKIN/ASTHMA
NILO IRRITATION-EYE, NOSE, THROAT
CUMULATIVE LIVER AND CMS DAMAGE
MARKED IRRITATION-EYE. NOSE. THROAT. LUNGS,
SKIN/CUMULATIVE TOXIC1TY
MODERATE IRRITATION-EYE. NOSE, THROAT/
NARCOSIS
SKIN MARKED IRRITATION-EYE, NOSE. THROAT, LUNGS
SKIN CUMULATIVE LIVER DAMAGE
CANCER
SKIN ACUTE LUNG EFFECTS/SUSPECT CARCINOGEN
MARKED IRRITATION-EYE, NOSE. THROAT. SKIN/
CUMULATIVE LIVER DAMAGE
SKIN METHEMOGLOBINEMIA
SKIN CUMULATIVE LIVER DAMAGE
SKIN ACUTE CNS TOXICITY AND ANEMIA/
SUSPECT CARCINOGEN
SKIN CUMULATIVE SYSTEMIC (METABOLIC) TOXIN
CUMULATIVE LIVER DAMAGE
SKIN METHEMOGL08INEMI A/HIGH ACUTE TOXICITY
SKIN METHEMOGLOBINEMIA/ANEMIA
SKIN CUMULATIVE KIDNEY AND LIVER DAMAGE/
SUSPECT CARCINOGEN
CHOLINESTERASE INHIBITION
CUMULATIVE LIVER, KIDNEY, BLADDER DAMAGE
SKIN MODERATE IRRITATION-EYE, NOSE, THROAT/
CUMULATIVE LIVER t LUNG DAMAGE
CUMULATIVE EFFECT ON EYES (CATARACTS)
ACUTE TOXICITY (ANTA8USE-L 1 KE EFFECTS)
SKIN CHOLINESTERASE INHIBITION
CHOLINESTERASE INHIBITION
"INERT1 P ARTICULATE (ACCUMULATION IN LUNGS)
SKIN ACUTE CNS TOXIN/CUMULATIVE KIDNEY DAMAGE
ACUTE TOXI CITY/SUSPECT CARCINOGEN
SKIN CUMULATIVE KIDNEY DAMAGE/MARKED SKIN
IRRITATION
SKIN CHOLINESTERASE INHIBITION
PERMISSIBLE
EXPOSURE LIMIT
(PEL) /OS HA
PPH MG/M3
NONE
NONE
NONE
-
25
10
NONE
NONE
100
NONE
NONE
NONE
0.25
75
50
NONE
NONE
360
0.5 2.3
CEILING
50
5
10
STO 1910
1
10
5
to
0.5
-
-
NONE
too
NONE
NONE
100
NONE
NONE
NONE
NONE
NONE
NONE
NONE
-
5
.
290
20
35
.1015
5
18
25
30
1
5
0.2
NONE
I
1.5
360
NONE
NONE
600
NONE
NONE
NONE
NONE
NONE
NONE
NONE
O.I
19
0.5
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S
S
0
S
S
S
S-A80VE I PPM;
4 MG/M3
S
S
S-ABOVE 2XPEL
S
S
S
S
S
S-ABOVE 2XPEL
S
S
S
S-ABOVE 10MG/M3
S
S
S-AT CURRENT
OSHA PEL
S-ABOVE 0.4MG/M3
S-ABOVE 10MG/M3
S
S-ABOVE 0.5MG/M3
S-ABOVE 0.1MG/M3
S-ABOVE 0. IMG/M3
S-ABOVE O.IMG/M}
S
S
S-ABOVE 3XPEL
L-69
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
ETHANE
ETHANOLANINE
ETHION (NIALATE) SKIN
2-CTHOXYCrHANOL
2-ETHOXYETHYLACETATE SKIN
ETHYL ACETATE
ETHYL ACRYLATE SKIN
ETHYL ALCOHOL
ETHYL BENZENE
ETHYL BftOHlOE
ETHYL BUTYL KETONE
ETHYL CHLORIDE
ETHYL ETHER
ETHYL FORMATE
ETHYL MERCAPTAN
ETHYL SEC-AHYL KETQNE
ETHYL SILICATE
ETHYLAHINE
ETHYLENE
ETHYLENE CHLOROHYDRIN SKIN
ETHYLENE OIAHINE
ETHYLENE 6LYCOL OINITRATE SKIN
ETHYLCNE GLYCOL MONOMETHVL
ETHERACETATE
ETHYLENE SLYCOl, PARTICULATE
ETHYLENE 6LYCOL. VAPOR
ETHYLENE OXIDE
ETHYLENCIMINE SKIN
ETHYL 1 DENE NORWRNENE
N-ETHYLNORPHOLINE SKIN
FENSULFOTHION (DASANIT)
FERBAH
HEALTH HAZARD
PRINCIPAL EFFECTS
OR SAS IS/PEL
SIMPLE ASPHYXIATION
CUMULATIVE LIVER, LUNG AND KIDNEY DAMAGE
CHOLINESTERASE INHIBITION
CUMULATIVE BLOOD DAMAGE
CUMULATIVE KIDNEY DAMAGE
MILD IRRITATION-EYE, NOSE, THROAT, LUNGS
(UPPER)
MARKED IRRITATION-EYE, NOSE, THROAT. LUNGS
MODERATE IRRITATION-CYC, HOSE. THROAT
MODERATE IRRITATION-EYE. HOSE, THROAT
NARCOSIS/CUMULATIVE LIVER, KIDNEY, AND
HEART DAMAGE
MILD IRRITATION-EYE. NOSE. THROAT/
NARCOSIS
NARCOSIS
MILD IRRITATION-EYE, NOSE, THROAT/
NARCOSIS
MILD IRRITATION-EYE, NOSE. THROAT
ODOR/ACUTE SYSTEMIC TOXICITY
MODERATE IRRITATION-EYE. NOSE, THROAT
MILD IRRITATION-EYE. NOSE. THROAT/
CUMULATIVE KIDNEY DAMAGE
MARKED IRRITATION-EYE. NOSE. THROAT, LUNGS
SIMPLE ASPHYXIATION
ACUTE TOXICITY (LOCAL ( SYSTEM 1C)
MODERATE IRRITATION-EYE. NOSE, THROAT,
SKIN/CONTACT ALLERGY
CUMULATIVE EFFECT ON BLOOD PRESSURE,
FIBRILLATION
CUMULATIVE CNS AND BLOOD (ANEMIA) EFFECTS
MODERATE IRRITATION-EYE. NOSE t THROAT
MODERATE IRRITATION-EYE, NOSE, THROAT
CUMULATIVE LUNG, LIVER ( KIDNEY DAMAGE
CANCER
MODERATE IRRITATION-EYE. NOSE, THROAT/
CUMULATIVE LIVER DAMAGE
MODERATE IRRITATION-EYE, NOSE, THROAT
CHOLINESTERASE INHIBITION
MILD IRRITATION-EYE, NOSE, UPPER
PERMISSIBLE
EXPOSURE LIMIT
(PED/OSHA
PPM MG/HJ
NONE
3
NONE
ZOO
100
400
25
1000
100
200
so
1000
too
too
10
25
100
10
NONE
5
10
NONE
6
NONE
7*0
5*0
1400
100
1900
*35
890
230
2600
1200
300
CEILING
130
850
18
NONE
16
25
0.2 1.2
CEILING
25
NONE
NONE
50
STD
NONE
20
NONE
_
120
NONE
NONE
90
1910.1012
NONE
9*
NONE
15
HAZARD OP
EXPOSURE
ABOVE PEL
S-SERIOUS
S
S-ABOVE 0.4MG/M3
S-AT CURRENT
OSHA PEL
S
. S-ABOVE 3XPEL
S
S-ABOVE 5XPEL
S-ABOVE 2XPEL
S
S-ABOVE 3XPEL
S-ABOVE 5XPEL
S-ABOVE 2XPEL
S-ABOVE 2XPEL
S-AT CURRENT
OSHA PEL
S-ABOVE ZXPEL
S
S
0-AT OXYGEN LEVELS
GREATER THAN 18*
BY VOLUME
S-AT CURRENT OSHA
PEL AND ACGIH
S-ABOVE 2XPEL
S
S
S-ABOVE 20MG/M3
S-ABOVE 200PPM;
520MG/M3
S
S
S
S-ABOVE 2XPEL
S-ABOVE 0.5MG/M3
RESPIRATORY
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
FERRO VANADIUM OUST
FLUORIDE (as F)
FLUORINE
FLUOROTRICHLOROMETHANE (Fit)
FORMALDEHYDE
FORMAMIOE
FORMIC ACID
FURFURAL-SKIN
FURFURYL ALCOHOL
GASOLINE
GERMANIUM TETRAHYORIOE
GLASS. FIBROUS OR DUST
GLUTARALOEHYOE
GLUTARALDEHYOE (ALKALINE
ACTIVATED)
GLYCERIN MIST
GLYCIOOl
GRAPHITE (NATURAL)
GRAPHITE (SYNTHETIC)
GYPSUM
HAFNIUM
HELIUM
HEPTACHLOR SKIN
HEPTANE
HEXACHLOROC YCLOPENTAD 1 ENE
HEXACHLOROETHANE SKIN
HEXACHLORONAPHTHALENE SKIN
HEXAFLUOROACETONE
N-HEXANE
2-HEXANONE (MBK) SKIN
HEXONE (MIBK) SKIN
HEALTH HAZARD
PRINCIPAL EFFECTS
OR BASIS/PEL
MODERATE IRRITATION-UPPER RESPIRATORY
MARKED IRRITATION-EYE. NOSE. THROAT/
CUMULATIVE BONE DAMAGE
MODERATE EDEMA-LUNGS
ACUTE CNS EFFECTS (MANIFESTED AS TREMORS)
MARKED IRRITATION-EYES, LUNGS. SKIN
CUMULATIVE SYSTEMIC TOXICITY
MARKED IRRITATION-EYES. NOSE. THROAT, LUNGS
MODERATE IRRITATION-EYE. NOSE, THROAT
MODERATE IRRITATION-EYES, LUNGS/NARCOSIS
MILD IRRITATION/CUMULATIVE BLOOD EFFECTS
ACUTE SYSTEMIC TOXICITY (HEMOLYSIS)
"INERT" PARTICULATE (LUNG ACCUMULATION)/
SKIN IRRITATION
MARKED IRRITATION-EYE. NOSE. THROAT
SKIN/ALLERGY
MARKED IRRITATION-EYE. NOSE, THROAT.
