DRAFT - DO NOT QUOTE OR CITE
MUNICIPAL WASTE INCINERATOR
AIR POLLUTION CONTROL INSPECTION
U.S. EPA, APTI COURSE 428
U.S. ENVIRONMENTAL PROTECTION AGENCY
STATIONARY SOURCE COMPLIANCE DIVISION
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
SEPTEMBER 1990
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DRAFT vDO NOT QUOTE
OR Cl?£
MUNICIPAL WASTE INQftflERATOR
AIR POLLUTION CONTROL INSPECTION OQURSE
Prepared jtfdr:
U.S. Environmental Protection Agency
stationary Source compliance Division
Office of Air Quality Ptanoifcg andt. Standards
Washington, D.c* *•*
EPA Work Assignment. Manager:
Joyce chandler *
Prepared bys
John Richards
Richards Engineering .
Durham, North Carolina 27705
Under Subcontract to:
i
Entropy Environmentalists, Inc.
Research Triangle Park, North Carolina 27709
EPA Contract No. 68-02-4462
Work Assignment Ko. 118
September, 1990
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Copyright © 1990
Richards Engineering
This manual, or any parts thereof, may not be reproduced in any
form without written permission of Richards Engineering or the
U.S. Environmental Protection Agency
ii
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DISCLAIMER
This manual was prepared by Richards Engineering and Entropy
Environmentalists, Inc. for the Stationary Source Compliance
Division of the U.S. Environmental Protection Agency. It has been
completed in accordance with EPA Contract Number 68-02-4462, Work
Assignment 118. The contents of this report are reproduced herein
as received from the contractor. The opinions, findings, and con-
clusions expressed are those of the authors and.' not necessarily
those of the U.S. Environmental Protection Agency. Any mention of
product names does not constitute endorsement by the U.S. Environ-
mental Protection Agency.
The safety precautions set forth in this manual and presented in
any training or orientation session, seminar, or other presentation
using this manual are general in nature. The precise safety
precautions required for any given situation depend upon and.must
be tailored to the specific circumstances. Richards Engineering
and Entropy Environmentalists, Inc. expressly disclaim any
liability for any personal injuries, death, property damage, or
economic loss arising from any actions taken in relianee~upon this
manual or any training or orientation session, seminar, or other
presentations based on this manual.
The inspection -procedures discussed in this course manual are based
on the proposed revisions to the New Source Performance Standards
for Municipal Waste Incinerators published in the Federal Register
on December, 1989. Possible revisions to the proposed
regulations, under review by EPA at the time this manual was
completed, were not considered. This course material will be
revised as necessary when the NSPS regulations are promulgated.
ill
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iv
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TABLE OF CONTENTS
Page
Disclaimer iii
Course Manual Introduction vii
Program Agenda ix
1. Regulatory Requirements and Inspection Approach 1-1
2. Introduction to Municipal Waste Incinerator
Facilities 2-1
3. Waste Preprocessing 3-1
4. Continuous Emission Monitoring Equipment and
Data " 4-1
5. Evaluation of-Combustion Practices _-^""1
6. Inspection of Electrostatic Precipitators and
Fabric Filters 6-1
7. Inspection of Dry Scrubbers and Wet Scrubbers 7-1
8. Inspection of Nitrogen Oxides Systems 8-1
9. Material Recovery 9-1
10. Operator Certification and Training 10-1
11. Inspection Health and Safety 11-1
Appendix A, Proposed Regulations A-l
Appendix B, Flowchart Preparation for Air Pollution
Source Inspections B-l
Appendix C, Inspection Checklists C-l
Appendix D, Definitions D-l
Appendix E, Acronyms E-l
Appendix F, Bibliography F-l
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vi
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COURSE MANUAL INTRODUCTION
This manual is intended for use in U.S. EPA sponsored courses
concerning air pollution control inspections of municipal waste
incinerators. This course material is based primarily on the manual
titled, "Municipal Waste Incinerator, Field Inspection Manual."
The lecture notes and slides reproduced in this manual are designed
to be a step-by-step discussion of the inspection procedures.
The scope of the course material includes the various types of
compliance requirements included in proposed Subparts Ca and Ea of
the New Source Performance Standards which were published in the
December 20, 1990 Federal Register. Some changes in the specific
inspection procedures may be necessary when the regulations are
promulgated.
COURSE MANUAL ORGANIZATION
The lecture material has been prepared in a format which-parallels
the Field Inspection Manual. However, several modifications were
necessary. The regulatory requirements are presented in Lecture 1
along with an expanded discussion of inspection preparation pro-
cedures. The material in Lecture 1 is used with two VHS videotape
programs listed below.
* Municipal Waste Incinerator Inspection
* Preparation of Flowcharts for Air Pollution Source
Inspections
The municipal waste incinerator tape is a summary of the compliance
issues which must be addressed for sources subject to the revised
NSPS regulations. The program on flowcharting is necessary since
much of the information in the course will be presented using
flowcharts. Copies of these tapes are not included as course hand-
outs. However, limited copies are available from the U.S. EPA Air
Pollution Training Institute. A copy of the manual concerning
flowchart preparation is included as an appendix to the Lecture 1
material.
Introductory material concerning municipal waste incinerators, air
pollution control systems, and pollutant formation mechanisms is
presented in Lecture 2. This information is intended primarily for
agency inspectors who have only limited experience with municipal
waste incinerators.
vii
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The remainder of the lectures follow the general organization of
the Field Inspection Manual. Reference material has been included
in these lecture where necessary in order to clarify the inspection
procedures. A set of review questions has been included at the end
of each of these lectures.
For convenience, copies of the proposed regulations have been
included in the appendix to this manual. Also, a glossary of
acronyms and definitions are provided.
PROGRAM AGENDA
The course is conducted over a three day period. The standard
agenda is presented at the conclusion to this section. Course
instructors are encouraged to modify this agenda as necessary in
order to meet the interests of each specific audience.
COURSE LIMITATIONS
This manual is restricted to technical and health/safety informa-
tion. Legal and administrative aspects of inspections are covered
in detail in various publications such as the Air Compliance
Inspection Manual and the Compliance Enforcement Guidance Manual
(Bibliography).
To the extent possible, this manual has been written to be consis-
tent with EPA policy and inspection guidelines. However, the
information and procedures in this manual should not be considered
as presenting EPA policy or State/local agency policy. Also, these
inspection procedures should not be considered as interpretations
of the NSPS regulatory requirements.
General inspection'health and safety procedures have been included
in this manual. It is not possible to anticipate all site-specific
hazards or combinations of hazards. For this reason, inspectors
must exercise their own judgement in regards to specific inspection
situations. Different or more comprehensive health and safety
procedures may be needed in some cases.
The information provided in this manual will help inspectors to
develop independent and accurate assessments of the sources com-
pliance status. Much of the information will be of value in
evaluating any corrective actions proposed by the source personnel.
However, inspectors should not use the inspection data or obser-
vations to demand or prescribe specific corrective actions or
operating conditions.
viii
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STANDARD AGENDA
MUNICIPAL WASTE INCINERATOR INSPECTION WORKSHOP
Dav 1
Time Topic
8:30 Welcome and Introduction
A. Registration
B. Purpose and Scope
C. Description of Handouts
8:45 Regulatory Requirements and Inspection Approach
A. Proposed Regulations
10:00 Break
10:15 Regulatory Requirements and Inspection Approach
B. Inspection Approach
C. Flowchart Preparation
11:30 Lunch
12:30 Characteristics of Municipal Waste Incinerators
~ and Air Pollution Control Systems
A. Types of Incinerators
B. Air Pollution Control Systems
2:00 Break
2:15 Characteristics of Municipal Waste Incinerators
and Air Pollution Control Systems
C. Pollutant Formation and Destruction Mechanisms
3:00 Waste Preprocessing
4:30 Adjourn
Dav 2
8:30 CEM Systems and Monitoring Data
A. Types of CEMs
B. Inspection of Analyzers and System Conditioning
Systems
10:00 Break
10:15 CEM Systems and Monitoring Data
C. Inspection of Stack- and Breeching-Mounted CEM
Equipment
D. Calculation of CEM Availability
11:30 Lunch
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Standard Agenda
Municipal Waste Incinerator Inspection
12:30 Incinerator Good Operating Practices
A. Carbon Monoxide Monitoring Data
B. Oxygen Monitoring Data
C. Incinerator Exit Gas Temperature and Air Pollution
Control Device Inlet Gas Temperature
D. Bottom Ash Characteristics and Handling
2:00 Break
2:15 Electrostatic Precipitators and Fabric Filters
A. Opacity Monitoring Data
B. Level 2 Inspection Procedures
1. Electrostatic Precipitators
3:15 Break
3:30 Electrostatic Precipitators and Fabric Filters
B. Level 2 Inspection Procedures
2. Fabric Filters -
4:30 _Adjourn_
Dav 3
8:30 Dry Scrubbers and Wet Scrubbers
A. Sulfur Dioxide Monitoring Data
B. Level 2 Inspection Procedures of Dry Scrubbers
9:45 Break
10:00 Dry Scrubbers and Wet Scrubbers
C. Level 2 Inspection Procedures for Wet Scrubbers
10:30 Nitrogen Oxides Emissions
A. Nitrogen Oxides Monitoring Data
B. Level 2 Inspection Procedures
11:30 Lunch
12:30 Operator Training and Certification
1:30 Break
1:45 Waste Material Recovery and Recycle Requirements
2:45 Break
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Standard Agenda
Municipal Waste Incinerator Inspection
Dav 3 (Continued)
3:00 Inspection Health and Safety
A. Inhalation Problems
B. Walking and Climbing Problems
C. Thermal and Chemical Burn Hazards
D. Confined Entry Hazards
4:00 Course Summary and Critique
4:30 Adjourn
xi
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1. REGULATORY REQUIREMENTS AND INSPECTION APPROACH
The inspection procedures presented in this course manual are based
primarily on the proposed Municipal Waste Combustor regulations
published in the Federal Register on December 20, 1990. The speci-
fic regulatory requirements are discussed in this lecture. The
general inspection approach and preinspection procedures are also
addressed.
SLIDE 1-1
REGULATORY REQUIREMENTS
Subpart Ea - New and Modified
Sources
Subpart Ca - Existing Sources
SLIDE 1-1 LECTURE NOTES:
The inspection procedures presented in this course are based
primarily on the proposed municipal waste combustor (MWC)
regulations published in the Federal Register on December 20, 1989.
The use of these proposed regulations as the basis for the
inspection procedures is appropriate because of the following.
* These are the most comprehensive regulations
that will apply to MWC units.
* Both new and existing sources will eventually
be subject to regulations similar to proposed
Subparts Ea and Ca.
* Inspection of existing sources not presently
subject to certain portions of these proposed
regulations can be accomplished simply by
deleting the inapplicable portions of the
inspection.
For the remainder of this course, the Subpart Ca and Subpart Ea
regulations will be referred to as the "proposed regulations."
They are summarized in this lecture. A full copy is provided at
the end of Section 1.
1-1
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Residential
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Block #3-
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Block #1 -
Material Recovery
Unprocessed
Recovered Recovered
Wastes Wastes and
Composted
Wastes
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SLIDE 1-3
TYPES OF COMPLIANCE REQUIREMENTS
* Waste Preprocessing
* Combustion Operating Practices
* Air Pollution Control - Pollutant
Emissions
* Operation certification and
Training
SLIDES 1-2 AND 1-3 LECTURE NOTES:
The proposed regulations have five separate compliance'Issues. The
four that apply "to equipment and emissions oriented subjects are
shown in Slide 1-2. The fifth requirement concerns operator certi-
fication and training. Under each of these five separate topics
there are number of specific requirements. In the remainder of this
lecture, the various compliance requirements are summarized in the
order shown in Slide 1-2.
1-3
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Aluminum Cans
Vehicle Batteries
Industrial Cardboard
Yard Wastes
Comingled Wastes
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Materials
Industries
Residential
Composting
Facility
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Air Pollution
Control System
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Landfill V
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SLIDE 1-5
MATERIAL SEPARATION AND
RECOVERY
* 25% by weight of the
waste stream must be
separated and recovered.
* Combustion permits for
combustible materials
may be obtained due to
temporary economic
constraints.
SLIDES 1-4 AND 1-5 LECTURE NOTES:
The proposed regulations specify that MWC facilities can burn only
processed waste. This is defined to mean that a certain fraction
of the waste stream must be recoverd and recycled.
The material separation and recovery requirements—are to be
achieved by a combination of means. As shown in Slide 1-4, the
total waste stream will be partially reduced by curbsids and
community waste separation programs (streams 6-9). Additional
waste quantity reductions will be achieved in some areas by the use
of Material Recovery Facilities (MRFs). As a net result of the
various programs and facilities, the quantity of waste burned in
the incinerator (stream 2) should be no more than 75% of the total
waste generated by the community.
The material separation and reduction calculations are to be per-
formed on an annual basis. No more than 10% of the 25% waste
eduction may be credited to the difficult-to-measure yard waste
reductions (stream 9) . The remainder of separation requirement (15%
or more) must be due to the recovery of items such as those listed
below and shown in Slide 1-4. This list has been abstracted
directly from the definition of "processed MSW or RDF" in Sub-
section 60.51a.
Paper and papeboard
Ferrous metals
Nonferrous metals
Glass
Plastics
Household batteries
Yard wastes
1-5
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SLIDE 1-6
ANNUAL MATERIAL RECOVERY
REPORTS
must be kept,
lations are
type of
ed
* Separat
requi
was
by "co-operators.
SLIDE 1-6 LECTURE NOTES:
Owners of MWC plants may choose to enter into contracts with owners
of separate material recovery facilities or other recycling pro-
grams in order to_demonstrate compliance with the material separa-
tion and recovery requirements. In" such cases, the owners of the
two separate facilities would be "co-operators" with respect to
these recovery- requirements.- -However,- the—operators of the
material recovery facilities would have no obligations regarding
other requirements included in the proposed regulations.
The regulatory agency would not be responsible for gathering the
material recovery data from the various organizations. A single
report would be submitted by the owner of the MWC alone or in con-
junction with other "co-operators."
1-6
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SLIDE 1-7
MAI
UAL SEPARATION AND
PLAN
[COVERY
The MSW se
Responsible
contractual
Material
Economic
Econom
Dete
re
pth
methods
centives
incentives
quantities
r recycling
haulers
astes
ed and waste combust*
Tcordkeeping and calculation
'procedures
SLIDE 1-7 LECTURED NOTES:
A material 'separation and recovery plan must be submitted in
accordance with the dates specified in the proposed regulations.
The content of this plan would include all of the items in this
slide. This list has been abstracted from the preamble to the
proposed regulations. This plan provides the background material
necessary for the regulatory agency to evaluate the annual reports
submitted by the MWC facility and other "co-operators."
1-7
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SLIDE 1-8
MBUSTION
material
can not be
red
* Apply to
separated
conomically
neration
* Allow
landfi
disposal
be renewed annually
SLIDE 1-8 LECTURE NOTES:
In certain areas of the country, it may be difficult to sell some
type of separated combustible wastes such as newpapers and
plastics. .These.wastes could be burned on a temporary basis if the
owners of the MWC "facility and any ""co-operators" can-demonstrate
that there is no viable market for this material. One of the key
tests of the marketability of the waste stream is a comparison of
the cost of landfilling the material versus the costs involved in
selling the separated material. If landfilling is less expensive,
the agency can permit the MWC facility to burn the separated wastes
for a period up to one year. A new permit application is required
on a yearly basis.
1-8
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SLIDE 1-9
WASTE PREPROC
SLIDE 1-9 LECTURE NOTES:
The proposed regulations(60.59a [b][ll]) prohibit burning of
vehicle batteries because they are a source of lead. These
batteries are defined as any lead acid battery weighing more than
5 kilograms (11 pounds) that is used for essentially any purpose.
Records must be maintained indicating the quantities removed and
recovered on a monthly basis.
There is a separate requirement (60.52a [f]) concerning a program
for household batteries. These are of concern because they
contain mercury, cadmium, and lead.
1-9
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SLIDE 1-10
COMBUSTION OPERATING PRACTICES
* Concern indirect indicators
of MWC organics and MffC metals
* Limit maximum operating rate
SLIDE 1-10 LECTURE NOTES:
Requirements pertaining to the combustion conditions are specified
in 60.52a of the proposed regulations. These requirements have
been included so that the generation of MWC organics and MWC metals
is minimized.
SLIDE 1-11
COMBUSTION PRACTICES REQUIREMENTS
* CO must be maintained below 50
to 150 ppm (corrected to 7% O2).
* Flue gas temperature to the
particulate control device
should be below 830- degrees-
Centigrade (450 F).
* Incinerator operating rate
should be less than tw% of
maximum load. u°
SLIDE 1-11 LECTURE NOTES:
The CO is limited since it is an indirect indicator of the
formation of dioxins and furans (MWC organics) . The flue gas
temperature is limited since research studies have indicated that
additional dioxin and furan compounds can form on the surfaces of
flyash at high temperatures. The flue gas temperature limit also
ensures that volatile metals have condensed on the particles before
the collection device.
1-10
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SLIDE 1-12
CARBON MONOXIDE LIMITS
* Modular units - 50
* Sloped grate mass burn - 100 ppm-
* Fluidized bed - 100 ppm-
* RDF spreader stoker - 150 PPM
Coci/ftDP ISO ?p«*
CO data presented in 4 -hour block
averages (i.e. 4 p.m. to 8 p.m.)
CO data presented on dry basis
SLIDE 1-12 LECTURE NOTES:
The carbon monoxide data must be recorded as four hour block
averages. This is defined in 60. 5 la as follows:
"... all hourly emission rates when the affected
facility is operating and combusting MSW measured
over 4-hour periods from 12:00 midnight to 4 a.m.,
4 a.m. to 8 a.jn. , 8 a.m. to noon, noon to 4 p.m. ,
4 p.m. to" 8 p7nu , and 8 p.m. to 12:00 midnight. " -"
The CO data must also
concentration of CO2) .
SLIDE 1-13
be corrected to 7% O2 (or an equivalent
INCINERATOR/BOILER
OPERATING RATE
* Limited to
of the maximum Crating
* Operating rate measured by means of
the steam generation rate
* Requirement not applicable to units
without heat recovery
VQ^" l^jWMj
SLIDE 1-13 LECTURE NOTES:
Incinerator and boiler operating rates are limited since pollutant
generation increases substantially at higher than maximum unit
loads. The load is measured using the steam rate since this is
more accurate than using either grappler data or long term waste
input weight measurements. The waste moisture content and density
are too variable for these operating rate measurement methods.
1-11
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SLIDE 1-14
POLLUTANT EMISSION
LIMITATIONS
* MWC metals
(as partieulate)
* MWC organics
* MWC acid gases
* Nitrogen oxides
SLIDE 1-14 LECTURE NOTES:
Subpart Ea includes emission limitations and reference test methods
specified for four groups of air pollutants: MWC metals, MWC
organics, MWC acid gases, and nitrogen oxides.
Subpart Ca includes emission guidelines for only three of these
categories, MWC metals, MWC organics, and MWC acid gases. The
emission guidelines for the MWC metals are somewhat different than
the limitations specified in Subpart Ea.
The pollutants listed above are groups of chemicals.
compounds included are listed below.
Th'e specific
MWC Acid Gases
* Sulfur-Dioxide
* Hydrogen Chloride
MWC Organics
* Dioxins
* Furans
Nitrogen Oxides
* Nitric Oxide
* Nitrogen Dioxide
MWC Metals
Any metal in a partieulate form
at the operating temperature
of the control device
MWC organics consist of all the tetra- through octa-substituted
forms of dioxins and furans. The metals include essentially all
metals which can volatilize during combustion.
1-12
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SLIDE 1-15
MWC METALS EMISSIONS
SUBPART 60.52 LIMITATIONS
NEW AND MODIFIED SOURCES
34 mg./DSCM (0.015 gr./DSCF)
Corrected to 7% O2, dry basis;
10% opacity
SUBPART 60.33 GUIDELINE
EXISTING SOURCES >
Same as above
noo
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SLIDE 1-16
MWC ORGANICS EMISSIONS
SUBPART 60.52 LIMITATIONS
MSW < 250 T/Y 75 Nanograms/DSCM
MSW > 250 T/Y 5-30 Manograms/DSCM
SUBPART 60.33 GUIDELINES
MSW > 250 T/Y 125 Nanograms/DSCM
MSW < 250 T/Y 500 Nanograms/DSCM
SLIDE 1-17
MWC ORGANICS EMISSIONS
SUBPART 60.52 LIMITATIONS
RDF < 250 T/Y 250 Nanograms/DSCM
SDBPART 60.33 GUIDELINES
RDF > 2200 T/Y 5-30 Nanograms/DSCM
RDF
250 Nanograms/DSCM
1000 Nanograms/DSCM
> 250 T/Y
< 2200 T/Y
RDF < 250 T/Y
SLIDES 1-16 AND 1-17 LECTURE NOTES:
The emission requirements for MWC organics concern total tetra
through octa-chlorinated dibenzo-p-dioxins and dibenzo-furans. It
should be noted that these are specified in terms of the quan-
tities of these materials and not in terms of toxic equivalents.
1-14
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SLIDE 1-18
MWC ACID GAS EMISSIONS
SUBPART Ea LIMITATIONS
APPLICABILITY EMISSION LIMITATIONS
PLANTS < 250 T/D SO2 - 50% OR 30 ppmv
HC1 - 80% OR 25 ppmv
PLANTS > 250 T/D SO2 - £«$ OR 30 ppmv
HC1 - 95% OR 25 ppmv
SUBPART Ca GUIDELINES
APPLICABILITY EMISSION GUIDELINES
PLANTS > *2tH> T/D SO2 - ;83% OR 30 ppmv
1100 HC1 - JSflt OR 25 ppmv
PLANTS < 2200 T/D
> 250 T/D SO2 - 50% OR 30 ppmv
HC1 - 50% OR 25 ppmv
SLIDE 1-18 LECTURE NOTES:
The emission limitations and guidelines for sulfur dioxide and for
hydrogen chloride are specified in alternative formats*'a percent-
age reduction, or a concentration. The least stringent of the two
can be used. All of the emission limitations and guidelines in the
proposed regulations are corrected to 7% oxygen.
SLIDE 1-19
NITROGEN OXIDES EMISSIONS
\<&o
SUBPART Ea - rf2*/TON2«O ppmv
SUBPART Ca - NONE
SLIDE 1-19 LECTURE NOTES:
Nitrogen oxides will be regulated for new, large MWC facilities
having a total plant capacity of greater than 250 tons per day.
No specific emission limitation has been proposed. However, a
range of 120 to 200 ppm was listed in proposed Subsection 60.55a.
No guidelines concerning nitrogen oxides were included for existing
sources.
1-15
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SLIDE 1-20
PERFORMANCE TEST METHODS
POLLUTANT
REFERENCE TEST METHOD
MWC Metals
opacity
MWC organies
Sulfur Dioxide
Hydrogen Chloride
Nitrogen Oxides
Carbon Monoxide
oxygen
5
9
23
19
26
19
Not Specified
Not Specified
APPLICABLE TIME
PERIOD
i MooV
6 Minute
o eo*c
24 Hour Daily /^Avera§e
~ 1 MooC -^ jifo ndni,
24 Hour Daily /(Average
4 Hour Block Average
4 Hour Block Average^
SLIDE 1-20 LECTURE NOTES:
These reference test methods involve a combination of manual stack
sampling techniques and continuous emission monitoring techniques.
Sulfur dioxide, nitrogen oxides, and carbon monoxide are to be
determined.usingJthe CEMs. These instruments must conform with the
Performance 'Specifications of 40 CFR Part 60 Appendix-A:
Manual stack sampling tests are required for MWC metals, MWC
organies and HC1. For these three categories of pollutants, the
required frequency of testing is a function of the capacity of the
overall facility. Methods 23 and 26 have been developed
specifically for MWC facilities subject to Subparts Ea and Ca.
They were also proposed in the December 20, 1989 Federal Register.
SLIDE 1-21
STACK TEST FREQUENCY
PLANTS > 250 T/D Annual
HdL
SLIDE 1-21 LECTURE NOTES:
Plants equal to or less than 250 tons per day capacity may test
once every three years if there have been three consecutive annual
tests which demonstrated compliance.
1-16
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SLIDE 1-22
OPERATOR CERTIFICATION
AND TRAINING
* Chief facility operators and
shift supervisors must have
current provisional or
operators certificates.
* All employees must be trained
on an annual basis.
* An Operation and Maintenance
Manual must be prepared for
the plant.
SLIDE 1-22 LECTURE NOTES:
The proposed regulations and some existing State regulations
include requirements for operator certification and training. The
proposed requirements presented in Section 60.57a are shown in
Slide 1-22. Air pollution agency inspectors will probably have a
role in confirming that MWC plants are in compliance.
1-17
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A - Unprocessed Waste Weight Data
B - Recovered Waste Weight Data
C - Processed Waste Weight Data and Characteristics
D - Combustion System Flue Gas Temperature,
CO Concentration and 02 Concentration
E - SO? Concentration, NOx Concentration/
02 Concentration, and Opacity Data
Treated Flue Qas
Air Pollution Control
,
Partlc.
*t Control
Device
Block #3-
Block #2 - Waste Processing Combustion
Block #1 -
Material Recovery
Untreated
Flue
Qas
Unacceptable Waste
Residential
Compost
Recovered Recovered
Wastes Wastes and
Composted
Wastes
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SLIDE 1-24
INSPECTION APPROACH
* Waste preprocessing
* Combustion system practices
* Emission limitations
* Operator training
SLIDE 1-23 AND SLIDE 1-24 LECTURE NOTES:
The inspection procedures have been arranged based on the struc-
ture of the proposed regulations. On-site observations would begin
in the waste receiving/preprocessing area and proceed co-currently
through the four boxes shown in Slide 1-23. Operator training
would be addressed following the equipment oriented inspection
steps shown in Slide 1-23.
There is a logical focal point for each of the equipment and
waste material oriented issues shown in Slide 1-23. For example,
the adequacy of the waste preprocessing activities can be evaluated
initially by checking the characteristics of the waste stream being
charged to the incinerator. The performance of the air pollution
control systems is evaluated first based on the CEM data.
SLIDE 1-25
INSPECTION PROCEDURES
* Primary
* Follow-up
SLIDE 1-25 LECTURE NOTES:
The Inspection steps have been divided into to two categories:
"primary" steps that are performed during each inspection, and
"follow-up" steps that are performed only when necessary. The time
savings inherent in this approach is important considering the very
comprehensive nature of the MWC regulations. This allows the
inspector to concentrate on any chronic or emerging compliance
problems while on-site rather than completing an arbitrary and
lengthy checklist. This also minimizes any inconvenience to plant
personnel due to the time requirements of the inspection.
1-19
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SLIDE 1-26
INSPECTION CHECKLIST
General Operating Conditions
Waste preprocessing
* Primary
* Follow-up
combustion System Operation
* Primary - GEM Systems
* Primary - operating Data
* Follow-up
Air Pollution Control Systems
* Primary
* Follow-up . .
Operator Training/Certification
SLIDE 1-26 LECTURE NOTES:
An inspection checklist has been prepared for illustrative
purposes. A complete copy is enclosed in this section of the
course manual and the outline of the checklist is presented in
Slide 1-26. This checklist has been divided into separate
sections, one for each of the major compliance issues listed
earlier. Within each one of the sections, the information/data
entries have been listed as "primary" and as "follow-up."
The checklist is designed to serve as the inspection report as long
as the facility is determined to be in compliance by the inspector
in conjunction with the agency management and legal staff. This
would save the significant time often needed to prepare narrative
reports for routine situations. If noncompliance is suspected, the
checklist would serve as a useful tool in preparing an enforcement
recommendation.
The initial section of the checklist includes the data necessary to
document that the facility is operating in a representative
fashion. This data would be entered during the preinspection
meeting with plant personnel.
There is space provided for data concerning three separate
incinerator systems at a single plant. If there are more units, an
additional form would be necessary.
1-20
-------
SLIDE 1-27
PREINSPECTION PREPARATION
* Review all quarterly
emission reports and
GEM Q/A reports.
* Review annual material
recovery reports
* Review combustion permits
* Review complaints and
correspondance files
* Review equipment flowcharts
and health/safety equipment
requirements
* Review confidentiality
determinations
SLIDE 1-27 LECTURE NOTES:
Preparation for MWC inspections should, at a minimum, consist of
the steps listed in this slide. It is important to review the
emissions reports and CEM Q/A reports so that possible issues can
be specifically addressed during the inspection. Questions may
also be derived from a review of recent complaints concerning the
facility.
Flowcharts of the combustion system, air pollution control system,
CEM instrument systems, and general waste processing/handling
system should be reviewed. Copies of these should be taken along
to facilitate the inspection.
A separate list should be maintained of any data or information
which is considered confidential. This could include, but not be
limited to, proprietary combustion equipment, CEM sample condition-
ing systems, or air pollution control device components. Any data
or observations obtained concerning confidential material should be
obtained and handled in accordance with the agency's procedures.
1-21
-------
SLIDE 1-28
ON-SITE INSPECTION
AGENDA
Preinspection Meeting
Review of Material
Recovery Report
Waste Preprocessing
Combustion System Operation
* OEM systems
* Equipment Inspection
Air Pollution Control
Equipment
Post Inspection Meeting
SLIDE 1-28 LECTURE NOTES:
The inspection of MWC units starts and concludes with meetings with
the plant personnel. The subjects covered in these meetings are
discussed in EPA policy guidelines. Any records or reports
necessary are requested at this time.
The combustion equipment evaluation begins with an inspection of
the CEM system. This is necessary to confirm that the instruments
are working properly and that the emissions reports submitted
previously contain accurate data. The CEM systems must be
evaluated at this time because CO data is one of the primary
combustion system operating parameters.
Performance of the air pollution control system is evaluated using
primarily the opacity, sulfur dioxide, and nitrogen oxides CEM
data. The evaluation of the equipment itself is inspected to the
extent necessary to.
* Document that the system is operating in a representative
manner,
* Obtain baseline data, and
* Follow-up on any suspected compliance problems.
1-22
-------
SLIDE 1-29
DATA EVALUATION
* Direct comparison to
Regulatory limits
* Evaluation of shifts
from site-specific
baseline levels
SLIDE 1-29 LECTURE NOTES: .
The inspection data is evaluated by the two procedures listed
above. An example of a direct evaluation is the comparison of the
observed particulate control device inlet gas temperature to the
regulatory limit of 230 degrees Celsius. An example of a baseline
evaluation is illustrated in the slide below.
1-23
-------
SLIDE 1-30
BASELINE EVALUATION
PRESENT BASELINE
DATA DATA
Average Opacity 15 3-5
Inlet Gas Temp. F. 385 370 - 420
Outlet Gas Temp. F. 341 360 - 420
Temperature Drop Across
the ESP, F. 34 5 - 25
30 - 36
125 - 300
60
Inlet Field, Sec. Voltage, kV 27
Inlet Field, Sec. Current, mA 300 izs -
inlet Field Spark Rate, #/Min. 0-2 10 -
Outlet Field, Sec. Voltage, kV 22
outlet Field, Sec. current, mA 300
Outlet Field Spark Rate, #/min. 0-2
30 - 38
150 - 300
0-10
Incinerator-CO, ppm - 35 Sj^
Incinerator Oxygen, % 11 9-12
SLIDE 1-30 LECTURE NOTES:
A baseline comparison is used to evaluate operating parameters that
indirectly affect compliance. These evaluations help determine if
conditions have shifted to the extent that compliance problems may
exist. They also help to identify fundamental reasons for the
shifts. This information is useful when reviewing the corrective
actions proposed by the plant operators.
In the example case shown above, there is an apparent air infil-
tration problem combined with a decay in the performance of the
first ESP field. This shift could be due to water or acid vapor
condensation on one or more support insulators in this first field.
1-24
-------
SLIDE 1-31
INSPECTION PREPARATION
SLIDE 1-31 LECTURE NOTES:
There is limited on-site time available for evaluation of the
numerous compliance issues involving the MWC regulations. Agency
inspectors should carefully review the reports submitted by the
plants so that this time can be devoted to the specific issues
which may become the subject of negotiation between the source and
the agency or the subject of litigation due to noncompliance.
SLIDE 1-32
REVIEW OF
EMISSION REPORTS
* Completeness and timeliness
* Frequency and severity of
exceedences of applicable
standards
* Adequacy of corrective actions
* Compliance issues
* Days and other time periods of
special interest
SLIDE 1-32 LECTURE NOTES:
Quarterly reports are required concerning the sulfur dioxide,
nitrogen oxides, carbon monoxide, and opacity data. These reports
should be carefully reviewed before the inspection to determine if
there are any compliance issues that warrant follow-up evaluation
while on-site. The limited on-site time available should be
focused on the issues which may become the subject of negotiations
or litigation in the future.
Days and other time periods of special interest should be noted so
that additional combustion system and air pollution control system
data can be obtained for times in which standards were exceeded.
1-25
-------
SLIDE 1-33
OTHER COMPLIANCE ISSUES
* Incinerator or boiler load levels
* Partieulate control device inlet
gas temperature
oA
SLIDE 1-33 LECTURE NOTES:
The MWC facility is required to submit data concerning the inciner-
ator load levels (steam rate data) and the particulate control/
device inlet gas temperatures. Any compliance problems indicated
by this data should further evaluated while on-site.
SLIDE 1-34
PERFORMANCE TESTS
* Particulate matter
* Dioxin/furans
* Hydrogen chloride
SLIDE 1-34 LECTURE NOTES:
Performance tests must be submitted on a yearly basis for the three
pollutants listed in Slide 1-34. Inspectors should review these
tests for the previous several years. The on-site inspection
should emphasize compliance problems.
If the unit has remained in compliance, the data contained in the
emission test report and in the inspector's test observation notes
provide useful baseline data.
1-26
-------
SLIDE 1-35
CEM QUALITY ASSURANCE REPORTS
* Requirements apply to sulfur
dioxide, nitrogen oxides, and
carbon monoxide monitors.
* Daily calibration drift tests
must be performed.
* Quarterly accuracy assessment
tests must be conducted.
SLIDE 1-35 LECTURE NOTES:
The CEM data for sulfur dioxide, nitrogen oxides, carbon monoxide,
and opacity is used as one of the main sources of information in
determining compliance. The quality assurance records submitted on
a quarterly basis should be reviewed to check for any major
problems with this data.
SLIDE 1-36
FLOWCHARTS
* combustion systems
* Air pollution control systems
* Waste handling and preprocessing
systems
* CEM systems
SLIDE 1-36 LECTURE NOTES:
Before leaving for the MWC facility, inspectors should review the
agency's files. Flowcharts made during previous inspections or
submitted by the plant should be examined. If possible, copies of
these drawings should be taken along on the inspection.
The flowcharts can be prepared by a variety of techniques. One
possible approach is discussed in a manual titled, "Flowchart
Preparation for Air Pollution Source Inspections" which has been
included in the Appendix to this manual. The procedures discussed
in this manual are illustrated in the videotape shown as part of
this lecture.
1-27
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SLIDE 1-37
HEALTH AND SAFETY EQUIPMENT
Safety glasses
Safety shoes
Hard hat
Respirators - Jt
Hearing protection
Gloves
SLIDE 1-37 LECTURE NOTES:
Prior to leaving for the inspection, agency personnel should deter-
mine what personal protection equipment is necessary. All of this
equipment should be obtained and examined to ensure that it is in
good condition. Agency personnel should not borrow personal pro-
tection equipment from the plant.
As part of the preinspection file review, inspectors should deter-
mine if there are any unusual health and safety hazards which could
affect the.inspection scope. These should be discussed with agency
supervisors and with MWC plant management personnel prior to begin-
ning the field work.
1-28
-------
REVIEW QUESTIONS - REGULATORY REQUIREMENTS AND INSPECTION APPROACH
Directions: Select the answer or answers which are correct.
1. The inspector discovers a vehicle battery in the waste-being
charged to the incinerator. Would this be a violation of the
proposed NSPS regulations?
a. Yes. Vehicle batteries are specifically prohibited.
b. Yes. Vehicle batteries contributed to increased
lead emissions.
c. No. A single battery can penetrate the preprocessing
sorting procedures.
2. A community has determined that 17% of the total waste stream
is yard wastes. Can this value be used in calculating the
25% material separation/recovery requirement, if the community
has instituted a strict program prohibiting curbside pick-up
and encouraging residential composting?
a. Yes
b. No
3. A modular incinerator has the following CO emissions data
expressed as hourly (8 a.m. means 7 a.m. to 8 a.m.-)* averages
corrected to 7% oxygen. Is this unit in compliance with the
proposed NSPS regulations?
S3
7 a.m.
8 a.m.
9 a.m.
10 a.m.
11 a.m.
12 noon
83 ppm
64 ppm
53 ppm
54 ppm
21 ppm
18 ppm
1 P
2 P
3 P
4 p
5 p
6 p
.m.
.m.
.m.
.m.
.m.
.m.
8
34
78
64
71
93
ppm
ppm
ppm
ppm
ppm
ppm
a. Yes
b. No
What is the minimum incinerator or boiler temperature allowed
by the proposed NSPS regulations?
a. 1200 degrees Fahrenheit
b. 1400 degrees Fahrenheit
c. 1600 degrees Fahrenheit
d. 1800 degrees Fahrenheit
e. 2000 degrees Fahrenheit
Must MWC operators conduct daily calibration drift tests and
quarterly accuracy tests on the CEMs?
(a) Yes
b. No
1-29
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2. INTRODUCTION TO MUNICIPAL WASTE
INCINERATOR FACILITIES
This lecture concerns the background information necessary to
understand the regulatory requirements and inspection procedures.
It is intended primarily for regulatory agency inspectors who have
field experience with other types of combustion sources, but who
have not had an opportunity to evaluate municipal waste facilities
recently.
SLIDE 2-1
SLIDE 2-1 LECTURE NOTES:
The performance of all combustion systems is dependent on fuel
quality. Municipal waste has several undesirable characteristics
which must be considered when designing and operating a MWC
facility. These include low heating value, low ash fusion
temperature, and high ash/residue content. The waste character-
istics are also highly variable geographically and temporally.
There are substantial differences from plant-to-plant with regard
to fuel-related problems due to the extent of preprocessing.
Plants utilizing wastes which have been processed in a material
recovered facility (such as shown in Slide 2-1) have higher quality
and easier-to-manage fuels.
2-1
-------
SLIDE 2-2
SLIDE 2-2 LECTURE NOTES:
The combustion characteristics
of municipal waste are compared
with bituminous coal to illus-
trate the fuel-related problems.
HEATING VALUE - The heating
value of the waste is usually in
the range of 3,000 to 5,000
Btu/Lb. This is 20% to 50% of
the typical values for bit-
uminous coal. This means that
the quantity of fuel necessary
to produce a pound of steam is
2 to 5 times greater than it is
for a coal-fired boiler.
In addition to the lower average
heating value, municipal wastes
have considerable temporal
variability in heating value.
Wastes with a large plastics and
paper content can have high
heating values and wastes composed mainly of yard wastes can have
a very low heating value. Substantial variations in waste charact-
eristics can occur in short time periods.
FUEL SIZING - MWC units have greater fuel sizing variability
than coal-fired boilers. This can affect the ability to maintain
proper air-fuel distribution in some types of incinerators.
ASH FUSION TEMPERATURE - Due primarily to the presence of glass,
the temperature at which the ash in the incinerator becomes fluid
or "sticky" is much lower for MWC units than it is for coal-fired
boilers. The variability of the waste composition and the com-
plexity of ash chemistry makes it difficult to accurately predict
this temperature. Low ash fusion temperatures can lead to a
variety of problems including slagging of the furnace walls (and
instrument probes) clinker formation, and pluggage of the grates.
Even coal-fired boilers have ash fusion problems, and they operate
with ash fusion temperatures of 2100 to 2500 degrees Fahrenheit.
This is well above the 2000 degree level possible in MWC units.
SULFUR, CHLORIDE/ AND NITROGEN CONTENT - The concentrations Of the
elements in the waste stream which are converted to pollutants such
as sulfur dioxide, hydrogen chloride, and nitric oxide are highly
variable. The air pollution control systems must be capable of
responding to frequent, short term changes in the pollutant levels.
2-2
-------
SLIDE 2-3
TYPES OF COMBUSTION SYSTEMS
SLOPED GRATE
* Reciprocating Grate "
* Rotary Combust or »
ROTARY KILN
MODULAR
* Starved Air
* Excess Air
SPREADER STOKER
FLUIDIZED BED
* Bubbling Fluidized Bed
* Circulating Fluidized Bed
SLIDE 2-3 LECTURE NOTES:
There are a variety of combustion systems used for waste incinera-
tion. Most existing units are sloped grate, modular, and spreader
stoker type systems. The sloped grate and modular units are "mass
burn" systems in that there is minimal waste preprocessing prior to
the combustion system. Spreader stoker type boilers only use RDF
which is a fuel processed to improve heat value and to improve fuel
sizing.