SKIN/ALLERGY
"INERT" PARTICULATE (ACCUMULATION IN
LUNGS)
MODERATE IRRITATION-EYE, NOSE, THROAT,
SKIN/NARCOSIS
CUMULATIVE LUNG DAMAGE-SILICOSIS
"INERT" PARTICULATE (ACCUMULATION IN
LUNGS)
CUMULATIVE LIVER DAMAGE
SIMPLE ASPHYXIATION
CUMULATIVE LIVER DAMAGE/SUSPECT CARCINOGEN
MODERATE IRRITATION-EYE, NOSE, LUNGS/
PLOYNEURITIS
MARKED EDEMA-LUNGS/CUMULATIVE (VARIED)
ORGAN DAMAGE
CUMULATIVE ORGAN DAMAGE (VARIOUS)
CUMULATIVE LIVER DAMAGE
CUMULATIVE LUNG, KIDNEY. TESTES DAMAGE
NARCOS 1 S/POLYNEUR 1 T 1 S
MODERATE IRRITATION-EYE. NOSE, THROAT/
PERIPHERAL NEUROPATHY
MODERATE IRRITATION-EYE, NOSE, THROAT
PERMISSIBLE
EXPOSURE LIMIT
(PEL) /OSHA
PPM M6/M3
-
-
O.I
1000
3
NONE
5
5
50
NONE
NONE
NONE
NONE
NONE
NONE
50
-
NONE
NONE
-
NONE
-
500
NONE
1
-
NONE
500
100
100
1
2.5
0.2
5600
NONE
9
20
200
NONE
NONE
NONE
NONE
NONE
NONE
ISO
15 MPPCF
NONE
NONE
0.5
NONE
0.5
2000
NONE
10
0.2
NONE
1800
410
410
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S
S-ABOVE 3XPEL
S-AT CURRENT
OSHA PEL
S-ABOVE 20PPM;
30MG/M3
S
S-ABOVE 2XPEL
S-AT CURRENT
OSHA PEL
S-AS
FLAMMABILITY
HAZARD
g-ABOVE^.ZPPM;
S-ABOVE 2PPM;
8 MG/M3
S-ABOVE
0.25 MG/M3
S-ABOVE 2XPEL
S
S
S-IF OXYGEN IS
LESS THAN
18% BY VOLUME
S
S
S-ABOVE tPPM;
IOMG/M3
S
S
S-ABOVE O.IPPM;
0.7MG/M3
S-AT CURRENT
OSHA PEL
S-AT CURRENT
OSHA PEL
L-71
S-ABOVE 2XPEL
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
HEXYLACETATE-SEC
HEXYLEME GLYCOL
HYDRAZINE SKIN
HYDROGEN
HYOKOeEN BROMIDE
HYDROGEN CHLORIDE
HYDROGEN CYANIDE SKIN
HYDROGEN FLUORIDE
HYDROGEN PEROXIDE, 90S
HYDROGEN SELENIOE
HYDROGEN SULFIOE
HYDROGENATED TERPHENYLS
HYOROQUINONE
INOEHE
INDIUM ( COMPOUNDS, (as In)
IODINE
IODOFORH
IRON OXIDE FUME
IRON PENTACAR80NYL
IRON SALTS. SOLUBLE (as Fe)
ISOAMYL ACETATE
ISOAMYL ALCOHOL
ISOBUTYL ACETATE
ISOBUTYL ALCOHOL
ISOPHORONE
ISOPHORONE DIISOCYANATE SKIN
ISOPROPYL ACETATE
ISOPROPYL ALCOHOL SKIN
ISOPROPYL AMI HE
ISOPROPYL ETHER
HEALTH HAZARD
PRINCIPAL EFFECTS
OR BASIS/PEL
MILD IRRITATION-EYE, NOSE. THROAT
MILD IRRITATION-EYE. NOSE THROAT, SKIN/
NARCOSIS
MARKED IRRITATION/CUMULATIVE LIVER DAMAGE/
SUSPECT CARCINOGEN
SIMPLE ASPHYXIATION
MARKED IRRITATION-EYE. NOSE. THROAT
MARKED IRRITATION-EYE. NOSE. THROAT
ACUTE AND CUMULATIVE SYSTEMIC TOXICITY
(CYANOSIS)
MARKED IRRITATION-EYE. NOSE. THROAT, LUNGS/
CUMULATIVE BONE DAMAGE
MARKED IRRITATION-EYE. NOSE. THROAT, SKIN
MARKED ACUTE LUNG DAMAGE AND SYSTEMIC
TOXICITY
NARKED IRRITATION EYE (CONJUNCTIVITIS).
LUNGS/ACUTE SYSTEMIC TOXICITY
CUMULATIVE LIVER, KIDNEY, LUNG DAMAGE
CUMULATIVE CORNEAL (EYE) DAMAGE
MARKED IRRITATION-EYE; NOSE. THROAT/
ACUTE SYSTEMIC TOXICITY
CUMULATIVE LUNG DAMAGE
MARKED IRRITATION-EYE. NOSE, THROAT, LUNGS
MODERATE IRRITATION-EYE, NOSE. THROAT.
LUNGS/ACUTE CNS EFFECTS
LUNG CHANGES (SIDEROSIS)/SUSPECT CARCINOGEN
(HAEMATITE MINES)
ACUTE TOXICITY (CNS)
MODERATE IRRITATION-UPPER RESPIRATORY TRACT,
SKIN
MODERATE IRRITATION-UPPER RESPIRATORY TRACT
MILD IRRITATION-EYE. NOSE, THROAT/KARCOS 1 S
MILD IRRITATION-EYE, NOSE, THROAT
MILD .IRRITATION-EYE, NOSE, THROAT
MARKED IRRITATION-EYE. NOSE. THROAT/
NARCOSIS (FATIGUE AND MALAISE)
MARKED IRRITATION-EYE, NOSE, THROAT. LUNGS,
SKIN/ALLERGY
MILD IRRITATION-EYE. NOSE, THROAT
MILD IRRITATION-EYE. NOSE. THROAT/
NARCOSIS
MARKED IRRITATION-EYE, NOSE. THROAT, LUNGS
MILD IRRITATION-EYE, NOSE, THROAT
PERMISSIBLE
EXPOSURE LIMIT
(PED/OSHA
PPM MG/M3
50 300
NONE NONE
1 1.3
NONE NONE
3 10
5 CEILING 7
10 11
3 2
1 1.4
0.05 0.2
20 30
CEILING
NONE NONE
2
NONE NONE
NONE NONE
0-'CE1LING '
NONE NONE
10
NONE NONE
NONE NONE
100 525
100 360
150 700
100 300
25 140
NONE NONE
250 950
400 980
5 12
500 2100
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S-ABOVE 2XPEL
S
S-IF OXYSEN IS
LESS THAN
18* BY VOLUME
S
S
S
S
S
S
S-AT CURRENT
OSHA PEL
S-ABOVE O.SPPH;
5MG/M3
S
S-ABOVE IOPPM;
d5MG/M3
S-ABOVE 0.1 MG/M3
S
S-ABOVE 0.2PPH;
3MG/M3
S-AT CURRENT
OSHA PEL
S-ABOVE 0.01 PPM;
0.8MG/M3
S-ABOVE 2XPEL
S-ABOVE 2XPEL
S-ABOVE 2XPEL
S-ABOVE 3XPEL
S-ABOVE 2XPEL
S-AT CURRENT
OSHA PEL
S
S-ABOVE 2XPEL
S
S-ABOVE 2XPEL
1-72
-------
SUBSTANCE
ISOPROPYL GLYCIOYL ETHER
KAOLIN
KETENE
LEAD ARSENATE (as Pb)
READILY
ABSORBED
THROUGH
SKIN
(IGE)
LEAD. INORG.. FUMES ( OUSTS
(as Pb)
LIMESTONE
LINOANE
LITHIUM HYDRIDE
LPG (LIQUIFIED PETROLEUM
MAGNESITE
MAGNESIUM OXIDE FUME
MALATHION
MALE 1C ANHYDRIDE
MANGANESE AND COMPOUNDS
SKIN
GAS)
SKIN
MANGANESE CYCLOPENTAOIENYL SKIN
TRICARBONYL ( Mn)
MARBLE
MERCURY (ALKYL COMPOUNDS)
(as Hg)
MERCURY (INORGANIC)
(as Hg)
MESITYL OXIDE
METHANE
METHOHYL (LANNATE)
METHOXYCHLOR
2-METHOXYETHANOL (METHYL
CELLUSOLVE)
METHYL ACETATE
METHYL ACETYLENE
SKIN
SKIN
SKIN
SKIN
METHYL ACETYLENE-PROPADIENE
MIX (MAPP)
METHYL ACRYLATE
METHYL ACRYLONITRILE
SKIN
SKIN
HEALTH HAZARD
PRINCIPAL EFFECTS
OR BASIS/PEL
MODERATE IRRITATION-EYE. NOSE. THROAT/
CUMULATIVE LUNG DAMAGE
"INERT" PARTICULATE (ACCUMULATION IN LUNGS)
HARKED IRRITATION-LUNGS (EDEMA)
CUMULATIVE INTOXICATION (VARIED)/
SUSPECT CARCINOGEN
CUMULATIVE INTOXICATION (BLOOD. NEUROLOGIC)
"INERT" PARTICULATE (ACCUMULATION IN LUNGS)
CUMULATIVE LIVER I CNS DAMAGE/
SUSPECT CARCINOGEN
MARKED IRRITATION-EYE, NOSE, THROAT
NARCOSIS
"INERT" PARTICULATE (ACCUMULATION IN LUNGS)
"INERT" PARTICULATE (ACCUMULATION IN LUNGS/
FUME FEVER
CHOLINESTERASE INHIBITION
MARKED IRRITATION-EYE. NOSE. THROAT. LUNGS.
SKIN/CONTACT ALLERGY (ASTHMA
CUMULATIVE CNS DAMAGE -
CUMULATIVE KIDNEY AND CNS DAMAGE
"INERT" PARTICULATE (ACCUMULATION IN LUNGS)
CUMULATIVE CNS DAMAGE
>
CUMULATIVE CNS DAMAGE
MARKED IRRITATION-EYE, NOSE. THROAT
SIMPLE ASPHYXIATION
CHOLINESTERASE INHIBITION
ACUTE SYSTEMIC TOXICITY (LOW)
CUMULATIVE CNS, KIDNEY AND LIVER DAMAGE
MILD IRRITATION-EYE, NOSE, THROAT, LUNGS/
METHANOL TOXICITY
GOOD HOUSEKEEPING PRACTICE ("INERT" VAPOR)
GOOD HOUSEKEEPING PRACTICE ("INERT" VAPOR)
MARKED IRRITATION-EYE, NOSE, THROAT, SKIN
ACUTE TOXI CITY/CUMULATIVE LIVER & CNS DAMAGE
PERMISSIBLE
EXPOSURE LIMIT
(PED/OSHA
PPM MG/M3
50 2
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
METHYL AMINE
METHYL N-AMYL KETONE
METHYL BROMIDE SKIN
METHYL CHLORIDE
"TV.MffloETHANE)
METHYL CHLOROMETHYL ETHER
METHYL 2-CYANOACRYLATE
METHYL CYCLOHEXANE
METHYL CYCLOHEXANOL
0-METHYL CYCLOHEXANONE JK'N
METHYLDEMETON ' SKIN
4.4-METHYLENE BIS (2-
CHLOROANILINE) (MOCA)
METHYLENE BIS (4-
CYCLOHEXYL 1 SOCYANATE)
METHYLENE BISPHEHYL 1 SOCYANATE
(MOD
METHYLENE CHLORIDE
METHYL ETHYL KETOHE PEROXIDE
METHYL FORMATE
METHYL IODIDE SKIN
METHYL ISOAMYL KETONE
METHYL ISOBUTYLCARBINOL SKIN
METHYL 1 SOCYANATE SK'»
METHYL MERCAPTAN
METHYL METHACRYLATE
METHYL PARATHION SKIN
METHYL SILICATE
HETHYLCYCLOPENTADIENYL SKIN
HEALTH HAZARD
PRINCIPAL EFFECTS
OR BASIS/PEL
MARKED IRRITATION-EYE. HOSE. THROAT. SKIN
MODERATE IRRITATION-EYE. HOSE, THROAT/NARCOSIS
MARKED EDEMA-LUNGS/CNS DAMAGE
ACUTE AND CHRONIC CNS EFFECTS
MILD IRRITATION-EYE. HOSE. THROAT
CANCER (LUNG)
MODERATE IRRITATION-EYE. NOSE. THROAT
MILD IRRITATION-EYE, NOSE, THROAT/NARCOSIS
NARCOSIS/CUMULATIVE LIVER AND KIDNEY DAMAGE
MODERATE IRRITATION-EYE, NOSE, THROAT/
NARCOSIS
CHOLINESTERASE INHIBITION
CANCER
MARKED IRRITATION OF SKIN/ASTHMA
MARKED IRRITATION-EYE. NOSE, THROAT, SKIN/
ASTHMA
NARCOSIS/CHRONIC SYSTEMIC TOXI CITY '
(METABOLIC CONVERSION TO CO)
NARKED IRRITATION-EYE. NOSE. THROAT. LUNGS
MODERATE IRRITATION-EYE. NOSE, THROAT. LUNGS
CUMULATIVE CNS DAMAGE
MODERATE IRRITATION-EYE. NOSE. THROAT
MARKED IRRITATION-EYE. NOSE. THROAT
MARKED IRRITATION-EYE. NOSE. THROAT, SKIN.
LUNGS/ASTHMA
ODOR/MODERATE IRRITATION-EYE. NOSE. THROAT
MILD IRRITATION-EYE. NOSE. THROAT
CHOLINESTERASE INHIBITION
MARKED IRRITATION-EYE, NOSE, THROAT, LUNGS.
CUMULATIVE KIDNEY « CNS DAMAGE
PERMISSIBLE
EXPOSURE LIMIT
(PEL) /OSHA
PPM MG/M3
10 12
100 465
20 80
CEILING
100 210
350 1900
STD 1910.1006
NONE NONE
500 2000
100 470
100 460
NONE NONE
STD 1910.1005
NONE NONE
.°-°2CE,L,NP
500 1800
NONE NONE
100 250
5 28
NONE NONE
25 100
0.02 0.05
'OCEILING 20
100 410
NONE NONE
NONE NONE
NONE NONE
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S
S-ABOVE 3XPEL
S
S
S-ABOVE 2XPEL
S
S-ABOVE 4PPM;
16MG/M3
S-ABOVE 2XPEL
S
S-AT CURRENT
OSHA PEL
S-ABOVE 0.5MG/H3
S-ABOVE 0.02PPM
S-ABOVE 0.01PPM;
0.11MG/M3
S-ABOVE CEILING
LIMIT
S-AT CURRENT
OSHA PEL
S-ABOVE CEILING
LIMIT OF 0-2 PPM;
1.5 MG/M3
S-A60VE 3XPEL
S
S-ABOVE
S-ABOVE 2XPEL
S
S-AT CURRENT
OSHA PEL
S-ABOVE 2XPEL
S-ABOVE 0.6MG/M3
S-ABOVE CEILING
LIMIT
S-ABOVE 0.1 PPM;
02MG/M3
MANGANESE TRICAR80NYL
MICA
MINERAL WOOL FIBER
MOLYBDENUM, as Mo (INSOLUBLES)
MOLYBDENUM, as Mo (SOLUBLES)
MONOCROTOPHOS (AZOORIN)
MONOHETHYL HYDRAZINE SKIN
PNEUMOCONIOSIS (ACCUMULATION IN LUNGS) 20 MPPCF
"INERT" PARTICULATE NONE NONE
CUMULATIVE SYSTEMIC TOXICITY/LIVER AND KIDNEYS - 15
CUMULATIVE SYSTEMIC TOXICITY/LIVER AND KIDNEYS - 5
CHOLINESTERASE INHIBITION NONE NONE
ACUTE LUNG. CNS AND BLOOD DAMAGE/
SUSPECT CARCINOGEN
S
S
S-ABOVE 0.25MG/M3
S-ABOVE CEILING
LIMIT
L-74
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
MONOMETHYLANILINE SKIN
MORPHOLINE SICIM
NAPHTHA (COAL TAR)
NAPHTHALENE
NEON
NICKEL (SOLUBLE COMPOUNDS)
NICKEL CARBONVL
NICKEL. METAL t INSOLUBLE
COMPOUNDS
NICOTINE SKIN
NITRIC ACID
NITRIC OXIDE
P-NITROANILINE SKIN
NITROBENZENE SKIN
4-NITROBIPHENYL
P-NITROCHLOROBENZENE SKIN
NITROETHANE
NITROGEN
NITROGEN DIOXIDE
NITROGEN TRI FLUOR IDE
NITROGLYCERIN SKIN
NITROMETHANE
I-NITROPROPANE
2-NITROPROPANE
N-NITROSOOIMETHYLAMINE SKIN
NITROTOLUENE SKIN
NITROUS OXIDE
NOHANE
OCTACHLORO NAPHTHALENE SKIN
OCTANE
OIL MIST, P ARTICULATE
OIL MIST, VAPOR
OSMIUM TETROXIOE, « Os
HEALTH HAZARD
PRINCIPAL EFFECTS
OR SAS IS/PEL
METHEMOGLOBINEMIA
MODERATE IRRITATION-EYE, NOSE, THROAT
MODERATE IRRITATION-EYE, NOSE, THROAT/
NARCOSIS
MARKED IRRITATION-EYE, NOSE, THROAT/ANEMIA
SIMPLE ASPHYXIATION
CUMULATIVE LUNG DAMAGE/SUSPECT CARCINOGEN
ACUTE SYSTEMIC TOXI CITY/SUSPECT CARCINOGEN
CUMULATIVE LUNG DAMAGE/SUSPECT CARCINOGEN
ACUTE SYSTEMIC TOXI CITY
MARKED IRRITATION-EYE, NOSE, THROAT, SKIN
METHEMOGL08INEMIA/CNS EFFECTS
METHEMOGLOBINEMIA/CUMULATIVE LIVER DAMAGE
METHEMOGLOBINEMIA
CANCER-BLADDER "
METHEMOGLOBINEMIA
MODERATE IRRITATION/NARCOSIS
SIMPLE ASPHYXIATION
CUMULATIVE LUNG DAMAGE (BRONCHITIS AND
EMPHYSEMA)
METHEMOGLOBINEMIA/CUMULATIVE LIVER & KIDNEY
DAMAGE
CUMULATIVE EFFECT ON BLOOD PRESSURE,
FIBRILLATION
MARKED IRRITATION-EYE, NOSE. THROAT/NARCOSIS
MODERATE IRRITATION-EYE. NOSE, THROAT/
CUMULATIVE LIVER DAMAGE
MODERATE IRRITATION-EYE, NOSE. THROAT/
CUMULATIVE LIVER DAMAGE
CANCER
METHEMOGLOBINEMIA
SIMPLE ASPHIXIATION
ODOR/UNKNOWN TOXIC POTENTIAL (OCTANE ANALOGY)
CUMULATIVE LIVER DAMAGE
ODOR
GOOD HOUSEKEEPING PRACTICE
GOOD HOUSEKEEPING PRACTICE
MARKED IRRITATION-EYE, NOSE, THROAT, LUNGS
PERMISSIBLE
EXPOSURE LIMIT
(PEL) /OS HA
PPM MG/MJ
2
20
100
10
NONE
-
0.001
-
-
2
25
1
1
STD
-
100
NONE
5
10
9
70
M>0
50
NONE
1
0.007
1
0.5
5
30
6
5
1910.1003
1
310
NONE
9
29
0.2 2
CEILING
100
25
25.
STO
5
NONE
NONE
-
500
-
NONE
-
250
90
90
1910.1016
30
NONE
NONE
0.1
2350
5
NONE
0.002
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S
S-ABOVE 2XPEL
S-ABOVE 3XPEL
S
0-IF OXYGEN IS
GREATER THAN
)8t BY VOLUME
S
S
S
S-ABOVE 2XPEL
S-ABOVE 5XPEL
S-ABOVE 2XPEL
S
S-ABOVE 3XPEL
S
S-ABOVE 2XPEL
S-ABOVE 3XPEL
S-IF OXYGEN IS
LESS THAN
18* BY VOLUME
S
S
S-ABOVE CEILING
LIMIT
S-ABOVE 2XPEL
S
S
S
S-ABOVE 2XPEL
S-IF OXYGEN IS
LESS THAN
18* BY VOLUME
S
S
L-75
-------
READILY PERMISSIBLE
ABSORBED HEALTH HAZARD EXPOSURE LIMIT
THROUGH PRINCIPAL EFFECTS (PED/OSHA
SUBSTANCE SKIN OR BASIS/PEL "M MG/M3
OXALIC ACID
OXYGEN 01 FLUOR IDE
OZONE
PARAFFIN WAX FUME
PARAOjUAT
PARATHION
PENTABOMNE
PENTACHORONAPHTHALENE
PENTACHLOROPHENOL
PENTAERYTHRITOL .
PENTANE
2-PENTANONE .