SLIDE 2-4
MWC FACILITY CAPACITY
SMALL < 250 TODS/Day -
LARGE > 250 Tons/Day
REGIONAL > 2200 Tons/Day
SLIDE 2-4 LECTURE NOTES:
The type of combustion device used depends partially on the overall
size of the MWC facility. Modular units are limited mainly to the
small plants. Sloped grate incinerators and spreader stoker boil-
ers are used mainly in the large and regional size facilities. It
should be noted that the proposed regulations are written in terms
of total facility size, not individual incinerator size.
2-3
-------
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SLIDE 2-6
OVERFIRE AIR (~\- •
NOZZLES ^~
REFRACTORY ARCH
WASTES
<- -BACK WALL
OVERFIRE AIR
MANIFOLD
NOZZLES
UNOEHGHATE
PLENUM '
tAIR FROM FORCED DRAFT FAN
order \\re. CX\r
Slide 2-6. Undergrate Plenums
SLIDES 2-5 AND 2-6 LECTURE NOTES:
Slide 2-5 illustrates some of the major components of a sloped
grate type incinerator. An expanded view of the undergrate plenums
is shown in the enlarged sketch above.
The wastes are charged by a overhead crane. As the wastes enter
the incinerator they are dried and heated by the radiant energy
from the refractory arch and by the undergrate air in the first
plenum. Active combustion occurs on the middle grates. Volatile
matter is released and the ash and char continue to burn on the
grates. Overfire air nozzles across the front and back walls
provide the oxygen and turbulence necessary to ensure combustion of
the volatile matter in the furnace area of the incinerator.
The air flows through the undergrate plenums are adjusted to pro-
vide the desired air-fuel ratios and also to maintain adequate air
flows through the fuel-ash bed. The undergrate air flows are
adjusted by dampers.
2-5
-------
OGTAUO SKETCH OF
ROTARY OOMBUBTOR
- MTERN AL WATER TUBE ORATE
-SEALS
10
I
CONTINUOUS
EMISSION
MONITORS
(CEMS)
I\1\J\I\IM\IM\I\I\1\I\
AIR POLLUTION
CONTROL DEVICE
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-------
SLIDE 2-7 Lecture Notes:
In a rotary combustor combustion occurs in a rotating cylinder with
an internal water tube grate. There are several undergrate and
overfire air plenums to maintain proper fuel-air ratios throughout
the incinerator. There is a separate sloped grate downstream-of the
rotary combustor for burnout of the bottom ash. There is also a
large, water tubed lined furnace area to complete combustion of
volatile compounds and carbon monoxide.
Both of the incinerators shown in slides 2-5 and 2-7 are "mass
burn" units. Preprocessing of the wastes is limited to the removal
of items which are too bulky to charge or which would cause toxic
emissions.
There are several fans on each of these incinerators. The flue gas
generated during combustion is drawn from the incinerator by the
induced draft fan. This can be located directly after the combus-
tion device (as shown in Slides 2-6 and 2-8) or downstream of the
air pollution control system. The operation of the induced draft
fan is controlled to maintain a static pressure in the incinerator
furnace area of approximately -0.05 to 0.020 inches. The forced
draft fan is used to supply combustion air to the undergrate area
and the overfire air nozzles. Only a single forced draft fan has
been shown in both slides. In some plants separate forced draft
fans are used for" undergrate and overfire air supplies,"-
The heat exchange equipment shown in Slide 2-7 (hypothetical plant)
includes a superheater, a convective tube banks, an economizer, and
an air preheater. The economizer is used to heat the boiler feed
water returning from the turbine. The flue gas leaving the
economizer is generally in the range of 600 to 750 degrees Fahren-
heit. The air preheater is used to recover sensible heat from the
flue gas. The exit gas temperature from the preheater is usually
350 to 400 degrees Fahrenheit.
2-7
-------
SLIDE 2-8
SLIDE 2-8 LECTURE NOTES:
The charging end of a rotary kiln incinerator is shown in this
photograph. The kiln rotates on a intermittent basis in order to
expose fresh fuel to the heat and air. Due to the frequent move-
ment, tightly packed wastes can be burned well.
Combustion occurs in the refractory lined kiln and in a down-
stream refractory lined secondary combustion chamber. Relatively
uniform combustion temperatures are possible since there are no
boiler tubes in the active combustion areas. This minimizes the
formation of partial oxidation products such as dioxins and furans
in cold zones of the incinerator furnace.
SLIDES 2-9 AND 2-10 LECTURE NOTES:
Slide 2-9 shows the duct leading from the secondary combustion
chamber to the waste heat boiler. The combustion exit gas tempera-
ture is monitored at this location. The unit operating rate is
determined based on the steam flow from the waste heat boiler shown
in the center of Slide 2-9.
An auxiliary burner on the secondary combustion chamber is shown in
Slide 2-10. This is operated only during startup or any other
period when the gas temperature in this chamber is too low.
2-8
-------
SLIDE 2-9
SLIDE 2-10
2-9
-------
SLIDE 2-11
SLIDE 2-11 LECTURE NOTES:
The burner side of the rotary kiln is shown in Slide 2-11. The
burner, shown on the right of the slide, is not used during routine
operation. It is necessary for startup.
An observation hatch (in the middle of the photograph) is used for
observing combustion conditions. However, inspectors make these
observations only to identify any fuel-ash bed distribution prob-
lems, and this is not an issue in the case of rotary kilns. For
this reason, this hatch would not normally be used by inspectors.
There is a large access hatch on the right side of the burner hood.
This is used to remove any oversized material which was inadvert-
ently charged. There is an internal screen within the kiln to
convey this large, noncombustible material to the collection point.
The bottom ash from the kiln is quenched in a pit directly below
the burner end of the kiln. There are several locations along the
quenched ash conveyor where the ash characteristics can be
observed.
2-10
-------
SLIDE 2-12
•AUXILIARY OAS-FIRED
BURNER (USUALLY OFF)
BURNER FAN
(USUALLY ON)
Slide 2-12. Modular Incinerator
SLIDE 2-12 LECTURE NOTES:
The basic features of a modular incinerator are shown in this
slide. The waste material is charged into the side of the primary
chamber by means of a hydraulic ram. During combustion, the fuel
and ash move downward due to the intermittent movement of two
internal hydraulic rams in the bottom of the primary chamber. The
waste rolls and falls approximately 1 foot as it pass over each of
these rams. This disturbs packed material and exposes fresh fuel
to the heat and air necessary to promote combustion.
In the primary chamber, the wastes are pyrolyzed. Ash and char
pass into the ash quench pit. Volatile matter released from the
fuel pile passes into the secondary chamber where oxidation is
completed.
The gas leaving the primary chamber is normally 1100 to 1400
degrees Fahrenheit. The secondary chamber exit gas temperature is
usually 1700 to 2000 degrees Fahrenheit.
Combustion air is partially supplied by a forced draft fan. This
air is injected through nozzles mounted on the hydraulic rams.
Some additional combustion air is often supplied by a gas recycle
duct (not shown) from the secondary chamber to the primary chamber.
2-11
-------
SLIDE 2-13
SLIDE 2-13 LECTURE NOTES:
This slide shows the primary chamber of a modular incinerator
during an outage. The charging area and the first hydraulic ram
are in the center of this photograph. One of the four underfire
air nozzles has been removed for repair.
It is apparent in this slide that the primary chamber is entirely
refractory lined. The heat radiated by this refractory helps to
dry and ignite the waste charged to the primary chamber. This
refractory also helps maintain the intended flue gas temperatures
throughout this chamber.
SLIDES 2-14 AND 2-15 LECTURE NOTES:
This is a side view of the secondary chamber burner. This is used
during startup and whenever the exit gas temperature is below 1600
degrees Fahrenheit. However, the fan for the burner is normally
operated in order to supply the combustion air needed in the
secondary chamber.
Slide 2-14 shows the flue gas recirculation fan which pulls gas
from the discharge side of the secondary chamber and injects it
into the primary chamber (not shown on sketch included with Slide
2-12) . This recirculation loop is needed to maintain the sub-
stoichiometric conditions in the primary chamber.
2-12
-------
SLIDE 2-14
SLIDE 2-15
2-13
-------
SLIDE 2-16
Steam
Drum
NOTE:
Sootbtowers not shown
RDF
Distribution
Air
Cinder
Reinfection
Line
NOTE:
Grate air seals
not shown
Undergrate
Air Plenums
Slide 2-16. Spreader Stoker Boiler
2-14
-------
SLIDE 2-17
SLIDES 2-16 AND,2-17 LECTURE NOTES:
©ne type of spreader stoker boiler used for burning refuse derived
fuel (RDF) is shown in Slide 2-16. This unit has a pneumatic dis-
tributor for injecting the RDF into the boiler. The fuel burns on
a grate which is moving forwards at a rate of 5 to 20 feet per
hour. The example unit shown in Slide 2-16 has five separate
undergrate air plenums for delivery of underfire air. In other
commercial units (including coal-fired) spreader stokers, there is
a single undergrate air plenum.
Slide 2-17 shows one of several RDF feeders across the front wall
*f the boiler. There are two to four feeders depending on the size
of the unit. The boiler shown in Slide 2-17 also has coal feeders
(not shown in Slide 2-16) for times when RDF is unavailable. The
coal is mechanically distributed using a belt feeder and a rotor.
Volatile matter is released from the RDF during the early stages of
combustion on the grates. The volatile matter is oxidized in the
middle and upper zones of the boiler. There are overfire air
nozzles across the front and back walls to introduce the air
necessary to mix and oxidize the volatile matter above the grates.
The char which remains after the volatile matter evolves continues
to burn as the grate moves forward. The ash and char are then
dumped into the ash pit below the front of the boiler.
2-15
-------
SLIDE 2-18
SLIDE 2-18 LECTURE NOTES:
The boiler bottom ash is wetted in a quench pit and removed by
means of the conveyor shown in this slide. This material should
have a loss-on-ignition value averaging less than 10% by weight.
This means that most of the combustible matter has been burned out
of the ash and residue.
Loss-on-ignition tests are usually performed only on an infrequent
basis. These tests are conducted by commercial laboratories
serving the utility industry.
2-16
-------
SLIDE 2-19
SLIDE 2-19 LECTURE NOTES:
The uniformity of the fuel-ash bed on the grates is important in
this type of combustion system. The undergrate air flow rates are
highest though the thin areas of the fuel-ash bed. The thick areas
may not receive adequate undergrate air and therefore operate in a
fuel-rich condition. This results in the formation of partially
oxidized compounds which must be further reacted in the upper areas
of the boiler.
This slide shows some of the observation hatches on each side of
the boiler. These are used by the operators to confirm that the
RDF (or coal) distribution is acceptable.
It should be noted that some variation in fuel-ash distribution is
to be expected. Slight variations do not cause problem since the
grates have enough air flow resistance to maintain relatively
uniform air flows through each area. However, there should not be
large piles in localized areas and exposed grates in others.
2-17
-------
SLIDE 2-20
Steam
Drum
SLIDE 2-23
SLIDE 2-22
NOTE:
An Heat Exchange
Equipment Not Shown
Ash & Fuel
Bed
Traveling
Cinder
Reinjection
Line
NOTE:
Grate Air Seals
Not Shown
SLIDE 2-21
Slide 2-20. Views Shown in Slides 2-21 to 2-23
SLIDES 2-20 TO 2-23 LECTURE NOTES:
The combustion air is supplied through the set of undergrate
plenums shown in Slide 2-21 and the overfire air nozzles on the
front and back walls of the boiler (see Slide 2-20) . The overfire
air is injected into the boiler through a set of large diameter
nozzles, one of which is shown in Slide 2-22.
Partially burnt char is reinjected back into the boiler by means of
a chute which terminates at the back wall. An interior view of
this chute is shown in Slide 2-23.
2-18
-------
SLIDE 2-21
SLIDES 2-22 AND 2-23
2-19
-------
SLIDE 2-24
AIR POLLUTION
CONTROL SYSTEMS
SLIDE 2-24 LECTURE NOTES:
The basic characteristics of the numerous types of air pollution
control systems are discussed in the next section. More detailed
information is available in U.S. EPA Courses #413 and #415 and in
EPA's Background Information Document for the MWC industry.
SLIDE 2-25
CONTROL SYSTEMS
SMALL PLANTS
Electrostatic Precipitators
Wet Ionizing Scrubbers
Dry Injection Type Dry
Scrubbers
SLIDE 2-25 LECTURE NOTES:
Small MWC plants are defined in the proposed regulations as having
a total plant capacity of less than 250 tons per day throughput.
These types of facilities generally have one of the types of air
pollution control systems listed above.
The electrostatic precipitators serve as stand-alone devices for
the removal of particulate matter. The wet ionizing scrubber and
the dry injection scrubbers are capable of removing both acid gases
and particulate matter.
2-20
-------
SLIDE 2-26
TYPES OF AIR POLLUTION
CONTROL SYSTEMS
LARGE PLANTS AND REGIONAL PLANTS
Spray Dryer Type Dry Scrubbers
with Fabric Filters
Spray Dryer Type Dry Scrubbers
with Electrostatic Precipitators
Combination Spray Dryer and Dry
Injection Type Scrubbers with
Fabric Filters
Selective Catalytic NOX Reduction
Systems
Selective Noncatalytic NOX
...Reduction systems
SLIDE 2-26 LECTURE NOTES:
The first three types of control systems listed above are alter-
native approaches for combined acid gas and particulate control.
They differ in the means used to atomize the alkaline slurry used
to absorb and adsorb sulfur dioxide and hydrogen chloride. The
particulate control device used for collection of the flyash and
alkali particles is also different.
The last two types of control systems listed in this slide are
competing types of nitrogen oxides control units. Both of these
use a reducing agent for converting the nitrogen oxides generated
in the combustion device to molecular nitrogen. The nitrogen
oxides control devices are used in series with dry scrubbers for
acid gas and particulate control.
2-21
-------
en
f
HIGH VOLTAGE FRAME
COLLECTION PLATE
GAS DISTRIBUTION
SCREEN
M
I
to
M
GAS
INLET-
TRANSFORMER
RECTIFIER SET «1 y
HIGH VOLTAGE
m
L 3
* \.
k
\
I
^
fr
1 ANTI-SV
^,1- INSULA
-TRANSFORMER
RECTIFIER SET 12
HIGH VOLTAGE
SHAFT INSULATOR
SUPPORT PLATE
SUPPORT SPRINGS
HIGH VOLTAGE FRAME
SUPPORT INSULATORS
D
M
N)
I
10
-J
OUTLET
PLENUM
COLLECTION
PLATE RAPPERS
HOPPER
-------
SLIDE 2-27 LECTURE NOTES:
A side view of an electrostatic precipitator is shown in Slide 2-
27. It consists of a large number of discharge electrodes and
collection plates arranged in parallel rows along the direction of
gas flow. The collection plates are grounded along- with the
hoppers and shell of the precipitator. The discharge electrodes
are energized to negative voltages ranging between 15,000 and
50,000.
The gas velocity through the numerous parallel passages of the
precipitator ranges from 3 to 6 feet per second. This is an order
of magnitude lower than the velocity in the duct leading to the
unit. The deceleration is accomplished in the inlet chamber at the
front of the precipitator. There are normally one or more
perforated plates in the inlet chamber to achieve as uniform gas
distribution as possible.
The high voltage for the discharge electrodes is provided by
transformer-rectifier sets (termed T-R sets). They convert
alternating current from a 480 volt supply to direct, pulsed
current at very high voltages. Each T-R set energizes an
independent field of the electrostatic precipitator. The T-R sets
are roof-mounted since it is difficult to run high voltage lines
for long distances.
In municipal waste incinerator applications, there are normally 2
to 4 fields in series along the direction of gas flow. The unit
shown in slide 2-27 has two fields. Each of the fields in a
precipitator removes 60 to 80% of the incoming particulate matter
to that field.
A series of insulators is necessary to keep the discharge elec-
trodes and collection plates properly spaced. The high voltage
frame support insulators above the hot roof are used to support the
weight of the high voltage frames and electrodes. Anti-sway
insulators at the bottom are necessary to prevent movement of the
high voltage frames toward the collection plates. At least two
support insulators and two anti-sway insulators are needed for each
field. Purge air blowers and insulator heaters are used to keep
dust and moisture off of the high voltage frame support insulators.
Alignment of the collection plates and discharge electrodes is very
important. In MWC applications, the plate-to-discharge electrode
spacing should be maintained at the design levels with a tolerance
of plus or minus 0.5 inches at all locations.
2-23
-------
SLIDE 2-28
*•••
SLIDE 2-28 LECTURE NOTES:
Each of the T-R sets is connected to a control cabinet. This
controls the 480 volt alternative current power supply to the T-R
set. It contains all of the electrical meters used to evaluate the
operating conditions inside each of the precipitator fields.
The types of meters present on the control cabinet are listed below
along with the usual range of the gauge.
Primary Current, 0 to 100 amps, A.C.
Primary Voltage, 0 to 500 volts, A.C.
Secondary Current, 0 to 1 amps (1000 mi11lamps), D.C.
Secondary Voltage, 0 to 50 kilovolts, D.C.
Spark Rate, 0 to 100 sparks/minute
The secondary current is the direct current from the T-R set that
passes through the field. The secondary voltage is the voltage on
the discharge electrodes. The spark rate is the number of short
duration arcs which occur in the field.
2-24
-------
SLIDE 2-29
SLIDE 2-29 LECTURE NOTES:
Rappers are used on a semi-continuous basis for removing a portion
of the accumulated solids from the collection plates and discharge
electrodes. This slide shows a rotating shaft arrangement in which
a hammer mounted on a shaft is used to strike an anvil mounted on
the lower side of each collection plate. In other designs, a set
of individual rappers is mounted on the ESP roof and connected to
the collection plates and discharge frames by means of a series of
rapper shafts.
The intensity and frequency of rapping must be matched to the
flyash characteristics. Excessive rapping results in increased
particulate emissions, generally in the form of frequent opacity
spikes. Inadequate rapping results in impaired electrical condi-
tions in an ESP field.
2-25
-------
SLIDE 2-30
200 300 400 500 600 700 800
Average Rue Gas Temperature, Degrees F
SLIDE 2-30 LECTURE NOTES:
The flyash resistivity is an especially important property. It is
the measure of the ability of the electrons on the particles to
pass through the dust layer on the collection plate. If the
electrons can flow easily, the resistivity is called "low" and
rapping related opacity spikes are common. If the electron flow is
very limited, the resistivity is called "high" and electrical con-
ditions within the precipitator can be severely impaired. The best
precipitator performance is obtained when the resistivity is
moderate.
There are two separate modes of electron flow which produce the
resistivity-temperature relationship shown in Slide 2-30. Below
approximately 350 degrees Fahrenheit, compounds such as sulfuric
acid and water vapor condense on the particle surfaces and provide
a charge conduction path. The effectiveness of this path increases
dramatically as the gas temperature cools. The resistivity can
2-26
-------
SLIDE 2-30 LECTURE NOTES (Continued)
decrease a factor of 10 with a 20 to 30 degree Fahrenheit gas temp-
erature drop.
Above approximately 350 degrees Fahrenheit, electron flow can only
occur due to conduction directly through the particles. As the
temperature increases, the compounds which make up f lyash particles
become better electrical charge carriers. For this reason, the
flyash resistivity decreases in the high temperature ranges.
However, this region of the resistivity-temperature curve is not
very relevant to MWC applications since the proposed regulations
prohibit inlet gas temperatures greater than 450 degrees
Fahrenheit.
Under normal MWC operating conditions, the f lyash resistivities are
generally in the moderate range where particulate removal perfor-
mance is very high. However poor combustion practices can cause an
increase in the carbonaceous content of the fly ash. Due to the
conductive nature of this material, this can create undesirable low
resistivity conditions as indicated by the multiple curves shown in
Slide 2-30. Decreased gas temperatures can also create low resist-
ivity conditions by lowering the gas temperature. These lower
temperatures can be due to changes in incinerator load or due to
air infiltration into the combustion system or into the ESP.
The average resistivity can not be measured directly by the primary
control cabinet electrical gauges. However, there are generally
reliable symptoms of low, moderate, and high resistivity condi-
tions. These are summarized below.
Low Resistivity
Reduced voltages in all fields
High currents in all fields
Very low spark rates
Moderate Resistivity
High voltages in all fields
Low currents in inlet field, higher currents in
middle and outlet fields
High spark rates in inlet field, lower spark rates
in middle and outlet fields
High Resistivity
Reduced voltages in all fields
Low currents in all fields
High spark rates in all fields
2-27
-------
SLIDE 2-31
•LOW TU
PILOT VALVE ENCLOSURE
DIAPHRAGM VALVE
— AIR MANIFOLD
BAG
'.PULSE TIMER
J
DIFFERENTIAL PRESSURE. SWITCH
IRTY GAS INLET
ARY VALVE
2-28
-------
SLIDE 2-31 LECTURE NOTES:
A cross-sectional sketch of a pulse jet baghouse is shown in Slide
2-31. The baghouse is divided into a "clean" side and a "dirty"
side by the tube sheet mounted near the top. The dust J.aden gas
stream enters below the tube sheet, and the filtered gas collects
in a plenum above the tube sheet. The are holes in the tube sheet
for each of the bags which are arranged in rows.
The bags and support cages hang from the tube sheet. The dust cake
gradually accumulates on the outside surfaces of the bags during
filtering. The cleaned gas passes up the inside of the bags and
out into the clean gas plenum.
A portion of the dust cake must occasionally be removed from the
bags in order to avoid excessively high gas flow resistances. The
bags are cleaned by introducing a high pressure pulse of compressed
air at the top of the bag. The sudden pulse of compressed air
generates a pressure wave which travels down inside of the bag.
The pressure wave also induces some filtered gas to flow downward
into the bag. Due to the combined action of the pressure wave and
the reverse gas flow, the bags are briefly deflected outward. This
cracks the dust cake on the outside-of the bags and causes the dust
to fall into a hopper. Cleaning is normally done on a row-by-row
basis. The compartments are generally isolated during cleaning so
that dust discharged from one row of bags does not get-captured by
adjacent rows of bags.
The compressed air pressures are usually between 60 and 100 psig.
However, some commercial models use lower air pressures and higher
gas flow rates to achieve bag cleaning. The frequency of cleaning
can be controlled by a differential pressure sensor or by a timer.
During cleaning, the pilot valve is opened. This exhausts the
trigger line from the diaphragm valve and allows the diaphragm
valve to open and pass compressed air from the air manifold to the
compressed air tube mounted above each row of bags.
One of the basic design parameters of pulse jet baghouses is the
air-to-cloth ratio. This is the number of cubic feet of gas (at
actual conditions) which passes through a square foot of fabric in
one minute. Most commercial units used on MWC systems are designed
for air-to-cloth ratios of 2 to 4.
The difference between the gas stream static pressure before and
after the baghouse is called the static pressure drop. This value
depends on the average air-to-cloth ratio, the type of fabric used,
and the adequacy of cleaning. During normal operation, the static
pressure drop is usually in the range of 3 to 8 inches of water.
Very low static pressure drops can indicate excessive cleaning
intensity and increased particulate emissions. Very high static
pressure drops can indicate fabric blinding or cleaning system
problems.
2-29
-------
SLIDE 2-32
_ COMPARTMENTS
FAN
•-5 GAS INLET _
2-30
-------
SLIDE 2-32 LECTURE NOTES:
In reverse air baghouses, the bags are suspended from the top and
are attached to a tube sheet which is immediately above the
hoppers. The inlet gas enters from the hoppers and passes upwards
into each of the bags. The dust cake builds up on -the—inside
surface of the bags, and filtered gas passes into the chamber
surrounding the bags.
The baghouse is divided into 2 or more compartments. The unit shown
in slide 2-32 has 6 compartments. The bags are cleaned by
isolating the compartment from the inlet gas stream. Filtered gas
is moved backward through the compartment to break up the dust cake
and discharge it to the hoppers below. The reverse air flow from
the compartment being cleaned is recycled to the inlet gas stream.
A set of dampers (poppet valves in slide 2-32) is used for isola-
ting the compartments.
The reverse air flow is maintained by a reverse air fan which oper-
ates continuously. This may be located at ground level as
indicated in slide 2-32 or the fan may be mounted on the roof of
the fabric filter unit.
Reverse air type baghouses for MWC applications are usually design-
ed for air-to-cloth ratios below those used in pulse jet- applica-
tions. These are generally in the range of 1 to 1.5 ft~./min.
The average static pressure drop across the entire reverse air bag-
house is generally in the range of 3 to 8 inches of water. This is
similar to pressure drops for pulse jet baghouses. Low static
pressure drops may mean excessive cleaning frequency or low flue
gas flow rates. High static pressure drops may mean cleaning sys-
tem failure or bag blinding.
Reverse air units generally use woven bags with anti-collapse
rings. Bag tensions are set at 70 to 120 pounds in order to reduce
flex related bag problems. The tension is provided by the springs
used in the bag hangers (Slide 2-32, top insert).
2-31
-------
SLIDE 2-33
FABRIC TYPES AND LIMITATIONS
Fiberglass
* Silicon-Graphite Coatings
* Acid Resistant Coatings
* Teflon B Coatings
P-84
Ryton
Nomex
Teflon
Long Term
Temperature
Limit, F
500
500
500
450
400
400
400
SLIDE 2-33 LECTURE NOTES:
The fabric types listed in Slide 2-34 are some of the materials
used for MWC applications. Temperature excursions of 25 to 50
degrees Fahrenheit above these values for time periods of more than
15 minutes may result in some damage to the bags. It is con-
ceivable that fabric damage could occur even though the plant did
not experience an excursion of the 4-hour block average tempera-
ture limits of 450 degrees Fahrenheit specified in the proposed
regulations.
SLIDE 2-34
Z98'F
294'F
2-32
-------
SLIDE 2-34 LECTURE NOTES:
Low gas temperatures in pulse jet and reverse air fabric filters
can create several problems. Condensation of moisture on interior
walls and access hatches can provide moisture layers for absorp-
tion of corrosive sulfur dioxide and hydrogen chloride. -Low gas
temperatures in the hoppers can create solids discharge problems.
Calcium chloride formed in dry scrubber applications is especially
hygroscopic and prone to solids bridging conditions. Due to the
low gas temperature problems, fabric filter systems must be well
insulated and they usually include heaters for the hoppers.
SLIDE 2-35
SLIDE 2-35 LECTURE NOTES:
One frequent cause of low gas temperature conditions is air
infiltration up through the baghouse handling equipment. Rotary
discharge valves (shown in Slide 2-35) or double flapper valves are
often used to provide an air seal.
2-33
-------
SLIDE 2-36
GAS
STREAM
SLURRY DROPLET
SURFACE
Ca(OH)2
PARTICLE
SUBSEQUENT REACTIONS FORM
CaS03l,CaS04i
I CaCL2
ABSORPTION
GAS
STREAM
so2
HCI --*.
Ca(OH)2
PARTICLE
Ca(OH).
PARTICLE
ADSORPTION
2-34
-------
SLIDE 2-37
TYPES OF DRY SCRUBBERS
* DRY INJECTION SCRUBBERS
* SPRAY DRYER ABSORPTION
Rotary Atomizers
Air Atomizing Nozzles
* COMBINATION SPRAY DRYER AND
DRY INJECTION SYSTEMS
SLIDES 2-36 AND 2-37 LECTURE NOTES:
There are two fundamental mechanisms used to capture hydrogen
chloride and sulfur dioxide in dry scrubbing systems. These acid
gases can be absorbed into droplets containing a partially dis-
solved alkaline slurry. As shown in the top portion of Slide 2-36,
the reactions products include calcium sulfite, calcium sulfate,
and calcium chloride. These reaction products and the remaining
unreacted alkali are evaporated to dryness as the atomized droplet
passes through the relatively hot spray dryer vessel. Additional
collection of acid gases occurs on the surfaces of the. particles
after the droplets evaporate. The adsorption mechanism shown in
the lower portion of Slide 2-36 is responsible for the additional
collection.
Dry injection systems use physical adsorption for capture of the
acid gases. Finely divided alkaline material is dispersed in the
inlet duct, and the gas stream is cooled to permit adsorption. More
alkali is need for this approach than for absorption based systems.
The general types of dry scrubbing systems are categorized based on
the principal type of mass transfer mechanism used. Spray dryer
systems are subdivided into two groups based on the physical means
used to generate very small slurry droplets which can evaporate to
dryness in the short residence time available. The components and
characteristics of these types of dry scrubber systems are intro-
duced in the following pages.
2-35
-------
SLIDE 2-38
UME SILO AND
FEEDING SYSTEM
AXIAL FANS
NOTE: FLUE GAS RECYCLE STREAM
AND HEATER NOT SHOWN
SOLIDS
REACTOR
INDUCED STACK
DRAFT
FAN
STREAMS
SOLID & LIQUID FLUE GAS
A HOT GAS FROM
WASTE HEAT BOILER
QUICKLIME
AMBIENT AIR
HOT AIR
FLYASH, LIME
FLYASH. LIME. RESIDUE D TREATED FILTERED GAS
FLYASH. LIME. RESIDUE E TREATED FILTERED GAS
B COOLED GAS
C COOLED GAS AND
RECYCLED SOLIDS
INSTRUMENTS
GASTEMP
LIME FEED
RATE
STATIC
PRESSURE DROP
PRESSURE
MOTOR
CURRENT
LZU OXYGEN
£& OPACITY
©SULFUR
DIOXIDE
©NITROGEN
OXIDES
2-36
-------
SLIDE 2-38 LECTURE NOTES:
This type of dry scrubber uses finely divided calcium hydroxide for
the adsorption of acid gases. The alkali feed material has parti-
cle sizes which are 90% by weight through 325 mesh screens. This
is approximately the consistency of talcum powder. This-s-ize is
important to ensure that there is adequate alkali surface area for
high efficiency pollutant removal.
The calcium hydroxide is transported to the injection point by
means of a positive pressure blower. This provides the initial
fluidization necessary to break up any clumps of alkali which have
formed during storage. The alkali is provided at rates equivalent
to 3 to 4 times the stoichiometric requirement. The feed rate of
alkali is monitored by a gravimetric feeder used to supply the
blower.
The gas stream is cooled to approximately 250 degrees Fahrenheit to
promote adsorption. In the system shown in Slide 2-38, gas cooling
is accomplished using a set of axial fans blowing ambient air
through an indirect heat exchanger.
Adsorption of acid gases on the alkali particles occurs while the
particles are entrained in the gas stream and while the particles
are trapped in the fabric filter dust cake. In some -systems, a
portion of the baghouse hopper solids are recirculated 'to the gas
stream to increase alkali utilization.
2-37
-------
SLIDE 2-39
NA
J — $>
(
" ^ D
©
1 »l
£
9
ij-
X:
V
•»
'
-fr
i
^
o
\
i
- --- - -\y~
r^
- •.
: * "
UME
SILO
SOLIDS
'RECYCLE
SLO
RESCUE TO
LANDFILL
•^j *-0-^« x
STREAMS
LIQUID & SOLID
<£> QUICKLIME
^N SLAKED LIME
^> REACTION PRODUCTS
AND LIME
&) REACTION PRODUCTS
^ AND LIME
<£> REACTION PRODUCTS
^ AND LIME
6> LIME SLURRY
FLYASHAND
REACTION PRODUCTS
LIME SLURRY
LIME SLURRY
^0> LIME SLUHRY
^N LIME SLURRY
^^ FLYASH AND
REACTION PRODUCTS
FLUE GAS
A RUE GAS FROM
INCINERATION
B SPLIT INLET GAS STREAM
C SPLIT INLET GAS STREAM
D TREATED FLUE GAS
E,F TREATED FILTERED
FLUE GAS
FABRIC
I FILTER
^-^-l
MDUCED STACK
DRAFT
FAN
FLY ASH AND
RESIDUE TO
LANDFILL
INSTRUMENTS
^ GAS TEMP ^
©FLOW
/g>
@ DENSITY ^^
©LIME FEED
RATE
©STATIC PRESSURE
DROP
^ PRESSURE
^£^ MOTOR CURRENT
^°») OXYGEN
(=^ OPACITY
SULFUR
DIOXIDE
NITROGEN
OXIDES
-------
SLIDE 2-39 LECTURE NOTES:
The alkaline reagent is prepared as a slurry containing 5 to 20% by
weight solids. This slurry is atomized in a large absorber vessel
having a residence time of 6 to 20 seconds.
There are two main ways of atomization: (1) rotary atomizers, and
(2) air atomizing nozzles. There is generally only one rotary
atomizer per spray dryer vessel. However, there may be as many as
4 air atomizing nozzles per vessel.
It is important that all of the slurry droplets evaporate to dry-
ness prior to approaching the absorber side walls and prior to
leaving with the gas stream. Accumulation of material on the side
walls or bottom of the spray dryer vessel would necessitate an
outage of the incinerator. Proper drying of the slurry is achieved
by the generation of small slurry droplets, by proper flue gas con-
tact, and by the use of moderately hot flue gases.
Drying that is too rapid can reduce pollutant collection efficiency
since the primary removal mechanism is absorption into the drop-
lets. There must be sufficient contact time for this mass transfer
step. For this reason, spray dryer absorbers are operated with
exit gas temperatures 90 to 180 degrees Fahrenheit above the
saturation tempe£ature. A temperature monitor located on the out-
let of the spray dryer vessel is used as an indirect indication of
the "approach-to-saturation."
In some commercial systems, the inlet gas stream to the spray dryer
is split to achieve droplet-gas stream contact. This approach is
shown in Slide 2-39. In other systems, droplet-gas stream con-tact
is achieved using a single inlet duct located near the top of the
spray dryer.
The alkaline material generally purchased for use in a spray dryer
absorber is pebble lime. This material must be slaked in order to
prepare a reactive slurry. Slaking is the addition of water to
convert calcium oxide to calcium hydroxide. Proper slaking condi-
tions are important to ensure that the resulting slurry has the
proper particle size distribution and that no coating of the
particles has occurred due to the precipitation of contaminants in
the slaking water.
2-39
-------
SLIDES 2-40 AND 2-41
SLIDES 2-40 AND 2-41 LECTURE NOTES:
A rotary atomizer is shown in Slide 2-4O (top left). Atomization
occurs as a thin film of slurry spins off the atomizer disk rota-
ting at 10,000 to 17,000 rpm.
The lines leading to a air atomizing nozzle are shown in slide 2-41
(top right). In this type of system, high pressure air is used to
provide the physical energy required for droplet formation. The
typical air pressures are 70 to 90 psig. Slurry droplets in the
range of 70 to 200 microns are generated.
The air assisted nozzles can generally operate over wider varia-
tions in gas flow rate than can the rotary atomizers. However, the
air assisted nozzles do not have the slurry feed turndown capabi-
lity of the rotary atomizers.
2-40
-------
SLIDE 2-42
Water
Water* — ,
C
Flue Gas
from
Incinerator
SLIDE 2-42 LECTURE NOTES:
One approach for controlling the feed rate of alkaline material to
the spray dryer vessel is shown in Slide 2-42. The slurry feed
rate is controlled using the outlet temperature gauge. The main
purpose of this control loop is to ensure proper approach-to-
saturation levels and to preclude any build-up of partially dried
solids in the absorber.
The slurry density can be adjusted slightly based on the outlet
sulfur dioxide monitor. The amount.of water added to the feed tank
is inversely related to the outlet sulfur dioxide level. This
approach is used to follow the rapid variations in inlet sulfur
dioxide levels due to nonhomogeneous waste materials.
It should be noted that some systems simply use the absorber outlet
temperature monitor for slurry feed rate control. In these units,
the slurry density is kept constant.
2-41
-------
SLIDE 2-43
STREAMS
> QUICKLIME
> SLAKED LIME
WATER
UME SLURRY
LIME SLURRY
FLYASH. LIME
FLYASH. LIME
RECYCLED
SOUOS
A HOT GAS FROM
INCINERATION
B TREATED GAS AND
SOLIDS
C TREATED GAS. SOUDS.
AND RECYCLED SOLIDS
0 TREATED FILTERED SAS
E TREATED FILTERED GAS
INSTRUMENTS
Q GAS TEMP fi
©CASTiMP ^
(WET BULB) ^
©LIM£ FEED t}
RATE
©SIORHY '^
FEED RATE
(iS& DENSITY
£Zi PRESSURE
©STATIC PRESSURE
DROP
£& MOTOR CURRENT
1 OXYGEN
OPACITY
) SULFUR
DOXDE
NITROGEN
OXIDES
-------
SLIDE 2-43 LECTURE NOTES:
The system shown in Slide 2-43 is a combined spray dryer and dry
injection system. A calcium hydroxide slurry is used in an upflow,
single nozzle type spray dryer. Flyash and unreacted alkali
removed from the baghouse hoppers are reinjected upstream of the
baghouse along with small quantities of calcium silicate (or other
additive).
SLIDE 2-44
100
*2
| 95
CD
•° 90
;j— J7U
LLJ
1
o 85
0)
oc
0 80
1
/
/
/
;
/
/
/
^
• ^^
/' /
/
/
//
//
/
^ —
^
• •
— •
, — **
**^
^m^ff^^^
•i •
•* —
,
250 °F
300 °F
350 °F
1
1.0 1.5 2.0 2.5 3.0 3.5
Alkali / HCI Stoichiometric Ratio — ^
^
SLIDE 2-44 LECTURE NOTES:
For the spray dryer (absorption) type systems, the acid gas removal
efficiency is a function of both the alkali-acid gas Stoichiometric
ratio and the outlet gas temperature. This relationship is shown
in Slide 2-44 for hydrogen chloride. A similar relationship exists
for sulfur dioxide with the difference being that it is collected
less effectively than hydrogen chloride. At Stoichiometric ratios
of 2 to 3, the sulfur dioxide removal efficiencies are in the range
of 80 to 90%.
2-43
-------
SLIDE 2-45
Reagent
SLIDE 2-45 LECTURE NOTES:
This drawing illustrates a gas-atomized scrubber with a condenser
pretreatment stage. The flue gas from the incinerator is cooled to
a temperature range of 100 to 120 degrees Fahrenheit by recircula-
ting liquor cooled in a heat exchanger or cooling tower. As the
flue gas temperature decreases, some of the water vapor in the flue
gas condenses on the surfaces of the submicron particulate. The
increased mass of the particles promotes high efficiency impaction
in the particulate scrubber vessel. In the system shown in Slide
2-45, a collision scrubber is used for particulate removal.
Acid gas removal is accomplished in both the condenser/absorber
vessel and in the particulate scrubber. The scrubber liquor pH
must be carefully controlled to a range of 6 to 8 in order to
ensure adequate acid gas removal and to prevent solids precipi-
tation in the scrubber vessels.
2-44
-------
SLIDE 2-46
Collection Plates
Flush Nozzles
Wires
Plates
Support Insulator
Recirculation Liquor
to Wire Flush Nozzles
Gas
Distribution
Screen
Fresh
Water
Packed Bed
Recirculation
Liquor
Nozzles
Pump
SLIDE 2-46 LECTURE NOTES:
A wet ionizing scrubber utilizes electrostatic charge for the col-
lection of particulate matter. The charged particles are attracted
to the water layers on the surfaces on the packing material. Acid
gases are absorbed in the wetted packing.
The gas stream enters the scrubber and passes through a short
ionizer section consisting of parallel rows of grounded collection
plates and high voltage discharge electrodes. The wire-to-plate
spacings are maintained at 3 inches plus or minus 0.25 inches in
order to ensure maximum voltages in the range of 20 to 25 kV.
The unit shown in Slide 2-46 can be used alone or as one module in
a series of similar units. The overall particulate removal
capability increases as the number of units in series increases.
Both the collection plates and the discharge wires must be cleaned
to remove accumulated solids. The plates are cleaned by means of
a continuous flow of scrubber liquor. The ionizer wires are
cleaned approximately once every 4 hours. The high voltage supply
must be turned off for three minutes during cleaning.
_/V'
2-45 re*
-------
SLIDE 2-47
NITROGEN OXIDES CONTROL
TECHNIQUES
COMBUSTION MODIFICATIONS
* Low Excess Air Combustion
* Flue Gas Reciroulation
ADD-ON CONTROL SYSTEMS
* Selective Noncatalytic
Reduction
* Selective Catalytic
Reduction
SLIDE 2-47 LECTURE NOTES:
The four general techniques used for reducing nitrogen oxides
emissions are listed in Slide 2-47. The combustion modifications
are intended to reduce the quantity of nitrogen oxides formed from
fuel nitrogen and_cpmbustion air nitrogen during waste combustion.
These approaches are limited to reduction efficiencies in the range
of 20 to 30%. Add-on systems use reduced nitrogen compounds to
chemically reduce the nitrogen oxides to molecular nitrogen. These
can achieve efficiencies in the range of 60 to 80%.