PERCHLOROETHYLENE
PERCHLOROMETHYLMERCAPTAN
PERCHLORYL FLOUR IDE
PERLITE
SKIN
SKIN
SKIN
SKIN
SKIN
PETROLEUM DISTILLATES-(NAPTHA)
PHENOL
PHENOTHUZINE
PHENYL ETHER (VAPOR)
PHENYL ETHER-OI PHENYL NIX
(VAPOR)
P-PHENYLENE OIAMINE
PHENYL6LYCIDYL ETHER (PGE)
PHENYLHYORAZINE
PHENYLPHOSPHINE
PHORATE (THIMET)
PHOSORIN (MEVINPHOS)
PHOSGENE
PHOSPHINE
PHOSPHORIC ACID
PHOSPHORUS (YELLOW)
PHOSPHORUS PENTACHLORIOE
PHOSPHORUS PENTASULFIOE
PHOSPHORUS TRICHLORIDE
PHTHALIC ANHYDRIDE
SKIN
SKIN
SKIN
SKIN
SKIN
SKIN
NARKED IRRITATION-EYE. NOSE, THROAT, SKIN
MARKED EDEMA-LUNGS/CUMULATIVE KIDNEY DAMAGE 0.05
MARKED IRRITATION-LUNGS/CUMULATIVE O.I
RAOIOMIMETRIC (AGING) EFFECTS
MILD IRRITATION-EYE, NOSE, THROAT NONE
CUMULATIVE SYSTEMIC ( LUNG DAMAGE
CHOLINESTERASE INHIBITION
CUMULATIVE CMS DAMAGE 0.005
CUMULATIVE LIVER DAMAGE I CHLORACNE
ACUTE SYSTEMIC TOXICITY ( VASCULAR INJURY
"INERT" PARTICULATE (ACCUMULATION IN LUNGS) NONE
MILD IRRITATION/NARCOSIS 1000
MARKED IRRITATION-EYE, NOSE. THROAT/ 200
NARCOSIS
CUMULATIVE LIVER ( CNS DAMAGE 100
MARKED IRRITATION-EYE. NOSE. THROAT 0.1
MODERATE IRRITATION-EYE, NOSE, THROAT/ 3
CUMULATIVE BONE DAMAGE
"INERT1 PARTICULATE (ACCUMULATION IN LUNGS) NONE
MODERATE IRRITATION/NARCOSIS 500
HARKED IRRITATION-EYE. NOSE. THROAT. LUNGS/ 5
CUMULATIVE LIVER. LUNG KIDNEY DAMAGE
MODERATE IRRITATION-SKIN/PHOTOSENSITIZATION- NONE
SKIN
MODERATE IRRITATION-EYE, NOSE, THROAT 1
MODERATE IRRITATION-EYE, NOSE, THROAT 1
RESPIRATORY SENS IT IZAT ION-ASTHMA
MODERATE IRRITATION-EYE, NOSE, THROAT/ 10
NARCOSIS
HEMOLYTIC ANEMIA/SKIN IRRITATION 5
CUMULATIVE BLOOD DAMAGE (ANEMIA) NONE
CHOLINESTERASE INHIBITION NONE
CHOLINESTERASE INHIBITION
MARKED EDEMA-LUNGS O.l
ACUTE SYSTEMIC TOXICITY 0.3
MARKED IRRITATION-EYE. NOSE, THROAT
CUMULATIVE BONE AND LIVER DAMAGE
MARKED IRRITATION S DAMAGE TO LUNGS (EDEMA)
MARKED IRRITATION S H2S HAZARD
MARKED IRRITATION-EYE, NOSE, THROAT. LUNGS 0.5
MARKED IRRITATION-EYE, NOSE, THROAT, LUNGS/ 2
1
O.I
0.2
NONE
0.5
0.11
0.01
0.5
0.5
NONE
2950
700
670
0.3
13.5
NONE
2000
19
NONE
7
7
0.1
60
22
NONE
NONE
0.1
0.4
0.4
1
O.I
1
1
3
12
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S
S
s
s
s
s
s
s
S-ABOVE 2XPEL
S
S
s
(DEPENDING
UPON MIXTURE
OF AROHATICS)
S
S-ABOVE 2XPEL
S-ABOVE 2XPEL
S-ABOVE 2XPEL
S
S-ABOVE 2XPEL
S
S-A30VE CEILING
S-ABOVE 0.05 HG/M3
S
S-AT CURRENT
OSHA PEL
S
S-ABOVE 2XPEL
S
S
s
s
s
M-PHTHALOOINITRILE
INERT" PARTICULATE (LOW TOXICITY)
1-76
NONE
NONE
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
PICLORAH (TOROON)
PICRIC ACID SKIN
PIVAL
PLASTER OF PARIS
PLATINUM (SOLUBLE SALTS) as Pt.
POLrTETRAFLUOROETHYLENE
DECOMP. PRODUCTS
PORTLAND CEMENT
POTASSIUM HYDROXIDE
PROPANE
PROPARGYL ALCOHOL SKIN
N-PROPYL ACETATE
PROPYL ALCOHOL SKIN
N-PROPYL NITRATE
PROPYLENE Dl CHLORIDE
1, 2-PROPYLENE GLYCOL SKIN
DINITRATE
PROPYLENE SLYCOL MONOMETHYL
ETHER
PROPYLENE ININE-SKIN
PROPYLENE OXIDE
PYRETHRUM
PYRIOINE
QUINONE
ROX (CYCLOTRIHETHYLENE SKIN
TRINITRAMINE)
RESORCINOL
RHODIUM, METAL FUME t DUSTS
(as Rh)
RHODIUM. SOLUBLE SALTS
RONNEL
ROSIN CORE SOLDER PYROLYSIS
PRODUCTS (AS FORMALDEHYDE)
ROTENONE
ROUGE
RUBBER SOLVENT
SELENIUM COMPOUNDS (as Se)
SELENIUM HEXAFLOURIDE,(as Se)
PERMISSIBLE
HEALTH HAZARD EXPOSURE LIMIT
PRINCIPAL EFFECTS (PEL)XOSHA
OR BASIS/PEL PPM HG/M3
"INERT" P ARTICULATE (LOW TOXICITY) NONE
CUMULATIVE KIDNEY, LIVER & RBC DAMAGE/
DERMATITIS
CUMULATIVE ANTICOAGULANT EFFECTS (WARFARIN
ANALOGY)
"INERT1 PARTICULATE (ACCUMULATION IN LUNGS) NONE
RESPIRATORY SENS IT I ZAT ION (ASTHMA)
ACUTE TOXIC EFFECTS (POLYMER FUME FEVER) NONE
"INERT" PARTICULATE (ACCUMULATION IN LUNGS)
MARKED IRRITATION-EYE. NOSE, THROAT, LUNGS, NONE
SKIN
NARCOSIS/ASPHYXIATION 1000
MARKED IRRITATION-EYE, NOSE, THROAT, SKIN 1
MILD IRRITATION-EYE, NOSE, THROAT 200
MILD IRRITATION-EYE, NOSE, THROAT 200
CUMULATIVE SYSTEMIC EFFECTS (METHEMO- 25
GLOBINEMIA, HYPOTENSION)
CUMULATIVE LIVER DAMAGE 75
CUMULATIVE BLOOD PRESSURE & CNS CHANGES NONE
(HEADACHE), FIBRILLATION
ODOR NONE
MODERATE IRRITATION-EYE. NOSE. THROAT/ACUTE 2
TOXICITY
CUMULATIVE CNS. KIDNEY t LIVER DAMAGE 100
MILD IRRITATION-LUNGS
CUMULATIVE LIVER, KIDNEY t BONE MARROW DAMAGE 5
CUMULATIVE EYE (CORNEA) DAMAGE 0.1
ACUTE CNS EFFECTS (NAUSEA, CONVULSIONS)
MODERATE IRRITATION-EYE, NOSE, THROAT, SKIN NONE
RESPIRATORY SENSITIZATION (ASTHMA)
RESPIRATORY SENSITIZATION (ASTHMA) 0.
CHOLINESTERASE INHIBITION
MARKED IRRITATION-EYE, NOSE, THROAT NONE
CUMULATIVE SYSTEMIC TOXICITY/
SUSPECT CARCINOGEN
"INERT1 PARTICULATE (ACCUMULATION IN LUNGS) NONE
CUMULATIVE CENTRAL & PERIPHERAL NERVOUS NONE
SYSTEM DAMAGE
MODERATE IRRITATION-EYE, NOSE, THROAT/
CUMULATIVE LUNG, LIVER, KIDNEY DAMAGE
ACUTE LUNG DAMAGE (EDEMA) 0.05
NONE
O.I
0.1
NONE
0.002
NONE
50 MPPCF
NONE
1800
2
840
500
110
350
NONE
NONE
5
2
-------
READILY
AtSORKO
THROUGH
SUBSTANCE SKIN
SILICA (AMORPHOUS)
SILICA (FUSED)
SILICA (OJUARTZ)RESPIRABLE
SILICON
SILICON CARBIDE
SILICON TETRAHYORIOE (SI LANE)
SILVER, METAL t SOLUBLE
COMPOUNDS, 11 Ag
SOAKTONC
SODIUM A2IOE
SODIUM FLUOROACETATE SKIN
(1080)
SODIUM HYDROXIDE
STARCH
STIBINE
STOOOARO SOLVENT
STRYCHNINE
STYRENE. HONOMER
SUBTILISINS (PROTEOLYTIC
ENZYMES)
SUCROSE
SULFUR DIOXIDE
SULFUR HEXAFLUORIOE
SULFUR MONOCHLORIOE
SULFUR PENTAFLUORIOE
SULFUR TETRAFLOURIOE
SULFURIC ACID
SULFURYL FLUORIDE
2. *, 5-T
TALC (NON-AS8ESTIFORM)
TANTALUM
TEOP SKIN
TEFLON DECOMPOSITION PRODUCTS
TELLURIUM
TELLURIUM HEXAFLUORIOE. a* T«
TEPP SKIN
TERPHENYLS
1, 1, 2, 2,-TETRACHLORO-
1. 2.-OIFLUOROETHANE
I, 1, 1, 2.-TETRACHLORO-
2, 2, DIFLUOROETHANE
'. I, 2. 2,-
PERMISSIBLE
HEALTH HAZARD EXPOSURE LIMIT
PRINCIPAL EFFECTS (PED/OSHA
OR BASIS/PEL PPM M6/M3
POSSIBLE SI LI COS IS 20 NPPCF
PHEUMOCONIOSIS (SILICOSIS) USE 8A1ARTZ FORMULA
PNEUMOCONIOSIS (SILICOSIS) 100MG/M3 / «,02+2
"INERT" PARTICULATE (ACCUMULATION IN LUNGS) NONE NONE
"INERT" PARTICULATE (ACCUMULATION IN LUNGS) NONE NONE
ACUTE SYSTEMIC TOXICITY BY ANALOGY WITH NONE NONE
OTHER METAL HYDRIDES
CUMULATIVE SKIN PIGMENTATION AND KIDNEY - 0.01
DAMAGE
PNEUHOCONIOSIS (ACCUMULATION IN LUNGS) - 20 MPPCF
CUMULATIVE CMS AND BLOOD PRESSURE DAMAGE NONE NONE
ACUTE SYSTEMIC TOXICITY (METABOLIC - 0.05
PATHWAY INHIBITOR)
MARKED IRRITATION-EYE. NOSE. THROAT. LUNGS. 2
SKIN
"INERT" PARTICULATE (ACCUMULATION IN LUNGS) NONE NONE
ACUTE SYSTEMIC TOXICITY (R8C HEMOLYSIS) O.I 0.5
NARCOSIS/CUMULATIVE SYSTEMIC EFFECTS 500 2350
ACUTE AND CHRONIC SYSTEMIC TOXICITY (CNS. - 0.15
PARALYSIS)
MODERATE IRRITATION-EYE, NOSE. THROAT/NARCOSIS 100 *20
RESPIRATORY ALLERGY (ASTHMA ( LUNG DAMAGE) NONE NONE
"INERT" PARTICULATE (ACCUMULATION IN LUNGS) NONE NONE