SLIDE 2-48
LOW EXCESS AIR
OPERATION
SLIDE 2-48 LECTURE NOTES:
Excess air is defined as the extra quantity of air provided to the
combustion system above that quantity necessary to oxidize the
waste material completely to carbon dioxide and water vapor. The
flue gas oxygen concentration is generally used as an indication of
the excess air level.
Lowering the excess air level is a logical control approach since
oxygen is needed to sustain both of the general reaction mechanisms
believed responsible for nitrogen oxides formation. These mech-
anisms include: (1) a free radical chain reaction which converts
molecular nitrogen to nitric oxide and nitrogen dioxide, and (2)
the oxidation of a portion of the nitrogen entering as organic
compounds in the waste material being burned.
2-46
-------
SLIDE 2-48 LECTURE NOTES (CONTINUED):
Low excess air operation can reduce the nitrogen oxides formation
rates by 20 to 30%. In addition, there are other advantages to
this approach.
* The thermal efficiency of the combustion system
is improved due to lower sensible heat losses
with the flue gas.
* Flue gas velocities through -the boiler tube banks
are reduced slightly, thereby minimizing erosion.
* Fan energy costs are reduced slightly.
However, there are also limits to the possible reductions in excess
air levels which can be achieved. If the oxygen levels are lowered
too much, combustion may be incomplete in certain localized areas
of the incinerator.
SLIDE 2-49
UJ
oz
^-o
X— •
oos
ZUJ
O<_)
CDZ
KO
«<_)
<_)
(
1
, \
\
H
^
X,
[D
'//fr,
^^
E
/
3 6 9 12 IS
OXYGEN CONCENTRATION
A - INSUFFICIENT AIR C*J02 — CO
B - APPROPRIATE OPERATING REGION
C - "COLO BURNING"
SLIDE 2-49 LECTURE NOTES:
Carbon monoxide is a useful indicator of the formation of partial
oxidation products. It is apparent in this general relationship
that the concentration of carbon monoxide increases sharply when
the oxygen levels decrease below the 6 to 9% range.
2-47
-------
SLIDE 2-50
FLUE GAS
RECIRCULATION
SLIDE 2-50 LECTURE NOTES:
Flue gas recirculation capability can be designed into new units.
The objective is to reduce the peak gas temperatures and peak
oxygen concentrations to suppress the free radical reactions
leading to nitrogen oxides formation.
The potential reduction efficiencies are in the range of 20 to 30%.
There are moderate costs involved with this approach since it is
necessary to operate and maintain a flue gas recirculation fan and
duct.
SLIDE 2-51
SLIDE 2-51 LECTURE NOTES:
One of the two general techniques for reducing nitrogen oxides to
molecular nitrogen is selective noncatalytic reduction. A reducing
agent is injected into the incinerator in the high temperature
zone. The unit shown in Slide 2-51 has two rows of nozzles so
that the point of injection can be matched to the desired flue gas
temperature at different incinerator operating rates.
2-48
-------
SLIDE 2-52
100
|f80
If60
X
O
40
20
0
-20
-40
1400
1800
2200
Gas Temperature,
Degrees Fahrenheit
SLIDE 2-52 LECTURE NOTES:
For selective noncatalytic reduction systems, the effectiveness of
control is a strong function of the flue gas temperature at the
point of reagent injection. This relationship is shown in Slide 2-
52.
The temperature range of maximum nitrogen oxides reduction is 1600
to 1900 degrees Fahrenheit. At lower gas temperatures, the reduc-
tion reaction is incomplete, and some of the reducing agent (such
as ammonia) is emitted. When the gas stream is too hot, some of
the reducing agent is oxidized to nitrogen oxides. In this case,
the emissions of nitrogen oxides can be higher than the "inlet"
levels.
There are two main types of reducing agents used: (1) ammonia gas,
and (2) urea solution. In both cases, it is important to inject
the material uniformly into the gas stream. The quantity of
reducing agent must be matched approximately to the nitrogen oxides
formation rates.
2-49
-------
SLIDE 2-53
20
O
"w H0
to 12
UJ
CO Q
c
O
Note: Data Shown Is
Only Approximate
1500 1600 1700 1800 1900 2000
Flue Gas Temperature, Degrees Fahrenheit
Upstream Of Injection Point
SLIDE 2-53 LECTURE NOTES:
Ammonia emissions (sometimes called "slip") can be high if the flue
gas temperatures are too low in selective noncatalytic systems.
The general relationship between ammonia emissions and flue gas
temperature is shown in Slide 2-53.
When the flue gas ammonia levels exceed 10 to 20 ppm, it is
possible to form ammonia compounds. These can condense to form
light scattering particulate in the stack discharge.
2-50
-------
SLIDE 2-54
SELECTIVE CATALYTIC
REDUCTION
SLIDE 2-54 LECTURE NOTES:
Catalytic reduction systems utilize a titanium catalyst bed to
promote nitrogen oxides reduction at temperatures of 550 to 750
degrees Fahrenheit. The catalyst bed is located downstream of the
incinerator economizers in order to maintain the necessary
temperature range.
Ammonia is injected immediately upstream of the catalyst bed in
order to reduce the nitrogen oxides. Reduction efficiencies are in
the range of 70 to 80% as long as the catalyst is in good chemical
and physical condition.
The catalyst beds are vulnerable to particulate matter related
problems since they are ahead of the particulate control systems.
Blinding of the catalyst can occur due to the deposition-"of flyash.
Deactivation of the catalyst can occur due to contact with high
concentrations of hydrogen chloride.
2-51
-------
SLIDE 2-55
POLLUTANT FORMATION AND
DESTRUCTION MECHANISMS
* Metals-Containing
Particulate Matter
* MWC Organics
(Diozins and Furans)
* MWC Acid Gases
(Sulfur Dioxide and
Hydrogen Chloride)
* Nitrogen Oxides
* carbon Monoxide
SLIDE 2-55 LECTURE NOTES:
The inspection of municipal waste incinerator concerns the five
separate groups of air pollutants listed in slide 2-55. The
pollutant formation and destruction mechanisms are briefly discus-
sed in the next section to clarify the regulatory requirements.
SLIDE 2-56
2-52
-------
SLIDE 2-56 LECTURE NOTES:
The gas temperatures in the furnace area of the incinerator are
sufficiently hot to vaporize some of the metals and metal compounds
present in the flyash entrained in the flue gas. As the, flue gas
begins to cool in the boiler tube banks (or waste heat boiler) some
of the vapor phase materials recondense on the surfaces of the sub-
micron particles. Condensation continues as the flue gas stream
continues to cool while passing through the air pollution system.
SLIDE 2-57
V
100000
0 200 400 600 800 T(°C)
I I I I I
400
800
1200 T("F)
SLIDE 2-57 LECTURE NOTES:
The tendency for a material to be volatilized in the incinerator
furnace is related to the saturation vapor pressure. Values for
commonly occurring metals and metal compounds are shown in Slide 2-
57. It is apparent that mercury is especially difficult to con-
dense and collect as particulate. A portion of the mercury can
escape the air pollution control system as a vapor.
The other volatile compounds are effectively condensed on the
flyash particles. Due to the "enrichment" of the flyash particles,
they can have higher concentrations of toxic metals than the bottom
ash leaving the incinerator.
2-53
-------
SLIDE 2-58
Dioxins
Furans
SLIDE 2-58 LECTURE NOTES:
The general chemical structures of dioxins and furans are shown in
Slide 2-58. There are 210 forms of these compounds depending on
the locations of the chlorine substitution. They are collectively
referred to as PCDD (polychlorinated dibenzo-dioxins) and PCDF
(polychlorinated dibenzo-furans).
The compound which is considered most toxic is 2,3,7,8 PCDD. In
some State and local agency regulations, the emissions of dioxins
and furans are expressed in terms of "toxic equivalents" using
2,3,7,8 PCDD as the basis. In the proposed NSPS regulation, the
emissions of dioxins and furans are expressed using a total weight
basis rather than the toxic equivalents approach.
There are a variety of theories concerning the formation mechanisms
for these compounds.
* Vaporization of PCDD and PCDF compounds present in the
waste feed to the incinerator
* Reactions between chlorinated organic precursors such
as chlorophenols and PCB
* Chlorination of polyvinyl chloride or lignin in waste
feed by salt, HC1, or chlorine gas
* Catalytic reactions between organic precursors and trace
metals adsorbed on flyash particles in the gas stream
2-54
-------
SLIDE 2-59
100
10
HEXACHLORO-
BENZENE
OIOXIN
FURANS
.1
1000 1100 1200 1300 UOO 1500 1600
TEMPERATURE (°F)
SLIDE 2-59 LECTURE NOTES:
There is still uncertainty regarding the chemical mechanisms
involved in the formation and destruction of dioxins and furans.
Due to this uncertainty, the control of these compounds is ap-
proached from several different directions.
* Maintaining sufficiently high temperatures to
oxidize PCDD and PCDF compounds
* Avoiding flue-rich zones where they could form
* Avoiding combustion quenching conditions
* Minimizing flue gas temperatures entering the air pollution
control device.
Slide 2-59 illustrates the beneficial effect on operation at high
flue gas temperatures. Emissions of PCDD and PCDF are minimized
when the gas temperature is above the 1300 to 1400 Fahrenheit
range.
Maintaining low gas temperatures during transport to and through
the air pollution control system reduces possible formation on the
surfaces of the particles. The surface related formation reactions
occur in the range of 550 to 750 degrees Fahrenheit. The proposed
regulations limit the inlet gas temperature to 450 Fahrenheit.
2-55
-------
SLIDE 2-60
3 6 9 12
OXYGEN CONCENTRATION
15
SLIDE 2-60 LECTURE NOTES:
The average flue gas temperature necessary for dioxin and furan
destruction is lower when -he oxygen concentration increases. This
is due in part to the minimization of any fuel-rich pockets of com-
bustion gases within the incinerator. However, there is a limit to
the desirable oxygen concentration. If too much air is introduced
into the incinerator, the peak gas temperatures are reduced. This
cooling quenches the reactions responsible for oxidation of carbon
monoxide and other partially combusted materials such as PCDDs and
PCDFs. The general relationship between flue gas carbon monoxide
and oxygen is shown in Slide 2-60.
Carbon monoxide concentrations from MWC units are generally in the
range of 10 to 150 ppm. Carbon monoxide substantially above this
level may be indicative of some PCDD and PCDF formation. The
oxygen concentrations are normally between 9 and 12%. Much higher
levels may be associated with higher PCDD and PCDF formation.
2-56
-------
REVIEW QUESTIONS - CHARACTERISTICS OF MUNICIPAL WASTE INCINERATORS
Directions: Select the answer or answers which are correct.
1. What fuel characteristics generally apply to MWC units?
a. High ash fusion temperature
b. Highly variable fuel heating value
@. High ash content
d. High sulfur content
2. What is the main reason that carbon monoxide emissions are
restricted in the proposed regulations?
(a\ Carbon monoxide is used as an indirect indicator of the
presence of dioxins and furans.
b. Carbon monoxide mass emission rates can be very high if
combustion conditions are poor.
c. Carbon monoxide emissions are an indication of inadequate
oxygen in the incinerator.
3. Why is overfire air pressure important in sloped grate type
incinerators?
\a/. The quantity of overfire air is important since much of
the waste is volatile matter than burns as a vapor above
the grates.
b. Overfire air pressure must be sufficiently high to provide
the turbulent mixing necessary for good combustion.
c. Overfire air pressure must be sufficient for the oxygen
to penetrate into the flue gases.
4. What is generally considered the most volatile metal in MWC
flue gases?
a. Lead
b. Cadmium
c. Lead oxide
d. Lead chloride
(1). Mercury
5. Why is the flue gas inlet temperature to the particulate
control devices limited?
a. High gas temperatures can harm the equipment.
b. Catalytic formation of dioxins and furans can occur on the
surfaces of the flyash particles.
c. To prevent condensation of volatile metals on the surfaces
of the particles
2-57
-------
3. WASTE PREPROCESSING
New requirements in the proposed NSPS regulation and in some new
State and local agency regulations now require inspectors to eval-
uate the waste preprocessing activities. This includes a brief
visual evaluation of the wastes being charged to the incinerator.
Also, records maintained by the plant and by associated waste
sorting/recycling centers are reviewed. The records reviewed in
this part of the inspection are evaluated at the same time as the
records pertaining t» material recovery practices. The two similar
topics are addressed separately in this course since the they are
in two separate portions of the proposed NSPS regulation.
SLIDE 3-1
SLIDE 3-1 LECTURE NOTES:
These objectives are accomplished primarily by observing the waste
materials being charged to the incinerator and the wastes being
stored temporarily in the tipping floor area. These observations
are made at a carefully chosen location away from moving equipment
and shredders. For routine inspections, there is no need to visit
any separate sorting/recycling centers or separate waste transfer
stations in order to evaluate the preprocessing activities. The
overall effectiveness of the preprocessing steps is evaluated based
on the characteristics of the "end product" - the wastes being
charged to the combustion equipment.
3-1
-------
SLIDE 3-2
4. WASTE PREPROCESSING
(Describe types of wastes being burned in significant
quantities.)
4.1 Prohibited Wastes
4.1.1 Vehicle Batteries
4.1.2 Other
4.2 Undesirable Wastes
Sources of Toxic Emissions
4.2.1 Waste chemicals
4.2.2 Flammable liquids
4.2.3 Asbestos
4.2.4 Other
Wastes Contributing to Unscheduled Startup/Shutdowns
4.2.5 Bulky materials
4.2.6 Gas cylinders
4.2.7 Other
4.3 General Observations
SLIDE 3-2 LECTURE NOTES:
The portion of the example inspection checklist pertaining to the
waste preprocessing activities is reproduced in Slide 3-2. The
information concerning specifically prohibited materials is
necessary to determine if there is a possible violation of the NSPS
or State/local agency requirements. The information concerning the
undesirable waste materials is used as support information when
evaluating chronic emission problems which are reported in the
quarterly excess emission reports and any malfunction reports.
The focus of this part of the inspection is on the effectiveness of
the overall preprocessing system. The presence of a single vehicle
battery or any single undesirable item does not mean that there is
a deficiency. Each plant handles huge quantities of wastes, and
the sorting out of unacceptable materials is inherently an imper-
fect and unpleasant task. A few items will occasionally pass
through the preprocessing steps undetected. The purpose of this
part of the inspection is to determine if "more than a few" items
are not being removed.
3-2
-------
SLIDE 3-3
SPECIFICALLY PROHIBITED MATERIALS
NewNtource Performance' ^Standatirds
State and Local Agency Requirements
(Vary substantially)
* Medical Wastes
* Hazardous Wastes
* Vehicle Tires
* Animal Remains
SLIDE 3-3 LECTURE NOTES:
The proposed NSPS regulation specifically prohibits the inciner-
ation of vehicle batteries. The particulate and vapor phase lead
emissions resulting from burning batteries would challenge the air
pollution control system. Also, -there is little or no benefit
derived from burning since the majority of the battery is non-
combustible. The batteries should be removed at the waste sorting-
recycling center or waste transfer-sorting facility. -'Since they
are relatively easy to spot, they should also be "picked-out" of
the wastes arriving at the waste-to-energy facility. Local
ordinances in many areas encourage recycling of vehicle batteries
by requiring auto repair shops to charge a deposit on the units.
In some areas, the items listed in the second group are also
prohibited. It would be helpful to amend the proposed inspection
checklist to include all specifically prohibited materials.
The items listed in the slide above are all relatively easy to see
while observing the combustion system charging practices. The
medical wastes are normally shipped in distinctive, bright red
bags. Nevertheless, some care is necessary in dimly lit tipping
floors to avoid confusing red medical waste bags with the orange
bags often used in roadside litter collection programs. The
vehicle tires and drums of waste chemicals are generally quite easy
to identify, even from the somewhat remote observation locations
necessary for safety reasons.
3-3
-------
SLIDE 3-4
Alkali
To
Hazardous
Landfill
SLIDE 3-4 LECTURE NOTES:
Records concerning the vehicle battery separation program should be
reviewed as part of the inspection. The first step is to determine
how the vehicle batteries and other specifically prohibited
materials are removed. Block type flowcharts similar to the type
shown in this slide should be prepared. The vehicle batteries and
other unacceptable materials are generally removed at the sorting-
recycling centers or the waste transfer facilities. Since the
batteries have some economical value, records are maintained which
indicate either the weight or number recovered and sold on a
routine basis. These records provide adequate documentation
regarding vehicle battery separation and recovery.
Records concerning the relatively small quantity or number of
batteries collected at the tipping floor are generally not required
by air pollution regulations. However, such records would be
necessary (1) if required by specific State or local agencies, or
(2) if the plant receives unsorted wastes and must separate
batteries at the tipping floor.
Records concerning other types of wastes which may be specifically
prohibited by State and local agencies may not be available. The
handling and weighing of such materials can be labor-intensive and
expensive.
3-4
-------
SLIDE 3-5
UNDESIRABLE WASTE MATERIALS
* Wastes which could cause
Toxic emissions
* Wastes which could damage the
combustion equipment
* Wastes which are bulky
There is a shared interest on the part of both the plant operators
and the regulatory agency inspectors to ensure that the burning of
these types of wastes is minimized by preprocessing separation.
During the routine Level 2 inspection, agency personnel should note
whether or not significant quantities of these materials are
present in the wastes being charged to the combustion equipment.
SLIDE 3-6
SLIDE 3-6 LECTURE NOTES:
The proposed NSPS regulation does not specifically prohibit house-
hold batteries. However, it does require that facilities subject
to these regulations have a program to reduce the quantities being
fired in the incinerator. These must be separated as part of the
community recycling program since it is presently difficult to
remove these small items from the as-received municipal wastes.
Household batteries are of concern because they are possible
sources of lead and cadmium emissions.
3-5
-------
SLIDE 3-7
SLIDE 3-7 LECTUREDNOTES:
Hazardous materials such as the bags of asbestos containing insu-
lation materials shown in this slide would contaminate the bottom
ash and flyash from the plant. If the bags passed through a
shredder they would also create a very localized inhalation hazard.
The bags are usually either bright yellow or clear. If bags of
these types (or any other bag) are suspected of containing asbestos
wastes, the plant operators should carefully move them to a secure
location and arrange for further testing by qualified persons.
They should not attempt to open these bags since they would
endanger themselves and possibly release asbestos fibers into the
community air. Regulatory personnel should not open these bags for
the same reasons.
Insulation materials which arrive unbagged are potentially of even
more concern. It is essentially impossible even for trained
industrial hygienists to visually distinguish between asbestos
containing materials and other types of insulation materials.
Accordingly, all apparently friable insulation materials which
arrive at the plant should be handled very carefully. They should
not be charged since they are uncombustible, and they may be a
source of asbestos.
When asbestos containing wastes are found during municipal waste
preprocessing, the regulatory agency will need to identify the
source to the extent possible. The persons or organizations
responsible are in violation of the EPA NESHAPS regulation con-
cerning asbestos disposal.
3-6
-------
SLIDE 3-8
SLIDE 3-8 LECTURE NOTES:
Flammable liquids such as gasoline, solvents, and oil-based paint
can explode in shredders and incinerators. While these are usually
not violent enough to damage the incinerator itself, there can be
localized damage to the refractory and the grates. The ultimate
result can be a deterioration in performance due to impaired air-
fuel contact or the need for unscheduled maintenance. The
explosions in the shredders are a safety problem for plant
personnel working in the immediate vicinity of the shredder or in
the line of flight of the explosion vents.
It is difficult to locate and remove all of the containers possibly
full of flammable liquids. These can be hidden within large opaque
garbage bags. This may be done intentionally by residents who are
trying to sneak these materials passed the scrutiny of san-itation
workers trained to reject such undesirable materials.
While observing the waste piles and waste charging activities,
inspectors will generally not be able to determine if containers in
plain view are full or empty. These will have to be removed and
checked by plant personnel using established procedures. It seems
obvious that regulatory agency personnel should not attempt to wade
into or climb over the waste piles in an attempt to reach any
suspect containers.
3-7
-------
SLIDE 3-9
SLIDE 3-9 LECTURE NOTES:
The compressed gas cylinders are a potential problem if the
pressure is sufficiently high to rupture the cylinder as it is
rapidly heated in the incinerator. The shrapnel-like metal debris
generated when the gas cylinder is destroyed can also damage the
incinerator refractory and grates.
Two common types of compressed gas cylinders include medical oxygen
cylinders and propane tanks used for gas barbecue grills. These
should be removed before the incinerator since it is difficult to
determine the internal pressure and since they are entirely
uncombustible.
3-8
-------
SLIDE 3-10
BULKY AND UNMANAGEABLE WASTES
Large appliances
Large furniture
Large automotive parts
Cables and wire rolls
Agricultural plastic rolls
Industrial cardboard rolls
SLIDE 3-10 LECTURE NOTES:
These types of trash are of concern to regulatory agency inspectors
when there are indications that the mechanical problems caused by
misguided attempts to burn these materials are causing frequent
combustion system unscheduled outages or malfunctions. Increased
pollutant emissions can occur due to frequent startup/shutdown
cycles and due to reduced combustion system performance. Since
these types of wastes are usually clearly visible in the waste
storage piles, their presence is noted on the inspection form while
checking for the specifically prohibited items and undesirable
items discussed earlier in this section.
3-9
-------
SLIDE 3-11
SLIDE 3-11.LECTURE NOTES:
The mattresses shown in the slide are one example of the bulky
wastes which can jam charging equipment and ash handling equip-
ment. It is also possible, that wastes of this size and shape
disrupt the intended air-fuel distribution and thereby slightly
increase air pollution emissions.
3-10
-------
SLIDE 3-12
SLIDE 3-12 LECTURE NOTES:
This is a automobile windshield that has been pulled from the waste
pile. Glass is especially troublesome since it can melt at normal
incinerator operating temperatures. The molten material can form
large clinkers which can block some of the air distribution slots
and holes in grates.
3-11
-------
SLIDE 3-13
ODOR AND WIMDBORNE LITTER
* Tipping floor enclosure
* General housekeeping
SLIDE 3-13 LECTURE NOTES:
Odor and windborne litter problems associated with the tipping
floor and waste storage areas are not specifically addressed by the
proposed NSPS regulations. However, in some localities there are
applicable ordinances. Whether of not it is specifically required,
most plants minimize these problems to keep the plant area clean
and to ensure good community relations.
If problems are noted during the- walkthrough inspection, they
should be described in the inspection form. The adequacy of the
tipping floor enclosure and any obvious housekeeping problems
should be briefly described. Also, plant management personnel
should be interviewed to determine if there are any especially
odorous wastes which have been received recently.
3-12
-------
REVIEW QUESTIONS - WASTE PREPROCESSING ACTIVITIES
Directions: Select the answer or answers which are correct.
1. What type or types of wastes are specifically prohibited by the
proponed1 regulations?
a. Vehicle tires
b. Vehicle batteries
c. Household batteries
© Hazardous wastes
e. Medical wastes
2. What incinerator problems can be created by glass?
(g) The glass can melt and block air holes through the grates.
b. The glass emits toxic materials.
c. The glass is difficult to handle with the incinerator
charging equipment.
3. Why is asbestos containing waste highly undesirable in MWC
systems?
a. The asbestos waste forms molten clinkers and slag in the
incinerator.
(^} Asbestos contaminants the bottom ash and the flyash
streams .
c. There is a slight risk that some asbestos fibers may pass
through the particulate control device and be emitted.
(cf) Some employee exposure may occur if asbestos is released
in the tipping floor area due to shredding or material
handling operations.
4. Why is it necessary to remove bulky items?
a. They can clog the charging chutes.
b. They can disrupt the air-fuel ratios in the incinerator.
c. Residue from the bulky wastes can clog the ash pits.
d. They generally have large quantities of metal and glass
which do not burn in the incinerator.
5. Is the charging of a full 5-gallon solvent container (toluene)
a violation of the preprocessing requirements in the proposed
regulations?
a. Yes
(^ NO - ioSV Cv'OioWrto*-' "r CXMA«V»»\ &OAV&C/ .
3-13
-------
Vft^J^MAAa ^a^^jJt,
e
«* "
0
4. CONTINUOUS EMISSION MONITORING EQUIPMENT AND DATA
This lecture begins with a brief introduction to the types of GEM
instruments and the characteristics of the gas sampling systems.
Not all types of instruments which could potentially be used at MWC
facilities are discussed in the lecture due to time and space
limitations. More complete information concerning CEM systems and
the applicable regulatory requirements are presented in the manuals
and publications listed in the bibliography.
This lecture emphasizes the inspection procedures discussed in the
MWC Field Inspection Notebook (Draft). These procedures have been
prepared to implement the monitoring requirements stated in the
proposed NSPS. The inspection procedures will have to be modified
in State or local areas having different requirements.
SLIDE 4-1
EVALUATION OF CEM INSTRUMENT SYSTEMS
AND EMISSION DATA
* OPACITY
* SULFUR DIOXIDE
* NITROGEN OXIDES
* CARBON DIOXIDE
* OXYGEN
* HYDROGEN CHLORIDE
* AMMONIA
SLIDE 4-1 LECTURE NOTES
New municipal waste incinerator facilities are generally required
to have sophisticated continuous monitoring systems for opacity and
a variety of gaseous pollutants. The proposed NSPS regulation
specifies that continuous emission monitors (CEMs) must be used for
sulfur dioxide, nitrogen oxides, and carbon monoxide. An oxygen
monitor or other diluent monitor is also required so that the
emission concentration data can be corrected to a consistent basis.
State and local agencies may require the use of hydrogen chloride
and ammonia monitors in the future.
The types of CEMs used at existing facilities depend primarily on
when these units were designed. Essentially all units have
opacity monitors. Relatively new plants may also have sulfur
dioxide, nitrogen oxides, and oxygen monitors.
4-1
-------
SLIDE 4-2
GENERAL CATEGORIES OF GEM SYSTEMS
In-Situ
* Cross-Stack
* Point
Extractive
* Undiluted
* Diluted
SLIDE 4-2 LECTURE NOTES:
There are two general categories of CEM systems as indicated in the
above slide. In-situ instruments utilize a light beam which either
traverses the entire stack (or breeching) or which passes through
a small sensor cell mount at a fixed point in the effluent gas
stream. Extractive instruments continuously pull a small sample
out of the effluent gas stream and transport it to the_ analyzers
mounted near* ground level. In extractive sample lines,-there must
be a means to prevent moisture condensation as the flue gas stream
cools. The sample can be diluted below its dewpoint using clean,
dry air, or the sample line can be heated well above the dewpoint
by using a set of electrical heat tapes surrounding the sample
line.
SLIDE 4-3
BASIS OF THE CEM ANALYSES
EXTRACTIVE - MAINLY DRY BASIS*
V*jr itr~-t v~r«-fc \f*4+jt>
IN-SITU - WET BASIS
* Note: In some cases, it can
be "partially" dry basis.
SLIDE 4-3 LECTURE NOTES:
The two general categories of CEM systems analyze pollutant con-
centrations of different moisture basis. In-situ instruments are
inherently "wet" since 10 to 20% of the flue gas is water vapor.
Extractive instruments are usually "dry" since the moisture must be
removed or diluted in order to transport the sample gas
4-2
-------
SLIDE 4-4
LOCATION/INSTALLATION CONSIDERATIONS
Extractive: The probes and sample condi-
tioning systems can be installed
at multiple locations, and the
analyzer can be used in a time
shared mode. The analyzer can be
at a convenient location.
In Situ: This samples only a single
monitoring location.
SLIDE 4-4 LECTURE NOTES:
A single analyzer can be used for several monitoring locations with
an extractive system. Accordingly, these instruments may be oper-
ated in a time shared mode. The in-situ monitors are inherently a
single location type instrument, but they can do multiple gases.
SLIDE 4-5
MINIMIZING THE EFFECTS OF PARTICULATE
Extractive
In-Situ:
Sample gas must be
filtered to remove
particulate.
Interface system must
be provided to protect
optics.
SLIDE 4-5 LECTURE NOTES:
Small quantities of flyash and other particulate can adversely
affect CEM systems. For extractive instruments a series of filters
is used. For in-situ instruments, the optics used for trans-
mission of the light beam must be protected by a clean air stream.
Particulate removal is especially important with extractive systems
having probes upstream and downstream of the air pollution control
devices in order to measure removal efficiency. The particulate
concentrations are high around the inlet probe.
4-3
-------
SLIDE 4-6
GEM SYSTEM ADVANTAGES
AND DISADVANTAGES
Extractive:
In-Situ:
Analyzer is protected.
Sample conditioning system
is vulnerable to problems.
Analyzer is vulnerable to
physical problems, but sample
conditioning system is not
necessary.
SLIDE 4-6 LECTURE NOTES:
Each type of GEM system has inherent advantages and disadvantages.
The inspection procedures presented- later in this lecture focus on
the vulnerable portions of the system. In the case of extractive
systems, sample line conditions are checked. In the case of the
in-situ instruments the protective purge air blowers-and filters
are checked along with the general physical environment around the
instrument.
SLIDE 4-7
TYPES OF EXTRACTIVE OEM INSTRUMENTS
A. Absorption Spec\troslpo|py
Non-dispersive infrared
Differential absorption
Gas filter cell correlation
B. Lujminesjcence
Chemiluminescence (NOX)
Fluorescence
Flame Photometry
C. Electro-analytical
Polarography
Electrocatalys is
Conductivity
Paramagnetism
SLIDE 4-7 LECTURE NOTES:
There are three categories of extractive CEM instruments. Some of
the instruments listed above are discussed in the following slides.
4-4
-------
SLIDE 4-8
BEAM SAMPLE SAMPLE
CHOPPER IN EXHAUST DETECTOR SENSOR
MOTOR fr
SAMPLE CELLf
| REFERENCE CELL
INFRARED
SOURCE
Nondispersive Infrared Analyzer with
"Microphone Type Detector
Source EPA; 625/6-79-005
SLIDE 4-8 LECTURE NOTES:
Infrared light generated by a lamp or glower is filtered (not shown
in drawing above) to provide a wavelength band in which the pol-
lutant of concern absorbs the light. The infrared light then
passes through two separate cells. One of these is filled with a
gas which does not absorb infrared light. The other has a contin-
uously flowing stream of the sample gas. Due to infrared light
absorption in the sample cell, less light energy reaches the
detector behind these cells. This difference in energy levels is
proportional to the concentration of the species absorbing the
infrared light.
Nondispersive infrared analyzer (NDIR) can be used for measuring
compounds such as sulfur dioxide, nitrogen oxides, carbon monoxide,
-carbon dioxide.
4-5
-------
SLIDE 4-9
MEASURING
PHOTOTUBE
SEMITRANSPARENT MIRROR
(BEAM SPLITTER)
SAMPLE CELL
S02/NOX
CALIBRATION FILTER 1
LAMP
i. , SAMPLE CELL
I SO2/NO
IN OUT
OPTICAL FILTER
ELECTRONICS
RECORDER
REFERENCE
^—^ PHOTOTUBE
Differential Absorption Analyzer
Source: EPA 625/6-79-005
SLIDE 4-9 LECTURE NOTES:
Differential absorption instruments compare light intensities at
two different wavelengths. The ultraviolet light leaving the
sample cell is split into two equal beams in the splitter. The
reference detector has a narrow bandpass filter which transmits
only light of the specific wavelength at which the pollutant does
NOT absorb. The measuring detector has a different bandpass filter
which transmits only light at a specific wavelength at which the
pollutant absorbs light effectively. The two detector signals are
compared and the result is proportional to the concentration of the
pollutant in the sample cell.
4-6
-------
SLIDE 4-10
NO2 TO NO
CONVERTER
STEP 2
NO*
NO (CONVERTED
FROM NO2)
FLOW CONTROL
SAMPLE IN
. c
soui
3 GENERATOR
!
ICE
DETI
CON
I REACTION CHAMBER
PHOTOMULTIPLIER!
TUBE
SAMPLE EXHAUST
Chemiluminescent Analyzer
Source: EPA 625/6-79-005
SLIDE 4-10 LECTURE NOTES:
Chemiluminescence analyzers utilize the reaction between nitric
oxide and ozone which generates infrared light. As shown in the
slide above, the gas sample containing nitric oxide is brought into
a reaction chamber adjacent to a photomultiplier tube (which is a
sensitive light detector). Ozone generate within the instrument is
mixed with the sample gas in order to initiate the chemiluminescent
reaction. The quantity of nitric oxide is proportional to the
electrical signal generated by the photomultiplier tube. Since
sample gas flow rate is carefully controlled, the electrical signal
can be related to nitric oxide concentration.
Nitrogen dioxide does not have a chemiluminescent reaction. There-
fore it must be catalytically reduced in a converter within the
instrument. Analyzers which switch the gas in and out of the
converter on a regular basis can determine the total nitrogen
oxides concentration.
4-7
-------
SLIDE 4-11
Xe
210 nm BANDPASS
FILTER
SAMPLE OUT
350 nm BANDPASS FILTER
ELECTRONICS r
PHOTOMULTIPLIER
TUBE
Pulse Fluorescence Analyzer
Source: EPA 625/6-79-005
SLIDE 4-11 LECTURE NOTES:
Ultraviolet light is used to excite sulfur dioxide molecules in the
sample gas passing through the exposure cell. A narrow bandpass
filter is used before the exposure cell so that the ultraviolet
light entering the chamber has a wavelength close to 210 nm where
sulfur dioxide absorbs very strongly. A photomultiplier tube
mounted at right angles to the cell is used to measure the light
released when these excited molecules return to a lower energy
state. A filter is used between the exposure cell and the detector
to ensure that only the fluorescent light emissions are measured.
The electrical signal generated by the photomultiplier and its
associated amplifier is proportional to the quantity of sulfur
dioxide in the sample cell.
4-8
-------
SLIDE 4-12
POROUS
ELECTRODE
Zr02 POROUS ELECTROLYTE | ELECTRON CURRENT
PREF(02) > PSAMPLE
-------
SLIDE 4-13
Gas filter
Rotating chopper disk
Sample cell
Detector
IR Source <7 ^^^ T Uo >
Measuring aperture
Extractive Type Gas Filter Cell
Correlation Analyzer
SLIDE 4-13 LECTURE NOTES:
Infrared light is passed through a sample gas cell containing the
flue gas drawn from the stack or breeching. The infrared light
penetrating this cell then passes though a rapidly rotating wheel
which contains two cells, one filled with a high concentration of
the pollutant being measured, and the other filled with nitrogen.
The detector alternatively receives the infrared light passing
through these two separate cells.
The cell filled with the high concentration pollutant gas removes
the IR light energy which escaped absorption in the sample cell.
Therefore, this cell allows the detector to establish a reference
value. When the cell containing nitrogen gas rotates into the
light path, the IR energy passing though the sample cell is trans-
mitted to the detector. The light energy detected is higher during
this part of the cycle. The difference in the two detector signals
as the disk rotates is an indication of the pollutant concentration
in the sample cell. If desired, several gas filter cells can be
mounted on the rotating chopper disk to measure these pollutants
simultaneously. This approach is being used for measuring of
hydrogen chloride.
4-10
-------
SLIDE 4-14
TYPES OF IN-SITU OEM SYSTEMS
* Differential Absorption
* Infrared Gas Correlation
Spectroscopy
* Second Derivative UV
Absorption
SLIDE 4-14 LECTURE NOTES:
All of the in-situ techniques utilize absorption spectroscopy which
is one of the three types of techniques used in extractive CEM
systems.
SLIDE 4-15
LIGHT
SOURCE
MONOCHROMETER
SYSTEM
MIRROR PHOTODETECTOR
BLOWER
CHOPPER
rJ>
In-Situ Differential Absorption Analyzer
Source: EPA 625/6-79-005
SLIDE 4-15 LECTURE NOTES:
The in-situ differential absorption instrument is similar to the
extractive type unit. A diffraction grating is used to select two
specific wavelengths from the total light beam passing through the
gas stream. One of these is the reference wavelength at which the
pollutant does not absorb light, and the other is the sample wave-
length at which it absorbs strongly. The ratio of intensities at
these two wavelengths is used to determine pollutant concentration.
4-11
-------
SLIDE 4-16
UV LIGHT MODULATED
BY GAS ABSORPTION
STACK
RETROREFLECTOR
NO CHANNEL
SCANNER
ENTRANCE
SLIT
nciURNED
SHI
I ULIKAVIOLET
LIGHT SOURCE
SEQUENTIAL
SHUTTERS S
DUAL EXIT SLITS
POROUS
WINDOW / FILTER
STACK
GAS
DIFFUSION
ABSORPTION
CHAMBER
Second Derivative Spectrometer
Source: EPA 625/6-79-005
SLIDE 4-16 LECTURE NOTES:
The second derivative spectrometer is an in-situ point monitor.
The gas sample cell is a 10 centimeter cell located at the end of
the probe. Gaseous pollutants diffuse through a ceramic thimble
which keeps particulate from entering the sensor and coating the
optical surfaces.
A diffraction grating oscillates back and forth slightly to
generate ultraviolet light having wavelengths which vary routinely
from 217.8 to 219.2 run. These wavelengths span a portion of the
sulfur dioxide absorption spectrum at which there is a sharp
absorption band. Due to the modulating wavelengths, the detector
receives a signal at a frequency which is proportional to the
second derivative of the absorption spectrum. Since sulfur dioxide
has a very sharp absorption peak in this part of the UV spectrum,
it is easy to "pick-out" this signal rrom the absorption signals
resulting from other compounds having broad band absorption peaks.
The concentration of sulfur dioxide can be related to the intensity
of the absorption which occurs at the appropriate frequency.
4-12
-------
SLIDE 4-17
LIGHT
BEAM
SPLITTER^ DETECTOR
llimiMllllWlMM*lilMltO»*""""ti
RETRO-
REFLECTOR
STACK
Double Pass Transmissometer
Source: EPA 625/6-79-005
ROTARY
BLOWER
SLIDE 4-17 LECTURE NOTES:
This slide illustrates the basic components of a double pass trans-
missometer used for monitoring the opacity of the particulate-laden
gas stream. It is similar to the gaseous pollutant in-situ moni-
tors discussed in previous slides. This instrument also uses light
in order to detect the presence of a pollutant. However, in this
case, the pollutant reduces light intensity by scattering portions
of the light beam rather than absorbing the light.
The light source and the light intensity detector are both located
in one of the modules. The retroreflector (shown on the right
side) is used simply to bounce the light beam back to the source.
This arrangement doubles the path length over which light scatter-
ing can occur, and thereby increases the sensitivity of the unit.
The blowers shown on each of the module provides a stream of clean
air around the optical windows (not shown) which are on each side.
This reduces the vulnerability of the instrument to drift or to
errors due to the accumulation of dust on the optical surfaces in
the path of the light beam. The light used in these instruments is
visible light so that the measurements correspond to the extent
possible with visible emission observations.
4-13
-------
SLIDE 4-18
TRANSCEIVER
RETROREFLECTOfl
ALIGNMENT
PORT
FAULT LAMPS
PANEL METER
i
LZH
CONTROL UNIT
ZERO
SPAN
COMPUTER
CHART
RECORDER
Components of an Opacity GEM System
Source: Peeler (1987)
SLIDE 4-18 LECTURE NOTES:
This is a drawing of the complete opacity monitoring system. The
electrical signal generated by the detector is amplified and pro-
cessed in the ground-mounted analyzer module. The analyzer also
initiates and controls the zero and span checks. A series of fault
lamps indicate if there are any mechanical or electrical problems
which could affect the accuracy of the data.
4-14
-------
SLIDE 4-19
To
Point-A-
Note: Many components not shown;
consult manufacturers drawings
when examining specific systems.
Heal Traced &
Insulated
Sample Line
CalGas
Cylinders
General Components of an
Extractive CEM System
SLIDE 4-19 LECTURE NOTES:
This is a simplified sketch of a complete extractive CEM system.
A probe with a coarse filter is used for acquiring the gas sample
at a representative location. In this particular style of unit,
the sample gas stream is kept relatively hot so that flue gas
moisture does not condense as the sample gas is brought down from
the monitoring location to the ground-mounted instruments. A
condenser is used to remove the water vapor from the sample gas.
The analyzer modules are used to measure the pollutant concentra-
tion and to perform all electronic functions necessary to generate
the concentration data fed to the data acquisition system and any
strip chart recorders.
4-15
-------
SLIDE 4-20
GEM INSTRUMENT SYSTEM
AND EMISSIONS DATA
EVALUATION
* Analyzer/sample conditioning
system evaluation
* Monitoring location checks
(if necessary)
* Instrument availability
requirements and quality
assurance test requirements
* Emissions data review
SLIDE 4-20 LECTURE NOTES:
The basic steps in evaluating the CEM systems and the emission data
are outlined in this slide. There are two basic reasons for con-
ducting the inspection in this order:
1. There are specific requirements applicable
directly to the CEM system.
2. The adequacy of the instrument systems should
be confirmed prior to spending relatively long
time periods examining the emissions data.
The first general step involves a basic inspection of the analyzer
and the source conditioning systems. These are usually at a con-
venient ground level location. The inspection checks made by plant
personnel while the inspector watches are similar to the checks
done on a daily basis. If problems are apparent during these
checks or from reports submitted by the plant, the inspection scope
includes the stack- or breeching-mounted equipment.
The records and reports generated based on the CEMs are examined
next. Plant quality assurance procedures and recprdkeeping pro-
cedures are checked for conformance with the various regulatory
requirements.
The review of the emissions data starts with the quarterly reports
submitted by the plant. Questions resulting from the preinspection
review of this information are addressed while examining the more
detailed data available on-site.
The overall process of evaluating the CEM equipment and data takes
a major fraction of the overall inspection time available. This is
justified since CEM data is especially important in evaluating
changes in emission rates at the facility.
4-16
-------
SLIDE 4-21
ANALYZER AND CONDITIONING SYSTEM CHECKS
Analyzers and Data Acquisition Systems
* Fault lamps and warning codes
* Span and zero checks
* Data acquisition system performance
Extractive Sample Conditioning Systems
* Inlet sample line temperature
* Condenser temperature
* Sample flow rate
Calibration Gas Cylinders
* Pressure and concentration
SLIDE 4-21 INSPECTION NOTES:
These checks closely parallel the daily CEM instrument checks which
are normally conducted by plant personnel. It should be Jioted that
any checks involving manual operation of the instruments should be
conducted only by qualified plant personnel. Regulatory agency
inspectors should witness, but not conduct these checks.
This portion of the inspection is relatively brief as long as the
necessary plant personnel are available. These arrangements can be
made during the preinspection meeting.
iAM^ w*-** i SO*/) ex
e*M \(*X> OA*^ CT KuXs
-------
SLIDES 4-22 AND 4-23
FAULT MONITORS
iioo lipaip^'iliiivl^
••^ffHi^'gym^ ,,101^ ^ ^Miy'i'^SMBlU'ii _
SLIDE 4-22 AND 4-23 LECTURE NOTES:
Most CEM systems have fault lamps which indicate if there are any
mechanical or electrical problems which could be affecting the
accuracy of the emissions data. In addition to these lamps on the
front panels of the instruments, there may also be warning codes or
symbols included on the data records. The presence of either type
of warning should be noted on the inspection report. Information
concerning the possible reasons for these instrument system prob-
lems should be obtained from plant personnel.
4-18
-------
SLIDE 4-24
GEM DRIFT SPECIFICATIONS
Pollutant
Opacity
SO2
NOX
O2
CO2
CO
PST
1
2
2
3
3
4
Zero
Drift
2.0%
2.5% of
2.5% of
-
—
Calibration
Drift
2.0%
span 2.5% of span
span 2.5% of span
0.5% O2
0.5% C02
0.5% of span
SLIDE 4-24 LECTURE NOTES:
These basic instrument checks are required by 40 CFR 60.13. They
are normally initiated automatically; however, they can also be
performed manually. Agency inspectors should determine what the
intended values should be before observing this check. This
information is available on the daily calibration drift records
maintained by the plant, and can also be obtained from plant
personnel. The results of the zero and span checks are then
compared against the allowable drift specifications stated in the
applicable Performance Specification Tests (abbreviated as PST in
the slide.)
It is important to note that instrument drift should be evaluated
using the main data acquisition system (DAS) used for storing the
raw data and for generating the records and reports required by the
regulations.
Adjustments to the GEMS are required whenever the zero and span
check responses exceed two times the applicable drift specification
for a period of five consecutive daily periods. The instrument is
considered "out-of-control" if the drift exceeds four times the
drift specification in the PST's at any time. Time periods when
the instrument is "out-of-control" can not be counted toward the
data availability requirement. Also, the emissions data can not be
used for demonstrating compliance during this time.
4-19
-------
SLIDE 4-25
••••••••••••••••••••••••••••••••••••••••••••••••••••••a*****
S02/NOX CALIBRATION REPORT 01:08:15
AUGUST B 1987
INDICATED
CALIBRATION
VALUE
.0 PPM
490.0 PPM
.2 PPM
473.0 PPM
.1 t
18.7 t
SO2 ZERO
SO2 SPAN
NOX ZERO
NOX SPAN
OXYGEN ZERO
OXYGEN SPAN
• NOTE: ?? INDICATES A CALIBRATION FAILURE
PREVIOUS
CALIBRATION
VALUE
0.0 PPM
450.0 PPM
0.0 PPM
471.0 PPM
0.0 »
20.9 I
t DRIFT
.0
.0
.0
.0
.1
-2.2??
Example Calibration Drift Report Format
Source: S.T.I. Tech. Bulletin
SLIDE 4-23 LECTURE NOTES:
This is one example format for maintaining the daily calibration
drift data. There is considerable diversity in the report formats
used.
The double question mark symbol shown next to the entry for oxygen
span is one example of warning "flags" used on computerized
reports.
It should be noted that plants subject to regulations similar to
the proposed NSPS would also have entries for carbon monoxide span.
4-20
-------
SLIDE 4-26
Data:
Tin*:
PERCENT REDUCTION
TRENDING GRAPHS
502 t/MBTU
S02 BEFORE
SCRUBBER
S02 AFTER
SCRUBBER
PERCENT OF
REDUCTION
.63
FULL
SCALE
1.6
1.4
1.2
1.0
is
.6
.4
.2
67 \
100
PERCENT
100
90
75
60
45
30
IS
Example DAS Terminal Display Screen
Source; S.T.I. Tech. Bulletin
SLIDE 4-26 LECTURE NOTES:
The computerized DAS systems used with the GEM instruments have the
capability to display current data in a variety of forms. Plant
personnel should be asked to call up several of the display screens
so that current data can be briefly scanned. This data should be
checked for "normality" with respect to data variability and
trends. Errors may be caused by electrical interference with the
signal carrying line or by computer related problems.
Plant personnel are generally able to provide hard copies of any of
the graphics displayed on the screens. These can be attached to
the inspection report to indicate that there is or is not a major
problem with the CEM system or the plant performance.
4-21
-------
SLIDE 4-27
Fault Panel Span 7 Chart Recorders
Lamps-v Meter-y Zero7.
SLIDE 4-27 LECTURE NOTES:
Strip chart recorders are often used as back-up systems for the
main computerized DAS. These should be checked for obvious
mechanical problems such as inoperative paper roll drives, improper
paper feed, and inking equipment failure. The dates and times
shown on the strip chart should correspond with the real clock
times.
4-22
-------
SLIDE 4-28
SLIDE 4-28 LECTURE NOTES:
Sample lines for extractive-type CEM systems must be kept heated
from the stack or breeching down to the condenser. The outer
temperature of the insulation surrounding the sample lines should
be felt to confirm that the heaters are working. It should feel
moderately warm to the back or the hand.
If the sample line has been cold for an extended time period, it is
possible that corrosion and solids build-up are occurring. It is
also possible that some loss of soluble pollutants is occurring.
This condition can lead to several significant measurement errors.
It should be noted that extractive systems with dilution probes are
not kept hot. For these instruments, condensed water problems are
avoided by keeping the diluted sample gas stream below the dewpoint
of the sample gas.
4-23
-------
SLIDE 4-29
SLIDE 4-29 LECTURE NOTES:
The condenser liquid bath temperature as indicated by the dial-type
thermometer in this slide should be maintained between 35 and 45
degrees Fahrenheit. Inadequate removal of water vapor can create
the potential for analyzer damaqe. It can also affect the accuracy
of the emission concentration measurement since the instrument is
no longer receiving a "dry" sample gas. The presence of water
vapor would cause lower-than-actual concentration values.
Bath temperatures lower than 35 degrees Fahrenheit are not
desirable. If freezing occurs around the sample line coils, heat
transfer is substantially reduced. Accordingly, less water vapor
may be condensed as the sample gas stream passes through the coils
in the condenser.
Plant personnel should be routinely checking the moisture traps
within the condenser and the coalescing filter downstream of the
condenser to see if water is being routinely discharged.
4-24
-------
SLIDE 4-30
SLIDE 4-30 LECTURE NOTES:
The sample gas flow rates to each of the gaseous pollutant analy-
zers should be checked against the minimum flow requirements stated
in the instrument manufacturer's specifications. This information
may also be available in the written operating procedures for the
CEM systems. Inadequate sample gas flow rates or significant
changes in sample gas flow rates can affect the accuracy of the CEM
data.
4-25
-------
SLIDE 4-31
SLIDE 4-31 LECTURE NOTES:
The gas cylinders shown in this slide are located immediately
adjacent to the ground level CEM analyser trailer. These gases are
used for the daily calibration ptf^ft ttests, but not for the quar-
terly audits discussed later in this lecture.
The indicated concentrations bf each of these cylinders should be
checked and compared against the span Values determined earlier.
The pressures should be above uSO^sig/since some changes in con-
centration are possible at lessVthan £nis pressure.
Also, the date when these gas samples were prepared should be
checked. Compressed gas samples older than 6 months may have suf-
fered some concentration changes.
4-26
-------
SLIDES 4-32 AND 4-33
STACK/BREECHING INSPECTION CHECKS
All Instruments
* Upstream air infiltration
Extractive Monitoring Systems
* Sample line insulation temp.
* Obvious probe corrosion
* Location of audit gas injection
STACK/BREECHING INSPECTION CHECKS
In-Situ Monitors (Cross-Stack)
* Purge air blowers
* Purge air hoses
* Purge air filters
* General physical conditions
* Module registration numbers
* Wall/pipe deposits
* Window cleaning
* Alignment
In-Situ (Point)
* General physical conditions
* Location of audit gas
injection
SLIDES 4-32 AND 4-33 LECTURE NOTES:
The stack/breeching CEM component checks are not in themselves time
consuming or difficult. However, it is sometimes necessary to
climb 50 to 100 feet in order to reach this equipment. Due to the
time required, these inspection checks are normally included in the
inspection only when there are some indications of CEM instrument
problems. These symptoms could include chronic drift problems,
extensive out-of-service periods, or conditions observed during the
zero/span checks performed earlier.
The scope of the stack/breeching CEM equipment checks are listed on
the two slides reproduced above. Obviously, the effort required
for in-situ monitors is greater than that required for extractive
type systems.
4-27
-------
SLIDE 4-34
SLIDE 4-34 LECTURE NOTES:
One of the most significant errors in emission monitoring is the
presence of a significant air infiltration source immediately
upstream of the instrument sampling or monitoring location. This
can cause much lower-than-actual concentration and opacity measure-
ments. Accordingly, the stack and/or breeching upstream of the CEM
equipment should be observed to the extent possible. The most
common causes of air infiltration include cracks in expansion
joints, holes through corroded breechings, and open stack sampling
ports.
This slide shows a portion of an expansion joint. These are used
to permit thermal expansion and contraction of the various vessels
and breechings used in the system. They also dampen any vibration
created by rotating equipment. Expansion joints are invariably
subject to flex wear and chemical attack. When the fabric begins
to fail, air can rush through the cracks. The localized cooling
caused by the initial air infiltration conditions can accelerate
further deterioration by allowing some condensation of corrosive
gases.
Expansion joints occasionally require replacement regardless of how
well the facility ^as been operated.
4-28
-------
SLIDE 4-35
SLIDE 4-35 LECTURE NOTES:
Cracks around the mountings for in-situ monitors are less common
than cracks in expansion joints. However, such leaks can develop
over time if the duct insulation was incompletely replaced after
the CEM unit was installed. The poorly insulated area can suffer
corrosion due to acid gas absorption in the condensed water layer
on the inside of the duct.
This slide shows one side of a double pass transmissometer. The
outer lagging apparent to the left of the instrument appears to be
properly installed. Although the thermal insulation can not be
seen, it is likely that it also has been completely wrapped around
the duct. In this case, gradually worsening corrosion and air in-
filtration problems are not likely.
If problems are suspected, an attempt should be made to hear the
somewhat characteristic sound of air inleakage through small cracks
and holes while standing next to the CEM mountings. Significant
leaks can usually be heard as long as the general noise levels are
not too high.
The leaks can usually not be seen since the outer lagging used for
weather protection hids the ductwork cracks and holes. The lagging
itself is not an effective barrier.
4-29
-------
SLIDE 4-36
SLIDE 4-36 LECTURE NOTES:
Another common site of air infiltration is open or partially open
sampling ports. These are usually 2 to 5 inch I.D. ports which
have caps, plugs, or blind flange type closures to prevent air in-
filtration. These can be especially troublesome since they are
often located in the immediate vicinity of the CEM components.
This slide shows a set of three of these ports. They are located
approximately 5 to 10 feet above the opacity monitor. As the gas
stream moves downward in the duct, any air which leaked in these
ports could affect the opacity monitor. Also, the extractive probe
for a set of CEMs is located on the same platform as the opacity
monitor. In this case, all of the blind flanges appear to be
bolted tightly, and there was no significant infiltration.
These ports are occasionally left open when a malfunctioning sensor
(such as a dewpoint analyzer or temperature monitor) has been
temporarily removed from service. They may also be left open after
special sampling tests to check for pollutant stratification or gas
flow distribution in the vicinity of the CEMs.
4-30
-------
SLIDE 4-37
LIME SILO AND
FEEDING SYSTEM
AMBIENT
AIR
INDUCED —STACK
DRAFT
FAN
AXIAL FANS
SLIDE 4-37 LECTURE NOTES:
CEM systems are especially vulnerable to localized air infiltration
problems when the monitor or probe is immediately upstream of the
induced draft fan for the incinerator. At this location, the
static pressure within the duct can be minus 10 to minus 15 inches
of water (well below ambient pressure). For this reason, large
quantities of air can leak through even small cracks and holes.
Air infiltration is less of a problem in stack mounted units since
the static pressure here is at most a minus 0.25 to minus 0.50
inches of water.
Despite the potential problems with air infiltration, the breeching
locations are often preferred. They are much more accessible for
routine maintenance and inspection of the CEM equipment.
4-31
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SLIDE 4-38
SLIDE 4-38 LECTURE NOTES:
The external portions of the extractive probe should be visually
checked for any obvious corrosion. In extreme cases, this
corrosion could create small pinhole type air leaks into the probe.
Obviously, the dilution effect of these leaks could cause major
errors in the measured pollutant concentrations.
The condition of the exterior portion of the probe is also indica-
tive of the condition inside the stack or breeching. If the inside
portion of the probe has corroded, the internal coarse filter may
not be effective and the sampling location may simply be the places
where corrosion is the worst.
These problems could conceivably be missed during the quarterly
accuracy tests. The calibration gas used in some of these tests
may be injected at a point downstream of the corroded portions of
the probe.
This slide shows the exterior portions of an extractive probe.
This unit is in good condition.
4-32
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SLIDE 4-39
SLIDE 4-39 LECTURE NOTES:
The adequacy of the extractive sample gas line heaters should be
checked by touching the outer surface of the insulated portion of
the line. If this surface is close to ambient temperature, the
heaters are probably not working properly, and long term deterior-
ation of the sampling lines is likely.
The sample line itself or any exposed metal parts of the probe
should not be touched directly. These can be at temperatures
ranging from 250 to 400 degrees Fahrenheit depending on the mon-
itoring location.
Any uninsulated portions of the sample line downstream of the probe
should be noted. Generally, the sample line can be checked only
where it starts on the sampling platform and where it stops at the
gas conditioning system.
4-33
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SLIDE 4-40
SLIDE 4-40 LECTURE NOTES:
The purge air stream directly into the mounting pipes of in-situ
monitors serves the following three functions.
* Reduces dust and moisture deposition on optical surfaces
* Reduces solids accumulation in the horizontal surfaces
* Reduces heat transfer from the hot effluent gas stream
to the instrument
The purge air blowers should be operating at all times, even when
the incinerator is out-of-service. These are checked by having the
plant personnel open the weather covers and listening for the sound
of the blower operation.
4-34
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SLIDE 4-41
SLIDE 4-41 LECTURE NOTES:
One or more dust filters are used to ensure that the purge air
stream is clean. These filters can be the leaf-type filters
similar to automobile filters, or they can be canister type
filters. A partial view of a leaf-type filter is shown in the
above slide.
The purge air stream leaving the blower and entering the instrument
mounting pipe is under positive pressure. Any leaks through the
hose will reduce the quantity of purge air flow used to protect the
instrument. The integrity of the hoses should be visually checked.
4-35
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SLIDE 4-42
LIGHT
11 RETRO-
\ \ REFLECTOR
.\Lrr>-^=
MIIIIIIUIIIIIIIIMIIIIIIIIIMlmllllllllll
BEAM
SPLITTER DETECTOR h
ROTARY
BLOWER
General View of Double Transmissometer
Source: EPA 450/2-84-004
SLIDE 4-42 LECTURE NOTES:
Any severe environmental conditions around the in-situ monitor
should be noted in the inspection report. Temperatures above 120
degrees Fahrenheit may cause severe zero and span drift or fre-
quent electronic component failures. Temperature problems are
often caused by heat radiation from adjacent hot equipment or poor
ventilation of instruments around generally hot areas of the plant.
Some protection of the instruments is necessary in both cases.
Vibration due to improper instrument mounting can fatigue the
electrical connections and damage the optics. Very moist
conditions due to steam vent discharges or other moisture sources
can adversely affect the purge air stream quality and thereby
contribute to condensation on the optical surfaces.
4-36
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SLIDE 4-43
SLIDE 4-43 LECTURE NOTES:
If the instrument has been experiencing drift problems, gradual
build-up on the optical windows may be responsible. The change
resulting from cleaning the windows can be used to confirm this
problem.
In order for this to be a practical test, the opacity (or gaseous
pollutant concentration) must be relatively stable. Frequent,
severe spiking will obscure any slight step decreases in the
indicated value.
Obviously, only plant personnel trained in servicing the instru-
ments should deactivate the units and clean the optics. It is
possible, although not highly likely, to scratch these surfaces and
to leave smears.
4-37
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SLIDE 4-44
SLIDE 4-44 LECTURE NOTES:
While the instrument has been opened to clean the optics, the pres-
ence of deposits in the mounting pipe should be noted. The
deposits are often due to intermittent failure of the purge air
blowers. They can also be caused by condensation on the inner
walls of the stack which accumulates on the horizontal surfaces of
these pipes. Dust trapped in this moisture layer can form a hard
deposit. Any obstacles in the light beam path can affect the
accuracy of the instrument by causing higher-than-actual concen-
tration readings.
4-38
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SLIDE 4-45
SLIDE 4-45 LECTURE NOTES:
Misalignment of the source and retroreflectors on cross-stack in-
situ instruments causes higher-than-actual readings. For this
reason, the alignment is checked whenever the values appear higher
than would be expected based on the air pollution control equipment
performance or based on visible emission observations made during
an early part of the on-site evaluation.
All units installed since 1983 are required by the PST's to have a
means to visually confirm the alignment. Plant personnel trained
to work on the instruments can provide the assistance necessary for
agency inspectors to visually check the alignment. This slide
illustrates the alignment viewing window on one commercial style of
transmissometer. In this case, it is necessary to set the unit to
alignment mode by rotating a switch on the lower side of the case.
This should be done by plant personnel since moving this switch
activates an alarm in the control room.
4-39
-------
SLIDE 4-46
SLIDE 4-46 LECTURE NOTES:
Alignment is checked in this type of instrument by looking at the
target visible through this scope. A switch must be activated in
order for this target to be in view.
With both styles of instruments shown in the last two slides, the
light beam is observed hitting within a prescribed target if align-
ment is proper. Misalignment is indicated when the light beam
is outside the circle.
4-40
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SLIDE 4-47
SUMMARY - CEM EQUIPMENT INSPECTION
* Analyzer, extractive sample gas
conditioning system and data
acquisition system
* Stack- and breeching-mounted
components
SLIDE 4-47 LECTURE NOTES:
The purpose of the equipment oriented inspection steps is to con-
firm that the CEMs are operating as required by the portions of
Appendix F (reproduced in appendix of this manual) which are
specified in the proposed NSPS. . The data and observations are also
used in determining if there are any instrument problems which may
be affecting the accuracy or completeness of the data submitted by
the plant on a routine basis.
An evaluation of - the analyzers and sample conditioning systems
(extractive-type units) are a logical starting point. These are in
readily accessible locations and relatively brief checks provide
revealing information concerning the overall adequacy of the
instrument system.
Stack- and breeching-mounted equipment checks are conducted only on
an as-needed basis. These are more time consuming because of the
climb necessary to reach this equipment. However, they are useful
in determining if the plant personnel have identified and corrected
the fundamental reasons for chronic instrument problems. Only
plant personnel should operate or adjust the instruments during
these inspection steps. Agency inspectors should function as
observers.
4-41
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SLIDE 4-48
GEM RECORDS AND REPORTS
Applicable Appendix F Requirements
* Daily calibration drift
* Quarterly accuracy tests
Instrument Data Availability
Emissions Data Format
* Averaging time
* Method 19 calculations
SLIDE 4-48 LECTURE NOTES:
The proposed NSPS regulation and the applicable CEM regulations
included in 40 CFR Part 60 include -a number of report and record-
keeping requirements. This next phase of the inspection evaluates
the plant compliance with these requirements.
Not all of the Appendix F requirements apply to municipal waste
incinerators subject to the revised/proposed NSPS. However, daily
calibration drift tests and quarterly accuracy tests must be con-
ducted. Reports concerning these tests must be submitted on a
quarterly basis. Accordingly, inspectors should have an oppor-
tunity to review these reports prior to the on-site inspection.
These tests are briefly described in this lecture. They are more
fully discussed in numerous EPA sponsored publications.
1::e proposed NSPS standard specifies a minimum CEM data avail-
ability. While on-site, the inspector should confirm that the
proper procedures are being used to calculate the availability.
Also, any chronic or repetitive problems should be discussed with
plant personnel.
The emissions data format and calculation procedures are specified
in the proposed NSPS. It would be very unusual for there to be
errors in either of these since there are incorporated into the
computerized data acquisition system algorithms. Superficial
checks are made by observing various data display screens. If
there are substantial concerns about the Method 19 procedures, a
special inspection devoted to this subject would be necessary.
4-42
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SLIDE 4-49
APPLICABLE APPENDIX F REQUIREMENTS
Conduct daily calibration drift
tests
Conduct quarterly accuracy tests
* One relative accuracy test
audit (RATA) every four quarters
* Up to three relative accuracy
audits (RAA) every four quarters
* Up to three cylinder gas audits (CGA)
every four quarters
SLIDE 4-49 LECTURE NOTES;
The Relative Accuracy Test Audit (RATA) is a test which is ident-
ical to the test procedure specified in the applicable Performance
Specification Test (PSTs) for the material being monitored. A list
of the PSTs is provided below.
Opacity Performance Specification Test 1
SO2, NOx Performance Specification Test 2
O2, CO2 Performance Specification Test 3
CO Performance Specification Test 4
The RATA is a comparison of the CEM output with the values obtained
using an EPA Reference Test Method. Either manual or instrumental
reference tests methods may be used.
Instrumental EPA Reference Tests Methods
Method 3A, Oxygen/Carbon Dioxide
Method 6C, Sulfur Dioxide
Method 7E, Nitrogen Oxides
If the relative accuracy exceeds the limits specified in the PST,
the plant's CEM instruments is considered "out-of-control" from the
moment that the test program is completed.
4-43
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SLIDE 4-50
PST DATA ACCURACY LIMITS
PST 2 < 20% of the mean value of
the reference method or
10% of the applicable
standard, whichever is
greater
PST 3 < 20% of the mean value of
the reference method or
1.0% O2, or CO2,
whichever is greater
PST 4 < 10% of the mean value of
the reference method or
5% of the applicable
standard, whichever is
greater
SLIDE 4-50 LECTURE NOTES:
The data accuracy limits specified in the PST's are summarized in
this slide. A complete copy of the PST's has been included in an
appendix to this manual.
4-44
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SLIDE 4-51
OTHER TYPES OF QUARTERLY
ACCURACY TESTS
* Relative Accuracy Audits
* Cylinder Gas Audits
SLIDE 4-51 LECTURE NOTES:
The Relative Accuracy Audit (RAA) is similar to the RATA test
discussed earlier. The difference is that there are less individ-
ual test series in the RAA tests. Another difference is in the
relative calculation. The RATA includes a statistical value for
precision while the RAA is a straight comparison of average values.
The cylinder gas audit test is performed by injecting a known
concentration of NBS/EPA traceable gas into the instrument (or
extractive sample line). At least two different concentrations
must be used as indicated by the table shown below which has been
reproduced from EPA regulations. ' — ~
Cylinder Gas Audit Concentrations
Audit Point
Pollutant Monitors
20 to 30% of span value
50 to 60% of span value
Diluent Monitors for
co2 o2
5 to 8% 4 to 6%
by volume by volume
10 to 14% 8 to 12%
by volume by volume
A separate gas cylinder must be used for each separate concen-
tration rather than attempting to dilute one cylinder.
4-45
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SLIDE 4-52
ACCURACY LIMITS FOR
RAA AND CGA TESTS
RAA Tests -
Plus or minus 15% of
the reference test
method or 7.5% of
the applicable
standard
CGA Tests - Plus or minus 15% of
the actual concentration
SLIDE 4-52 LECTURE NOTES:
The accuracy limits when using the CGA test and the RAA test are
stated in the above slide. These are different than the accuracy
limits when using the RATA test.
If the CEM instrument does satisfy these accuracy limits, it is
considered to be "out-of-control."
Example data recording forms for a RATA test series and-"a CGA test
series are shown in Appendix D to this manual. A complete Data
Assessment Report: form (required to be submitted quarterly) is also
included. Inspectors should confirm that the tests are being con-
ducted at the required frequency and that the plant personnel are
responding when the accuracy limits are exceeded.
4-46
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SLIDE 4-53
CEM MINIMUM DATA AVAILABILITY,
PROPOSED NSPS REQUIREMENTS
75% of operating hours each day
for 75% of the operating days
each month
SLIDE 4-53 LECTURE NOTES:
Compliance with this requirement is determined during the review of
the quarterly excess emission reports and data assessment reports.
This occurs before the inspection, not while on-site. However, if
there are questions concerning instrument availability, the cal-
culations can be spot checked for one or more days. The daily
incinerator operating logs can be reviewed along with the CEM
instrument operation and maintenance logs. Any incorrect cal-
culation procedures can be resolved following these checks.
Plant personnel ^hould not include any time periods during which
the instrument is "out-of-control" due to either calibration drift
or due to accuracy tests. The unit is considered "out-of-control"
immediately after the test that identified the problem, and it
remains so until another test is completed which demonstrates
adequate performance.
The time periods during incinerator startup and shutdown should
generally be included unless there are specific agency policies to
the contrary.
In checking data availability problems, the inspector's attention
should focus on gaseous pollutant monitors. Opacity monitors
generally operate with availabilities of 90 to 95%.
4-47
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SLIDE 4-54
AVERAGING TIME REQUIREMENTS
PROPOSED NSPS REGULATION
Opacity
Sulfur Dioxide,
Nitrogen Oxides
Carbon Monoxide
6 -Minute averages
average of
hourly average emission
rates from midnight to
midnight
Arithmetic average of
hourly average emission
rates for 4 -hour block
periods
SLIDE 4-54 LECTURE NOTES:
The CEM data should be prepared in the averaging time formats
specified in the applicable regulation. In the case-of the pro-
posed NSPS, the averaging times are shown in the above slide. The
use of the proper averaging times can be confirmed by. requesting
operators to display several data screens using the computerized
DAS system terminal.
SLIDE 4-55
METHOD 19 CALCULATIONS
SLIDE 4-55 LECTURE NOTES:
The emission calculations must be performed using EPA Reference
Method 19 procedures (copy provided in appendix to this manual) .
These procedures are included within the software algorthim of the
DAS. It is beyond the scope of a routine inspection to check that
the proper calculations are being used. However, an inspection
specifically for this purpose can be scheduled if necessary.
4-48
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SLIDE 4-56
SUMMARY - CEM RECORDS AND REPORTS
* Applicable Appendix F requirements
* Data availability requirements
* Data averaging time requirements
SLIDE 4-56 LECTURE NOTES:
Compliance with the requirements pertaining to CEM records and
reports is primarily evaluated before the on-site inspection. It
some cases, spot checking of records and calculation procedures may
be necessary during the inspection to confirm that the operators
have properly interpreted these requirements and procedures.
4-49
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REVIEW QUESTIONS - CONTINUOUS EMISSION MONITORS AND DATA
Directions: Select the answer or answers which are correct.
1. Adjustments to the CEMs are required whenever the zero and span
check responses exceed
a. the applicable drift specification for three consecutive
/^ daily periods.
\b_) two times the applicable drift specification for five
consecutive daily periods.
c. four times the applicable drift specification on any one
daily test.
d. four times the applicable drift specification on two
consecutive daily periods.
2. What problems may occur if the electrical heating system for an
extractive sample line has failed?
Soluble pollutants could be absorbed into condensed water
layers resulting in lower-than-actual concentrations.
b. Corrosion of the sample line could occur.
c. The moisture content of the sample gas would be reduced
and this_would affect the apparent pollutant concentration
3. Can air infiltration upstream of the CEM sampling location
affect the accuracy of the pollutant concentration measurements
if the values are corrected to 7% oxygen using the oxygen
analyzer?
a. No. That is the main purpose for having the oxygen
analyzer and for correcting the concentrations to a
standard condition
b. Yes. The gas stream passing the probe or in-situ
monitor may be very stratified due to the entry of
cold ambient air at the surface of the duct.
c. Yes. The infiltrating ambient air stream could affect
the pollutant monitor but not be sensed by the oxygen
analyzer due to stratification problems.
4. If a double pass transmissometer is out-of-alignment, will the
indicated opacity be higher or lower than actual?
Higher
Lower
5. How often must a Relative Accuracy Test Audit (RATA) be
conducted?
a. Quarterly
(B}> Once every four quarters
c. Once every three years
4-50
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5. EVALUATION OF COMBUSTION PRACTICES
The purpose of the combustion system evaluation is to determine
compliance with the various specific requirements included in the
proposed NSPS regulations and in promulgated State and local regu-
lations. The compliance requirements are designed to prevent
conditions which are conducive to the formation of dioxins and
furans. They are also intended to minimize the emission of vola-
tile metal-containing particulate matter.
SLIDE 5-1
PRIMARY DATA AND OBSERVATIONS
Operating Rate
Auxiliary Burner Operation
Carbon Monoxide Emissions
Combustion Temperature -tt-v r
Ash Burnout
Ash Fugitive Emissions
SLIDE 5-1 LECTURE NOTES:
The primary inspection data is obtained during each on-site
inspection. This data is used for three purposes.
* To document the operating conditions of the facility
during the on-site visit
* To confirm that ash fugitive emissions are being
adequately controlled and that the ash burnout
is similar to conditions observed during the initial
facility compliance tests
* To document that the required records and reports concerning
carbon monoxide concentrations, incinerator operating rate,
and furnace temperature (if applicable) adequately represent
the combustion conditions
The on-site inspection is the only opportunity for the agency to
determine if the incinerator bottom ash is being properly handled.
It is also important to confirm that the quarterly compliance
reports used as one of the main foundations of the overall compli-
ance determination are representative of actual conditions.
5-1
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SLIDE 5-2
COMBUSTION PRACTICES
FOLLOW-UP DATA AND OBSERVATIONS
Incinerator or Boiler Draft
Effluent Gas oxygen Concentrations
Combustion Air Supply Pressures
Overfire Air Pressures
Fuel/Ash Bed Distribution
ESP Operating Conditions
Fabric Filter Operating Conditions
Wet Scrubber Operating Conditions
NOX system Operating Conditions
Stack Opacity
SLIDE 5-2 LECTURE NOTES:
The follow-up operating data and observations are included within
the scope of the inspection when chronic problems have been noted
in the quarterly compliance reports or when the primary inspection
data suggests possible problems. Only those steps directly rele-
vant to the suspected problems should be included.
The data is obtained from two sources. The present operating con-
ditions are recorded directly from the plant's instruments in the
control room. Both the average value and the short term vari-
ability are noted. This data is used along with any equipment
observations to characterize performance during the inspection.
Combustion system operation during the previous year (or since the
last inspection) should be evaluated by checking the plant's oper-
ating logs or computerized data sheets. The previous data should
be compared against the values observed during the inspection and
the baseline data recorded by agency personnel during the initial
set of compliance tests conducted when the source became subject to
the regulatory requirements.
The air pollution control device operating conditions have been
listed on this slide simply to emphasize that the performance of
these units is not independent of the combustion system. If there
are possible combustion problems, inspectors should be prepared to
conduct more detailed than usual inspections of the air pollution
control systems. The specific inspection steps for this equipment
are discussed in later portions of the course.
5-2
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SLIDE 5-3
INCINERATOR OPERATING RATE
* Extended Unscheduled outage
of One of the Units at the
Plant
* Short Term Increase in Paper
and Plastics Content of
Wastes
* Inaccurate steam Flow Rate
Meter
SLIDE 5-3 LECTURE NOTES:
The operating rate of the incinerator or boiler is measured by the
steam flow meter. These instruments are normally accurate to plus
or minus 5%, and they are not especially vulnerable to the various
problems which can affect other instruments at the facility.
However, if there are any questions concerning the accuracy of
these meters, they can be checked by comparing the indicated steam
flow rate against the feed water flow rate. The flows, expressed
in terms of pounds per hour, should be very similar. Also, the
steam flow rate can be qualitatively checked by comparing the steam
flow rate and the power generation rate (where applicable). The
proposed NSPS regulations do not include specific quality assurance
requirements pertaining to the steam flow rate meter.
The operating rate ujLJiour block average) must be below .&feAmaximum
operating rate determined during the initial compliance tests.
Some of the possible reasons for exceeding this limit are listed in
the above slide. The first of these is the most common since many
facilities have contractual obligations to burn a set quantity of
waste. There can be substantial financial penalities if a portion
of this waste must be landfilled.
Short term variations in the incinerator load may be caused by
wastes containing large quantities of paper or plastics, both of
which have high heating values. However, these variations are not
usuallysevere enough to increase the incinerator operating rate
over a/X jhour time period.
Hux:
5-3
-------
CO
SYMBOLS
TEMPERATURE
(T) PRESSURE
(BP) QAS STATIC PRESSURE
(7) FLOW
MOTOR CURRENT
OA») BURNER FUEL
(»t) OXYGEN
O
w
U1
I
U1
ISISIMMMMMM
-------
SLIDE 5-5
"Due \t>:
HIGH CO LEVELS
* Severe Air Infiltration
* Overcharging
* Inadequate Overfire Air
Pressures
* Poor Fuel-Air Distribution
on the Grates
SLIDES 5-4 AND 5-5 LECTURE NOTES:
Carbon monoxide is a useful indicator of the adequacy of combustion
because it is an especially difficult gas to oxidize. The reaction
shown below does not go to completion unless there is sufficient
oxygen and temperature.
CO
0.5 O,
CO,
When the CO levels exceed the 150 to 300 ppm range, it is possible
that emissions of dioxins, furans, and other partial oxidation
products increase.
The carbon monoxide can be monitored either in the stack or down-
stream of the boiler (as indicated in Slide 5-4). An oxygen meter
is necessary to correct the data to the equivalent CO levels at 7%
oxygen. The CO data is further processed to provide concentrations
on a 4-hour block average basis. This is the type of data used for
evaluating CO emissions.
Some of the possible reasons for high CO emissions are listed in
Slide 5-5. Severe air infiltration, especially in the incinerator
ash pit and the furnace area, reduces flue gas temperatures below
the level at which the reaction above can proceed. Overcharging
the incinerator, in some cases, can create lower than desirable
oxygen levels in localized areas of the furnace. Carbon monoxide
in the flue gas passing through these areas is not oxidized.
f
Both inadequate overfire air pressures and poor fuel-air distri-
bution on the grates create nonuniform combustion conditions. As
in the case with overcharging, carbon monoxide can be formed in the
fuel-rich areas having low oxygen concentrations.
5-5
-------
SLIDE 5-6
SLIDE 5-7
HIGH CO LEVELS
SEVERE AIR INFILTRATION
* High Effluent Gas 02
Concentrations
* Reduced Furnace Gas
Temperatures ;
* Audible Air Leaks
(In Some Cases)
SLIDES 5-6 AND 5-7 LECTURE NOTES:
Severe air infiltration can develop due to the frequent thermal
expansion and contraction of the incinerator and due to the gradual
deterioration of packing/sealing materials. This conditions is in-
dicated clearly by consistently higher-than-baseline oxygen levels
immediately downstream of the incinerator. The incinerator furnace
gas temperatures also are consistently lower. Audible air infilt-
ration can be detected only in the most extreme cases.
5-6
-------
SLIDE 5-8
JHIGH C6 LEVELS
OVERCHARGING
* Incinerator Draft Approaching
0.0 Inches or Frequently
Swinging Positive
* incomplete Ash Burnout -
* Reduced O2 Concentrations
SLIDE 5-8 LECTURE NOTES:
The data and observations listed in Slide 2-8 is intended to docu-
ment that overcharging conditions indicated by the steam flowmeter
are having a direct impact on the combustion conditions in the
incinerator.
fhe incinerator ".draft11 is the static pressure in the incinerator
urnace area. It is monitored by a simple manometer or differ-
ential pressure gauge, which is monitored in the control room. The
average value and variability of the instantaneous values should be
noted if overcharging is occurring. This data should be compared
against baseline levels for that specific combustion unit. For most
systems, this static pressure is in the range of -0.05 to -0.20
inches of water. Deviations in either direction from the baseline
levels indicate combustion problems. Overcharging conditions
generally cause less negative (closer to ambient pressure) values
due to the inability of the induced draft fan to withdraw all of
the combustion products being formed.
The average oxygen levels should be compared against baseline
levels to document the effect of the overcharging condition.
The general relationship between oxygen concentration and carbon
monoxide concentration is shown in Slide 2-59.
The ash burnout should be qualitatively evaluated since this a
clear indication of the adequacy of combustion. The presence of
substantial quantities of carbonaceous material or partially com-
busted waste should be noted if overcharging is occurring during
the inspection. Ash burnout is discussed in more detail later in
this lecture.
5-7
-------
SLIDE 5-9
SLIDE 5-10
HIGH CO LEVELS
LOW OVERFIRE AIR PRESSURES
* Low Overfire Air Pressures
* Increased Incinerator Draft
SLIDES 5-9 AND 5-10 LECTURE NOTES:
High CO levels can be caused by inadequate overfire air pressure
(sloped grate incinerators and by improper firing practices. The
overfire air pressure is important since this air stream is used to
mix the volatile matter released from the grates with combustion
air. A reduction in the overfire air pressure from baseline levels
may indicate reduced turbulent mixing and lower overfire air flow
rates. The overfire air pressures are usually in the range of 10
to 50 inches of water. Overfire air manifolds for an incinerator
are shown in Slide 5-9.
5-8
-------
SLIDE 5-10 LECTURE NOTES (Continued):
Operation of sloped grate type incinerators with very high drafts
(more negative than 0.20 inches of water) can disrupt oxidation
reactions in the incinerator furnace. The large quantities of
relatively cold air reduce the rate of oxidation reactions.
SLIDE 5-11
HIGH CO LEVELS
POOR FUEL-AIR DISTRIBUTION
* Obvious Piles and Thin
Spots on Grates
* Highly Nonhomogeneous Wastes
SLIDE 5-11 LECTURE NOTES:
In grate type incinerators, high carbon monoxide emissions can be
caused by fuel-air distribution on the grates. Highly nonuniform
waste layers on the grates can create fuel-rich conditions.
The waste layers can be observed through hatches mounted along the
side walls of the incinerators. However, hatches which do not have
protective glass shields in place should not be used since metal
fragments from aerosol cans and other wastes can cause eye
injuries.
Poor waste distribution on the grates could be caused by highly
nonuniform waste sizes in the charge material. If this is observed
while looking into the incinerator, the characteristics of the
wastes being charged should be further evaluated at the tipping
floor.
5-9
-------
SLIDE 5-12
FURNACE TEMPERATURE
IMMMMMMMMMMXIM
SLIDE 5-13
LOW FURNACE TEMPERATURES
POSSIBLE CAUSES
* Severe Air Infiltration
* Wet Wastes
* High Excess Air Rates
* Waste Charging Interruption
* Temperature Measurement Error
SLIDE 5-12 AND 5-13 LECTURE NOTES:
Furnace temperature (exit gas temperature) is used as follow-up
information when evaluating possible overcharging problems and air
infiltration problems. Minimum values also are specified in some
State and local agency regulations. For both reasons, the furnace
temperature data during the inspection is often checked.
5-10
-------
SLIDES 5-12 AND 5-13 LECTURE NOTES (Continued):
This temperature can be monitored at the top of the incinerator or
after the first set of boiler tubes in the superheater area (Slide
5-12). Lower than baseline temperatures at a given incinerator
load may indicate combustion system performance problems.