NARKED IRRITATION-EYE. NOSE. THROAT. LUNGS 5 1}
1000 6000
MARKED IRRITATION-EYE. NOSE. THROAT. LUNG 1 6
MARKED IRRITATION-LUNGS (EDEMA AND DAMAGE) 0.025 0.25
MARKED IRRITATION-LUNGS (EOEMA)/ACUTE NONE NONE
TOXICITY
MARKED IRRITATION-EYE. NOSE, THROAT, SKIN - I
CUMULATIVE LIVER « KIDNEY DAMAGE 5 20
ACUTE SYSTEMIC TOXICITY - ]fl
PNEUCOHONIOSIS (TALCOSIS) - 20 MPPCF
MILD IRRITATION-EYE, NOSE, THROAT. LUNGS - 5
CHOLINESTERASE INHIBITION . 0.2
ACUTE SYSTEMIC TOXICITY (POLYMER FUME FEVER) NONE NONE
CUMULATIVE LIVER DAMAGE/GARLIC BREATH - O.I
ACUTE SYSTEMIC TOXICITY (HIGH) 0.02 0.2
CHOLINESTERASE INHIBITION - 0.05
MARKED IRRITATION-EYE. NOSE, THROAT. LUNGS 1 9
CEILING
CUMULATIVE LIVER DAMAGE S LEUKOPEHIA 500 M70
CUMULATIVE LIVER DAMAGE t LEUKOPENIA 500 4170
CUMULATIVE LIVER DAMAGE 5 35
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S
S
S
S-ABOVE 0.5PPH;
0.7 MG/H3
S
S-IF CONTAINS
TREMOLITE
S-ABOVE O.IPPM;
0.3M6/M3
S
S-ABOVE CEILING
LIMIT
S
S-AT CURRENT
OSHA PEL
S
S
S-ABOVE CEILING
LIMIT OF 0.00006
MG/M3
S
S
S
S-A80VE O.IPPM;
0.![]()
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
TETRACHLORONAPHTHALENE SKIN
TETRAETHVL LEAD (a* Pb) SKIN
TETRAHYDROFURAH
TETRAMETHYL LEAD (as Pb) SKIN
TETRANETHVL SUCCINONITRILE SKIN
TETRAN ITROMETHANE
TETRYU-SKIN
THALLIUM (SOLUBLE COMPOS) SKIN
4, V-THIOBIS (6 TERT
BUTYL-M-CRESOL)
THIRAM
TIN (INORGANICS, EXCEPT SnH(, t
Sn02)
TIN (ORGANICS) », So SKIN
TIN OXIDE
TITANIUM DIOXIDE
TOLUENE SKIN
TOLUENE-2. 4-0 II SOC YANATE (TOI)
0-TOLUIDINE SKIN
TRI BUTYL PHOSPHATE
1, 2, 4-TRICHLOR08ENZENE
1, 1, I-TRICHLOROETHANE
1,1, 2-TRICHLOROETHANE SKIN
TRICHLOKOETHYLENE
TRICHLORONAPHTHALENE SKIN
1,2, 3-TRICHLOROPROPANE
1,1, 2,-TRICHLORO-l, 2, 2-
TRIFLUOROETHANE
TRICYCLOHEXYLTIN HYDROXIDE
(PLICTRAN)
TRIETHYLAMINE
TR 1 FLUOROMONOBROMOMETHANE
TRIMETHYLBENZENE
TRINITROTOLUENE SKIN
TRIORTHOCRESYL PHOSPHATE
TRIPHENYL PHOSPHATE
TRIPHENYLAMINE
TUNGSTEN & COMPOUNDS, as V
(INSOLUBLE)
HEALTH HAZARD
PRINCIPAL EFFECTS
OR BASIS/PEL
CUMULATIVE LIVER DAMAGE S CHLORAONE
CUMULATIVE LIVER CNS/KIDNEY DAMAGE
MARKED IRRITATION-EYE, NOSE, THROAT/
NARCOSIS
CUMULATIVE LIVER, CNS, KIDNEY DAMAGE
ACUTE SYSTEMIC TOXICITY (CNS)
MARKED IRRITATION-EYE, NOSE, THROAT/
CUMULATIVE LUNG, HEART. I CNS DAMAGE
CUMULATIVE SYSTEMIC TOXICITY (LIVER)/
CONTACT DERMATITIS
CUMULATIVE CNS AND ENDOCRINE DAMAGE
"INERT" P ARTICULATE (ACCUMULATION IN LUNGS)
ACUTE SYSTEMIC TOXICITY ("ANTABUSE"-LIKE
EFFECTS) (LOW)
PNEUNOCONIOSIS (STANNOSIS) t LUNG DAMAGE
CUMULATIVE SYSTEMIC TOXICITY
"INERT" PARTICULATE (ACCUMULATION IN LUNGS)
"INERT" PARTICULATE ACCUMULATION IN LUNGS)
MODERATE IRRITATION-EYE, NOSE, THROAT/
NARCOSIS
MARKED IRRITATION-EYE, NOSE, THROAT, LUNGS/
ASTHMA
HETHEMOGLOB 1 NEH 1 A/SUSPECT CARC 1 NOGEN
MODERATE IRRITATION-EYE, NOSE, THROAT, LUNGS
CUMULATIVE LIVER DAMAGE
MILD IRRITATION-EYE, NOSE, THROAT
NARCOSIS/CUMULATIVE LIVER DAMAGE
NARCOSIS S ACUTE CARDIAC FAILURE/
SUSPECT CARCINOGEN
CUMULATIVE LIVER DAMAGE
MODERATE IRRITATION CUMULATIVE LIVER DAMAGE
MARKED IRRITATION-LUNGS. SKIN
MARKED IRRITATION-LUNGS, SKIN
METHEMOGL08INEMIA/CUMULATIVE EYE
(CATARACTS) i LIVER DAMAGE
CUMULATIVE NEUROMUSCULAR DAMAGE
(PARALYSIS)
CHOLINESTERASE INHIBITION
PNEUMOCONIOSIS (LUNG ACCUMULATION)
PERMISSIBLE
EXPOSURE LIMIT
(PED/OSHA
PPM MG/M3
2
0.075
200 590
0.07
0.5 3
1 8
1.5
0.1
NONE NONE
5
2
O.I
NONE NONE
15
200 750
0.02 0.14
CEILING
5 22
5
NONE NONE
350 1900
10 45
100 535
5
50 300
1000 7600
NONE NONE
25 100
1000 6100
NONE NONE
1.5
O.I
3
NONE NONE
NONE NONE
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S
s
S
s
s
s
' s
s
s
s
S-AT CURRENT
OSHA PEL
S-A80VE CEILING
LIMIT
S
S-ABOVE 3XPtL
S-ABOVE 3XPEL
S-ABOVE 2XPEL
S
S
s
s
0
s
S-ABOVE 25PPM;
120MG/M3
S
S
S-ABOVE l.SXPEL
1-79
-------
READILY
ABSORBED
THROUGH
SUBSTANCE SKIN
TUNGSTEN t COMPOUNDS, n V
(SOLUBLE)
TUMENTINC
UKANIUN (MATUML) INSOLUBLE
URANIUM (NATURAL) SOLUtlC
VANADIUM (V.O.) AS OUST
VANADIUM (VjO.) AS FUME
VINYL ACETATE
VINYL MOHIOE
VINYL CHLORIDE
VINYL CYCLOHEXENE DIOXIDE
VINYL TOLUENE
VINYLIOENE CHLORIDE
VN £ P NAPHTHA
WARFARIN
WELDING FUMES (TOTAL PARTICULAR)
WOOD OUST (NOHALLERGENIC)
XYLENE (0-.M-.P-ISOMERS) SKIN
H-XYLENE, ALPHA, ALPHA, DIAHINE
XYLIOINE SKIN
YTTRIUM
ZINC CHLORIDE FUME
ZINC CHROHATE, as Cr03
ZINC OXIDE FUME
ZINC STEARATE
ZIRCONIUM COMPOUNDS (** Zr)
HEALTH HAZARD
PRINCIPLE EFFECTS
OR BASIS/PEL
ACUTE SYSTEMIC TOXICITY (CNS, ANOXIA)
MODERATE IRRITATION-EYE. NOSE. THROAT/
CUMULATIVE KIDNEY OAMA6E
CUMULATIVE BLOOD AND KIDNEY DAMAGE
CUMULATIVE BLOOD AND KIDNEY DAMAGE
HARKED IRRITATION-EYE, NOSE, THROAT, LUN6S
HARKED IMITATION-EYE. NOSE. THROAT, LUNGS
MILD IMITATION-EYE, NOSE. THROAT
CUMULATIVE BROMIDE INTOXICATION
CANCER (LIVER)
MARKED IRRITATION-SKIN/SUSPECT CARCINOGEN
MODERATE IRRITATION-EYE, NOSE, THROAT
CUMULATIVE LIVER * KIDNEY DAMAGE
NARCOSIS/CUMULATIVE SYSTEMIC TOXIC EFFECTS
CUMULATIVE ANTICOAGULANT EFFECT
MODERATE IMITATION/ACUTE TOXICITY FROM
METAL OXIDES
LUNG DAMAGE/SUSPECT CARCINOGEN
MODERATE IRRITATION-EYE, NOSE. THROAT/
NARCOSIS
MODERATE IRRITATION-EYE. NOSE. THROAT, SKIN
(CONTACT ALLERGY)
METHEMOGLOBINEMIA/ACUTE SYSTEMIC TOXICITY
PNEUMOCONIOSIS (DIFFUSE FI8ROSIS)
MARKED IRRITATION-EYE. NOSE. THROAT. LUNGS
SEE CHROMATES/SUSPECT CARCINOGEN
ACUTE SYSTEMIC TOXICITY (METAL FUME FEVER)
"INERT' P ARTICULATE (ACCUMULATION IN LUNGS)
PNEUMOCONIOSIS (LOU TOXICITY)
PERMISSIBLE
EXPOSURE LIMIT
(PED/OSHA
PPM MG/HJ
NONE NONE
100 560
O.Z5
0.05
0.5
CEILING
CEILING0'1
NONE NONE
NONE NONE
STD 1910.1917
NONE NONE
100 WO
NONE NONE
NONE NONE
0.1
NONE NONE
NONE NONE
100 435
NONE NONE
5 25
1
1
NONE NONE
5
NONE NONE
5
HAZARD OF
EXPOSURE
ABOVE PEL
S-SERIOUS
S -ABOVE 1 HG/M3
S
S
S
S-ABOVE CEILING
LIMIT
S-AT CURRENT
OSHA CEILING
LIMIT
S-ABOVE ZO PPM;
60 MG/M3
S-ABOVE 250 PPM;
MOO NG/M3
S-ABOVE 1 PPM OR
CEILING S PPM
S-ABOVE 10 PPM;
60 MC/MJ
S-ABOVE 3XPEL
S-ABOVE 10 PPM;
40 MG/HJ
S-ABOVE 200 PPM:
tOO HG/H3
S
S-ABOVE 5 MG/M3
S-ABOVE 5 MG/M3
S-ABOVE 2XPEL
S
S
S
S
S-ABOVE 0.05 MG/M3
L-80
-------
Safety References for Stack Sampling
Some of the references that would be useful for a library
on safety and occupational health for stack sampling organizations
is listed here. Not listed, but very useful, are the current catalogs
of the vendors of safety equipment such as self-contained breathing
apparatus, fire extinguishers, safety climbing gear, hoisting equip-
ment, ladders and scaffolds, communications equipment, electrical
safety testing equipment, chemical exposure monitoring equipment,
flammable vapor and gas detection equipment, and all sorts of
personal protective equipment.