If the temperature records indicate that the values are consis-
tently lower than the baseline values, severe air infiltration or
temperature measurement errors are possible. Firing with too high
excess air rates is indicated by oxygen levels above the baseline
levels and normally above the 12% level.
SLIDE 5-14
•>*••<"• •rv^s*
y^-*^- 4K
-JT^TI
-latf* kf&
SLIDE 5-14 LECTURE NOTES:
Low temperature excursions occurring on a short term basis or on a
seasonal basis may be due partially to wet wastes. The moisture
content of the wastes can be evaluated qualitatively while watching
the charging practices near the tipping floor. Low temperature
conditions may be caused by the charging of large quantities of
yard waste. The fluctuations in waste moisture content can be
minimized by the mixing wastes in the tipping floor area.
5-11
-------
SLIDE 5-15
FURNACE TEMPERATURE
MEASUREMENT PROBLEMS
* Slagging/Blinding
* Radiation Heat Loss to
Adjacent Boiler Tubes
* Radiation Heat Input
From Flames
* Nonrepresentative
Measurement Location
SLIDE 5-15 LECTURE NOTES:
The exit gas temperatures being monitored range between 1600 and
2000 degrees Fahrenheit. These very high temperatures are diffi-
cult to monitor, and several problems can affect the accuracy of
the measurement.. For these reasons, a downstream temperatures
gauge can used as a "back-up" for the high temperature monitor. If
the downstream gauge (Slide 5-16) have not changed from baseline
levels (at a given incinerator load), then indicated changes in the
high temperature monitor may be questioned.
SLIDE 5-16
FURNACE TEMPERATURE
DOWNSTREAM" TEMPERATURE
5-12
-------
SLIDE 5-17
SLIDE 5-17 LECTURE NOTES:
One monitoring problem which can significantly affect the indicated
temperature is thermal radiation from the temperature probe to
colder surroundings. As shown in Slide 5-17, the probe is often
surrounded by heat exchange surfaces which are several hundred
degrees cooler than the probe. Radiation from the probe to these
cooler materials can be significantly since the rate of heat trans-
fer is proportional to the fourth power of the absolute tempera-
ture. This could create lower-than-actual indicated temperatures.
Radiation from the flames above the active combustion area could
cause the opposite condition since these temperatures exceed the
surface temperature on the probe. The extent to which flame
radiation affects the measurements depends on the position of the
probe.
5-13
-------
SLIDE 5-18
SLIDE 5-19
THERMOOOUP1£
FLUEQASTO
WASTE HEAT
BOILER AUC
INDUCED
DRAFT FAN
RAUSAND'
UNDERFIRE
AIR NOZZLES
AUXILIARY GAS-FIRED
BURNER (USUALLY OFF)
BURNER FAN
(USUALLY ON)
TIPPMO
FLOOR
'FORCED DRAFT FAN
SLIDES 5-18, 5-19, AND 5-20 LECTURE NOTES:
Other temperature measurement problems include slagging of the
probe and nonrepresentative measurement locations. The potential
for slagging-related blinding of the measurement probe is shown in
Figures 5-19 and 5-20. Slide 5-19 is an exterior view of two
thermocouples and a static pressure tap on the discharge side of
the secondary chamber of a starved air incinerator. The location
of Slide 5-19 is indicated on the drawing shown in Slide 5-18. An
interior view of the two thermocouple probes is shown in Slide
5-20. The slagging condition has completely blinded the static
pressure tap and it is starting to accumulate around the tempera-
ture probes. If this condition worsens, the probes could be
covered with a material which insulates them from the hot gas
stream. This could result in lower-than-actual temperature
indications.
Due to the very high gas temperatures in this area, it is also
possible for the probe to fail due to materials of construction
problems. Occasional replacement of the probes is necessary.
5-14
-------
SLIDE 5-19
SLIDE 5-20
5-15
-------
SLIDE 5-21
.BOTTOM ASH
UNDESIRABLE CHARACTERISTICS
* Large, Dnburned Debris
* Highly carbonaceous Residue
* Low Moisture Content
SLIDE 5-21 LECTURE NOTES:
The combustibles content of the ash is not explicitly restricted by
the proposed regulations. However, it is a useful inspection ob-
servation since combustion problems are clearly indicated if the
quality of the ash deteriorates.
SLIDE 5-22
SLIDE 5-22 LECTURE NOTES:
The general characteristics of this waste should be observed from
a safe vantage point. The ash and residue should not be composed
of carbonaceous material or clearly unburned material. Inspectors
should look for unburned newspapers, rolled up cardboard, construc-
tion wastes and other material that have passed through the unit
without being properly burned.
5-16
-------
SLIDE 5-22 LECTURE NOTES (Continued):
If the ash characteristics are not "normal", inspectors may need to
request recent loss-on-ignition tests of the ash. These values^
should be less than 10% by weight of the ash sample or close to th
baseline levels for the unit. A loss-on-ignition test is the heat-
ing of a dried sample to 1450 degrees Fahrenheit in an oxidizing
atmosphere. The weight loss following heating is an indication of
the quantity of combustible material present in the sample.
SLIDE 5-23
SLIDE 5-23 LECTURE NOTES:
Fugitive emissions from the bottom ash or combined ash handling
operations should be observed from a location upwind of any
fugitive emissions. Emissions can occur in a variety of ways,
including the following problems.
* Reentrainment during ash discharge to storage piles
* Reentrainment during ash loading for transport to
the landfill
* Ash contamination on the transport vehicle wheels
* Drainage of ash-laden water from transport vehicles
* Improper landfill practices
Ash handling operations should be observed to the extent possible,
during the inspection to check for these conditions. Also, the
cleanliness of the ash handling areas should be checked for indica-
tions of past problems with fugitive emissions.
5-17
-------
SLIDE 5-24
SLIDE 5-24 LECTURE NOTES:
The operation of any auxiliary burners during the on-site inspect-
ion should be noted. This can be determined by checking the fuel
flow monitors in the control room.
Generally, the auxiliary burner is needed only during startup,
shutdown, and malfunction periods.
5-18
-------
REVIEW QUESTIONS - COMBUSTION SYSTEMS
Directions: Select the answer or answers which are correct.
1. The steam rate (JL-hovIr average) for an incinerator'is 208,000
pounds per hour and the maximum rating of the unit is 200,000
pounds per hour. Is this a violation of the propoood pcomowAe^
regulation? ^
a. Yes. The present steam rate exceeds the maximum rating
of the unit.
No. The present value is within 110% of the maximum rating
of the unit.
No. The present value is within the maximum rating of the
unit taking into account the measurement error of the
steam rate gauge
No. Steam rate is evaluated based on 4-hour block
averages.
Which conditions should be evaluated if high CO emissions are
occurring frequently on a sloped grate type incinerator?
a. Poor waste-ash-residue layers on the grates
b. Low overfire air pressures
c. Overcharging
d. Incinerator draft
3. Which measurement problems can affect the incinerator furnace
temperature.data?
Probe burnout
Slag-related blinding of the probe
Thermal radiation to boiler tubes
Air infiltration around the probe
Nonrepresentative monitoring location
Cooling by adjacent overfire air jets
4. What is the typical draft in sloped grate incinerators?
+0.10 to 0.50 inches of water
+0.05 to 0.20 inches of water
0.00 to +0.05 inches of water
0.00 to -0.05 inches of water
-0.05 to -0.20 inches of water
-0.10 to -0.50 inches of water
5. What are typical loss-on-ignition levels for bottom ash?
Ca) Less than 10% by weight
b. Less than 25% by weight
c. Less than 50% by weight
5-19
-------
6. INSPECTION OF ELECTROSTATIC PRECIPITATORS
AND FABRIC FILTERS
Electrostatic precipitators and fabric filters serve as stand-alone
particulate control systems for small MWC facilities. They are
also used as part of dry scrubbing systems for large plants. The
inspections of these units are similar regardless of the applica-
tion. Limited data is needed during each inspection to document
that the overall system is operating in a representative fashion.
More detailed inspections are performed when there are indications
of compliance problems affecting MWC metals and MWC organics.
SLIDE 6-1
PRIMARY INSPECTION DATA
PRECIPITATORS AND FABRIC FILTERS
>_Visible emissions (Method 9)
L* CEM opacity
'* Presence/absence of condensing
plume
* Inlet gas temperature during *-•
inspection (4-hour block average)
* Inlet gas temperature during
inspection (Instantaneous)
* Outlet gas temperature during
inspection (Instantaneous)
PRECIPITATORS
* T-R set data
FABRIC FILTERS
* Static pressure drop
SLIDE 6-1 LECTURE NOTES:
The primary inspection data is necessary to document the general
operating condition of the particulate control device during the
inspection. This data is also used to identify problems which may
not be indicated on the previously submitted compliance reports.
All of this data can be obtained from instruments or data recorders
available in the plant control room. When no problems are
indicated by the compliance reports and the on-site data, the
information listed in Slide 6-1 becomes part of the baseline data
set used in future inspections.
6-1
-------
SLIDE 6-2
FOLLOW-UP INSPECTION DATA
ELECTROSTATIC PRECIPITATORS
AND FABRIC FILTERS
ELECTROSTATIC PRECIPITATORS
* General physical condition
* Rapping practices
* Component failure records
FABRIC FILTERS
* General physical condition
* Pulse jet compressed air pressure
* Pulse jet diaphragm valve
operation
* Reverse air fan operating status
* Reverse air unit compartment
static pressure drops during
cleaning
* Clean side conditions
SLIDE 6-2 LECTURE NOTES:
Follow-up inspection steps are included when there are some
indications of increased emissions. One such indication would be
an increase in the duration or frequency of excess emission
incidents listed on the quarterly report submitted to the agency.
Any unusual conditions observed while compiling the primary
inspection data would also warrant follow-up inspection steps.
Only the data and observations relevant to the suspected problem (s)
should be included in the scope of the inspection. The limited on-
site time available should be conserved so that the inspector can
focus on those issues which will either be the subject of negotia-
tion or litigation between the agency and the plant owners.
6-2
-------
SLIDE 6-3
-
-------
SLIDE 6-4
CONDENSINGJfLUMES
* Near zero opacity at the stack
discharge
* Rapidly increasing opacity as
the plume moves downwind
* Bluish-^ lite color
* Low residual plume
SLIDE 6-4 LECTURE NOTES:
During the visible emission observation, any symptoms of a
condensing plume should be noted on the form. This condition is
caused by vapor phase pollutants which condense to form particles
after leaving the stack and" mixing with the relatively:cold air.
The most distinctive symptoms are a relatively low opacity zone
immediately above the stack and a bluish-white color.
This type of plume is unusual at MWC plants. However, the use of
ammonia or urea based nitrogen oxides control systems increases the
chances of the plumes being created during malfunctions. Between
10 and 20 ppm of ammonia in the effluent gas would be sufficient to
create a condensing plume due to the formation of submicron
ammonium chloride and ammonium sulfate particles.
The bluish-white color is the result of the very small particle
sizes formed when vapors condense to form particles. The particle
size is approximately equal to the wavelength of blue light.
It is important to distinguish between condensing plumes and water
vapor condensation. Due to the high flue gas moisture levels, it
is possible to have water vapor condensation in the initial part of
the plume. The water vapor generally has a bright, white appear-
ance, and it dissipates rapidly.
6-4
-------
SLIDE 6-5
COMPARISON OF VEO OPACITIES
AND CEM OPACITIES
VEO OPACITIES HIGHER
* Condensing plume
* Condensing water vapor
CEM OPACITIES HIGHER
* Instrument problems ,
* Poor weather conditions \16O ^aj^ > ia
-------
SLIDE 6-6
20 —
15 —
I
5—
90%
CONFIDENCE
INTERVAL
BASEUNE DATA
(SHOWN AS • )
RECENT OBSERVATIONS
(SHOWN AS •)
75 80 85 90 95 100
INCINERATOR OPERATING RATE. % OF FULL LOAD
SLIDE 6-6 LECTURE NOTES:
The daily opacity monitoring data (CEM data) for the period since
the last on-site inspection should be requested during the pre-
inspection meeting. Recent data (1 day to 14 days before the
inspection) should be compared against baseline incinerator load-
opacity data for the specific unit. An example load-opacity curve
is shown in Slide 6-6. Preferably this relationship is compiled by
plant personnel and maintained in their operating manual. However,
it can also be compiled by agency personnel using 6-minute average
opacity data recorded during several previous visits to the plant.
If the 6-minute opacities are several percent above the baseline
range, compliance problems may be occurring on an intermittent
basis. It is also possible that the frequency and severity of
excess emission incidents will increase in the near future. For
both reasons, inspectors should perform the follow-up inspection
steps listed earlier and review the CEM opacity data in detail.
In compiling the baseline load-opacity relationship shown in this
slide, as many 6-minute data points as possible should be included
in order to reduce the size of the confidence interval. Opacity
data during nonrepresentative time periods, such as start-up and
shut-down, should be excluded.
6-6
-------
SLIDE 6-7
PRE-INSPECTION
EVALUATION OF CEM DATA
* Severity of exceedance
incidents listed in the
compliance reports
* Trends in emission rates
* Response to malfunctions
upsets
* Duration of malfunctions -3V<
* Chronic malfunctions
* Frequency of incinerator
start-ups and shut-downs
SLIDE 6-7 LECTURE NOTES:
Prior to arriving at the MWC facility, agency inspectors should
evaluate the quarterly reports submitted by the plant operators.
The data included in these reports provides a general indication of
the severity of any compliance problems and of the emission trends.
Based on these records, inspectors can estimate the on-site time
necessary to obtain all of the support information necessary to
evaluate the plant's response to these problems.
The plants response to malfunctions and the duration of the
malfunctions are indications of (1) the adequacy of the operation
and maintenance procedures, and (2) the vulnerability of the
equipment design and process control. The duration of the mal-
functions should be relatively short. The frequency of the mal-
functions should decrease over time as plant personnel identify and
rectify the factors causing these problems.
The reason codes assigned to each of the excess emission incidents
should be reviewed for indications of chronic problems. However,
these reason codes should not be interpreted as complete and final
assessments of the causal factors since it is sometime difficult to
determine the actual problem while the unit continues to operate.
6-7
-------
SLIDE 6-8
ON-SITE INSPECTION
EVALUATION OF CEM DATA
* Evaluation of strip charts
(instantaneous data)
* Evaluation of average opacities
and spiking tendencies
* comparison of strip charts and
averaged data with incinerator and
air pollution control system
operating logs
SLIDE 6-8 LECTURE NOTES:
The average opacity data recorded on the Data Acquisition System
(DAS) is used to document present operating conditions. The 6-
minute averages for at least the 24 hours proceeding the:inspection
should be examined.
If possible, instantaneous opacity data recorded on a strip chart
recorder should be reviewed for the same time period. The duration
and frequency of opacity spikes should be recorded in the inspec-
tion notes. This instantaneous data is useful in determine some of
the causal factors for the spiking condition. Significant spikes
on either a regular basis or on a random basis are not normal for
MWC units.
Severe spiking from electrostatic precipitators may be caused by
low resistivity conditions or by excessive rapping (cleaning)
intensities. Spiking from fabric filters is often due to the onset
of small fabric holes and tears resulting from excessive cleaning
intensity.
6-8
-------
SLIDE 6-9
I" "I" "I
-ESP FIELD TRIP
TIME, hours
SLIDE 6-9 LECTURE NOTES:
When evaluating the instantaneous opacity data (when available), it
is important to remember that the intensity of the spikes is not
independent of the average opacity. Problems which impair the
performance of an electrostatic precipitator often cause a slight
increase in the average opacity. When the unit is impaired,
routine operations such as rapping and incinerator soot blowing can
create spikes due to the inability of the precipitator to collect
all of the particulate resuspended during these operations. Slight
increases in the average opacity are often associated with large
increases in the spiking frequency and intensity. This is illus-
trated by the opacity profile shown in Slide 6-9 (Time moves from
left to right due to the way strip chart is generated). In this
case, the failure of one of the T-R sets impaired the performance
of the overall unit. Immediately after this failure, severe
spiking was apparent.
When evaluating the cause of an excess emission problem, it is
important to look for the fundamental problems and not just
associate the emissions with the operation that happened to cause
the opacity spike.
6-9
-------
SLIDE 6-10
SLIDE 6-10 LECTURE NOTES:
7:.e inlet gas temperature to the precipitator or fabric filter is
important because the proposed regulations specify a maximum value
and since high temperatures can harm the unit.
The 4-hour block average data for the day of the inspection should
be obtained to document conditions during the on-site visit. The
data recorded since the last quarterly compliance report should
also be examined to confirm compliance with the 450 degree Fahren-
heit (230 C) limit in the proposed regulation. This temperature
limit has been included in the regulations to minimize catalytic
reactions on the surfaces of particles which could generate dioxins
and furans as the flue gas travels from the incinerator to the
particulate control device.
The instantaneous gas inlet temperature data should be obtained for
the time of the inspection. Also, the operating logs for the past
year should be scanned for the hourly recorded values. This data
should be scanned for any short time period temperature excursions
which could have adversely affected the precipitator or fabric
filters. Temperature excursions above 500 degrees Fahrenheit for
time periods as short as 10 to 15 minutes can cause problems.
6-10
-------
SLUE 6-11
BAGHGUSE
T| BAGH0USE INLET
T2 FAN INLET
SLIDE 6-11 LECTURE NOTES:
For systems operating under negative pressure (upstream of the
fan) , the instantaneous outlet gas temperature data during the time
of the inspection should be compared with the inlet data. If the
temperature drop has increased 5 to 10 degrees Fahrenheit above the
baseline level for the unit, significant air infiltration is
likely. Temperature decreases greater than 25 degrees
also suggest problems.
Due to the high concentration of hydrogen chloride in the gas
stream, corrosion can be severe in the localized areas near the air
infiltration sites. Acid gases absorbed into the water layers coat
the equipment near the leak sites. As corrosion becomes worse,
more air is able to infiltrate the unit.
If significant gas temperature drops across the unit are observed,
some follow-up inspection steps are necessary. A walk-around
inspection should be performed to check for any audible or visible
signs of infiltration. Also, the component failure records (bag or
ESP wire) should be checked for localized failure patterns.
6-11
-------
SLIDE 6-12
SLIDE 6-12 LECTURE NOTES:
The transformer-rectifier (T-R) set electrical data for electro-
static precipitators is primary inspection data which should be
obtained during each inspection. The data is obtained using the
gauges on the primary control cabinets for each of the T-R sets.
These cabinets are usually mounted in a protected area within the
incinerator building.
The control cabinet shown in this slide has secondary voltage and
secondary current analog-type gauges. Other units have primary
voltage, primary current, and spark rate gauges. Some new units
have replaced the analog gauges (indicator needles) with digital
displays.
Regardless of the type of gauges, some fluctuations in the values
are normal. The value that should be recorded in the inspection
notes is the highest sustained value which is sustained for a brief
time. Normally, the analog needle or digital value pauses for a
fraction of a second at the maximum value.
The fluctuations are caused by electrical sparking within the
fields. Following a spark, the automatic voltage controller shuts
down the power for several milliseconds and then ramps the voltage
back to the approximate voltage where the spark occurred.
6-12
-------
SLIDE 6-13
Checklist Format for T-R Set Data
_ Primary Primary -Secondary Secondary Spark
Voltage Current Voltage Current Rate
(Volts) (Amps) (Kilovolts) (Milliamps) (#/min.)
Inlet
Field
Second
Field
nth
Field
SLIDE 6-13 LECTURE NOTES:
The data should be recorded in a form similar to the excerpt shown
in Slide 6-13. It is important that the data for each field be
written down in order, starting with the inlet field and proceeding
to the middle and outlet fields. This procedure is important
because the trends in the currents and voltages are as meaningful
as the absolute values.
If the electrical conditions in all of the fields vary in unison
(perhaps a 1 to 2 hour v^g foy out letfi elds) , a f lyash resistivity
problem is likely. CLOW resistivity? is indicated by increased
currents and decreased sparK rares in all of the fields. High
resistivity has the opposite pattern. Resistivity problems are
generally caused by shifts in combustion-related conditions or
major changes in the waste characteristics. The precipitator
rapping practices should be checked since the operators should be
able to minimize particulate emissions by adjusting the rapper
frequencies and intensities.
An internal mechanical or electrical fault is indicated if one of
the fields is impaired while the others are operating close to
baseline levels. The component failure records should be checked
to determine if the unit is suffering repeat or frequent failures.
6-13
-------
SLIDE 6-14
SLIDE 6-14
For fabric filters, the static pressure drop during the inspection
should be obtained to complete the primary inspection data set.
This is generally monitored in the main control room. However, it
can also be determined by the magnehelic gauges or manometers
mounted on the units.
Some variations in the static pressure drop are normally since
cleaning of the baghouse compartments is not continuous. The data
generally has the appearance of a sawtooth pattern. The value
which should be recorded is the highest value.
The value should be similar to the baseline values recorded during
the initial test series and previous inspections. Significantly
higher values may indicate compartment cleaning problems or blind-
ing of the bags. Blinding could be caused by a variety of problems
including, but not limited to inadequate drying of solids in the
spray dryer, condensation of water in compressed air used for bag
cleaning, condensation of water in the flue gas due to air
infiltration, and/or boiler tube leaks.
Very low static pressure values generally indicate over cleaning of
the bags. This may be associated with higher than normal average
opacities and a tendency to spike during cleaning cycles.
6-14
-------
SLIDE 6-15
ELECTROSTATIC PRECIPITATOR
COMMON OPERATING PROBLEMS
* Low resistivity flyash
* Excessive rapping and rapping
reentrainment
* Poor discharge electrode-to-
collection plate alignment
* Insulator leakage and failure
SLIDE 6-15 LECTURE NOTES:
Common problems affecting MWC electrostatic precipitators are
listed in Slide 6-15. The possible existence of these problems
(alone or in combination) should be evaluated during the follow-up
portion of the ESP inspection.
Low resistivity has been discussed in Lecture 2 of this program.
If the flyash has too low of a resistivity (material is electri-
cally conductive) , the solids on the vertical collection plates are
not held strongly. Even moderate rapping force can disperse the
flyash which had been precipitated. Low resistivity conditions
are normally the result of combustion problems which allow high
combustibles content in the flyash.
Rapping reentrainment can occur whenever rapping is too frequent or
too severe. It is especially troublesome when the flyash resis-
tivities are low or when the gas velocities are high.
Poor discharge electrode-to-collection plate alignment can be
caused by poor erection practices, poor hopper pulling procedures,
hopper flyash fires, poor support insulator replacement procedures,
and/or air infiltration. Proper alignment is critical to the
performance of the unit.
Insulator electrical leakage and failure are the result of the
accumulation of water and solids on the surfaces. The short
circuit across the surfaces causes localized heating which even-
tually results in either the tripping of the field or the breakage
of the insulator. Poor combustion conditions and poor start-up
practices can significantly increase the frequency of insulator
failure.
One of the objectives of this brief introduction to the common ESP
problems is to indicate the interdependency of the various condi-
tions. The follow-up inspection data must be reviewed carefully to
identify the fundamental problems.
6-15
-------
SLIDE 6-16
SYMPTOMS OF LOW RESISTIVITY
* High currents in all fields*
* Low spark rates in all fields
* Reduced voltages in all fields
* Reduced ESP inlet gas temperatures
* High flyash loss-on-ignition
levels
SLIDES 6-16 AND 6-17 LECTURE NOTES:
Low resistivity is indicated by the shifts in T-R set electrical
data listed in Slide 6-16. Regularly occurring rapping spikes
often occur during low resistivity conditions, since the flyash is
only weakly retained on the collection plates. A typical opacity
profile during low resistivity conditions is shown in Slide 6-17.
The average opacity is generally 2 to 5% higher than normal, and
there are opacity spikes occurring at a frequency approximately
equal to the outlet or inlet field collection plate rapping cycle.
SLIDE 6-17
100
REENTRAINMENT
TIME, hours
6-16
-------
SLIDE 6-18
SLIDE 6-18 LECTURE NOTES:
Low resistivity conditions are generally caused by high corobust-
bles levels in the flyash. The flyash characteristics should be
qualitatively evaluated for indications of increased carbonaceous
matter. Also, loss-on-ignition data should be requested. Values
greater than 10% by weight can be associated with low resistivity.
However, there are considerable plant-to-plant differences in
flyash characteristics, and the loss-on-ignition data should be not
be relied upon exclusively in evaluating possible low resistivity
conditions.
The combustion system should be carefully evaluated to determine if
the operators are taking prudent steps to minimize combustible
levels. Some of the relevant combustion system data include:
* Incinerator exit gas oxygen concentrations
* Incinerator exit gas carbon monoxide concentrations
* Overfire air pressures
* Incinerator draft
* Incinerator temperature
Also, the flue gas temperature entering the precipitator should be
checked. Decreases of only 20 to 30 degrees from baseline levels
can significantly reduce the prevailing flyash resistivities.
6-17
-------
SLIDE 6-19
SYMPTOMS OF EXCESS RAPPING
AND RAPPING REENTRAINMENT
* opacity spikes corresponding to
collection plate rapping frequencies
* High currents in all fields
* increased sparking rates in one or
more fields
* Reduced ESP inlet gas temperature
* High ESP aspect ratio
* High average gas velocity
SLIDE 6-19 LECTURE NOTES:
The symptoms of rapping reentrainment are very similar to those for
low resistivity. In fact, it is not strictly an independent
problem which can be separated from low resistivity. However,
is a condition which can persist even when the flyash resistivity
returns to the moderate range. The main symptom of Capping re
entrainment is continued, regularly occurring opacity spikes during
most operating conditions. The reentrainment emissions can be
minimized by reducing the frequency or intensity of the collection
plate rappers. However, the adjustability of the rappers varies.
The internal rotating hammer type rappers shown in Slide 6-20 can
only be adjusted by decreasing the frequency. The intensity can be
changed only be installing smaller hammer weights during a ma^or
unit outage.
SLIDE 6-20
6-18
-------
SLIDE 6-21
SLIDE 6-21 LECTURE NOTES:
The rappers shown in Slide 6-21 are one example of roof mounted
rappers. These are connected to the collection plates and high
voltage frames by means of rapper shafts. Both the frequency and
intensity of the various types of roof mounted rappers can be
easily adjusted.
Due to the interrelated and complex nature of the various ESP
problems, care is necessary when making adjustments. The currents
in the affected fields should be carefully monitored for several
days after any rapper system adjustments. If the currents decline
significantly, it is possible that the collection plates (or wire
frames) are not being adequately rapped. It is often prudent to
make rapper adjustments on a step-by-step basis rather than as one
large change. This allows an opportunity to check for performance
trends and confirm that the adjustments are correct.
6-19
-------
M
TRANSFORMER
RECTIFIER SET fly
HIGH VOLTAGE FRAME
COLLECTION FtATE
GAS DISTRIBUTION
SCREEN
a\
I
M
o
GAS
MLET-
-TRANSFORMER
RECTIFIER SET K
HIGH VOLTAGE
SHAFT INSULATOR
SUPPORT PLATE
SUPPORT SPRINGS
HIGH VOLTAGE FRAME
SUPPORT INSULATORS
H
a
n
a\
i
M
to
-------
SLIDE 6-22 LECTURE NOTES:
The collection plates and discharge electrodes (wires or masts)
must be properly aligned to prevent electrical sparking at low
voltages. Improper alignment is one of several problems which
causes low voltages, low currents, and high spark rates "in a field.
One symptom of improper alignment is a marked deterioration of the
electrical performance as compared to baseline data. Nevertheless,
some day-to-day variation in electrical conditions continue due to
flyash resistivity variations.
Poor alignment can not be identified simply by checking opacity
data and T-R set electrical data. An internal inspection must be
conducted to check for proper alignment at the top, middle, and
bottom of each high voltage frame. This inspection should only be
conducted by plant personnel. However, agency inspectors can
request to review copies of the field measurements. Alignment
tolerances are normally plus or minus 0.5 inches from centerline
placement.
When alignment problems are suspected, agency inspectors should
include several follow-up inspection points.
* A check for audible or visible air infiltration sites
up through the hopper area (negative pressure units).
* A qualitative evaluation of the carbonaceous content
of the flyash.
* A check of the stack (or ESP exit) oxygen levels.
These checks focus on three of the many possible causes of poor
alignment. Air infiltration creates localized gas temperatures
well below the gas temperatures in the middle of the unit. This
can cause gradual bowing of the collection plates.
Air infiltration conditions also cool the solids in the hoppers and
increase the chances for hopper overflow problems. This can result
in severe warping of the high voltage frames and in the bowing of
the collection plates.
High oxygen levels combined with highly carbonaceous waste can
create conditions favorable for smoldering fires in the hoppers.
The high temperatures generated by the fires can causing bowing of
the collection plates and of the lower high voltage frames.
6-21
-------
SLIDE 6-23
RECmEMSETfl
raOHVOLTME
UNE-
- TRANSFORMER
RECTIFIER SET f2
HOH VOLTAOE FRAME
COLLECTKW PLATE
GAS DISTRIBUTION
OAS
•(LET-
SLIDES 6-23, 6-24 AND 6-25 LECTURE NOTES:
Insulator problems are indicated by low voltages, high currents,
and low spark rates in one or more fields. Once they develop,
electrical performance of the field rarely improves until ESP
internal maintenance work can be performed.
When these conditions are suspected, inspectors should confirm that
insulator heaters are operational by checking the status lights on
the heater control cabinets. Also, the operation of any purge air
blowers used to keep clean air flowing downward through the high
voltage frame support insulators should be confirmed.
Failure to keep high voltage frame support insulators warm and dry
can lead to electrical tracking and eventual shattering of the
units. One failed porcelain insulator is shown in Slide 6-24.
Heat and purge air streams can not be used to protect the anti-sway
insulators which span between the lower high voltage frames and the
grounded parts of the precipitator. Electrical tracking lines are
clearly apparent in Slide 6-25. This problems can be minimized,
but not eliminated by proper design.
6-22
-------
SLIDE 6-24
SLIDE 6-25
6-23
-------
SLIDE 6-26
ESP PHYSICAL CONDITION
* Obvious corrosion near access
hatches
* Audible air infiltration near
hatches and expansion joints
* Incomplete insulation and
weatherproof ing
SLIDES 6-26, 6-27, AND 6-28 LECTURE NOTES:
One of the main purpose of the walk-around inspection of the
precipitator is to identify conditions which could cause corrosion.
Corrosion problems can cause frequent failure of ESP components and
thereby result in frequent excess emission problems. Plant person-
nel should be taking reasonable steps to minimize the corrosion
related problems.
Severe air infiltration damage adjacent to an ESP side access hatch
is shown in Slide. 6-27. The opening will gradually enlarge due to
the absorption of corrosive gases on the relatively cold metal
surfaces close to the leak site.
Slide 6-28 shows the bottom of a hopper on a MWC incinerator ESP.
Due to the lack of an air seal such as a rotary discharge valve
severe air infiltration is occurring through the screw conveyor and
up into the hopper. This hinders solids discharge through the
hopper throat, increases the risk of hopper overflow, and causes
corrosion in the lower sections of the unit. The air infiltration
was clearly audible several feet from the screw conveyor.
6-24
-------
SLIDE 6-27
SLIDE 6-28
6-25
-------
SLIDE 6-29
.FABRIC FILTERS
POSSIBLE OPERATING PROBLEMS
Bag blinding
Bag chemical attack
Inadequate bag cleaning
Excessive bag cleaning
Localized abrasion and
flex failure
* Air infiltration
SLIDE 6-29 LECTURE NOTES:
The follow-up phase of the inspection of fabric filters should
focus on the various problems listed in Slide 6-29. The data used
to determine which problems are responsible for excess emissions
include the component (bag) failure records, bag cleaning condi-
tions, and observations of the general physical condition of the
fabric filter.
SLIDE 6-30
BAG BLINDING
SYMPTOM
* High static pressure drop
* Frequent and severe CO
spikes
POSSIBLE CAUSE
* Sticky, carbonaceous flyash
generated during combustion
upsets
* Moisture condensation due to £.
low gas inlet temperatures
* Moisture condensation due to
poor quality compressed air
* Fine particle deposition due
to improper startup procedures
V
SLIDE 6-30 LECTURE NOTES:
Bag blinding is the coating of a portion of the fabric with a semi-
permeable material which restricts gas flow. It creates a possible
6-26
-------
SLIDE 6-30 LECTURE NOTES (Continued):
emissions problem since the flue gas is channeled through the more
permeable fabric area least affected by the sticky deposits. Due
to the high localized air-to-cloth ratios, some bleeding of part-
iculate can occur through" the fabric.
Overall baghouse static pressure drops above approximately 10
inches of water are a possible indication of bag blinding. If this
is observed while compiling the primary inspection data set, the
inspection should include an evaluation of the flyash character-
istics. Highly carbonaceous flyash generated by poor combustion
conditions could be a contributing factor. This would be indicated
by high loss-on-ignition values and by frequent, severe CO concen-
tration spikes.
Air infiltration related water vapor condensation problems can be
significant due to the characteristics of the solids collected in
fabric filters serving spray dryers and dry injection units. The
calcium chloride reaction product is very hygroscopic. Also, the
unreacted alkali reagent can adsorb the water. Air infiltration
problems are indicated by checking for large temperature drops
across the collector and by conducting a walk-around inspection for
audible and visible symptoms of infiltration.
Moisture condensation in pulse jet bags due to low quality com-
pressed air is unusual in MWC applications. These facilities
generally have driers on the compressed air lines for removal of
the water vapor. Also, they have generally installed moisture
drains on compressed air headers. These standard procedures to
minimize compressed air moisture problems can be confirmed by
walking back along the compressed air supply line and checking for
drains and driers.
Blinding due to the deposition of fine particles is generally the
result of improper start-up conditions. New bags must be protected
until sufficient dust cake accumulates on the dirty side to prevent
the deposition of fine particles within the yarns and pores of the
fabric.
6-27
-------
SLIDE 6-31
INADEQUATE BAG CLEANING
SYMPTOMS
* High static pressure drop
* Slightly increased average
opacity
POSSIBLE CAUSES
* Failure of Components
(i.e. Diaphragm valves)
* Failure of dampers
* Failure of timers or
differential pressure
controllers
SLIDE 6-31 LECTURE NOTES:
Inadequate cleaning problems yield symptoms which are very similar
to bag blinding problems. Cleaning problems are identified by
checking the cleaning system components during the walk-around
inspection.
SLIDE 6-32
6-28
-------
SLIDE 6-32 LECTURE NOTES:
For pulse jet fabric filters, the operation of the pilot valves
(electrically operated solenoids) and the diaphragm valves can be
checked audibly. Each compartment should be being cleaned on a
regular basis. The number of diaphragm valves which activate
properly is counted and compared with the total number of valves in
each set. Proper activation is judged based on the characteristic
"thud" sound caused by the rapid opening and closing of the valve.
Also, the compressed air supply pressure should be compared with
the baseline levels. This pressure gauge should fluctuate slightly
during the activation of each diaphragm valve.
SLIDE 6-33
SLIDE 6-33 LECTURE NOTES:
For reverse air systems, the operation of the reverse air fan
should be confirmed audibly. The fan normally is operated
continuously.
The static pressure drops of any compartments which are isolated
for cleaning should be noted. These values are normally 1 to 2
inches of water (Note: the gas flows in opposite direction,
therefore, the needle should deflect left on the gauge). Damper
problems are indicated if the static pressure drops are close to
zero or if they do not change significantly when the compartment is
isolated.
6-29
-------
SLIDE 6-34
BAd CHEMICAL ATTACK
SYMPTOMS
* Frequent bag failures
* Low gas inlet temperatures
POSSIBLE CAUSES
* Acid vapor condensation during
frequent start-up/shut-down
cycles
* Acid vapor condensation due to
severe air infiltration
* Acid vapor condensation due to
malfunctions of the dry scrubber
SLIDES 6-34 AND 6-35 LECTURE NOTES:
Chemical attack related bag failures are due primarily to the
condensation/absorption of acid gases in cold areas. Bag chemical
attack problems are indicated by a sudden increase in the failure
rates of the bags or a consistently high bag failure rate. A
failure frequency chart, such as shown in Slide 6-35 is one con-
venient means to identify higher-than-normal bag losses at an early
stage (see arrow). Without this record, the conditions may not be
identified until the failures are more freguent, and the excess
emission incidents are more severe.
SLIDE 6-35
48
6-30
-------
xP
SLIDE 6-36
do
M»
..OOC
•OOO
,OOO
.OOO
,OOO
• OOO
,OOO
.OOO
-OOO
BAG FAILURE LOCATION RECORD
666-
ooo«
ooo-
ooo
00
ooo.
OOO-
OOO.
OOO.
OOO.
SLIDES 6-36 AND 6-37 LECTURE NOTES:
Bag failure location records should be examined (if compiled by the
plant) to determine if there is a spatial pattern. Bag chemical
attack may be isolated to the "cold" zones of the fabric filter
such as the hoppers and to areas adjacent to side access hatches.
The possible gas temperature nonuniformity in a large reverse air
is indicated in Slide 6-37.
;\
NONUNIFORMITY
Z98-F
6-31
-------
SLIDE 6-38
SLIDE 6-38 LECTURE NOTES:
A walk-around inspection of the unit should be conducted if bag
failure rates are high or if opacity excursions are frequent. One
common area for air infiltration is the hopper discharge valves and
solids handling equipment. The rotary valve shown in the center of
Slide 6-38 is very important in that it provides the air seal for
the baghouse hoppers.
The integrity of any expansion joints in the solids handling
equipment or in the ductwork should be noted on the inspection
checklist.
6-32
-------
SLIDE 6-39
COMMON SITES OF AIR INFILTRATION
* Top access hatches
* Side access hatches
* Hopper access hatches
* Hopper poke holes
* Pneumatic system inlet
valves
SLIDE 6-39 LECTURE NOTES:
If bag failure rates have been high, the walk-around inspection
should include the areas listed in Slide 6-39. The top access
hatches of pulse jet units are especially prone to leakage since
they are located at the point of maximum negative static pressure
and since they are relatively large. The side access hatches of
reverse air units are vulnerable if the hatch and adjacent metal
has not been insulated to prevent "sweating" on the interior metal
surfaces exposed to the moist, corrosive flue gas stream.
The hopper areas should be checked for audible infiltration
problems as long as there are no inhalation hazards present.
Hoppers on baghouse under positive pressure should not be checked
since air infiltration is impossible and since inhalation hazards
are very possible.
6-33
-------
SLIDE 6-40
.FABRIC FILTER
COMPONENT FAILURE RECORDS
* Bag failure locations and
dates "
* Bag laboratory analyses
SLIDES 6-40 AND 6-41 LECTURE NOTES:
The importance of bag failure location and rate records has already
been discussed. If the bag failure related excess emission pro-
blems are high, it may be helpful to request that plant personnel
provide laboratory test data to confirm the failure mechanisms.
This data is very useful in confirming that plant personnel have
identified the fundamental causal factors and that they will be
able to reduce excess emission problems in the immediate future.
The laboratory tests are useful in determining if the mode of
failure is due to .mechanical abrasion/flex damage, chemical attack,
or improper installation procedures. These tests are also helpful
in determining if blinding or damaged bags can be salvaged, laund-
ered, and reinstalled. A partial list of the tests which can be
conducted is provided in Slide 6-41.
SLIDE 6-41
FABRIC LABORATORY TESTS
* Mullen burst
* MIT flex test
* Breaking strength
* Extracted sample pH
* Extracted sample
chlorides and sulfates
content
* Microscopic analyses
6-34
-------
REVIEW QUESTIONS - ELECTROSTATIC PRECIPITATORS AND FABRIC FILTERS
Directions: Select the answer or answers which are correct.
1. What is the maximum 4~-hour (block average) inlet gas
temperature for particulate control devices allowed by
the proposed regulations?
a. 350 degrees Fahrenheit
b. 400 degrees Fahrenheit
©' 450 degrees Fahrenheit
d. 500 degrees Fahrenheit
e. 550 degrees Fahrenheit
f. 600 degrees Fahrenheit
g. 350 degree Centigrade
2. What are the electrical symptoms of low resistivity in an
electrostatic precipitator?
a. Reduced currents and increased spark rates in all fields
(b) Increased currents and reduced spark rates in all fields
c. Increased currents and increased spark rates in all fields
3. What are the _electrical symptoms of electrical leakage across
a high voltage frame support insulator with an electrostatic
precipitator?
a. Reduced currents, reduced voltages, reduced spark rates
in one-of the fields
(^ Reduced voltages, increased currents, reduced spark rates
in one of the fields
c. Reduced voltages, reduced currents, increased spark rates
in one of the fields
4. What is a typical gas temperature drop across a precipitator
or fabric filter which does not have a significant air
infiltration problem?
a. 5 degrees Fahrenheit
b. 10 degrees Fahrenheit
{£) 25 degrees Fahrenheit
d. 50 degrees Fahrenheit
5. Which of the following conditions could cause low static
pressure drop across a pulse jet fabric filter?
a. Excessive cleaning frequency or intensity
-------
7. INSPECTION OF DRY SCRUBBERS
AND WET SCRUBBERS
The emphasis in this lecture is on compliance with the sulfur
dioxide and hydrogen chloride emission requirements. The agency
evaluation begins with a complete review of the quarterly compli-
ance reports. Chronic problems apparent in the CEM data are
discussed during the preinspection meeting with plant personnel.
Follow-up inspection steps are included whenever necessary to
evaluate system performance problems.
Due to differences in the scope of the on-site inspections, dry
scrubber systems and wet scrubber systems are discussed separately
in this lecture. The dry scrubber inspection procedures are
limited to the spray dryer or dry injection system since the
particulate control devices (precipitators or fabric filters) have
been discussed in the previous lecture.
SLIDE 7-1
DRY SCRUBBER SYSTEMS
PRIMARY INSPECTION DATA
* Alkali feed rate
* Spray dryer inlet gas
temperature
* Spray dryer outlet gas
temperature
* Dry injection system heat
exchanger outlet gas
temperature
SLIDE 7-1 LECTURE NOTES:
The primary data set for dry scrubbing systems is necessary to
document the operating status of the unit. It also provides an
indirect indication of on-going compliance problems.
All of the information listed in Slide 7-1 is available in the
plant control room. The data for the time period during the
inspection should be recorded on the inspection checklist. Shifts
from baseline conditions for the specific dry scrubber system
should be discussed with plant personnel. When no problems exist,
the primary data becomes part of the baseline data available for
use in future inspections.
7-1
-------
SLIDE 7-2
PRE-INSPECTION
EVALUATION OF CEM DATA
* Severity of exceedance
incidents listed in the
compliance reports
* Trends in emission rates
* Response to malfunctions
and upsets
* Duration of malfunctions
* Chronic malfunctions
* Frequency of incinerator
start-ups and shut-downs
SLIDE 7-2 LECTURE NOTES:
Prior to arriving at the MWC facility, agency inspectors should
evaluate the quarterly reports submitted by the plant operators.
The data included in these reports provides a general indication of
the severity of any compliance problems and of the emission trends.
Based on these records, inspectors can estimate the on-site time
necessary to obtain all of the support information necessary to
evaluate the plant's response to these problems.
The plant's response to malfunctions and the duration of the
malfunctions are indications of (1) the adequacy of the operation
and maintenance procedures, and (2) the vulnerability of the
equipment design and process control. The duration of the
malfunctions should be relatively short. The frequency of the
malfunctions should decrease over time as plant personnel identify
and rectify the factors causing these problems.
The reason codes assigned to each of the excess emission incidents
should be reviewed for indications of chronic problems. However,
these reason codes should not be interpreted as complete and final
assessments of the causal factors since it is sometime difficult to
determine the actual problem while the unit continues to operate.
7-2
-------
SLIDE 7-3
ON-SITE INSPECTION
EVALUATION OF CEM DATA
* Evaluation of strip charts
(instantaneous data)
* Evaluation of average opacities
and spiking tendencies
* comparison of strip charts and
averaged data with incinerator and
air pollution control system
operating logs
<*$ ^fcnAoi*
SLIDE 7-3 LECTURE NOTES:
The average sulfur dioxide concentration data recorded on the Data
Acquisition System (DAS) is used to document present operating
conditions. The 24-hour average for the day proceeding the
inspection should be recorded.
If available, instantaneous sulfur dioxide data recorded on a strip
chart recorder should be reviewed for the previous 12 to 24 hours.
The duration and frequency of sulfur dioxide concentration spikes
should be recorded in the inspection notes. This instantaneous
data is useful in evaluating the ability of the dry scrubber system
to respond to the short term variations in inlet sulfur dioxide and
hydrogen chloride concentrations.
The use of sulfur dioxide CEM systems to indicate the dry scrubber
system removal effectiveness for both hydrogen chloride and sulfur
dioxide is possible since sulfur dioxide is collected with less
efficiency than hydrogen chloride. If the sulfur dioxide concen-
tration is low, it is reasonable to conclude that hydrogen chloride
levels are also low. This, of course, is based on the assumption
that the waste materials being burned have sufficient sulfur to
generate measurable levels of this pollutant. This question can
be answered by monitoring both the inlet and outlet streams to the
dry scrubber.
7-3
-------
SLIDE 7-4
UPFLOV
SPRAY
DRYER
^
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PUMP
STREAMS
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Combination Spray Dryer and
Dry Injection System
7-4
-------
SLIDE 7-5
100
s*
g 95
(D
'£ 90
LU
1
o 85
-------
SLIDE 7-6
SLIDE 7-6 LECTURE NOTES:
Gradually increasing sulfur dioxide concentrations (24-hour average
data) reported in the quarterly compliance reports could be due to
lime slurry feeding problems. Scaling in the lines can reduces the
cross-sectional area of the pipe available for slurry flow. This
condition is indicated by the inability of the system to respond to
spikes of sulfur dioxide in the inlet gas. During these periods,
the average sulfur dioxide concentrations increase, and there are
short term spikes in the effluent sulfur dioxide concentration.
Due to the inability of the slurry equipment to supply the
necessary flow, the outlet gas temperature may increase. For this
reason, the spray dryer vessel outlet gas temperature data should
be obtained for selected days in which the sulfur dioxide concen-
trations have been especially high.
7-6
-------
SLIDE 7-7
SLIDE 7-7 LECTURE NOTES:
The slurry pressures to the spray nozzles or rotary atomizers
should be checked whenever the quarterly reports indicate that the
stack gas sulfur dioxide concentrations are increasing. Any shifts
from the baseline operating range should be discussed with plant
personnel.
Problems which may be indicated by changes in the pressure include
(1) reduced slurry flow due to scaling in the piping leading up to
the spray dryer, (2) scaling in the pipes immediately upstream of
the nozzles or rotary atomizers, and (3) erosion of the nozzle
orifices.
7-7
-------
SLIDE 7-8
t'trvTl i
MH
MOUCEO STACK
DRAFT
FAN
STREAMS
LIQUID & SOLID
<0> QUICKLIME
> SLAKED LIME
<£> REACTION PRODUCTS
V AND LIME
<^S REACTION PRODUCTS
V AND LIME
<£> REACTION PRODUCTS
V AND LIME
LIME SLURRY
/?S FLYASH AND
^^ REACTION PRODUCTS
<^> LIME SLURRY
/?> LIME SLURRY
<^tf> LIME SLURRY
^ LIME SLURRY
^> FLYASH AND
V REACTION PRODUCTS
FLUE GAS
A FLUE GAS FROM
INCINERATION
B SPLIT INLET GAS STREAM
C SPLIT INLET GAS STREAM
D TREATED FLUE GAS
E,F TREATED FILTERED
FLUE GAS
INSTRUMENTS
GAS TEMP
££^ FLOW
(£& DENSITY
©LIME FEED
RATE
©STATIC PRESSURE
DROP
£1} PRESSURE
f^\ MOTOR CURRE^fT
J£ OXYGEN
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7-8
-------
SLIDE 7-9 LECTURE NOTES:
')
•)
£"Y*/*\, v A«*~t
• AjAV^VWv
SLIDES 7-8 AND 7-9 LECTURE NOTES:
For spray dryer systems, the inlet gas temperature is important
because the sensible heat of the flue gas is needed to evaporate
the slurry droplets to dryness. Inlet temperatures which are too
low can create sludge build-up problems in the spray dryer vessel.
For these reasons, the inlet gas temperature (instantaneous value)
should be recorded. The temperature strip charts or incinerator
operating log sheets should be checked to confirm that the inlet
gas temperature has remained above this minimum level during
routine operating periods.
The spray dryer outlet gas temperature should be recorded in the
primary data set since this is an indirect indication of acid gas
removal. Efficiency of absorption increases as the outlet
temperature decreases. Unfortunately, the risk of wet solids
build-up in the spray dryer also increases at lower temperatures.
Operators must maintain the system in a temperature range which is
adequate for acid gas removal but not too cold.
7-9
-------
SLIDE 7-10
WET.SCRUBBER SYSTEMS
PRIMARY INSPECTION DATA
* Visible emission observation
* Opacity CEM data during
VEO (if CEM present)
* Presence of absence of condensing
plume
* Gas-atomized scrubber pressure
drop
* Wet ionizer scrubber T-R set
electrical data
SLIDE 7-10 LECTURE NOTES:
The visible emission observation is especially important during the
on-site inspection since many wet scrubber systems do not have
opacity monitors to provide continuous data. The condensed water
droplets in the stack gas preclude use of these instruments.
In accordance with Method 9, the plume should be evaluated at the
point of maximum opacity which is free of condensed water droplets.
This is normally downwind in the plume after the "steam" plume
breaks. It is possible to differentiate between the steam plume
and particulate plume (residual plume) based on the color and
character of the materials.
However, it is difficult to independently identify the presence of
a condensing plume resulting from the nucleation of vapor phase
material generated in the combustion system. One general symptom
of a condensing plume is the persistence of a relatively high
residual plume (> 20%) which is relatively independent of scrubber
operating conditions.
While observing the stack, agency inspectors should also look for
any signs of droplet reentrainment. The deposition of droplets in
the immediate vicinity of the stack is a clear indication that the
scrubber demister is not performing adequately, Some of the symp-
toms of reentrainment include the following conditions.
* Readily apparent droplet deposition from the stack
* Discoloration of adjacent columns, beams, and equipment
* Mud lips at the stack
7-10
-------
SLIDE 7-11
O/Pump
SLIDE 7-11 LECTURE NOTES:
The capability of a scrubber system to collect particulate matter
is usually directly related to the static pressure drop. This is
measured by a static pressure gauge with measurement taps upstream
and downstream of the scrubber throat. In the case of the colli-
sion scrubber shown in Slide 7-11, these measurement locations
would be at the locations shown by the large dots.
The static pressure data is electrically transmitted back to the
control room and is generally recorded as part of the daily system
operating logs. For many types of units, the data is used to
control the adjustable throat mechanisms or flue gas recirculation
dampers (Flue gas recirculation not shown on Slide 7-11.) to
maintain constant pressure drop.
The data obtained during the on-site inspection should be compared
with the baseline data recorded during the initial series of emis-
sion tests and during previous inspections. For MWC units, the
normal pressure drop range is 30 to 50 inches of water. A decrease
of 3 to 5 inches of water may indicate emission problems,
especially if the plume opacity appears to be high.
The pressure drop data for the time period since the last on-site
inspection should be reviewed. Possible reasons for lower-than-
normal values include low recirculation liquor flow rates, erosion
of adjustable throat mechanisms, and decreased gas flow rates.
These should be evaluated by follow-up phase inspection steps.
7-11
-------
SLIDE 7-12
'Pump
SLIDE 7-12 LECTURE NOTES:
The adequacy of acid gas removal in wet scrubber systems is par-
tially dependent on the liquor pH entering the packed bed vessel.
The pH levels should usually be less than 8. At low pH levels, the
sulfur dioxide is not removed effectively. At high pH levels,
there is a risk that calcium and magnesium dissolved in the scrub-
ber will precipitate in the packed bed and cause gas distribution
problems.
Low pH levels are usually due to failure of the alkali feed system
(not shown in Slide 7-12). High pH levels are due to overfeed
conditions when the levels of acid gases entering the scrubber
decrease.
For the system shown in Slide 7-12, the liquor pH levels should be
measured at the discharge of the condenser/absorber and the
discharge of the demister (see Dots #1 and #2 on Slide 7-12). The
recirculation tanks immediately upstream of the recirculation pumps
(tanks not shown on Slide 7-12) provide convenient measurement
locations. However, the pH levels at these discharge points may be
slightly lower than the inlet pH levels due to the neutralization
of acid gases while passing through the scrubber vessels.
7-12
-------
C5P £>\U*J( W atiA^f&A
SLIDE 7-13
GAS-ATOMIZED SCRUBBER SYSTEMS
FOLLOW-UP INSPECTION STEPS
* Condenser/absorber exit gas
temperature
* Liquor recirculation rates
* Evaporative cooling water
quality
* Demister pressure drop
SLIDES 7-12 AND 7-13 LECTURE NOTES (Continued)
The condenser/absorber outlet gas temperature (Dot #3) should be
checked if the stack opacity is high but the scrubber pressure drop
remains similar to baseline levels. If this gas temperature has
increased, it is possible that the quantity of water vapor
condensed on the. surfaces of the difficult-to-collect: submicron
particles has decreased. This would reduce the scrubber's ability
to capture these small particles. An increase of 5 to 10 degrees
Fahrenheit could have a noticeable impact on scrubber performance.
The liquor recirculation rate to the particulate scrubber vessel
(collision scrubber in Slide 7-12) should be checked if the plume
opacity has increased and the scrubber static pressure drop has
decreased. The liquor recirculation rate is often monitored by
means of magnetic flow meters and swinging vane meters upstream of
the recirculation pumps (Dots #4 and #5 in Slide 7-12). Indirect
indicators of liquor flow rate can be used if flow rate instruments
are not available or if they are not working properly. These
indicators include the recirculation pump motor currents and the
scrubber nozzle header pressures.
On older incinerators without heat recovery, the inlet gas tempera-
ture must be reduced by evaporative cooling upstream of the scrub-
ber vessel. Since a large fraction of the cooling water spray is
evaporated, suspended and dissolved solids in the spray water can
be released as small diameter particles. To avoid this problem,
clean water should be used for cooling. Analyses of the total
solids content of the cooling water should be requested if the
opacity is high and scrubber pressure drop appears normal.
The demister pressure drop should be checked if there are any
indications of liquor reentrainment. Substantial increases from
baseline levels or values in excess of 1.5 to 2 inches of water may
indicate partial pluggage of the demister.
7-13
-------
SLIDE 7-14
Collection Plates
Flush Nozzles
Support Insulator
Recirculation Liquor
to Wire Flush Nozzles
Gas
Distribution
Screen
Fresh
Water
Packed Bed
Recirculation
Liquor
Nozzles
Pump
SLIDE 7-14 LECTURE NOTES:
The T-R set electrical data recorded for Wet Ionizing Scrubbers is
very similar to the data used for electrostatic precipitators. The
voltages and currents should be recorded at the values correspond-
ing to the highest sustained levels. Generally the primary con-
trol cabinets have only secondary voltage and secondary current
gauges.
The secondary voltages should be compared against the baseline
levels for the unit. These voltages are usually in the range of 20
to 22 kilovolts. Decreases in the voltages could indicate
increased emissions from the incinerator or solids accumulation on
the small collection plates in the ionizer section. Reduced
voltages could also be caused by support insulator electrical
leakage.
The secondary currents are mainly dependent on the secondary
voltage. If the voltage drops because of an internal problem, the
current drops significantly. However, reductions in currents can
also be caused by solids build-up on the wires or plates or by
increased generation of particulate matter in the incinerator.
7-14
-------
SLIDE 7-14 LECTURE NOTES (Continued):
The spark rate in a single field module can be estimated by
counting the fluctuations of the voltage gauge. A major increase
in the spark rate can be due to alignment problems in the ionizer
section.
The packed bed liquor pH data should be checked since this is an
indirect indication of the adequacy of acid gas removal in the
packed bed section. The pH levels should be between 6 and 8.
Corrosion and poor acid gas absorption are possible at low pH
levels, and chemical precipitation is possible at very high pH
levels.
7-15
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REVIEW QUESTIONS - DRY SCRUBBERS AND WET SCRUBBERS
Directions: Select the answer or answers which are correct.
1. Why are sulfur dioxide CEMS used as an indirect indicator of
dry scrubber hydrogen chloride collection?
a. Hydrogen chloride is present in relatively low
concentrations compared to sulfur dioxide.
Sulfur dioxide is more difficult to collect than
hydrogen chloride.
Hydrogen chloride monitors have not been used
extensively on MWC units.
2. What is the typical stoichiometric requirement for alkali
in dry injection type dry scrubbers?
a. 0.5 to 1.0
b. 1.0 to 2.0
(q) 2.0 to 3.5
d. 3.5 to 5.0
3. The outlet ga.s temperatures (dry bulb) of a spray dryer
absorber has increased 30 degrees Fahrenheit from -baseline
levels. Has acid gas collection probably increased or
decreased?
a. Increased
(b) Decreased
4. What is the typical liquor pH is wet scrubber systems used
on MWC units?
a. 2 to 4
b. 4 to 6
-c. 6 to 8
d. 8 to 10
e. 10 to 12
f. Greater than 12
5. What is the purpose of installing a condenser/absorber vessel
upstream of a particulate scrubber?
-a. Remove acid gases
-(B) Promote growth of particles
-c. Cool the gas stream to prevent thermal damage
d. Reduce possible corrosion in the particulate scrubber
7-16
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8. INSPECTION OF NITROGEN OXIDES SYSTEMS
The evaluation of NOX control systems is based primarily on the
continuous monitoring data. Visible emission observations are also
important as a check for ammonia-related secondary plume formation.
Data concerning the add-on equipment is used primarily as follow-up
information when evaluating proposed corrective actions.
SLIDE 8-1
NITROGEN OXIDES CONTROL SYSTEMS
PRIMARY INSPECTION DATA
Visible emissions data
Opacity OEM data
Presence of absence of
condensing plume
Inlet gas temperature
Reagent feed rate
)
SLIDE 8-1 LECTURE NOTES:
The visible emission observation and CEM data evaluation are
generally performed as part of the evaluation of the particulate
control system. These are discussed briefly in this lecture
because ammonia emissions from poorly operating nitrogen oxides
control systems is one of the possible causes of condensing plumes.
It should be noted that the visible emission observation does not
address the emissions of nitrogen oxides. Opacity is the result of
light scattering by aerosols not the absorption of light by mole-
cules. There is sometimes some confusion regarding nitrogen oxides
since one of the chemical forms, NO2, does have a distinct reddish
brown color. No attempt should be made to read this color as
"opacity" in the unusual circumstances when this is present.
The inlet gas temperatures and the reagent feed rates directly
affect the nitrogen oxides reduction efficiencies. This data
should be recorded during the inspection to document the operating
status of the units. A review of the operating records since the
last inspection should be conducted if there have been significant
excursions above the nitrogen oxides limits.
8-1
-------
SLIDE 8-2
SLIDE 8-2 LECTURE NOTES:
The nitrogen oxides CEM data provides the most useful information
for evaluating the performance of add-on nitrogen oxides systems.
The data should be evaluated using a baseline emissions-load curve
similar to the one introduced for opacity. In the case of noncata-
lytic systems, an upward shift could be due to fouling of the heat
exchange surfaces and a resulting change in the prevailing gas
temperatures at the reagent injection locations during certain
incinerator loads. In the case of catalytic systems, a gradual
deterioration in performance could be due to blinding or
deactivation of the catalyst bed.
When evaluating the nitrogen oxides data, the ability of the system
to handle peak nitrogen oxides generation rates should be evaluat-
ed to the extent possible. Nitrogen oxides emissions are often at
peak levels during the combustion of wastes having a large fraction
of yard wastes. Nitrogen oxides also increase during periods when
the incinerator oxygen concentrations are high. The incinerator
daily operating records should be reviewed to select days in which
either or both conditions existed. The nitrogen oxides concentra-
tions in the flue gas during these periods should be checked.
8-2
-------
SLIDE 8-3
-40
1400 1800 2200
Gas Temperature,
Degrees Fahrenheit
SLIDE 8-3 LECTURE NOTES:
For noncatalytic reduction systems, there is a strong relationship
between the gas temperature (at the reagent injection point) and
the efficiency of nitrogen oxides reduction. The desirable operat-
ing range is 1600 to 1900 degrees Fahrenheit. However, due to site
specific temperature monitoring problems, the baseline data
obtained during the initial emission test series should be used as
the main guideline when evaluating the temperature data.
The present temperature data should be obtained to document the
operating conditions during the inspection. Also, temperature data
should be obtained from the plant records (DAS system) for any
periods in which the nitrogen oxides concentrations exceeded
allowable limits. This data is used to independently determine if
there is a chronic emission problem due to improper injection
locations.
Inlet gas temperature data is also important for catalytic systems.
The normal operating range is 550 to 750 degrees Fahrenheit. Low
temperatures can result in lower nitrogen oxides reduction
efficiency.
8-3
-------
SLIDE 8-4
100
CM
Z
80
60
o
'•8
I 40
tr
X
O
^ 20
0
Note: Efficiencies are as
shown only when
injection occurs in
proper temperature
range.
0.2
0.4 0.6 0.8 1.0
Urea/NOx Molar Ratio —*>
' 1 L_
0.4 0.8 1.2 1.6 2.0
NH 3/NOx Molar Ratio —*
2.4
SLIDE 8-4 LECTURE NOTES:
The effectiveness of the noncatalytic reduction systems is related
to the feed rate of the reagent. The reagent feed rate during the
inspection should be recorded on the inspection checklist. The
ability of the feed rate to keep up with short term fluctuations in
nitrogen oxides generation rates should be evaluated by observing
the instantaneous nitrogen oxides data.
The reagent feed rates during noncompliance periods should be
obtained from the DAS system or plant operating logs. The reasons
for any lower-than-normal feed rates should be discussed with plant
personnel.
8-4
-------
SLIDE 8-5
Supcftwiur
Source: Hurst and White
Ammonia Injection Nozzle Locations for the
Thermal DeNox Process
SLIDE 8-5 LECTURE NOTES:
The adequacy of NOx reduction in noncatalytic reduction systems
depends partially on the mixing of the ammonia gas or urea solution
with the flue gas. The nozzle operating conditions affect the
penetration of the reducing agents. If there have been NOX compli-
ance problems, the present data should be compared with baseline
conditions. A reduction in the operating pressures would be
associated with less effective mixing.
8-5
-------
REVIEW QUESTIONS - NITROGEN OXIDES CONTROL SYSTEMS
Directions: Select the answer or answers which are correct.
1. Why are visible emission observations a necessary step in
evaluating nitrogen oxides control systems?
a. Improperly operating nitrogen oxides systems can
generate soot.
JD. Nitrogen dioxide emissions can have a high opacity.
(c) Ammonia emissions can react to form submicron aerosols.
2. In a noncatalytic reduction system using ammonia, the gas
temperature at the injection point has increased from 1800
degrees Fahrenheit to 2000 degrees Fahrenheit. Will the
nitrogen oxides emissions increase or decrease from the
baseline levels?
(a> Increase due to oxidation of ammonia to nitrogen oxides
b. Increase due to unavailability of ammonia for reduction
of nitrogen oxides
c. Decrease due to increased reaction rate between ammonia
and nitrogen oxides r
d. Decrease due to shift in amount of nitrogen oxides in the
the nitric oxide form
3. What is the stoichiometric requirement for ammonia in
noncatalytic reduction systems?
a. 0.1 to 0.5
b. 0.5 to 1.0
c. Approximately 1.0
d. 1.0 to 2.0
(e\ 2.0 to 5.0
4. Which factors influence the formation rate of nitrogen oxides
in MWC units?
(JL\ The quantity of yard waste being charged
© The flue gas oxygen concentrations
c. The operating rate
d. The quantity of plastics being charged
5. What chemicals are often used as reducing agents in nitrogen
oxides control systems?
(a) Ammonia
b. Acetone
© Urea
d. Phenol
8-6
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9. MATERIAL RECOVERY
This lecture concerns the evaluation of the material recovery
programs intended to achieve compliance with the 25% reduction
requirement specified in the proposed NSPS regulations and included
in many State regulations. It is anticipated that the air pollu-
tion control inspector will be one member of the agency team
reviewing compliance information.
SLIDE 9-1
SLIDE 9-1 LECTURE NOTES:
The inspection and evaluation procedures described briefly in this
section are based on a weight measurement approach. The quantity
of wastes received at the plant (stream number 2) is compared with
the weights of the various recovered material streams (streams
number 8-15). This approach has been used since it is consistent
with the proposed regulations.
9-1
-------
SLIDE 9-2
Aluminum Cans
Vthicte BanaiiM
Industrial Cardboard
YardWaftM
Secondary
Materials
Industries
Residential
Composting
ComingM Wanes
tr <" f"
<•*"« %< -4
Alkali
Incinerator &
Air Pollution
To
Hazardous
Landfill
SLIDE 9-2 LECTURE NOTES:
The waste separation and processing scheme shown in Slide 9-2 is
being used simply as an example of one possible approach. The
specific procedures used any a given MWC facility being evaluated
would be described in the Waste Reduction Compliance Plan sub-
mitted by the MWC facility owners and any "Co-operators" having
contractual agreements with the plant to assist in waste reduction.
The waste separation and processing approach described in this plan
should be illustrated using a flowchart similar to the one shown in
Slide 9-2. The procedures for drawing this flowchart are described
in the Flowchart Preparation Manual included in the Appendix of
this course manual.
The next step is to determine the weight data is necessary in order
to assess the quantities of wastes diverted from the incinerator
facility. Not all of the various material streams can be weighed
with equal accuracy and convenience.
9-2
-------
SLIDE 9-3
SLIDE 9-3 LECTURE NOTES:
The processed waste sent to the incinerator (stream number 2 in
Slide 9-2) is weighed with a high degree of accuracy using the
truck scales at the entrance to the plant. They are designed to
have an accuracy of plus or minus 2%. However, the actual accuracy
of the measurement depends on whether or not tare measurements are
used or simply -incoming weight measurements are used. If only the
incoming truck weights are used, the measurement will be subject
the random error associated with the quantity of gas in the truck
tank.
9-3
-------
SLIDE 9-4
SLIDE 9-4 LECTURE NOTES:
Some of the recovered material streams from the MRF are weighed
using truck scales having accuracies similar to those used at the
incinerators. For example, the truck shown in Slide 9-4 is being
loaded with recovered ferrous metals (stream 11 in Slide 9-2).
However, some of the recovered material streams have relatively low
densities and may be difficult to weigh with the same accuracy as
ferrous metals. These low density streams include plastics and
newspaper.
9-4
-------
SLIDE 9-5
SLIDE 9-5 LECTURE NOTES:
The quantities of materials recovered in community sponsored
programs and "buy-back" type programs (streams 6-9 in Slide 9-2)
must be determined by the receiving organizations. The calculation
procedures proposed by the MWC owners in their compliance plan will
outline the means of obtaining this information specific for the
area served by the MWC facility.
The quantity of yard wastes recycled by means of residential
composting is especially difficult to measure. For this reasons,
MWC operators are allowed to claim that up to 10% of the total
waste stream has been recycled in this manner.
9-5
-------
SLIDE 9-6
1-15
£f
Where:
T =
Total Quantity
Recovered, Tons/Yr.
R = Fraction Recovered,
Dimensionless
W,= Weights of Material
Streams, Tons/Yr.
SLIDE 9-6 LECTURE NOTES:
Based on the MWC plant compliance plan, a set of equations should
be used to calculate the weight fraction of material recovered. An
example set of equations for the relatively simple situation shown
in Slide 9-2 is shown in Slide 9-6.
9-6
-------
REVIEW QUESTIONS - MATERIAL RECOVERY
Directions: Select the answer or answers which are correct.
1. What fraction of the total municipal waste must be'separated
and recovered according to the proposed regulations?
a. 10%
b. 15%
c. 20%
d. 25%
e. 50%
2. What waste is specifically prohibited by the proposed
regulations?
a. Medical waste
b. Asbestos containing materials
c. Vehicle batteries
d. Flammable materials
3. MWC facilities may claim up to a % reduction in the
waste stream incinerated due to the residential composting of
yard wastes.
a. 10%
b. 15%
c. 20%
d. 25%
e. 50%
4. Can a MWC facility obtain a special combustion permit for the
charging of glass and ferrous materials for which no recycling
options presently exist?
a. Yes, but only on a one year renewable basis
b. No
5. What types of materials can often be economically recovered?
a. Aluminum beverage cans
b. Glass
c. Food wastes
d. Office paper
9-7
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10. OPERATOR CERTIFICATION AND TRAINING
The proposed NSPS regulations and some State agency regulations
include requirements for training of MWC plant personnel. The air
pollution control inspector may have some responsibility for con-
firming that these requirements have been satisfied.
SLIDE 10-1
OPERATOR CERTIFICATION
AND TRAINING REQUIREMENTS
CERTIFICATION
* Chief facility operators
* Shift supervisors
TRAINING
* All employees affecting
plant operations
OPERATING MANUAL
SLIDE 10-1 LECTURE NOTES:
The proposed regulations have three separate training and
certification requirements.
* Chief facility operators and shift supervisors
must hold a currently valid certificate issued
by ASME or other approved organization.
* Annual refresher training must be provided to
all plant employees affecting equipment performance.
* A site-specific operations and maintenance manual
must be prepared and made available for review by
the regulatory agency.
During the preinspection meeting, the inspector should request that
all of the necessary documentation concerning these requirements be
compiled. This material can be reviewed following the completion
of the other portions of the on-site inspection.
10-1
-------
SLIDE 10-2
EVALUATION OF
OPERATOR CERTIFICATION
AND TRAINING
* compare employee job classifications
with operating logs to confirm that
a certified individual was on duty.
* Compare the employee list with plant
records to confirm that all individ-
uals have received training.
SLIDE 10-2 LECTURE NOTES:
All chief facility operators and shift supervisors must have a
currently valid provisional or operator's certificate. The
provisional certificate, as defined by the American Society of
Mechanical .Engineers (ASME) requires a minimum of 5 years
experience and the successful completion of a written'test. The
operator's certificate requires an addition 6 months experience as
a chief facility operator and an oral examination.
There must an individual holding a valid certificate in responsible
charge during all times that wastes are being burned. The operat-
ing recoreds of the plant should be examined to confirm that
qualified personnel were on duty as required.
All plant employees affecting equipment performance must receive
training annually. The plant personnel subject to this requirement
includes, but is not limited to the following:
* Control room operators
* Ash handlers
* Crane/load handlers
* Maintenance personnel
Inspectors should review the training records to confirm that all
personnel have received this training. The scope of the training
should also be compared with the specifications included in the
regulations.
10-2
-------
SLIDE 10-3
OPERATION AND MAINTENANCE
MANUAL
Applicable regulations
Basic combustion theory
Waste receiving, handling and
charging
Start-up and shut-down
Combustion air supply
Responding to upsets
Minimizing particulate carryover
Bottom ash burnout
Procedures for handling bottom
ash and flyash
Monitoring emissions
Recordkeeping and reporting
SLIDE 10-3 LECTURE NOTES: 7
MWC owners and operators are required to compile site-specific
operation and maintenance procedures for all equipment affecting
compliance with the proposed regulations. The scope of the manual
should include, but not necessarily be limited to, the subjects
listed in Slide 10-3. This list has been drawn from the proposed
regulations.
Inspectors should review the manual to confirm that it meets the
specific criteria in the proposed regulation. The extent to which
the manual has been updated and modified to respond to chronic
excess emission problems should be checked.
10-3
-------
REVIEW QUESTIONS - TRAINING AND CERTIFICATION
Directions: Select the answer or answers which are correct.
1. Which plant personnel~must have a currently valid certificate?
(a). Chief facility operators
b. Chief electricians
c. Maintenance foreman
(d) Shift supervisors
e. Environmental managers
2. How often must plant employees receive training?
a. Once per quarter
(b) Once per year
c. Once every five years
3. How many years of experience are necessary in order to qualify
for a provisional certificate (ASME program)?
a. No experience is necessary
b. > 1 year
c. > 2 years
<^D > 5 years
e. >10 years
4. Which type of certificate would take longer to obtain?
(ASME program)
(a^ Operator's certificate
V. Provisional certificate
5. In the proposed regulations, how often must the operation
and maintenance manual be updated?
Once per year
. Once every five years
c. Whenever necessary
10-4
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11. INSPECTION HEALTH AND SAFETY
The inspection of MWC plants does not involve any special or
unusual health and safety risks. However, air pollution control
agency personnel must recognize possible problems so that they can
be avoided if they occur. This section provides introductory
information concerning these possible health and safety risks.
More detailed information is available in the agency's written
safety procedures manual. Health and safety issues should also be
discussed during the preinspection meeting.
SLIDE 11-1
INSPECTION HEALTH
AND SAFETY
* complete all health and
safety training.
* Bring all necessary personal
protection equipment to the
plant being inspected.
* work with a qualified plant
representative.
* Ask plant personnel to take
all samples
* Discontinue work whenever
necessary
SLIDE 11-1 INSPECTION NOTES:
Prior to performing any field inspection activities, agency
inspectors should complete classroom training in industrial health
and safety. This should include, but not be limited to recognition
of hazards, consequences of exposure, uses and limitations of
personal protection equipment, and first aid. Inspectors should
also take a medical monitoring examination to determine if they are
physically able to perform the field work and to wear any personal
protection equipment such as respirators.
Agency inspectors should not borrow personal safety equipment from
plant personnel. If the agency has not provided the equipment
necessary, the areas where such equipment is required must be
avoided during the on-site inspection.
11-1
-------
SLIDE 11-1 LECTURE NOTES (Continued) :
Inspectors should always be accompanied by plant representatives
who are familiar with the facility's operations. Nothing should be
done which endangers the _inspector, plant personnel, or the equip-
ment. The scope of the inspection should be adjusted as necessary
to avoid all significant hazards.
Regulatory agency inspectors should not enter confined spaces. All
of the inspection objectives can be accomplished very well without
taking these risks. Inspectors do not have the time which is
necessary to double check the equipment isolation, lockout, tagout,
and pretesting of the confined spaces. Serious accidents can occur
even when the plant personnel appear to have taken all of the
normal precautions.
Only plant personnel should take samples of ash, liquid streams,
and waste materials. These samples should be taken using the
established plant procedures. Also, all hatches on equipment out-
of-service or isolated for maintenance should be opened by plant
personnel using established procedures. Potential hazards created
by improper procedures include burns due to contact with hot, free
flowing ash; exposure to hot gas; and hopper fires
Inspectors should, discontinue the inspection if they feel there are
significant health and safety risks. Also, field work should be
discontinued if there are any nonspecific symptoms of illness. A
partial list of these initial symptoms of distress includes the
following.
* Headaches
* Lightheadedness
* Dizziness
Nausea
Loss of coordination
Difficulty in breathing
Chest pains
Exhaustion
Such symptoms may be the result of heat stress, inhalation problems
or a variety of non-occupational related conditions. The field
work should be interrupted or terminated since the inspector may
become seriously impaired in the immediate future if these symptoms
are due to heat stress or inhalation hazards in the areas of the
facility being inspected.
Inspectors should dress appropriately for the field work. Hard
hats, safety shoes, and eye hearing protection are necessary.
Loose fitting clothes or ties which could get caught in poorly
shielded rotating equipment should be avoided. Natural fiber work
clothes are necessary if any areas near hot equipment will be
visited.
11-2
-------
SLIDE 11-2
SLIDE 11-2 LECTURE NOTES:
The characteristics of the wastes being charged to the incinerator
should be observed from a safe vantage point. The inspectors
should be out of the way of all moving trucks, front end loaders,
and overhead equipment.
Areas adjacent to flail mills or shredders should be avoided.
Materials such as paint cans, gas cylinders and other undesirable
wastes can explode inside this equipment. These areas are often
roped off to prevent unauthorized entry.
Normal care is necessary when walking across the tipping floor.
Grease and oil from the trucks and from the waste materials can
create slippery conditions.
Inspectors should not try to reach into or climb into waste piles
in order to retrieve materials believed to be prohibited or hazard-
our. These should only be removed by plant personnel using
standard plant safety procedures.
11-3
-------
SLIDE 11-3
SLIDE 11-3 LECTURE NOTES:
Unprotected observation hatches, such as the old-style hatch shown
in Slide 11-3, should not be used under any circumstances by the
agency inspector. The potential hazards include, but are not
limited to the following.
* Shrapnel from disintegrating aerosol cans and
solvent cans
* Sudden high temperature gas puffs due to pressure
fluctuations in the incinerator
* Intense thermal radiation
* Exposure to toxic pollutants escaping through the
open hatch during short term positive pressure
fluctuations
The ash pit observation hatches are also unprotected and should not
be used by inspectors. These are located on the front walls of
spreader stoker boilers and the back walls of some types of sloped
grate incinerators. They are also located on the back walls of
starved air type modular incinerators.
11-4
-------
SLIDE 11-4
SLIDE 11-4 LECTURE NOTES:
The hatch shown in Slide 11-4 is an example of a protected observa-
tion hatch. There is a transparent panel to reduce the risk due to
metal fragments and high temperature gas puffs. There is also a
purge air stream to minimize any fugitive emissions of partially
oxidized contaminants out into the breathing zones of the
observers.
Before using any observation port, inspectors should ask plant
personnel about the need for special eyewear. Hot surfaces close
to these ports must also be avoided.
11-5
-------
SLIDE 11-5
POORLY VENTILATED AREAS
(Partial List)
* Hoppers on positive pressure
equipment
* Walkways between positive
pressure equipment
* GEM sampling locations
* Ash storage bins
* Alkali storage and handling
areas
* Fan and pump houses
SLIDE 11-5 LECTURE NOTES:
Poorly ventilated areas in the vicinity of positive pressure dry
scrubber absorbers, particulate control systems and ductwork should
be avoided. There are a variety of inhalation hazards associated
with MWC emissions.
* Hydrogen chloride
* Sulfur dioxide
* Dioxins and furans
* Carbon monoxide
* Toxic metal enriched particulate
Concentrations of these pollutants can easily exceed the maximum
allowable use concentrations of air purifying respirators. Also,
air purifying respirators are not designed for this wide variety of
contaminants.
Several of the common air pollutants have good warning properties.
Hydrogen chloride and sulfur dioxide are both soluble gases which
have distinctive odor and irritation characteristics =•*• ~*a«-<™»i"
low concentrations. Areas where these
should be left immediately.
at
pollutants
-------
SLIDE 11-6
SLIDE 11-7
SLIDES 11-6 AND 11-7 LECTURE NOTES:
Before beginning the field work, inspectors should refer to the
block diagram type flowchart of the combustion and air pollution
control system. Any poorly ventilated areas around equipment
operating under positive pressure should be approached carefully.
Positive pressure conditions generally exist downstream from any
fans handling flue gases. The fans which should be identified on
the drawings include the main induced draft (I.D.) fan used for
moving flue gases through the air pollution control system and any
flue gas recirculation fans used for nitrogen oxides control.
11-7
-------
SLIDE 11-8
SLIDE 11-9
11-8
-------
SLIDES 11-8 AND 11-9 LECTURE NOTES:
Slide 11-8 illustrates a poorly ventilated area where pollutants
could accumulate in localized areas. The fan of the left has a 2
inch drain plug mounted_on the fan housing. The plug- has been
removed allowing some fugitive emissions to fill the area next to
a baghouse located to the right of the area shown.
The CEM sampling area shown in Slide 11-9 is an area which should
normally be free of contaminants. The equipment shown in this
photograph is located on a stack platform located approximately 100
feet above the ground. The platform is surrounded by a refractory
stack used for structural support of the separate incinerator
stacks. If an expansion joint begins to leak on the discharge side
of one of the fans, this area could partially fill with flue gas.
It would take some time to leave this area due to the time
necessary to climb down from the platform.
11-9
-------
SLIDE 11-10
SLIDE 11-10 LECTURE NOTES:
Inspectors should avoid areas near open hopper hatches. Hot
solids can avalanche from the hopper as it is being opened or as
plant personnel work near the equipment. Serious burns and fatal
injuries can result. The solids collected in the hoppers can
remain hot for more than a week since the hopper ash is an
exceptionally good thermal insulator. The hot ash can flow and
splash like water.
11-10
-------
SLIDE
«v
OTHER HEALTH AND SAFETY HAZARDS^ ^^___^
* Improper ladder climbing techniques
* Eye and skin contact with strong
alkalis
* Severely vibrating fans
* Hot surfaces
* Falling equipment from stack
sampling platforms
SLIDE 11-11 LECTURE NOTES:
Care is needed when climbing ladders. Around wet scrubbers, slip
hazards can be created by liquor entrained from the stack. In cold
weather, icing is also a problem. Only ladders which meet OSHA
requirements should be used. Inspectors should not climb tall
ladders unless they are trained in proper climbing -techniques,
especially when using third rail type equipment.
When working on stack sampling platforms, inspectors should be
careful not to drop equipment or to accidently kick material off
the platform. They should avoid areas in possible drop zones where
sampling equipment is being hoisted.
The strong alkalis used in dry and wet scrubber systems have the
potential to cause severe eye and skin burns. Inspectors should be
trained in proper first air procedures. It is also important to
know the locations of emergency eye wash stations and showers.
Much of the equipment being inspected is operating at elevated
temperatures. Skin contact with these surfaces should be avoided.
If the walking surfaces are too hot, such as the top access hatches
of a pulse jet fabric filter, these areas should be avoided.
Severely vibrating fans can disintegrate and cause fatal injuries.