Also not listed but highly recommended are the current articles
on the toxic effects of chemicals which stack sampling personnel may
encounter in high concentrations in specific industries.
Because of the wide range of activities in stack sampling, the
following list of references is not likely to cover all needs, and some
of the references may provide more information than is needed.
When ordering any of these references, always request the latest
edition. The date of the latest current edition may be shown in ( ).
"Handbook of Hazardous Materials", Technical Guide No. 7 (1974)
American Mutual Insurance Alliance
20 North Wacker Dr., Chicago, Illinois 60606
Excellent data on the chemicals for which Threshold Limit
Values have been established by the ACGIH, and for which
OSHA has adopted Permissible Exposure Limits (see Appendix
pages 60-76 for list, with brief information on those which
are readily absorbed through the skin, and a listing of the
key health effects of exposure, the OSHA PEL, and at what
concentrations OSHA considers exposure serious.)
"Handbook of Organic Industrial Solvents", Technical Guide No. 6 (1972)
American Mutual Insurance Alliance
20 North Wacker Dr., Chicago, Illinois 60606
A tabulation of data on solvents and their characteristics,
including their physical properties, evaporation rates and
physiological effects.
"Threshold Limit Values" (published annually)
American Conference of Governmental Industrial
Hygienists, P.O. Box 1937, Cincinnati, Ohio 45201
"The Condensed Chemical Dictionary" (1971, Eighth Edition)
Gessner G. Hawley, Editor
Van Nostrand Reinhold Company
450 West 33rd St., New York, N. Y. 10001
L-81
-------
"Dangerous Properties of Industrial Materials"
N. Irving Sax, Editor
Van Nostrand Reinhold Company
450 West 33rd St., New York, N. Y. 10001
"Hazardous Chemicals Data", NFPA No. 49-1975
"Fire Hazard Properties of Flammable Liquids, Gases,
and Volatile Solids", NFPA No. 325M-1977
National Fire Protection Association
470 Atlantic Avenue, Boston, Mass. 02210
"Fire Protection Handbook", Fourteenth Edition, 1976
Gordon P. McKinnon, Editor
National Fire Protection Association
470 Atlantic Avenue, Boston, Mass. 02210
"Handbook of Industrial Loss Prevention", Second Edition, 1967
Factory Mutual Engineering Corporation
McGraw-Hill Book Company
New York, N.Y.
Recommended Practices for the Protection of Property and
Processes against Damage by Fire, Explosion, Lighting, Wind,
and Earthquake
"Accident Prevention Manual for Industrial Operations
Frank E. McElroy, Editor
National Safety Council
444 North Michigan Avenue, Chicago, Illinois 60611
1-82
-------
Example of Information Required on a SHIPPING PAPER
for Hazardous Materials
Per CFR 49, DOT Regulations
for Hazardous Materials
From: To:
Date ship Origin Carrier and Route
Pieces Type of Haz. Description (Proper Shipping Name)
Package Mtl. and Hazard Class
Acetic acid, glacial, CORROSIVE MATERIAL
Acetone, FLAMMABLE ~
Benzene, FLAMMABLE LIQUID
Barium Perchlorate, OXIDIZER
Hydrochloric Acid, Solution, CORROSIVE
MATERIAL
Hydrogen Peroxide, 8-40%, OXIDIZER
Nitric Acid, CORROSIVE MATERIAL
Shipment FORBIDDEN in Passenger Aircraft
Carbolic Acid (Phenol), POISON B
Oleum (Sulfuric acid, fuming),
CORROSIVE MATERIAL
Sodium Hydroxide, Dr# CORROSIVE MATERIAL
Toluene, FLAMMABLE LIQUID
(Other materials can be listed after
the listing of Hazardous Materials
This is to certify that the above named materials are properly
classified, described, packaged, marked, and labeled, and are
in proper condition for transportation, according to the applicable
regulations of the Department of Transportation.
(Signature)
L-83
-------
SLIDE 253-0 NOTES
SAFETY IN STACK TESTING
SLIDE 253-1
SUBPART 60.8(e)
(e) The owner or operator of
an affected facility shall provide,
or cause to be provided, performance
testing facilities as follows:
(1) Sampling ports adequate for
test methods applicable to such
facility.
(2) Safe sampling platform(s).
(3) Safe access to sampling
platform(s).
SLIDE 253-2
The agency observer has both
the responsibility and authority
to stop or disallow the starting
of testing when unsafe conditions
exist.
L-85
-------
SLIDE 253-3
SAFETY PROBLEMS
NOTES
1. Physical Injury
2. Electrical Shock
3. Fire
4. Exposure to Heat
and Cold
5
6
Exposure to pollutant
Exposure to Process
Materials
Exposure to Sampling
Chemicals
SLIDE 253-4
SAFETY PRECAUTIONS
1. Fill out safety checklist dur-
ing presurvey visit or have
facility complete checklist
prior to presurvey.
2. Take all necessary steps to
ensure safety.
3. Inspect all facilities and
equipment.
4. Hold a pretest safety meeting
with facility person in"charge
of safety.
L-87
-------
SECTION M. DATA VALIDATION TECHNIQUES
Subject page
1. A data validation scheme for pulverized boilers M-3
2. Slides \H-2l
M-l
-------
A DATA VALIDATION SCHEME FOR PULVERIZED BOILERS
Charles Bruffey, William G. DeWees
PEDCo Environmental, Inc.
Cincinnati, Ohio
Combustion of coal with air can be defined by stoichio-
metric equations; therefore, many of the by-products of combus-
tions can be calculated by knowing the quantity and composition
of the fuel and some of the products of combustion. By applying
these combustion balances and knowing one or more input data the
user can calculate or validate other data. The user should be
aware of two things. First, when a calculated combustion product
does not agree with the measured product it means that one or
more of the input or calculated data is wrong. Many times the
use of a combination of data and equations will provide insight
to the data that is in error. For this reason the more com-
bustion and emission data that can be collected, the better the
chance to validate and determine the bad data. Second, the user
should be aware that some of the data that is recommended to be
collected (Figure 1), are average values and may not be an exact
representation of test conditions. Also the assumed values are
only estimates of an average combustion system. For this reason
all validations are good for within about +10 percent. Typical
values for the different size boilers and the relationships of
combustion values can be seen in Figure 2.
M-3
-------
RECOMMEND DATA FOR EACH RUN (If Available)
Coal Data
Coal Sample Collected - (as close to furnace entry as
possible - i.e. after pulverizers)
Coal Analysis - XC, XH, %H, XO, XS, XFC, XVM, %H20, %Ash,
and Btu/lb (all analyses must be presented on the same
basis)
Boiler Data
Megawatts, pounds of coal per hour to boiler , steam
production in pounds of steam per hour , monthly average
of Btu per kilowatt hour , Ib of steam per pound of
coal and estimated thermal efficiency of boiler
Emission Test Data
Pollutant(s) concentration
02 C02
Flue gas flow rate (dscfh)
Stack temperature Stack pressure
Percent moisture
Figure 1.
M-4
-------
I
en
CLASSIFICATION
OF
BUILDING AND
PLANT
SIZE RANGES
i : 1 1
CROUP in -'pukic UTILITY STEAK ELECTRIC GENERATION STATION
CROUP H -LARGE INDUSTRIAL tITH PROCESS STEAK I
CROUP!- SMALL INDUSTRIAL IITH PROCESS STEAM, DAIRIES, etc.
GROUP HI-CENTRAL PLAITS
CROUP HA-LARCE INSTITUTIONAL, HOSPITALS, etc. J
CROUP m- BUSINESS 1 MANUFACTURING I/O PROCESS STEAM !
CROUP OB-OFFICE BUILDINGS, HOTELS, THEATERS, etc !
CROUPIIA- SCHOOLS, CHURCHES, SMALL COLLEGES, etc.
fCRbUPIB-APARTMENT BUILDINGS j
JROUPIA- ITO 4 FANILT DWELLINGS
FIRING METHODS
RANGE OF
EQUIPMENT
SIZES
|~"J ' PULVERIZED COAL FIRED UNITS
1 CHAlii OR TRAVELING GRATE
1 IATER COOLED VIBRATING GRATE | |
SPR.*- TRAVELING GRATE 1
SfJif'iiSli'
| SPR'-STATIONART OR DUMPING GRATE
! ISPR'-VIBMTING CRATEl
(SCR AUTOMATIC PACKAGED BOILER 1 1 KULTIPLE RETORT UNDERFEED STOKER 1
SINGLE RETORT UNDERFEED STOKER l
CLASS 1 (CLASS 2| CLASS 3 I CLASS 4 1 CLASS 5 !
HAND FIRED EQUIPMENT | ! ! i
EFFLUENT l-i 1
j
1 1 1 1 1 1
TEMPERATURE.'F r-L -1- ^ ^ , ^ ^ .^ ,, ;
' i i
COAL TO SUAM t-J 1 I ' 1 1 1 1
55 60 65
EXCESS AIR,% | | | 1 1 1
100 90 15 10 75 70 i
STACK GAS EFFLUET
at indicated | 1 1 Mill 1
EwssAir 1 50 100
EQUIVALENT
UNIT CAPACITY '
IN MEGAWATTS |
at 10,500 BTU/KWI
BOILER OUTPUT
per HOUR at JJJJJ 1 1 1 LJ
IflOO BTU /Ib STEAM O.I 0.5
BOILER INPUT |__ , , , ,
Ibs COAL per HOUR i I 1 1 1 1 1 1
at I3.IOO BTU/lb j |o 50
BOILER INPUT j , , , , ,,
MILLION BTU j I 1 1 1 1 1 II
per HOUR ot 0.5
1 TO i 75 10 15 j
1 1 1 * i 1 j 1 1
1 1 1 _J 1 1 1 . 1
t 60 55 50 45 40 35 30 25
J-i i i i i 1 1 1 p1 i i i iiiii r 1 | MINI 1 1 TT~
_| 1 Mill II 1 1 1 1 1 1 1 1 1 1 1 IIIII L 1 1 1_
500 WOO 5,000 10,000 ! 50,000 IOOMO i 500.001
< i
"l 1 1 1 1 1 1 1 1*1 1 1 1 IIIHI 1
1 5 NO 50 100
TTTI 1 i i i i i 'H i 1 i i i i 1 1' 1 1 1 1 i i 1 1 1 1 1 1
11 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 LI 1 1 1 1 1 1 1 1 J 1
1*5 5 f 10 50 j 100 500 'l,000
! 1
j i
m 1 i i i i I'm 1 i r i 1 1 in 1 i i i ii'm r
ii i i_ ii i i i i ' ii ii 1 L_J ''i'" i
"iOO 500 j 1,000 W» 1 IMM 5IWW i 100,000
1 i i i 1 1 nt 1 i r i 1 1 1 1\ \l l i i 1 1 III 1
| ' ' ' | ' ' "|'0 ' 50 IM 500 l»0
l
i
i
t CTCIONE FURNACES
1 1
350 (300
90
t
20
run i i i IMII
5 nooaooo I 5,000,000 KIOOO.OOO
1
1 | | [ || 1*1 1 | t MMI
500 1X00 5400
1 | | | | ill 1 1 Mill
5,000 illUOO 50400
1
i i i i Tin 1 iiill
500,000 |woo,ooo smooo
1
1
i i 1 1 nil 1 i i 1 1 1 1 r
5J555 Rijwo &MW
SPR*- SPREADER STOKER
WALTER tX SMITH
Figure 2. Summary of characteristics of coal-firing equipment.