Although these are unusual in MWC facilities, inspectors should
remain cognizant of this hazard and leave areas immediately if
there is a possible problem. Plant personnel should be notified
immediately of the possible problem.
More detailed information concerning these health and safety risks
and other hazards that can be present in industrial facilities are
addressed in standard health and safety courses for agency person-
nel. Training should be completed before starting field work.
11-11
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REVIEW QUESTIONS - HEALTH AND SAFETY
Directions: Select the answer or answers which are correct.
1. What possible hazards "are involved in viewing combustion 'condi-
tions through an unshielded and protected observation hatch?
a. Eye injury due to metal fragments from exploding
aerosol cans
b. Puffs of hot gas due to fluctuations in the pressure
c. Thermal radiation
d. Inhalation hazards due to dioxins and furans
- . ,
Under what circumstances should a regulatory agency inspector
participate with the plant personnel in an internal evaluation
of an out-of-service air pollution control device?
a. When the unit has been properly locked out for entry
b. When the unit has been properly prepared for internal
entry and plant personnel are already inside
c. When plant personnel grant permission for entry
(g> Never
What potential hazards are involved with opening a hopper hatch
on an air pollution control device?
(§} Hot, free flowing ash
>»b. Puffs of hot gas due to fluctuations in the incinerator
pressure
c. Hopper fires due to the inrush of air around partially
combusted, hot ash
d. Static electricity
What areas are especially prone to the localized accumulation
of air pollutants?
a. Any duct or vessel handling flue gas which is downstream
of a fan
b. CEM platforms on stacks
rc. Emission testing areas (while sampling ports are open)
d. Areas adjacent to bins where bottom ash and flyash are
combined for transport to a landfill
-
Under what circumstances should an inspector work alone during
the on-site inspection?
a. When plant personnel are very busy and the inspector is
very familiar with the facility
b. When the inspector wishes to conduct an unannounced
inspection
c. When plant personnel provide permission
(eft Never
11-12
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APPENDIX A
PROPOSED NSPS REGULATIONS
A-l
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Federal Register/Vol. 54. No. 243. Wednesday. December 20. 1989/Proposed Rules
52297
entitles will be mitigated. First, the
standards contain mitigation measures.
Several of the requirements are less
restrictive for smaller MWC's. To the
extent the proportion of small-entity
owners and operators of small MWC's
exceeds the proportion of small-entity
owners and operators of large MWC's.
the proposal provision for small MWC's
translates into an easing of the
economic burden on small entities
relative to large entities.
Second, there are several things small
governments can do in the face of steep
compliance costs. In almost all cases
these governments have available to
them an alternative waste disposal
technology—landfilling—end many
ways to expand source reduction.
materials separation, and recycling
programs. Small governments have the
opportunity to join in. or join in forming.
intergovernmental service districts, or to
contract with neighboring waste
disposal operations for disposal
services. Whenever intergovernmental
agreements lead to the construction of
MWC's of larger capacity than
otherwise would have been constructed.
air pollution control costs per Mg of
MSW will shrink. Governments also can
exercise monopoly market power to
restrict competition among landfills and
MWC's to improve the financial
viability of particular MWC's. Finally.
small governments that want to combust
MSW have the option of building and
operating MWC's as public ventures, or
arranging for the MWC's to be built and
operated as private ventures. The small
governments can investigate both
financial markets and then select
whichever approach offers the best
terms.
F. List of Subjects in 40 CFR Parts 51.52
and 60
Air pollution control. Incorporation by
reference. Intergovernmental relations.
Reporting and recordkeeping. Municipal
waste combustora. Municipal solid
waste.
Dated November 30.1969
William K. Rsdiy.
Administrator
For the reasons set forth in the
preamble, it is. proposed that part 51. 52.
and 60. chapter L title 40 of the Code of
Federal Regulations, be amended as
follows
PART 51—REQUIREMENTS FOR
PREPARATION, ADOPTION, AND
SUBMITTAL OF IMPLEMENTATION
PLANS
1. The authority citation for pan 51
continues to read as follows1
A j-.Ncritv. Sees. 101(b);:;. 110.1CO-13Q.
i?'-ira. and 301fa) a! the Clear. Air Act 42
US C. 74Ol(bJJl). 7410. 7470-74'9. 7501-7308.
end 7601 (a).
§51.166 [Amended]
2. In { 51.106 paragraph (b)(23)(i) the
"Pollutant and Emission Rate" is
amended by adding an entry to the end
to read as follows:
Municipal waste combustor emissions:
10 tpy
PART 52—APPROVAL AND
PROMULGATION OF
IMPLEMENTATION PLANS
3. The authority citation for part 52
continues to read as follows:
Authority. 42 U.S.C. 7401-7462.
652L21 [Amended]
4. In 9 52J1. paragraph (b)(23)(i) the
"Pollutant and Emission Rate" is
amended by adding an entry to the end
to read as follows:
Municipal waste combustor emissions:
10 tpy
PART 60—STANDARDS OF
PERFORMANCE FOR NEW
STATIONARY SOURCES
5. The authority citation for part 60
continues to read as follows:
Authority. 42 U.S.C 7401.7411.7414.7416
and 7601.
6. Part 60 is amended by adding a
Subpart Ea. consisting of §§60.50a
through 60.59a. as follows:
Subpart Ea—Standard! of Performance for
Municipal Waste Combustora
Sec.
BO.SOa Applicability and delegation of
authority.
60.51 a Definitions.
B0.52a Standard for MWC metals.
BO 53a Standard for MWC orgarucs.
60S4a Standard for MWC acid gases.
eO.SSa Standard for nitrogen oxides.
B058a Standard for MWC operating
practices.
60 S7a MWC operator certification and
training.
60.53a Compliance and performance testing.
60.59a Reporting and recordkaeping
requirements.
Subpart Ea—Standards of
Performance for Municipal Waste
Combustors
9 60.50a Applicability and delegation of
authority.
(a) The affected facility to which this
subpart applies Is each municipal waste
combustor (MWC) unit for which
construction, modification, or
reconstruction is commenced after
December 20.1989.
(b) Physical or operational charges
—ode to an existing MWC unit to
comply with emissjon guidelines under
Subpart Ca arc not considered a
modification or reconstruction and do
not bring an existing MWC unit under
this subpart.
(c) The following authorities shall be
retained by the Administrator and not
transferred to a State.
§ 60.56a(h)
6.60.51a Definitions.
"ASME" means the American Society
of Mechanical Engineers.
"Bubbling fluidized bed combustor"
means a fluidized bed combustor in
which the majority of the bed material
remains in the primary combustion zone.
"Chief facility operator" means the
person in direct charge and control of
the operation of an MWC and who is
responsible for daily on-site supervision.
technical direction, management, and
overall performance of the facility.
"Circulating fluidized bed combustor"
means a fluidized bed combustor in
which the majority of the bed material is
carried out of the primary combustion
zone and is transported back to the
primary zone through a recirculation
loop.
"Coal/RDF co-fired combustor"
means a combustor that is designed to
fire coal and refuse-derived fuel (RDF)
simultaneously.
"Continuous emission monitoring
system" or "CEMS" means a monitoring
system for continuously measuring the
emissions of a pollutant from an
affected facility.
"Dioxin/furan" means total tetra-
through octa-chlorinated dibenzo-p-
dioxins and dibenzofurans.
"Ferrous metals" means metals and
alloys containing iron. Ferrous metals
include, but are not limited to. pieces of
scrap metal and household appliances
made of iron-containing metals.
including stoves, refrigerators, air
conditioners, and other appliances.
Ferrous metals do not include whole
automobiles or other vehicles or vehicle
bodies.
"Four-hour block average" or "4-hour
block average" means the average of all
hourly emission rates when the affected
facility is operating and combusting
MSW measured over 4-hour periods of
from 12:00 midnight to 4 a.m.. 4 a.m. to 8
a.m.. 8 a jn. to 12:00 noon. 12:00 noon to 4
pjn.. 4 p.m. to 8 p.m.. and 8 p.m. to 12:00
midnight.
"Large MWC plant" means an MWC
plant with an MWC plant capacity
greater than 225 megagrams per day (250
tons per day) of municipal-type solid
waste (MSW).
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52298
Federal Register/Vol. 54. No. 243. Wednesday. December 20. 1989/Proposed Rules
"Mass burn refractory MWC" means
a combustor that combust* MSW in a
refractory wall furnaca.
"Mass bum rotary waterwall MWC'
means a combustor that combusts MSW
in a cylindrical rotary waterwall
furnace.
"Mass burn waterwall MWC" means
a combustor that combusts MSW in a
conventional waterwall furnace.
"Maximum MWC unit load" means
the maximum 1-hour MWC unit load
achieved during the initial compliance
test or during any subsequent test
demonstrating compliance at a higher
unit load.
"Modular excess air MWC" means a
combust.-r that combusts MSW and that
is not field-erected and has multiple
combustion chambers, all of which are
designed to operate at conditions with
combustion air amounts in excess of
theoretical air requirements.
"Modular starved air MWC" means a
combustor that combusts MSW and that
is not field-erected and has multiple
combustion chambers in which the
primary combustion chamber is
designed to operate at substoichiometric
conditions.
"Municipal waste combustor" or
"MWC" or "MWC unit" means any
device that combusts MSW including,
but not limited to. field-erected
incinerators (with or without heat
recovery), modular incinerators (starved
air or excess air), boilers (i.e.. steam
generating units), and furnaces (whether
suspension-fired, grate-fired, mass-fired.
or fluidized bed-fired).
"Municipal-type sobd waste" or
"MSW" means refuse, more than 50
percent of which is waste consisting of a
mixture of paper, wood, yard wastes.
food wastes, plastics, leather, rubber.
and other combuouble ma tens Is. and
noncombustible materials such as metal.
glass, and rock. RDF is considered to be
MSW. Construction/demolit-.on waste is
not considered to be MSW.
"MWC acid gases" means sulfur
dioxide and hydrogen cblonde gases
emitted from MYYC units.
"MWC moials" means condensible
metals associated with particulaie
matter emissions from MWC units.
"MWC organics" means organic
compounds emitted from MWC units
and includes total tetrd- through octa-
chlonnated dibenzo-p-dioxins and
dibenzofurans.
"MWC plant" means one or more
MWC units at the same location for
which construction, modification, or
reconstruction is commenced after
December 20.1989.
"MWC plant capacity" means the
aggregate MWC unit capacity of all
MWC units at an MWC plant MWC
units for which construction.
modification, or reconstruction is
commenced before December 20.1989
are not included for determining
applicability under this subpart
"MWC unit capacity" means the
maximum design charging rate of an
MWC unit expressed in megagrams per
day (tons per day) of MSW combusted.
"MWC unit load" means volume of
steam produced expressed in kilograms
per hour (pounds per hour) of steam.
"Particulate mattcr"means total
particulate matter emitted from MWC
units as measured by Method 5 (see
9 60.58a).
"Potential hydrogen chloriJe emission
rate" means the hydrogen c.ilorids
emission rate that would occur from
combustion of MSW in the absence of
any hydrogen chloride emissions
control.
"Potential sulfur dioxide emission
rate" means the sulfur dioxide emission
rate that would occur from combustion
of MSW in the absence of any sulfur
dioxide emissions control.
"Processed MSW or RDF' means
MSW or RDF that has been processed to
separate materials for recovery prior to
combustion in an MWC unit. MSW or
RDF is considered to be processed MSW
or RDF if an overall 25 percent or
greater reduction by weight (annual
average) of MSW is achieved through
separation for recovery of some or all of
the following recoverable materials:
Paper and paperboard combined:
Ferrous metals;
Nonfeiroiu metals;
Class:
Plastics:
Household batteries: and
Yard waste.
A maximum of 10 percent reduction (by
weight) of the overall MSW shall be
attributed to separation of yard waste.
The 25 percent or greater overall
reduction requirement may be achieved
by on-site mechanical separation. on-
Bit e manual separation, off-site
mechanical separation, off-site manual
separation, or a curbside source
reduction or materials separation
(recycling) program, or a combination
thereof.
"Recoverable materials" means paper
and paperboard combined: ferrous
metals; nonferrous metals; glass;
plastics: household batteries; and yard
waste.
"Refuse-derived fuel" or "RDF" means
a type of MSW produced by processing
MSW through shredding and size
classification. This includes all classes
of RDF including low density fluff RDF
through densified RDF fuel pellets.
"Refuse-derived fuel spreader stoker"
means a steam generating unit that
combusts RDF in a semi-suspension
firing mode using air-fed distributors.
"Same location" means the same or
contiguous property that is under
common ownership or control, including
properties that are separated only by a
street road, highway, or other public
right-of-way. Common ownership or
control includes properties that are
owned, leased, or operated by the same
entity, parent entity, subsidiary.
subdivision, or any combine lion thereof.
including any municipality or other
governmental unit or any quaai-
govemmental authority (e.g., a public
utility district or regional waste disposal
Euthority).
"Shift supervisor" means the person
in direct charge and control of the
operation of an MWC and who is
responsible for on-site supervision.
technical direction, management and
overall performance of the facility
during an assigned shift
"Small MWC plant" means an MWC
plant with an MWC plant capacity of
225 megagrams per day (250 tons per
day) or less of MSW.
"Twenty-four hour daily average" or
"24-hour daily average" means the
average of all hourly emission rates
when the affected facility is operating
and firing MSW measured over a 24-
hour period between 12.-00 midnight and
the following midnight
"Unprocessed MSW or RDF' means
MSW or RDF that has not been
processed to separate materials for
recovery prior to combustion or for
which less than a 25 percent reduction
by weight (annual average) of MSW is
achieved as specified under "processed
MSW or RDF."
"Vehicle batteries" means any wet
lead-acid battery weighing more than 5
kilograms (11 pounds) that is
manufactured for use in motor vehicles.
vessels, or aircraft or for any ether
(nonvehicular) use.
"Yard waste" means vegetative
matter removed as a result of outdoor
maintenance practices frcrn residential
and commercial yards, municipal parks.
gardens, golf courses, and other similar
areas, and includes, but is not limited to,
grass trimmings, tree branches, straw.
and leaves.
§60.52a Standard for MWC metals.
(a) On and after the date on which the
initial compliance test is completed or is
required to be completed under S 60.8.
no owner or operator of an affected
facility shall cause to be discharged into
the atmosphere from that affected
facility any gases that contain
particulate matter in excess of 34
milligrams per dry standard cubic meter
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Federal Register/Vol. 54. No. 243. Wednesday. December 20. IPM/Proposed Rules 52299
(0 CIS grav.s per dry standard cubic
foot), corrected to 7 percent oxygen (dry
basis).
(b) On end after the dele on which the
initial compliance test is completed or is
required to be completed under § 60.3.
no owner or operator of an effected
facility subject-to the participate matter
emission limit under paragraph (a) of
this section shall cause to be discharged
into the atsjosphere from that affected
facility any gases that exhibit greater
than 10 percent opacity (B-rrvnute
average)
§ 60.S3a Standard lor MWC organic*.
(a) On and after the date on which the
initial compliance test is completed or is
required to be completed under § 60.8.
no owner or operator of an affected
facility located within a small MWC
plant shall cause to be discharged into
the atmosphere from that affected
facility any gases that contain dioxin/
furan emissions that exceed 75
nanograms per normal cubic meter (30
grains per billion standard cubic feet).
corrected to 7 percent oxygen (ilry
basis), except as provided under
paragraph (b) of this section. ~
(b) On end after the date on which the
initial compliance test is completed or is
required to be completed under 8 60 8.
no owner or operator of an affected
facility combusting RDF and located
within a small MWC plant shall cause to
be discharged into the atmosphere from
that effected facility an> gasrs that
contain dio\in/furcn emissions trmt
exceed 250 nanogrems per normal ci-bic
meter MOO gidins pc: billion standard
cubic fee'). conec'fd to 7 pi'.-rcnl
uxj'jc-n [dr\ bas1.*)
(c) On *nd after t^e d-itc o:: which the
initial compl.c-riv-e lost is corr.pUlcd or ;s
required to be C'.rpplelcd und^-r § GO B.
no ov\nrr cr cipcrj'-T of an affcc'pd
facility locati J \\':hin a larp.- MWC
plan! sha'l rd-j«L Ic bs dis( h.i.Rcr! i."lo
tne a :n.u> :•!'£! t f.-T i tlirft jffr, u-d
facility d"> ij.ist:., tiidt conl.i.,' liox.n/
furan eni:-.!, .Ji-s ifidl e^c'-i::.! J1 lo 30)
ndiioyrdrrs \ \.- inri <1 CLUIL r.'C cr ('.2 to
12] grdir.s p. i ;,i!. ~n ftandni-J cuhi'.
f'-ct), c-jrr'.-ci'-d : 7 r.erccnl o\j gt n (ilry
basis]
§ 60.549 Standard lor UWC acid gases.
!d] On and aftcr 'He de!e i>r v. iit-'n the
initial complnnrc IPS' is completed or is
required In L
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52300
Federal Register/Vol. 54, No. 243, Wednesday. December 20. 1989/Propo8ed Rules
separation/combustion permit for any
combustible material designated for
separation under the materials
separation plan under S 60.59a(d) for
which a market is unavailable for the
separated material for 120 days. A
market is considered to be unavailable
for such combustibles if the
Administrator determines that: the cost
of recycling such combustibles exceeds
the cost of landflUing them, and that the
25 percent reduction in the weight of
MWC or RDF contained in the definition
of "processed MSW or RDF" cannot be
obtained through separation of other
recoverable materials. An owner or
operator wishing to demonstrate that a
recycling market is unavailable for
recoverable combustibles must submit a
demonstration to the Administrator that
includes: a list of recycling facilities and
facility officials contacted, a written
discussion of why he was not able to
obtain recycling for the combustible
wastes, and/or a list of landfill facilities
and facility individuals contacted and a
documented comparison of the costs of
recycling versus the costs of landfilling.
The MWC owner or operator must also
provide to the Administrator the
following certification:
I certify under penalty of law thai a
recycling market is unavailable for the
following combustible recoverable^ as
defined in 40 CFR 60.51 a. I believe that the
information submitted is true, accurate, and
complete. I am awire that there are
significant penalties for submitting false
information, including the possibility of fine
or imprisonment.
(2) If a materials separation/
cumbustion permit has been issued.
separated materials) covered under the
materials separat. on/combustion permit
may be combusted in the affected
facility and are credited toward the
overall 25 percent materials separation
requirement under the definition of
"processed MSW or RDF' under
S 6051a
(3) If a mdtunuls separation/
combustion permit is granted by the
Admimsti-'nr. it shall be valid for a
'laximurr. of 1 year. Rcapplicaticn may
be made for subsequent materials
scparation/combust'on permits within
CO djys before expiration of such a
and may bo renewed for 1 year.
§ 60 57a MWC operator certification end
falnlng.
(a) Within 24 months from the dale
that ASME adopts a certification
program for MWC unit (resource
recovery facility) operators, each chief
facility operator and shift supervisor of
an affected facility shall obtain and
keep current either a provisional or
operator certification from ASME.
(b) The owner or operator of an
affected facility shall cause an ASME-
certified shift supervisor to be on duty at
the-affected facility at all times during
periods of MWC unit operation. This
requirement shall take effect 24 months
after the date that ASME adopts a
certification program for MWC unit
(resource recovery facility) operators
(c) The owner or operator of an
affected facility shall develop and
update on a yearly basis a site-specific
operating manual that shall, at a
minimum, address the following
elements of MWC unit operation:
(1) Summary of the applicable
standards under this subpart;
(2) Description of basic combustion
theory applicable to an MWC unit
(3) Procedures for receiving, handling.
and feeding MSW:
(4) MWC unit startup, shutdown, and
malfunction procedures:
(5) Procedures for maintaining proper
combustion air supply levels:
(6) Procedures for operating the MWC
unit within the standards established
under this subpart:
(7) Procedures for responding to
periodic upset or off-specification
conditions;
(6) Procedures for minimizing
particulate matter carryover;
(9) Procedures for monitoring the
degree of MSW burnout;
(10) Procedures for handling ash;
(11) Procedures for monitoring MWC
unit emissions: and
(12) Reporting and rer.ordkecping
procedures.
(d) The owner or operator of an
affected facility shall establish a
program for reviewing the operating
manual annually with each person who
has responsibilities affecting the
operation of an affected facility
including, but not limited to. chief
facility operators, shift supervisors.
control room operators, ssh handlers.
maintenance personnel, and crane/lond
handlers.
(e) The initial review of the operating
manual, as specified under paragraph
(d) of this section, shall be conducted
prior to assumption of responsibilities
affecting MWC unit operation by any
person required to undergo training
under paragraph (d) of this section.
Subsequent reviews of the manual shall
be carried out annually by each such
person.
(f) The operating manual shall be kept
in a readily accessible location for all
persons required to undergo training
under paragraph (d) of this section. The
operating manual and records of
training shall be available for inspection
by EPA upon request
{ 6038a Compliance and performance
testing-
(a) The standards under this subpart
apply at all times, except during periods
of startup, shutdown, or malfunction:
Provided, however. That the duration of
startup, shutdown, or malfunction shall
not exceed 3 hours per occurrence.
(b) The following procedures and test
methods shall be used to determine
compliance with the emission standards
for PM under S 60.52a:
(1) Method 1 shall be used to select
sdmplmg site and number of traverse
points.
(2) Method 3 shall be used for gas
analysis.
(3) Method 5 shall be used for
determining compliance with the
particulate matter emission standard.
The minimum sample volume shall be
3.4 cubic meters (120 cubic feet). The
temperature of the sample gas in the
probe and filter holder shall be 160 *C
(320 *F). An oxygen or carbon dioxide
measurement shall be obtained
simultaneously with each Method 5 run.
(4) For each Method 5 run, the
emission rate shall be determined using.
(i) Oxygen or carbon dioxide
measurements.
(ii) Dry basis F factor, and
(iii) Dry basis emission rate
calculation procedures in Method 19.
(5) An owner or operator may request
that compliance be determined using
carbon dioxide measurements corrected
to an equivalent of 7 percent oxygen.
The relationship between oxygen and
carbon dioxide levels for the affected
facility shall be established during the
initial compliance test
(6) The owner or operator of an
affected facility shall conduct an initial
compliance test for particulate matter
and opacity as required under S 60.8
(7] Method 9 shall be used for
determining compliance with the opacity
standard.
(B) The owner or operator of un
affected facility shall install, calibrate.
maintain, and operate a continuous
emission monitoring system (CEMS) for
measuring opacity and record the output
of the system.
(9) Following the date the initial
compliance test for particulate matter is
completed or is required to be
completed under 8 GO B for an affected
facility located within a lurg-j MWC
plant, the owner or operator shall
conduct a performance test for
particulate matter on an annual basis
(no more than 12 calendar months
following the previous compliance lest)
(10) Following the date the initial
compliance test for particulate matter is
completed or is required to be
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Federal Register/Vol. 54. No. 243. Wednesday. December 20. 1989/Proposed Rules
52301
! ur.drr | 60.8 for an affected
facility located within a small MWC
plant, the owner or operator shall
conduct a performance test for
particulars matter on an annual basis
(no more than 12 calendar months
following the previous compliance test).
If all three performance tests for a 3-
yenr penod indicate compliance with
the participate matter standard, the
owner or operator may forego a
performance test for the subsequent 2
years. At a minimum, a performance test
for paniculate matter shall be conducted
every third year (no more than 36
months following the previous
compliance test). If a performance test
conducted every third year indicates
compliance with the particulate matter
standard, the owner or operator may
forego a performance test for an
additional 2 years.
(c) The following procedures and test
methods shall be used to determine
compliance with the standards for
dioxin/furan emissions under S 60.S3a:
(1) Method 23 shall be used for
determining compliance with the
dioxin/furan emission standards.
(2) The owner or operator of an ~
affected facility shall conduct an initial
compliance test for dioxin/furan
emissions as required under § 60.8.
(3) Following the date of the initial
compliance test or the date on which the
initial compliance test is required to be
completed under 8 60.8. the owner or
operator of an affected facility located
within a large MWC plant shall conduct
a performance test for dioxin/fuian
emissions on an annual basis (no more
than 12 calendar months following the
previous compliance test).
(4) Following the date of the initial
compliance test or the date on which the
initial compliance test is required under
{ 60 8. the owner or operator of an
affected facility located within a small
MWC plant shall conduct a performance
test for dioxm/furan emissions on an
annual basis (no more than 12 calendnr
months following the previous
comr-liarce tcsl) If ell three
pcrf jrmance tests in a 3-year period
indicate compliance with the ilioxm/
furan emissions standard, the owner or
oper.Uur nay forego a performance test
for the subsequent 2 years At a
minimum, a performance test for dioxin/
fur.m emissions shall be conducted
everv third >ear (no more than 38
monthj follow.ng the previous
compliance tes1.) If e performance test
conducted every third year indicates
con.pliance with the dioxin/furan
emissions standard, the owner or
operator may forego conducting a
performance test for an additional 2
years.
(5) An owner or operator may request
that compliance with the dioxin/furan
emissions standard be determined using
carbon dioxide measurements corrected
to ar. equivalent of 7 percent oxygen.
Hie relationship between oxygen and
carbon dioxide levels for the affected
facility shall be established during the
initial compliance test
(d) The following procedures and test
methods shall be used for determining
compliance with the sulfur dioxide
standards under 8 60.54a:
(1) The percentage reduction in the
potential sulfur dioxide emissions
(%Psoi) i» computed using the following
formula*
(E.-EJ
E,
XlOO
where:
E, is the daily potential sulfur dioxide
emission rate.
E. is the daily sulfur dioxide emission rate
measured at the outlet of the acid gas
control device.
(2) Method 19 shall be used for
determining the sulfur dioxide emission
rate.
(3) An owner or operator may request
that compliance with the sulfur dioxide
emissions standard be determined using
carbon dioxide measurements corrected
to an equivalent of 7 percent oxygen.
The relationship between oxygen and
carbon dioxide levels for the affected
facility shall be established during the
initial compliance test
(4) The owner or operator of an
affected facility shall conduct an initial
compliance test for sulfur dioxide as
required under 8 60.8. The sulfur dioxide
compliance test shall be conducted over
24 consecutive unit operating hours at
maximum MWC unit load. Compliance
with the sulfur dioxide standard shall be
determined using a 24-hour daily
average.
(5) The owner or operator of an
affected facility shall install, calibrate.
maintain, and operate a CEMS for
measuring sulfur dioxide emissions
discharged to the atmosphere and
record the output of the system.
(6) Following the date of the initial
compliance test or the date on which the
initial compliance test is required to be
completed under 8 60.8. compliance with
the sulfur dioxide standard shall be
determined based on the arithmetic
average of the hourly emission rates
during each 24-hour daily period
measured between 12:00 midnight and
the following midnight using CEMS inlet
and outlet data, if compliance is based
on a percentage reduction, or outlet data
only if compliance is based on m:
emission limit.
(7) At a minimum CEMS daK« sh.,ll In-
obtained for 75 percent of the hours per
day for 75 percent of the days per mor.ih .
the unit is operated and combusting
MSW.
(B) The 1-hour averages required
under paragraph (d)(5) of this section
shall be expressed in nanograms pur
hour (pounds per hour) and used to
calculate the 24-hour daily average
emission rates. The 1-hour averages
shall be calculated using the data points
required under fi 60.13(b). At least two
data points shall be used to calculate
each 1-hour average.
(9) All valid CEMS data shall be used
in calculating emission rates and
percent reductions even if the minimum
CEMS data requirements of paragraph
(d)(7) of this section are met.
(10) The procedures under { 60.13
shall be followed for installation.
evaluation, and operation of the CEMS.
(11) The CEMS shall be operated
according to Performance Specification
1.2. and 3 (Appendix B).
(12) Quarterly accuracy
determinations and daily calibration
drift tests shall be performed in
accordance with Procedure 1 (Appendix
F).
(13) The span value of the CEMS at
the inlet to the sulfur dioxide control
device is 125 percent of the maximum
estimated hourly potential sulfur dioxide
emissions of the MWC unit, and the
span value of the CEMS at the outlet to
the sulfur dioxide control device is 50
percent of the maximum estimated
hourly potential sulfur dioxide
emissions of the MWC unit.
(14) When sulfur dioxide emissions
data are not obtained because of CEMS
breakdowns, repairs, calibration checks
and zero and span adjustments.
emissions data shall be obtained by
using other monitoring systems as
approved by the Administrator or
Method 19 to provide as necessary
emission data for a minimum of 75
percent of the hours per day for 75
percent of the days per month the unit is
operated and combusting MSW.
(e) The following procedures and lest
methods shall be used for determining
compliance with the hydrogen chloride
standards under 8 60.54a:
(1) The percentage reduction in the
potential hydrogen chloride emissions
(*PHO) >• computed using the following
formula:
A-7
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52302
Federal Register/Vol. 54. No. 243. Wednesday. December 20. 1989/Proposed Rules
(E.-EJ
X 100
where:
E IB the daily potential hydrogen chloride
emission rate.
E. is the daily hydrogen chloride emission
rate measured at the outlet of the acid
gjs control device.
(2) Method 26 sl.all be used for
determining the hydrogen chloride
emission rate.
(3) An owner or operator may request
that compliance with the hydrogen
chloride emissions standard be
determined using carbon dioxide
measurements corrected to an
equivalent of 7 percent oxygen. The
relationship between oxygen and
carbon dioxide levels for the affected
facility shall be established during the
initial compliance test.
(-1) The owner or operator of an
affected facility shall conduct an initial
compliance test for hydrogen chloride as
required under 9 60 8.
(5) Following the date of the initial
compliance test or the date on which the
initial compliance test is required under
§ 60.8. the owner or operator of an
effected facility located within a large
MWC plant shall conduct a performance
tpst for hydrogen chlonde on an annual
basis (no more than 12 calendar months
following the previous compliance test).
(6) Following the date of the initial
compliance test or the date on which the
initial compliance test is required under
5 80 8. the owner or operator of an
affected facility located within a small
MWC plant shall conduct a performance
test for hydrogen chloride on an annual
basis (no more than 12 calendar months
following the previous compliance test).
If all three performance tests in a 3-year
period indicate compliance with the
hyurogen chlonde standard, the owner
or operator may forego a performance
test for the subsequent 2 years. At a
minimum, a performance test for
hydrogen chlonde shall be conducted
every third year (no more than 38
months following the previous
compliance test). If a performance test
conducted every third year indicates
compliance with the hydrogen chloride
standard, the owner or operator may
forego conducting a performance test for
R.I additional 2 years.
(f) Ths following procedures and test
methods shp'l be ua>:d to determine
compliance with the nitrogen oxides
standard under 9 60.55a:
(I) Method 19 shall be used for
determining the nitrogen oxides
emission rate.
(2) An owner or operator may request
that compliance with the nitrogen
oxides emissions standard be
determined using carbon dioxide
measurements corrected to an
equivalent of 7 percent oxygen. The
relationship between oxygen and
carbon dioxide levels for the affected
facility shall be established during the
initial compliance test
(3) The owner or operator of an
affected facility subject to the nitrogen
oxides standard under 9 60.55a shall
conduct an initial compliance test for
nitrogen oxides as required under { 60.8.
The initial compliance test for nitrogen
oxides shall be conducted over 24
consecutive hours of unit operation
using a CEMS for measuring nitrogen
oxides to determine compliance with the
nitrogen oxides standard. Compliance
with the nitrogen oxides standard shall
be determined using a 24-hour daily
average.
(4) The owner or operator of an
affected facility subject to the nitrogen
oxides emissions standard of fi 60.55a
shall install, calibrate, maintain, and
operate a CEMS for measuring nitrogen
oxides discharged to the atmosphere
and record the output of the system.
(5) Following the initial compliance
test or the date on which the initial
compliance test is required to be
completed under 8 60.8. compliance with
the emission limits for nitrogen oxides
required under 9 60.55a shall be
determined based on the arithmetic
average of the hourly emission rates
during each 24-hour daily period
measured between 12.-OO midnight and
the following midnight using CEMS data.
(6) At a minimum CEMS data shall be
obtained for 75 percent of the hours per
day for 75 percent of the days per month
the unit is operated and combusting
MSW.
(7) The 1-hour averages required by
paragraph (f)(6) of this section shall be
expressed in parts per million volume
(dry basis) and used to calculate the 24-
hour daily average emission rates under
9 60.55a. The 1-hour averages shall be
calculated using the data points required
under 9 60.13(b). At least two data
points shall be used to calculate each 1-
hour average.
(8) All valid CEMS data must be used
in calculating emission rates even if the
minimum CEMS data requirements of
paragraph (f)(?) of this section are met
(9) The procedures under 9 60.13 shall
be followed for installation, evaluation.
and operation of the CEMS. - • •
(10) Quarterly accuracy
determinations and daily calibration
drift tests shall be performed in
accordance with Procedure 1 (Appendix
F).
A-8
(11) When nitrogen oxides emissions
data are not obtained because of CEMS
breakdowns, repairs, calibration checks,
and zero and span adjustments.
emission data calculations to determine
compliance shall be made using other
monitoring systems as approved by the
Administrator or Method 19 to provide
as necessary emission data for a
minimum of 75 percent of the hours per
day for 75 percent of the days per month
the unit is operated and combusting
MSW.
(g) The following procedures shall be
used for determining compliance with
the operating standards under 9 b0.56a:
(1) Compliance with the carbon
monoxide emission limits in 9 60.5Ba(a)
shall be determined using a 4-hour block
average.
(2) The owner or operator of an
affected facility shall install, calibrate.
maintain, and operate a CEMS for
measuring carbon monoxide at the
combustor outlet and record the output
of the system.
(3) An owneror operator may request
that compliance with the carbon
monoxide emission limit be determined
using carbon dioxide measurements
corrected to an equivalent of 7 percent
oxygen.
(4) The owner or operator of an
affected facility shall install calibrate.
maintain, and operate a steam flow
meter and measure steam flow in
kilograms per hour (pounds per hour)
steam on a continuous basis and record
the output of the monitor. Steam flow
shall be calculated in 1-hour block
averages.
(5) The owner or operator of an
affected facility shall install, calibrate.
maintain, and operate a device for
measuring temperature and measure the
temperature of the flue gas stream at the
inlet to the particulate mailer air
pollution control device on a continuous
basis and record the output of the
device. Temperature shall be calculated
in 4-hour block averages.
(6) Maximum MWC unit load shall be
determined during the initial compliance
test. Maximum MWC unit load shall be
the maximum 1-hour load achieved
during the initial compliance test or any
subsequent tests.
(7) The minimum data requirement
under this section is 75 percent of the
hours per day for 75 percent of the days
per month the MWC ur.il is operated
and combusting MSW.
(8) All valid data must ba used in
calculating the parameters specified
under paragraph (g) of this section even
if the minimum data requirements of
paragraph (g)(6) of this section are met.
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Federal Registcr/Vol. 54. No. 243. Wednesday. December 20. 19B9/Proposed Rules 52S03
(H) Quarterly accuracy determinations
and daily calibration drift tests for
carbon monoxide CEMS shall be
performed in accordance with Procedure
1 (Appendix F)-
(10) (i) Except as provided under
paragraph (g){10)(iv) of this section, the
initial demonstration of compliance with
the percent reduction requirement
(annual average) contained in the
definition of "processed MSW or RDF"
in ( GO.Sla and the provisions of
Si 60.56a (d). (e). and (f) shall be
required at the end of the second full
calendar year (January through
December) after the date of initial start-
up of an affected MWC. The annual
average percent MSW reduction
calculated and reported at the end of the
first full calendar year after initial start-
up shall riot be used to determine
compliance.
(ii) Compliance with the percent
reduction requirement contained in the
definition of "processed MSW or RDF'
in 9 60.51 a shall be determined by
calculating the percentage difference
between the weight of MSW received at
the affected facility (as defined in —
5 60.51e) and the weight of MSW
combusted in the MWC unit or the
weight of separated recoverable
materials. Except as provided under
paragraph (iv) of this section, beginning
the month after the date of the ttutial
start-up for new MWC's. the percent
reduction in MSW shall be calculated on
a monthly basis using the monthly total
weights recorded in compliance with
5§ GO 59a (8) and (9} At the end of each
full calendar year (January through
December) the annual average percent
MSW reduction (by weight) shall be
calci'la'.ed In calculating the percent
MSW red-action a maximum of 10
percent MSW vt eight reduction shall be
Rtlr.b j'ed to separation of yard waste. If
the nr.m..il avercge percentage reduction
requirement contained in the definition
of "processed MSW or RDF' in { 60.51a
is not achieved the MSW or RDF is not
ron^iccred to be j-ncp'sed MSW or
RDF
(in) Ar. ow r.er or operatrr who elects
to achir.p. c.:h-- who'.ly cr partially, the
percent reduction rrquiremei:l contained
in the defin-tiiT of "processed MSW or
RDF1 in 1 M.5: i u: the prohibition of
vi-hic'.e baf.enes -n 8 (iQ 58a (e) or the
removal of household ba'tcncs in
9 60 S6a (f) thro-ugr an off-site source
reduction cr mafnels separation
(rec> cling) prog-am shall submit a
aeparst.cn plan \\hich contains
suflcient information to measure the
performance cf She off-site separation
program on HP. annual basis beginning
the first full ralendsr year (January
through December] after the initial start-
up of the affected facility, except as
provided under paragraph (g)(10)(iv) of
this section. The off-site separation plan
shall be~subinitted along with the initial
compliance demonstration results.
(iv) The owner or operator cf an
effected facility that commenced
construction after December 20.1939.
but on or before (date of publication of
final rule), shall meet the requirements
of paragraphs (g)(10)(il) and (g)(10)(iii) of
this section beginning the month after
start-up or January 1993. whichever is
later. For such affected facilities, the
initial demonstration of compliance with
the percent reduction requirement
(annual average) contained in the
definition of "processed MSW or RDF*
in 9 60.51a and the provisions of
SS 60.56a (d). (e). and (f) shall be
required at the end of the second full
calendar year (January through
December) after the date of initial start-
up of the affected MWC or at the end of
calendar year 1994. whichever is later.
(v) The owner or operator of an
affected facility is responsible for
operating the affected facility in
compliance with all provisions of the
standards including the prohibition on
combustion of unprocessed MSW and
vehicle batteries under 59 60.56a (d) and
(e) and the implementation of a program
for removal of household batteries under
S 60.56a (f). In cases where another
party provides processed MSW. or
removes vehicle batteries or removes
household batteries, the provider of the
service may become a co-operator of the
affected facility. If the party providing
the off-site processing of MSW. removal
of vehicle batteries or removal of
household batteries elects to become a
co-operator for purposes of
demonstrating compliance with the
provisions of (S BO.SBa (d). (e) or (f). the
owner or operator of the affected facility
shall submit, at the time of submittal of
the initial compliance demonstration
related to the requirements under
{ S 60.56a (d). (e) and (f):
(A) A copy of a validly executed
contract between the owner and
operator of the affected facility and the
party providing the processing of MSW.
removal of vehicle batteries, or removal
of household batteries which contain the
following provisions:
(7) An undertaking by the party that is
co-operator or sole operator of the
affected facility within the meaning of
9 111 of the Clean Air Act. 42 U.S.C.
7411. regarding compliance with the
requirements under §{ 60.56a (d). (e) or
(fj; and
(2} An undertaking by the party to
meet the requirements under 99 60.56a
A-9
(d). (e) or (f) and a description of ih»
specific actions that will be
implemented to comply with these
requirements; and -_
(B) A certified statement signed by ui
authorized official representing the
party that they agree to become a co-
operator, or sole operator, for the
purpose of demonstrating compliance
with the requirements under 9 9 60.50a
(d). (e) or (f) and recognizing that
enforcement actions, including
penalties, may be taken against the
party for failure to demonstrate
compliance with these requirements
§ 6O59a Reporting and recordkeeplng
requirements.
(a) The owner or operator of an
affected facility shall provide
notification of intent to construct and of
planned initial start-up date. The MWC
unit capacity and MWC plant capacity
shall be provided at the time of the
notification of construction.
(b) The owner or operator of an
affected facility subject to the standards
under 9 60.52a. 9 60.53a. 9 60.54a.
9 60.55a. or 5 60.56a shall maintain
records of the following information for
each affected facility:
(l) Calendar date.
(2) The emission rates and parameters
measured.
(3) Identification of the operating days
when the calculated sulfur dioxide and
nitrogen oxides emission rates or when
the operating parameters exceeded the
applicable standards, with reasons for
such exceedances as well as a
description of corrective actions taken.
(4) Identification of operating days for
which sulfur dioxide or nitrogen oxides
emissions or operational data have not
been obtained, including reasons for not
obtaining sufficient data and a
description of corrective actions taket
(5) Identification of the times when
sulfur dioxide or nitrogen oxides
emission or operational data have been
excluded from the calculation of average
emission rates or parameters and the
reasons for excluding data.
(6) The results of daily sulfur dioxide.
nitrogen oxides, and carbon monoxid"
CEMS drift tests and accuracy
assessments as required under
Appendix F. Procedure 1.