-------
F-FACTOR CALCULATIONS
Equation #1
P = TO6 [3.64 %H + 1.53 %C + 0.57 %S + 0.14 %N - 0.46 %0]
h GCV
where:
F = a factor representing a ratio of the volume of dry flue gases
generated to the calorific value of the fuel combusted, expressed as
dry standard cubic feet per million Btu of heat input (dscf/MM Btu)
H, C, S, N, and 0 = content by weight of hydrogen, carbon, sulfur, nitrogen,
and oxygen (expressed as %), respectively, and on a dry basis
GCV = the gross calorific value (Btu/lb) of the fuel combusted on a dry
basis
Run
F _ IP6 L(3.64)( ) + (1.53)( ) + (0.57K ) + (0.14)( ) - (0.46)(
F = dscf/MM Btu
For bituminous coal, F can be assumed to be 9820 dscf/MM Btu. The
calculated F generally is within +3.1 percent of 9820. See the NSPS for
fossil fired steam generators for additional information.
M-6
-------
EMISSION RATE CALCULATIONS
Equation #1
F = CF f 20-9 ]
t ^ ^20>9 _ % Q^;
where:
E = pollutant emission rate (Ib/MM Btu), dry basis
C = pollutant concentration (Ib/dscf or ynnn )» dry basis (measured)
%Q£ = oxygen volume (expressed as percent), dry basis (measured)
F-factor = dscf/MM Btu (calculated or estimated)
Run
20.9
E ^7000^ ^20.9 - '
E = Ib/MM Btu
Equation #2
Pmr = C Qstd
where:
Pmr = parti cul ate mass emission rate (Ib/h)
C = pollutant concentration (Ib/dscf or nnn ) dry basis (measured)
Q . . = flue gas flow rate, dry standard cubic feet per hour (dscfh),
(measured)
Run _
Pmr = ( )( ) = Ib/h
M-7
-------
I. Total Heat Input Million Btu Per Hour (MM Btu/h)
Equation #1
.(Qstd)(20.9 - %02)
H (F) (20.9)
where:
Qu = total heat input, million Btu per hour (MM Btu/h)
Q td = flue gas flow rate, dry standard cubic feet per hour (dscfh)
(measured)
%02 = oxygen content (expressed as percent), dry basis (measured)
F-factor = calculated or assumed, dry standard cubic feet per million Btu of
heat input (dscf/MM Btu)
Run
K20.9 - )
Q -
H
)(20.9)
QH = MM Btu/h
Equation #2
(m)(HHV)
where:
ny = fuel firing rate (measured coal to boiler)(lbs of coal/h)
HHV = Higher Heating Value (Btu/lb of coal)(as received basis coal
analysis)
Run
0 -
QH (io6)
QH = MM Btu/h
M-8
-------
I. Total Heat Input Million Btu Per Hour (MM Btu/h) (continued)
Equation #3
Q = (P)(Hrj
where:
P = absolute unit of power (kW) (from plant data during test period) '
Hr = heat rate, Btu per kilowat hour (Btu/kWh)
Run
Qu = A ^1 L
H 106
QH = MM Btu/h
Equation #4
(Ps)(1100 Btu/lb of steam)
Qhl (n)(106)
where:
PS = steam production (Ib of steam/h) (from steam chart)
1100 Btu/lb of steam = this value is the estimated Btu's required to produce
a pound of steam per pound of water including heat losses such as
blow down.
n = thermal efficiency (actual or estimated from Figure 3)
Run
n = ( HUPP)
QH = MM Btu/h
Note: The heat input can be calculated by more than one of the equations
to determine errors in measured flue gas flow rate, coal scale readings
or steam readings. In general the reliability of values would be
megawatts, steam readings, flue gas flow rate, and coal scale from
most to least reliable, respectively.
M-9
-------
o
t-I
Ll_
Ll_
LJ
_J
cc
90
85
80
75
70
65
60
12 11 10 9 8 7 6 5 4
PERCENT 02 IN FLUE GAS
NOTE: TEMPERATURE SHOULD BE REPRESENTATIVE OF TEMPERATURE
AFTER LAST BOILER HEAT REMOVAL SYSTEM-i.e. AIR PREHEATER,
ECONIMIZER. COOLING FROM DILUTION AIR SHOULD NOT BE INCLUDED.
Figure 3. Thermal efficiency curves.
M-10
-------
II. Estimated Flue Gas Flow Rate
Equation #1
n = n Ff, 20« 9 .1
gstd wHhH20.9 - %02);
where:
Q .d = estimated flue gas flow rate (dscfh)
QH* = total heat input (MM Btu/h) (not calculated using flue gas flow)
%^2 ~ oxygen volume (expressed as percent), dry basis (measured)
F-factor = (dscf/MM Btu) (calculated or assumed)
Run
20.9 x
Q=( )( )(
20.9 -
Q = dscfh
Note: The total heat input (Q^) can not be calculated from flue gas flow.
The use of this equation as a check for (Q^) would give the same
results.
M-ll
-------
III. Pounds of Particulate Per Million Btu to the Inlet of
Air Pollution Control Equipment (Ibs/MM Btu)
Equation #1
F - (106)(%ash/10Q)(0.85)
i " HHV
where:
E.J = particulate emission rate to the inlet of air pollution
control equipment (Ibs/MM Btu)
%ash = coal analysis (as received basis)
0.85* - approximately 85% of the ash is carried by the flue gas to the air
pollution control device
HHV = Higher Heating Value coal analysis (Btu/lb coal) (as received basis)
Run
F '- (1o6H /100)(0.85)
i (Btu/lb)
E. = Ib/MM Btu
*Note: This emission factor is for pulverized coal fired units. Spreader
stokers and underfeed units have a different emission factor and
are generally less reliable because of a high degree of variation
in stoker operation and maintenance.
M-12
-------
IV. Pounds of Participate Per Hour
to the Air Pollution Control Equipment
Equation #1
Pmr = (mf)(-*jg!L)(o.85)
where:
Pmr = pounds of particulate per hour to the air pollution control
equipment (Ibs/h)
try = fuel firing rate (measured coal to boiler)(lbs of coal/h)
%ash = coal analysis (as received basis)
0.85* = approximately 85% of the ash is carried by the flue gas to the air
pollution control device
Run
Pmr = ( )( )(0.85)
100
Pmr = Ibs/h
Equation #2
Pmr = (Ep)(QH)
where:
Ep* = particulate emission rate at the inlet of the control equipment
(Ib/MM Btu) (calculated or measured)
QH = total heat input (MM Btu/h) (not calculated from flue gas flow)
Run
Pmr = ( )( )
Pmr = Ibs/h
*Note: These factors are for pulverized coal fired units. The heat input in
Equation No. 2 can be calculated by any of the previous methods other
than by the use of flue gas flow rate. The results of particulate
mass rate can then be compared with the measured rate. This comparison
is a combination of the heat input validation and fuel composition
comparison.
M-13
-------
V. Pounds of Sulfur Dioxide Per Million Btu (Ib S02/MM Btu)
to Air Pollution Control Equipment
Equation #1
'
US HHV
where:
ES = S02 emission rate to air pollution control equipment (Ib S02/MM Btu)
2 = there are 2 pounds of SO,, generated per pound of sulfur
%S = coal analysis (as received basis)
0.95 = approximately 95 percent of the sulfur is converted to sulfur
dioxide
HHV = Higher Heating Value coal analysis (Btu/lb coal) (as received basis)
Run
(106 Btu)(2)(TO)(0.95)
ES = HHV
ES = Ibs S02/MM Btu
Note: Because of the difficulty in obtaining representative coal samples,
the average of coal-analyses calculated results should be compared to
the average of measured sulfur dioxide emission results (excluding
any suspected outliers). Comparison on a run by run results is
generally not very consistent.
M-14
-------
VI. Pounds of Sulfur Dioxide Per Hour to the Air
Pollution Control Equipment
Equation #1
Mc = (m.p'
o T
where:
MS = pounds of sulfur dioxide per hour to the air pollution control
equipment (Ibs S02/h)
mf = fuel firing rate (measured coal to boiler)(lbs of coal/h)
%S = coal analysis (as received basis)
0.95 = approximately 95 percent of the sulfur is converted to sulfur
dioxide
2 = there are 2 pounds of S02 generated per pound of sulfur combusted
Run
Ms = ( )(TO)(0.95)(2)
MS = Ibs S02/h
Equation #2
MS = (ES)(QH)
where:
E<- = S02 emission rate to air pollution control equipment
b (Ibs S02/MM Btu)
Q* = total heat input (MM Btu/h)(not calculated from flue gas flow)
rl
Run
Ms = ( )( )
PL = Ibs S02/h
*Note: The heat input in Equation No. 2 can be calculated by any of the
previous methods other than by the use of flue gas flow rate. The
results of sulfur dioxide mass emission rates can be compared with
measured results. This comparison is a combination of the heat input
validation and fuel composition comparison.
M-15
-------
VII. Collection Efficiency of Control Equipment
Equation #1
- _ (E inlet) - (E outlet)
n E inlet x
where:
T] = collection efficiency of control equipment (expressed as a percent)
E inlet = pollutant emission rate at inlet (Ib/MM Btu)(measured or calculated)
E outlet = pollutant emission rate at outlet (Ib/MM Btu) (measured)
Run
n = r^-^ x 100%
n =
Equation #2
M inlet
where:
M. , . = pounds of pollutants per hour to the inlet of the air pollution
control equipment (Ibs/h) (measured or calculated)
M .,' = pounds of pollutants per hour to the outlet of the air pollution
control equipment (Ibs/h) (measured)
Run
n = -^ - * " * - ~ x
n = %
M-16
-------
VII. Collection Efficiency of Control Equipment (continued)
Equation #3
where:
C. -I , = grains of pollutants per dry standard ft of flue gas to the inlet
of the air pollution control equipment (gr/dscf)
3
C ., . = grains of pollutants per dry standard ft of flue gas to the outlet
of the air pollution control equipment (gr/dscf)
Run
' , J- x 100%
n =
M-17
-------
VIII. Collection Efficiency Required for Compliance
Equation #1
-
n
req
^ inlet' " ^ regulation'
Tr - r" - x
where :
"n
= collection efficiency required for compliance (expressed as a
req percent)
E. , . = pollutant emission rate at inlet (Ib/MM Btu) (measured or
inlet calculated)
lation = P°^utant emission rate at outlet set by regulation (Ib/MM Btu)
E
Run
10M
Note: This should be the minimum collection efficiency that the air pollu-
tion control equipment was guaranteed.
M-18
-------
IX. Evaluation of Orsat Data
o is a type of F-factor derived from combustion calculations. Values
are available for all types of fuels just as F, F , or F . F can be
c wo
represented by the following formula:
Equation #1
20.9 - Mo
F. =
o %C02
For bituminous coal 1.09 < fn < 1.19
o
Orsat data can also be validated with the use of Figure 4.
Note: The measured oxygen readings can also be validated by comparison with
the boiler's oxygen monitor used by the boiler operator to set the
excess. Plant personnel should have a good estimate on the amount of
air leakage between the boiler's continuous oxygen monitor and the
sampling site.
M-19
-------
SLIDE 254-0 NOTES
A DATA VALIDATION SCHEME
FOR PULVERIZED BOILERS
SLIDE 254-1
RECOMMEND DATA FOR EACH RUN (If Available)
Coal Data
Coal Sample Collected - (as close to furnace entry as
possible - i.e. after pulverizers)
Coal Analysis - %C, %H, %N, W, %3, *FC, *VM, SSHzO, %Ash,
and Btu/lb (all analyses must be presented on the same
basis)
Boiler Data
Megawatts, pounds of coal per hour to boiler _ , steam
production in pounds of steam per hour _ , monthly average
of Btu per kilowatt hour _ , Ib of steam per pound of
coal _ and estimated thermal efficiency of boiler
Emission Test Data
Pollutant(s) concentration
02 C02
Flue gas flow rate (dscfh)
Stack temperature Stack pressure
Percent moisture
M-21
-------
SLIDE 254-2 NOTES
F-FACTOR CALCULATIONS
106 [3.64 (%H) + 1.53 (%C) +1.57 (%S) + 0.14 (%N) - 0.46 (%0)]
GCV
where:
F = a factor representing a ratio of the volume of dry flue gases generate! to the
calorific value of the fuel combusted, expressed as dry standard cubic feet
per million Btu of heat input (dscf/MM Btu)
H, C, S, N, and O = content by weight of hydrogen, carbon, sulfur, nitrogen, and oxygen
(expressed as %), respectively, and on a dry basis
GCV = the gross calorific value (Btii/lb) of the fuel combusted on a dry basis
NOTE: For bituminous coal, F can be assumed to be 9820 dscf/MM Btu. The calculated F generally is
within +3.1 percent of 9820. See the NSPS for fossil fired steam generators for additional
information.
SLIDE 254-3
EMISSION RATE CALCULATIONS
Eq.1
E = CF 20'9
20.9 - %Q2
where: E = pollutant emission rate (Ib/MM Btu), dry basis
C = pollutant concentration Ib/dscf or gr/dscf
dry basis (measured) 700°
%C>2 = oxygen volume (expressed as percent), dry basis
(measured)
F-factor = dscf/MM Btu (calculated or estimated)
M-23
-------
SLIDE 254-4 NOTES
EMISSION RATE CALCULATION
Eq.2
Pmr = C Qsw
where:
Pmr = paniculate mass emission rate (Ib/h)
C = pollutant concentration Ib/dscf or g dry basis
(measured) 700u
= f|Ue gas flow rate, dry standard cubic feet per hour
(dscfh), (measured)
SLIDE 254-5
TOTAL HEAT INPUT MILLION BTU PER HOUR
Eq.1
_ (CU (20.9 - 02)
H ~ (F) (20.9)
where: QH = total heat input, million Btu per hour (MM Btu/h)
Qsld = flue gas flow rate, dry standard cubic feet per hour
(dscfh) (measured)
%C>2 = oxygen content (expressed as percent), dry basis
(measured)
F-factor = calculated or assumed, dry standard cubic feet per
million Btu of heat input (dscf/MM Btu)
M-25
-------
SLIDE 254-6 NOTES
TOTAL INPUT MILLION BTU PER HOUR
Eq.2
= (m,) (HHV)
H (106)
where: m, = fuel firing rate (measured coal to boiler) (Ibs of coal/h)
HHV = Higher Heating Value (Btu/lb of coal) (as received
basis coal analysis)
SLIDE 254-7
TOTAL HEAT INPUT MILLION BTU PER HOUR
Eq.3
a = JO C*>
where:
P = absolute unit of power (kW) (from plant data during test
period)
Hr = heat rate, Btu per kilowat hour (Btu/kWh)
M-27
-------
SLIDE 254-8
NOTES
TOTAL HEAT INPUT MILLION BTU PER HOUR
Eq.4
Q = (Ps) (1100 Btu/lb of steam)
(106)
where:
P, = steam production (Ib of steam/h)
(from steam chart)
11 00 Btu/lb of steam = this value is the estimated Btu's re-
quired to produce a pound of steam
per pound of water including heat
losses such as blow down.
rj = thermal efficiency (actual or estimated
from Figure 3)
NOTE: The heat input can be calculated by more than one of the
equations to determine errors in measured flue gas flow rate,
coal scale readings or steam readings. In general the reliability
of values would be megawatts, steam readings, flue gas flow
rate, and coal scale from most to least reliable, respectively.
SLIDE 254-9
O
m
O
in
DC
UJ
I
-------
SLIDE 254-10 NOTES
ESTIMATED FLUE GAS FLOW RATE
Eq.1
- r\ c 20-9
d - QHF
(20.9 - %O2)
where:
QM = estimated flue gas flow rate (dscfh)
QH* = total heat input (MM Btu/h) (not calculated using
flue gas flow)
%O2 = oxygen volume (expressed as percent), dry basis
(measured)
F-factor = (dscf/MM Btu) (calculated or assumed)
NOTE: The total heat input (QH) can not be calculated from flue gas
flow. The use of this equation as a check for (QH) would give
the same results.
SLIDE 254-11
POUNDS OF PARTICULATE PER MILLION BTU
TO THE INLET OF AIR POLLUTION
CONTROL EQUIPMENT
Eq-1
_ (106)(% ash/100) (0.85)
1 HHV
where:
E, = particulate emission rate to the inlet of air polution
control equipment (Ibs/MM Btu)
% ash = coal analysis (as received basis)
0.85* = approximately 85% of the ash is carried by the flue
gas to the air pollution control device
HHV = Higher Heating Value cost analysis (Btu/lb coal) (as
received basis)
NOTE: This emission factor is for pulverized coal fired units.
Spreader stokers and underfeed units have a different
emission factor and are generally less reliable because of a
high degree of variation in stoker operation and maintenance.
M-31
-------
SLIDE 254-12 NOTES
POUNDS OF PARTICULATE PER HOUR
TO AIR POLLUTION CONTROL EQUIPMENT
Eq.1
Pmr = (m.) (0.85)
where:
Pmr = pounds of particulate per hour to the air pollution
control equipment (Ibs/h)
m, = fuel firing rate (measured coal to boiler) (Ibs of coal/h)
% ash = coal analysis (as received basis)
0.85* = approximately 85% of the ash is carried by the flue
gas to the air pollution control device
SLIDE 254-13
POUNDS OF PARTICULATE PER HOUR
TO AIR POLLUTION CONTROL EQUIPMENT
Eq.2
Pmr = (Ep) (QH)
where:
E * = particulate emission rate at the inlet of the control equip-
ment (Ib/MM Btu) (calculated or measured)
QH = total heat input (MM Btu/h) (not calculated from flue
gas flow)
*NOTE: These factors are for pulverized coal fired units. The heat
input can be calculated by any of the previous methods
other than by the use of flue gas flow rate. The results of
particulate mass rate can then be compared with the
measured rate. This comparison is a combination of the
heat input validation and fuel composition comparison.
M-33
-------
SLIDE 254-14 NOTES
POUNDS OF SULFUR DIOXIDE PER MILLION BTU
TO AIR POLLUTION CONTROL EQUIPMENT
Eq.1
HHV
where:
Eg = SO2 emission rate to air pollution control equipment
(Ib SOz/MM Btu)
2 = there are 2 pounds of SO2 generated per pound of
sulfur
% S = coal analysis (as received basis)
0.95 = approximately 95 percent of the sulfur is converted to
sulfur dioxide
HHV = Higher Heating Value coal analysis (Btu/lb coal) (as
received basis)
NOTE: Because of the difficulty in obtaining representtive coal
samples, the average of coal analyses calculated results
should be compared to the average of measured sulfur
dioxide emission results (excluding any suspected outliers).
Comparison on a run by run results is generally not very
consistent.
SLIDE 254-15
POUNDS OF SULFUR DIOXIDE PER HOUR TO AIR
POLLUTION CONTROL EQUIPMENT
Eq.1
Ms = (m.) (0.95) (2)
where:
MS = = pounds of sulfur dioxide per hour to the air pollution
control equipment (Ibs SCVh)
m, = fuel firing rate (measured coal to boiler) (Ibs of coal/h)
% S = coal analysis ( as received basis)
0.95 = approximately 95 percent of the sulfur is converted to
sulfur dioxide
2 = there are 2 pounds of SO2 generated per pound of
sulfur combusted
M-35
-------
SLIDE 254-16 NOTES
POUNDS OF SULFUR DIOXIDE PER HOUR TO
AIR POLLUTION CONTROL EQUIPMENT
Eq.2
Ms = (Es) (QH)
where:
Eg = SOa emission rate to air pollution control equipment
(Ibs SOa/MM Btu)
QH* = total heat input (MM Btu/h) (not calculated from flue
gas flow)
NOTE: The heat input can be calculated by any of the previous
methods other than by the use of flue gas flow rate. The
results of sulfur dioxide mass emission rates can be
compared with measured results. This comparison is a
combination of the heat input validation and fuel composi-
tion comparison.
SLIDE 254-17
EVALUATION OF ORSAT DATA
Eq.1
_ 20.9-%Q2
" %C02
For bituminous coal 1.09 < F0 < 1.19
NOTE: The measured oxygen readings can also be validated by
comparison with the boiler's oxygen monitor used by the
boiler operator to set the excess. Plant personnel should
have a good estimate on the amount of air leakage between
the boiler's continuous oxygen monitor and the sampling
site.
M-37
------- |