(7) The results of all annual
performance tests conducted to
determine compliance with the
participate matter, dioxin/furan.
hydrogen chloride, and mercury
standards.
(8) Except as provided under
paragraph (b)(13) of this section.
beginning the month after the date of the
initial start-up, the amount (by weight)
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Fed-rsl Register/Vol. 54, N?. 243. \Vedr.esday December 20. 19e9/?ro?a£fd
of .*.fS'.V or RDF received on a nouthly
bsj's B! the affected facih'y, the amount
(by -Aeight) of MSW or RUF comhvsied
c.n a -lor.th'y basis, aid the crr.ount of
/•.•-overable materials {by type a".d
v>--7:g;.tj separated on a n'on'-hly basis.
*"»para!ed paper and paperbcard are to
be slore-'1 in e covered area and
prettied from rain end moisture, so
•.'idt the moisture content of the paper
end pciperboard when weighed is
similar to their moistme content when
received in the MSW or RDF.
(9) Fxcept as provided under
paragraph (b)(13) of this section.
beginning the month after the date of the
ipitial start-up, the estimated amount
(hy type and weight) of recoverable
materials reduced or separated for
recovery on a monthly basis through an
off-site or community source reduction
or materials separation (recycling)
progi or Janucry 1S?S3.
whi.-.heYsr is later.
(c) TV. cwn=r or operator of sr.
affec'eJ.facility shall submit the init^l
CCT- ' --.ce test data, Use performance
eva.-jm.-n of the CEMS using the
apvi'wabie pfcifciiTKni.s specification* ::i
f"/-f(.>,d:x. 3. and the ir.Gximum M\\C
unu losd.
(d} A pMn descril-lng the procedures
for separating materials for recovery to
achieve tae 25 percent or greater MSW
reduction requirement contained in the
definition .of "processed MSW or RDF"
in § 60.51 a and describing the
procedures for ensuring that vehicle
batteri»9 are not combusted in the
affected facility and a description of the
program for removal of household
batteries shall be provided at the time of
submittal of the initial demonstration of
compliance with the requirements of
SS 60.56a (d). (e). and (f). For affected
facilities that commenced construction
after December 20.1989 but on or before
(date of promulgation), such information
shall be provided by the 30th day
following the end of calendar year 1994
or the end of the second full calendar
year after initial start-up, whichever is
later. For all other affected facilities.
such information shall be provided by
the 30th day following the end of the
second full calendar year after initial
start-up.
(e) The owner or operator of an
affected facility shall submit quarterly
compliance reports for sulfur dioxide.
nitrogen oxide (if applicable), carbon
monoxide, load level and temperature
. to the Administrator containing the
information recorded under paragraph
(b) of this section for each pollutant or
parameter. Such reports shall be
pos'jr.arkcJ by ihs 'JO1!: clpy foUoti'r.g
the ei;d of»ach calendar quarter.
(f) The i---c-.°r or operator of an
aJTecteJ fs'-.u'y shall subnil quarterly
excess emis.ion repoifs containing the
ir.formaticn recorded urcer paragraph
(b) cf this sc-.haa. cs spp'ir.able. for
opacity. Sucl.exnes* emiss'on repcns
shall be pnstmerkeii by the 3Cth day
following 'hr. end of each calender
quarter.
(gj The owner or operatur cf an
affected facility shall submit annual
reports to the Administrator containing
the information recorded under
paragraph (b) of this section for all
pollutants regulated under this subpart
as applicable, to the affected facility.
Such reports shall be postmarked by the
30th day following the end of each
calendar year.
(h) Records of CEMS. steam flow, and
temperature data shall be maintained
for at least 2 years after date of
recordation and be made available for
inspection upon request.
(i) Records showing the names of
persons who have completed review of
the operating manual, including the date
of the initial review and all subsequent
annual reviews, shall be maintained for
at least 2 years after date of manual
review and be made available for
inspection upon request.
(j) A description of the procedures
employed for ensuring that unprocessed
MSW or RDF is not combusted in an
affected facility shall be maintained.
along with associated records to
demonstrate use of such procedures.
and made available for inspection upon
request.
[FR Doe. 89-28718 Filed 12-19-89:8:45 ami
A-10
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ssssn
Federal Reaster/VoL 54. No. 243. Wednesday. December 20, 1989/Proposed Rules
submitted to or otherwise considered in
the development of this proposed
ruiemaking. The principal purposes of
the docket are: (1) to allow interested
parties to identify end locate documents
so that they can effectively participate
in the rulemaking process, and (2) to
serve as the record in case of judicial
review (except for interagency review
materials [Section 307(d)(7](A)]). The
docket number for this rulensaking is A-
69-08.
C. Clean Air Act Procedural
Requirements
1. Administrator Listing—section ill.
As prescribed by Section 111 of the
CAA. as amended, establishment of
emission guidelines for MWC's is based
on the Administrator's determination (52
FR 25399. dated July 7.1987) that these
sources contribute significantly to air
pollution which may reasonably be
anticipated to endanger public health or
welfare.
2. Periodic Review—flection 111. The
guidelines will be reviewed 4 years from
the date of promulgation as required by
the CAA. This review will include an
assessment of such factors as the need
for Integration with other programs, the
existence of alternative methods.
e^Jorceability. improvements in
emission control technology, and
reporting requirements.
3. External Participation—section 117.
In accordance with Section 117 of the
CAA. publication of this proposal was
preceded by consultation with
appropriate advisory committees.
independent experts, and Federal
departments and agencies The
Administrator will welcome comments
en all aspects of the proposed
guidelines, including economic and
technological issues.
4 economic Impact Assessment—
section 317. Section 317 of the CAA
requires the Administrator to prepare an
economic impact assessment for any
erniibion guidelines promulgated under
Feet.on lll(d) of the Act. An economic
impact assessment was prepared for the
proposed guidelines and for other
regulatory alternatives All aspects of
the assessment were considered in the
formulation of the proposed guidelines
to ensure that (he proposed guidelines
would represent the best system of
(•mission reduction considering costs
Portions of the economic impact
assessment are included in the
background information documents
(BID's) and additional information :s
included in the docket
List of Subjects in 40 CFR Part 60
Air pollution control. Incorporation by
reference. Intergovernmental relations.
Reporting and recordkepping. Municipal
waste ccmbustors. Municipal solid
waste.
Deled: November 30.1989.
William K. Reilly.
A dinitnsirator.
PART 60—GUIDELINES AND
COMPLIANCE TIMES FOR EXISTING
STATIONARY SOURCES
Fur the reasons set out in the
preamble, title 40. chapter I. of the Code
of Federal Regulations is proposed to be
amended as follows:
1. The authority citation for part 60
continues to read as follows:
Authority: 42 U S C. 7401. 7411. 7414. 7410
end 7601.
2. Subpart C of part 60 is amended by
revising 8 60.30 to read as follows:
} 60JO Scope.
The following subparta contain
emission guidelines and compliance
times for the control of certain
designated pollutants in accordance
with section lll(d) of the Act and
subpart B.
(a) Subpart Ca—Municipal Waste
Combustors.
(b] Subpart Cb—Sulfuric Acid
Production Plants.
3. Part 60 is further amended by
adding subpart Ca to read as follows:
Subpart C»—Emission* Guidelines and
Compliance Tunaa for Municipal Waste
Combuatora
Sec.
e030a Scope.
fi0.31a Definitions.
60.32a Designated facilities.
60.33a Emission guidelines for MWC metals.
U).34a Emission guidelines or MWC
organic*
60 35a EmiBiion guideline* for MWC acid
gases
60 36a Emission guidelines for MWC
operating practices.
K) 37a MWC operator certification and
training.
ec.SHa Compliance and performance testing
and compliance tunps.
60 39a Reporting and recordkeepuig
guidelines.
Subpart Ca—Emissions Guidelines and
Compliance Times for Municipal Waste
Ccmbustors
§60JOa Scope.
This sul'part contains emission
guidelines and compliance times for the
control of certain designated pollutants
from certain municipal waste
combustors (MWC's) in accordance
with Section lll(d) of the Act and
Subpart B.
A-H
JWJie Definition*.
Terms used but not defined in this
subpart have the meaning given them in
the Act and subparts A. B and Ea of this
part.
"MWC plant" means ona or mere
MWC units at the same location for
which construction, modification, or
reconstruction is commenced before
December 20.1989.
"MWC plant capacity" means the
aggregate MWC unit capacity of all
MWC units at an MWC plcnt for which
construction, modification, or
reconstruction is commenced before
December 20,1989.
"Regional MWC' means an MWC
plant with an MWC plant rapacity
greater than 2.000 megagrama per day
(2£00 tons per day) of MSW.
9 60.32a Designated fadttaes.
(a) The designated facility to which
the guidelines apply is each MWC unit
for which construction, modification, or
reconstruction is commenced before
December 20.1989.
(b) Physical or-operational changes
made to an existing MWC unit to
comply with an emission guideline are
not considered a modification or
reconstruction and would not bring an
existing MWC unit under the provisions
at subpart Ea [see 8 OO.SOafb)).
• 60.33* Emission guidelines tor MWC
metals.
For approval, a State plan shall
include the emission guidelines for
MWC metals listed below, except as
provided for under § 60.24. The emission
guidelines for MWC metals expressed
as particulate matter contained in gases
discharged to the atmosphere from any \
designated facility are as follows:
MWC plant
capacity
1 stftMi. ,,,—
m^m yw— .. — ill
S^sf1
Gmdehne
nw/dBcni
(gr/dscl)
34 (0015)
69 (0.030)
69 (0.030)
Opaoty
(percent)
10 (e-mn.)
10 (6-mn.)
10 (6-
-------
Federal RegUter/Vol. 54. No. 243. Wednesday. December 20. 1989/PropO8ed Rules 52251
MWC plant
capacity
Regional
(including
regional RDF) —
LSfQ8 (QJLCept
RDF)
Large RDF
Smail (except
RDF)
SenaS RDF
Guideline, ng/
ROfiTw III*
rs-30]
125
250
500
1.000
(gr/bUUon
dscf)
(12-121)
(50)
(100)
(200)
(400)
Nate: All levels corrected to 7 percent O».
96035*
•CM 94
Emission guidelines for MWC
For approval, a State plan shall
include the emission guidelines for
MWC acid gases for MWC's located at
large and regional MWC plants listed
below, except as provided for under
9 60.24. The emission guidelines for
MWC acid gases expressed as sulfur
dioxide and hydrogen chloride
contained in gases discharged to the
atmosphere from any designated facility
are as follows:
MWC
plant
capacity
Regnrtal.-..
Large
orppmv)
SO.
85% or 30 ppmv
50%or30ppmv
na
95% or 25 ppmv
50% or 25 ppmv
Note: Al ppmv levels corrected to 7 percent O>.
Either the applicable percent
reduction or the ppmv guideline.
whichever is less stringent, is the
guideline limit for a designated facility.
{ 60.36a Emission guidelines for MWC
operating practices.
For approval, a State plan shall
include the requirements for MWC
operating practices listed in 9 60.56a cf
Subpart Ea including the materials
separat.on requirement under { 60.56a.
except as provided for under 8 60.24.
§ SQJ7a MWC operator certification end
training.
For approval, a State plan shall
include the requirements listed in
{ 60.S7a of Subpart Ea. except as
provided for under 5 60.24.
{ SO-38a Compliance and performance
testing and compliance times.
(a) For approval, a Slate plan shall
include, for small, large, and regional
MWC's. the compliance and
performance testing methods listed in
9 eo.58a for small MWC plants, as
applicable, except as provided for under
960.24.
(b) Except as provided for under
paragraph (c) of this section, planning.
awarding of contracts, and installation
of equipment capable of attaining the
level of the emission guidelines
established under this subpart are
expected to be accomplished within 36
months afier the effective date of State
emission standards for MWC units.
(c) Planning, awarding of contracts.
and installation of equipment and
procedures capable of attaining the level
of materials separation specified in the
emission guidelines under 60.36a are
expected to be accomplished by no later
than December 31.1992. The initial
demonstration of compliance with the
materials separation provisions in
9 60.36a is expected to be accomplished
at the end of calendar year 1994.
S 60.3sa Reporting and recordkeeplng
guidelines.
For approval a State plan shall
include the reporting and recordkeeping
provisions listed in 9 60.59a. as
applicable, except as provided for under
9 60.24.
4. Subpart C of part 60 is amended by
removing 99 60.32.60.33. and 60.34; and
Subpart Cb is added as follows:
Subpart Cb—Emission Guidelines and
Compliance Times for Sulfurlc Add
Production Units
9 60JOb Designated facilities.
(a) Sulfuric acids production units.
The designated facility to which
9 9 60.31b and 60.32b apply is each
existing "sulfuric acid production unit"
as defined in 9 60.81(a) of subpart H.
S 60.31b Emission guidelines.
(a) Sulfuric acid production units. The
emission guideline for designated
facilities is 0.25 gram sulfuric acid mist
(as measured by Method 8. of Appendix
A) per kilogram of sulfuric acid
produced (0.05 Ib/ton). the production
being expressed as 100 percent HiSCu
60.32b Compliance times.
(a) Sulfunc acid production units.
Planning, awarding of contracts, and
installation of equipment capable of
attaining the level of the emission
guideline established under 9 60.33(a)
can be accomplished within 17 months
after the effective date of a State
emission standard for sulfuric acid mist
(FR Doc. 80-28719 riled 12-19-Ofc 8:45 am]
Bumtoccoe«tio-Bxi
40 CFR Parts 51.52, and 60
[AD-FRL-3C48-1]
R!N 2080-AC28
Standards of Performance for New
Stationary Sources; Municipal Waste
CoRibustors
AGENCY: Environmental Protection
Agency (EPA).
A-12
ACTION: Proposed rule and notice of
public hearing.
SUMMARY: This proposal would add
Subpart Ea to 40~CFR part 60. Subparf
Ea would limit emissions from new.
modified, and reconstructed municipal
waste combustors (MWC's). The
proposed standards implement Section
lll(b) of the Clean Air Act (CAA) and
are based on the Administrator's
determinations that emissions from
MWC's cause, or contribute significantly
to. air pollution which may reasonably
be anticipated to endanger public health
or welfare. The intent of the proposed
standards is to require new MWC's to
control emissions to the level achievable
by applying the best demonstrated
system of continuous emission
reduction, considering costs, nonair
quality health and environmental
impacts, and energy requirements.
These are proposed rather than final
standards, and comments are requested.
The EPA will consider all comments and
new information received during the
public comment pjeriod, and will make
changes to the standards, where
appropriate, based on these comments.
If requested, a public hearing will be
held to provide interested parties an
opportunity for oral presentations of
data, views, or arguments concerning
the proposed emission guidelines.
DATES: Comments must be received on
or before March 1.1990.
Public Hearings. Public hearings will
be held in Boston, Massachusetts, on
January 22 and 23,1990: in Detroit,
Michigan, on January 25 and 26.1990;
and in Seattle. Washington, on January
30 and 31.1990. All hearings will start at
9:00 am. Persons wishing to present oral
testimony at the public hearings must
call Ms. Ann Eleanor at (919) 541-5578
before January 15.1990. for the Boston
hearing: January 18.1990. for the Detroit
hearing: and January 23,1990, for the
Seattle hearing. Each speaker will be
allowed up to 10 minutes, and each
group or organization will be allowed a
maximum of 20 minutes to speak. If no
one requests to speak at a hearing
before these dates, the hearing may be
cancelled. Persons interested in
attending the hearings should also call
Ms. Ann Eleanor at (919) 541-5578 to
verify that a hearing will be held.
ADDRESSES: Comments. Comments
should be submitted (in duplicate if
possible) to: Air Docket (LE-131).
Attention Docket No. A-89-08. Room
M1500, U.S. Environmental Protection
Agency. 401M Street SW.. Washington
DC 20460.
-------
APPENDIX B
FLOWCHART PREPARATION FOR AIR POLLUTION
SOURCE INSPECTIONS
B-l
-------
B-2
-------
FLOWCHART PREPARATION
_ for
AIR POLLUTION SOURCE INSPECTIONS
1. Introduction
1 1 Purpose of Flowcharts
One of the basic first steps in solving essentially any technical problem
is to "draw a picture." This is especially true with regards to the inspection
of air pollution sources since the agency inspector is often confronted with
very complex process and pollutant removal systems. Operating problems which
result in excessive emissions are rarely due to simple failures of a single
component but are instead usually due to combinations of problems affecting the
entire system. Furthermore, even under the best of circumstances, some of the
plant's instruments may be either inaccurate or inoperative due primarily to
the hostile physical and chemical environments within the operating equipment.
The inspection flowchart is a valuable tool for sorting out the usually complex
and sometimes conflicting data available concerning the operating problems.
The ability to communicate is a fundamental requirement for effective
field inspections. The agency inspector must visit a large number_of diverse
industrial facilities and evaluate the performance of one or more of their
systems in a very short amount of time. A simple flowchart is very useful
when discussing the systems being evaluated with plant personnel, especially
those not directly involved in day-to-day plant operation or those who work at
a central office away from the plant. The flowchart helps both the inspector
and the plant representative to avoid misunderstandings due to the differences
in terminology which exist in various types of industries and employment
backgrounds. In other words, the "picture" rises above potentially confusing
industrial "jargon."
The flowchart is also useful when determining which gauge in the control
room corresponds to which part of the system. This is especially important
since in most cases an inspector must evaluate the trends of parameters such
as gas temperature, gas static pressure, and liquor pH through a system. Also,
these trends or "profiles" are useful for identifying malfunctioning gauges.
There are a number of other equally important advantages to inspection
flowcharts A partial list of these is provided below.
* Allow the inspector's supervisor to provide direction concerning
the scope of the inspection and concerning the potential health
and safety problems.
* Improve communication regarding the results of the inspection
between the inspector and the agency supervisors and attorneys.
* Reduce the inspection report preparation time.
B-3
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1.2 Basic Concepts
There are many levels of sophistication in flowchart preparation simply
because they can serve many purposes. Some of the most complex are."design
oriented piping and instrumentation drawings (termed P&I drawings) which show
every major component, every valve, and every pipe within the system. These
drawings can have more than 500 separate items shown on a single drawing, even
for a relatively simple system or part of a system. Conversely, a simple
block diagram used as a field sketch may only have 3 to 5 symbols on a drawing.
Flowcharts for air pollution control agency field personnel should be
relatively simple. Generally, inspectors need more equipment detail than
shown on a simple block diagram, but far less information than is provided by
the standard P&I drawing. The drawings should not be so cluttered with system
design details that it is difficult to write present system operating condi-
tions there to help identify performance problems. Since these are primarily
"working" drawings, they must be small enough to be carried easily while
walking around the facility. Also, the flowcharts should not require a lot
of time to prepare or revise.
For these reasons, an expanded block diagram format has been adopted.
In this type of flowchart, only the system components directly relevant to the
inspection are included. Major components such as baghouses are shown as a
simple block rather than a complex sketch resembling the actual ba^house.
Most minor components and material flow streams are omitted to avoid cluttering
the drawing. A set of conventional instrument symbols and minor equipment
symbols have been adopted. The symbols used have been drawn primarily from
conventional chemical engineering practice.
The size of the flowchart has been designed so that it fits entirely on a
single 8 and 1/2 by 11" page and that it can be carried in a standard clipboard
or notebook Furthermore, most of the standard symbols have been reproduced on
the back of the sheet of paper so that the inspector does not need to remember
any of the specific information included within this manual. The form is
basically "self contained."
Along with the basic diagram, health/safety guidelines and baseline data
are presented on the drawing as "reminders" of important points that the
inspector should have reviewed during the pre-inspection file review and field
work preparation The inspector's supervisor should either prepare or carefully
review any health and safety guidelines so that the all field personnel are
adequately prepared for both routine and emergency situations which could arise.
The baseline data could be prepared either by the inspector or his or her
supervisor
An example flowchart for a relatively complicated air pollution source, a
waste solvent incinerator, is shown in Figure 1. The process equipment in this
example consists of a starved air modular incinerator having primary and
secondary chambers. The air pollution control system consists of a venturi
scrubber followed by a demister tower. In the following sections, step-by-step
procedures are discussed for preparing inspection flowcharts.
B-4
-------
Plant Name: Waste Solvent Incinerator Unit: No. 6 Confidential: Yes _ No
Prepared by: John Richards Date: August 15,1981
HEALTH & SAFETY
1. Use full face respirator with organic
vapor cartridges if inspecting waste
receiving area.
2. Avoid contact with wastes, wash hands
often.
3. Bring portable eye flush bottles.
4. Avoid dripping or spraying caustic
lines.
5. Leave stack sampling platform if
downwash or fumigation occurs.
BASELINE DATA
1. Solvent Feed Rate 12-20 GPM;
22 GPM Max-Permit
2. Inc. Primary Temp. 1050-1250°F
3. Inc. Secondary Temp. 1950-2350°F;
1800°F Min-Permit"
4. Scrubber Inlet Temp. 210-260°F
5. Scrubber Ap 30-40" w.c.; 30" w.c.
Min-Permit
6. Demister Ap 1-2" w.c.
7. Fan Inlet sp 34-45" w.c.
8. Fan Motor Current 60-85 amps
9. Liquor pH 6.5-8.5
Waste
Feed
Purge
Figure 1. Example Flowchart Sheet
B-5
-------
2. Preparation
2.1 Material Flow Stream Designations
A complete flowchart consists of several symbols representing jnajor_ pieces
of equipment and numerous material flow streams. It is important to be able
to differentiate between the various types of material flow streams without
sacrificing simplicity and clarity. The recommended symbols selected for the
streams are presented in Figure 2.
Flow Stream Identification
Gas • " A
Figure 2. Material Flow Streams
Gas flow streams"are shown as two parallel lines spaced slightly apart
so that they appear larger than any of the other streams. This is important
so that the inspector can quickly scan the flowchart and differentiate between
gas and liquid material flow streams. Segments of ductwork going from one
major piece of equipment to another are labelled with an alphabetic character.
For example, ductwork leading from the venturi scrubber to a demister is label-
led "C" and the ductwork carrying the gas stream to the downstream fan is
labelled "D" in Figure 1.
Important liquid and solid material flow streams are shown as solid,
single lines Diamonds with enclosed numbers are used to identify each of the
streams For example, in Figure 1, the liquid stream designated as number 1 is
the liquor discharged from the bottom of the venturi scrubber, and the stream
designated as number 2 is the total recycle liquor flow from the recirculation
pump.
To avoid cluttering the drawing, some of the liquid and solid material
streams for which operating data will not be necessary are unnumbered. These
types of streams are often called "utility" streams since they provide neces-
sary materials to the system being shown and since the characteristics of these
streams is relatively constant. Typical utility streams for air pollution
control equipment systems include make-up water, cooling water, and low pres-
sure steam. Natural gas, oil, and other fossil fuels can also be treated as
utility streams to simplify the drawings. Instead of the number diamonds,
these utility streams are identified either by using one of the codes listed
below or by a one or two word title.
B-6
-------
Table 1, Utility Stream Codes
--Compressed Air (Plant Air)
- Compressed Calibration Gas
- Condensate
- City (or Plant) Fresh Water
- Natural Gas
- High Pressure Steam
- Low Pressure Steam
- Instrument Air
CA
Cal
CD
CW
Gas
HS
LS
IA
The codes or word titles are placed next to a "stretched S" symbol which
is used to indicate that the source of the utility stream is outside the scope
of the drawing.
2.2 Major Equipment Designations
A square or rectangle is used to denote major equipment such as the air
pollution control devices, tanks and vessels, and process equipment. Fans are
denoted using a relatively large circle with a set of tangential lines to
indicate the discharge point. A stack is shown as a slightly tapered rectangle.
As shown in Figure 3, all of these symbols are "shaded" using cross hatch
diagonal lines so thaC it is easy to pick out the major equipment items from
the material flow streamlines entering and leaving these units.
Major Equipment
Fan
Stack
Figure 3. Major Equipment Designations
Items which should be treated as "major equipment" depend on the overall
complexity of the system being drawn and on individual preferences. They are
determined primarily based on the types of data and observations which are
possible and the level of detail which is necessary to evaluate the performance
of the overall system.
B-7
-------
For example, the primary and secondary chambers of the waste solvent
incinerator shown in Figure 1 have been shown separately since data from each
chamber is important to the inspection. However, many components of the
incinerator and wet scrubber systems have not been shown since their operating
conditions are not central to the potential air pollution emission problems.
Another example is shown in Figure 4. This is a simple wet scrubber system
serving a recycle operation within a hot mix asphalt plant. Most of the plant
has not been shown since the scrubber controls only the particulate emissions
from the mixing of hot, new aggregate with cold, aged recycle asphaltic concrete.
It is apparent in Figure 4 that the duct labelled as section "C" serves as the
discharge point. The liquor recycle pond has been shown using an irregular
shape and with a slightly different form of cross hatching so that it is easy
to differentiate between the pond and the major equipment items. Also, it
should be noted that the symbols for the major pieces of equipment and the
symbols for other parts of the system should be located in logical positions.
For example, the pond in Figure 4 is placed near the bottom of the sketch and
the stack is at a relatively high location. The material flow streams enter
the major equipment "boxes" from the same approximate direction as the real
flow streams.
Aggregate
Recycle
Spray
•'Scrubber'
Asphalt
Binder
Pump
Asphalt
Concrete
Figure U. ExamT>!= Flowchart of a Simple Wet Scrubber System
B-8
-------
The stack (or emission discharge point) is obviously important due to the
visible emission observations and due to the presence of continuous emission
monitors and stack sampling ports in some systems. The emission points which
should be subject to Method 9 or Method 22 visible emission observations are
identified by means of inverted triangles immediately above the source as shown
in Figure 5 (also, see symbols in Figures 1 and 4). These are numbered when-
ever there is any possibility of confusing different sources within a single
industrial complex. The numbers used in the triangles should correspond with
the emission point identification numbers used in the inspector's working files.
Typical identification numbers are El, E2, ... En for enclosed emission points
such as stacks and Fl, F2, ... Fn for fugitive emission points such as storage
piles and material handling operations.
sion Points
Stack
Storage Pile
Figure 5. Identification of Emission Points
2 3 Small Equipment Designations
There are a number of relatively small components in air pollution control
systems which should be shown on the block diagram type flowcharts in order to
clarify how the system operates. A partial list of the possible "small" equip-
ment components which could be shown for various types of air pollution control
systems are listed in Table 2.
Table 2. "Small" System Components
1 Fabric Filters
* Bypass dampers
* Reverse air fans
2 Wet Scrubbers
* Pumps
* Nozzles
* Manual valves
* Automatic valves
3 Carbon Adsorbers and Incinerators
* Heat exchangers
B-9
-------
Symbols for the components listed in Table 2 are shown in Figure 6.
Some of the most frequently used of these are also reproduced on the back of
the flow-chart form. Note that all of these symbols are relatively simple and
quick to draw. _
Common Symbols
Fan
Pump
Valve
(Manual)
Valve
(Auto.)
Emission Point
Damper
Heat
Exchanger
Nozzles
Figure 6. Small Components
2.4 Instrument Designations
The presence of an instrument or a sampling port is indicated by a small
circle connected to a streamline by a short dashed line. The type of instrument
is indicated using the symbols listed in Table 3.
Table 3, Instrument Codes
A - Motor current
CEM - Continuous emission monitor
Den - Density
F - Flow
L - Liquid level
MP - Measurement port
P - Gas or liquid pressure
pH - Liquid or slurry pH
SP - Gas static pressure
SSP - Stack sampling port
T - Temperature
V - Vacuum gauge
VOC - Low concentration VOC monitor
B-10
-------
Instruments such as manometers and dial-type thermometers can only be read
at the gauge itself. These "indicating" gauges are denoted simply by the
instrument circle and the symbol (Figure 7).
More sophisticated instruments with panel-mounted readout gauges (normally
in a control room) are indicated using a line bisecting the instrument circle.
In this case, the instrument symbol is placed directly above the line as shown
in Figure 7. When the instrument readout is a continuous strip chart recorder
or data acquisition system, the letter "R" (for "Recording") is placed below
the line as shown in Figure 7.
Indicating Gauge,
Equipment Mounted
Indicating Gauge,
Recording Gauge,
Panel Mounted
Figure 7. Instrument Symbols
In several cases, more than one dashed line is necessary to describe the
instrument For example, static pressure drop gauges monitor the static pres-
sures in two separate locations (see example at the bottom of Figure 7).
Instruments which control automatic valves should have dashed lines to both the
monitoring location and the valve being controlled.
2 5 Materials of Construction
The materials of construction are relevant whenever there has been or may
be a serious corrosion problem which could affect either system performance or
reliability On a single page format type of flowchart, it is impractical to
specify the exact type of material and protective coatings on each vulnerable
component since there are several hundred combinations of materials/coatings in
common use and innumerable others used in isolated cases. However, the general
type of material in certain selected portions of the system may be important.
A small set of symbols is presented in Table 4 for identifying these materials.
For general classes of materials not listed, it is desirable simply to write
out the complete descriptive term.
B-ll
-------
Table 4. Material of Construction Symbols
CS _- Carbon steel
SS - Stainless steel
FRF - Fiberglass reinforced plastic
RL - Rubber lined
N - Nickel alloy
WD - Wood
3. Use of the Inspection Flowchart Form
A general inspection flowchart form has been developed. This consists
of a grid section on the lower one-half of the page for the drawing itself.
Baseline data obtained during a previous inspection and/or stack test is
included in the upper right corner. Health and safety considerations are
provided in the upper left corner. The combination of these three types of
information makes the form a useful "working drawing" to facilitate the
inspection analyses and to minimize health and safety risks. A copy of this
form is provided as Figure 8.
A condensed summary of the manual has been prepared so that inspectors
do not have to remember all of the symbols. This becomes the back side of the
flowchart form (Figure 9). The inspector can simply turn over the form to
refresh his or her memory concerning the symbols and codes. These forms have
been reproduced in a tablet form.
The remainder of this section demonstrates the advantages of this
inspection flowchart form specifically, and the advantages of inspection flow-
chart in general. An actual rotary kiln type hazardous waste incinerator will
be used as an example case. Its flowchart is shown as Figure 10. While much
of the data is real, it should be noted that some license has been exercised
with some of the data to maximize the utility of this example. For that reason,
any "conclusions" are hypothetical and do not apply to the actual plant. Also,
it should be noted that this plant can be seen in the U.S. EPA Air Pollution
Training Institute videotape 455-1 which concerns the preparation and use of
inspection flowcharts.
3.1 Evaluating the Adequacy of On-Site Instrument Data
One of the main advantages of flowcharts is that large quantities of
operating data are compiled in a condensed, easy-to-use format. The operating
conditions indicated by the plant's instruments can be scanned to determine if
they are both consistent and logical. For example, in the flowchart shown in
Figure 10, the gas temperatures and static pressures can be checked along the
gas flow stream. This data is listed in Tables 5 and 6 below and is shown in
Figures 11 and 12.
B-12
-------
Plant Name: 1
Prepared by:
HEALTH & SAFETY
-
• • •.....•.....•.....•....:.... I ....!...
••••:••••.
.
Ui
D:
. !
lit: Confidential: Yes _ No £
ite:
BASELINE DATA
'-
...:.... i ....•-....•.....•.....*.....•.....• • • •. . . .
Figure 8. Inspection Flowchart Form (Front Side)
B-13
-------
FLOW CHART PREPARATION SYMBOLS
Flow Stream Identification
Gas i
Liquid or Solid
Utility
Utility Notations
CA - Compressed Air
CD - Condensate-
CW - City (Plant) Water
Gas - Natural Gas
HS - High Pressure Steam
LS - Low Pressure Steam
IA - Instrument Air
Cal - Calibration Gas
Materials of Construction
CS - Carbon Steel
SS - Stainless Steel
FRP - Fiberglass Reinforced Plastic
RL - Rubber Lined
N - Nickel Alloy
WD - Wood
Common Symbols
Fan
Pump
Valve
(Manual)
Valve
(Auto.)
Emission Point
Damper
Heat
Exchanger"
Nozzles
Instrument Symbols and Notation
A - Motor Current
CEM - Continuous Emission Monitor
DEN - Density
F - Flow
L - Liquid Level
MP - Measurement Port
P - Gas or Liquid Pressure
SP - Gas Static Pressure
pH - Liquid or Slurry pH
T - Temperature
SSP - Stack Sampling Ports
V - Vacuum Gauge
VOC - Low Cone. VOC Monitor
Indicating Gauge,
Equipment Mounted
Control Room or Panel Mounted
Differential Gauge
Figure 9. Inspection Flowchart Form (Back Side)
B-14
-------
Plant Name: Hazardous Waste Incinerator Unit: Lake View Confidential: Yes _ No £
Prepared by: John Richards Date: August 15,1989
HEALTH & SAFETY
1. Avoid contact with carcinogenic un-
treated din.
2. Avoid fugitive vapor emissions from
drier discharge.
3. Do not go on top of baghouses.
4. Wear tyvek suit with hood near equip-
ment, use decontamination showers.
5. Use pressure-demand SCBA around
untreated dirt handling.
BASELINE DATA
1. Kiln Exit Gas Temp. 805-825°C
2. Kiln Hood Static Pressure -0.05 to
-0.20" w.c.
3. Evap. Cooler Outlet Temp. 215 -245°C
4. Evap. Cooler Inlet Temp. 750 -775°C
5. Baghouse Outlet Temp. 185 -195°C
6. Baghouse Air Pressure 60-110 psig
7. Stack (E,) Opacity 0-5%
Paniculate
Treated Pile
Figure 10. Hazardous Waste Incinerator System Flowchart
B-15
-------
+1
0)
I
H
0\
0
-1
•s
-2
£
a
en
!
). Kiln
tZJ
!
j Cooler
•
j Baghouse !
"!
i
!
i
!
I I
Combined
Cooler &
Baghouse
Pressure
Drop
Gas Flow
Figure 11. Static Pressure Profile
-------
1000
800
U
21 600
a
a
400
200
Kiln
AT 180°C
j
Cooler !
. I Baghouse ;
I- AT 29° C
I I
j J
I
i !
Gas Flow
Figure 12. Gas Temperature Profile
-------
Table 5. Gas Temperature Profile for the Hazardous Waste Incinerator
(Listed Co-Current With Gas Stream)
Kiln exhaust gas 819 C
Evaporative cooler inlet gas stream 659 C
Evaporative cooler outlet gas stream 234 C
Baghouse inlet gas stream 204 C
Baghouse outlet gas stream 176 C
Table 6. Gas Static Pressure Profile for the Hazardous Waste Incinerator
(Listed Co-Current With Gas Stream)
Kiln hood -0.10
Evaporative cooler inlet gas stream -1.0
Evaporative cooler outlet gas stream No Data
Baghouse outlet gas stream -3.2
The gas temperature and static pressure profiles through the system are
both logical. The static pressure at the kiln hood is within the -0.05 to
-0.20 inches o'f water~which is typical of most combustion operations. As
expected, the static pressures get progressively lower as the gas stream
approaches the fan (see Figure 11). Obviously, the fan inlet must be the
location of the lowest static pressure.
The gas temperature appears to decrease as the gas stream moves away from
the combustion operation (see Figure 12). The only thing that appears to be
unusual is the relatively sudden drop from 819 C to 659 C in the short duct
between the kiln and the evaporative cooler. In this case, this decrease was
due to the combined effect of heat radiation from a refractory lined metal duct
and air infiltration through corroded portions of the duct.
Since the temperature profiles and static pressure profiles appear to be
logical, there is some justification for accepting the plant's instruments as
generally correct It should be noted that this is an unusual case and that
even under the best of circumstances one or more gauges available to the
inspector can be incorrect.
3 2 Evaluating of System Performance
The system performance is evaluated by comparing the present operating
conditions with baseline conditions which are shown in the upper right corner
of Figure 10. In some cases, the present data is also compared to industry
"norms" if these are known to be applicable. To facilitate these comparisons,
the operating data obtained during the inspection has been written directly
onto the flowchart taken to the plant site. The evaluation of this data is
illustrated in the following sections.
B-18
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3.2.1 Combustion System
The primary function of this portable plant is to incinerate the contam-
inated soil present at an abandoned chemical plant. It is apparent .from the
flowchart that the most useful"single parameter for evaluating the-destruction
efficiency of the rotary kiln system is the kiln outlet temperature monitored
by the temperature gauge on the left side of duct "B." The present value of
819 C compares well with the baseline data obtained during the trial burn tests
in which the unit demonstrated good performance. Accordingly, it appears that
the unit is continuing to operate in compliance. In most cases, the agency
inspector will want to confirm this by checking records for a number of time
periods extending back to the last on-site inspection.
3.2.2 Evaporative Cooler
This system component is important primarily because it protects the
temperature sensitive nomex bags used in the downstream pulse jet baghouses.
It is clear from the flowchart that there is a gas temperature drop of 425 C
(765 F). This fact combined with an observed outlet gas temperature of
236 C demonstrates that this unit is operating as intended. However, this
outlet gas temperature is above the maximum rated temperature limit of nomex
cloth which is 215 C (many users of nomex consider the maximum long-term
temperature limit to be 190 to 205 C). Obviously, the plant is relying on some
gas cooling in the uninsulated metal duct (labelled "C" in Figure 10) going from
the evaporative cooler, to the pulse jet baghouses. It will be necessary to
carefully evaluate the baghouse inlet gas temperature records and i>ag failure
records for any symptoms of high gas temperature related problems.
3.2.3 Pulse Jet Baghouses
There are several symptoms which suggest overcleaning of the pulse jet
bags. The compressed air cleaning pressure is 95 psig which is on the high end
of industry "norm11 range of 60 to 100 psig. This pressure is generally used
only when the dust loadings are high or the dust is difficult to dislodge from
the fabric.
Also, the baghouse static pressure drop calculated from the flowchart is
at most 2.2 inches of water since this is the difference between the inlet
static pressure to the evaporative cooler and the inlet static pressure to the
fan. The actual baghouse static pressure drop is probably well below the 2.2
inches of water range since there is some slight gas flow resistance in the
evaporative cooler and the duct labelled "C" in the flowchart. Nevertheless,
the present baghouse pressure drop is well below the typical industry "norms"
of 3 to 10 inches of water. Unfortunately baseline data specifically appl-
icable to this system is not available. This very low pressure drop suggests
that the baghouses are now operating with a minimal residual dust layer on the
fabric. Some pulse jet baghouses can be susceptible to dust seepage through
the unprotected cloth under such operating conditions. For this reason, the
visible emission observation at.point El on Figure 10 becomes especially
important.
The present baghouse outlet gas temperature of 176 C is below the baseline
levels of 185 to 195 C. Since there is no comparable drop in the inlet gas
temperature, the possible emergence of baghouse air infiltration problems
B-19
-------
should be considered. This can be a problem for almost any air pollution
control device. However, in this case, it could become especially significant
since the gas stream contains large quantities of acid vapor and moisture.
The nomex cloth is immune to these materials in the vapor state, bu£~extremely
vulnerable to them if they condense as liquids. The inrushing cold ambient
air could create localized cold spots where the acid and moisture can attack
the bags.
3.3 Minimizing Health and Safety Risks
Field inspections of air pollution sources can be performed without
substantial health and safety risks as long as agency personnel (1) recognize
and avoid the hazards to the maximum extent possible, (2) use personal protec-
tion equipment for "back-up" protection, and (3) comply with all plant and
agency safety policies. However, it is difficult to remain conscious of health
and safety risks while attempting to understand somewhat unfamiliar equipment
and while discussing system performance with facility representatives. The
health and safety guidance presented in the upper left of the form serves as a
convenient reminder of some of the most. important considerations. This is
essentially "in front" of the inspector as he or she walks around the facility
and evaluates system operation.
At this plant, there are numerous important conditions to recognize and
avoid. The inspectors" should avoid any contact with the carcinogen-contaminated
soil in and around the charge pile when making visible emission observations at
point Fl. If there is any contact, personal protective clothing would be needed
and decontamination procedures would have to be strictly followed. The roofs
of the pulse jet baghouses should be avoided since these are uninsulated metal
shells operating between 176 and 204 C which is equivalent to 350 to 400 F.
This is too hot for standard safety shoes and there are no guard rails.
Within the health and safety block of the standard inspection flowchart
form, the inspector's supervisor and/or agency's safety specialists can specify
the type of respirator to be worn. In this case, a self contained breathing
apparatus, pr-ssure demand mode has been specified since the material is a
suspected carcinogen and since the concentration is unknown. Either condition
is alone sufficient to warrant the pressure demand SCBA. It should be noted
that OSHA requires that supervisors play a significant role in the selection
and use of respiratory protection.
3 4 Inspection and Inspection Report Preparation Time
Air pollution control agency field personnel generally are assigned a large
number of industrial facilities. Also, they have a number of responsibilities
entirely independent of their field inspection work. For these reasons, time is
precious
The use of the flowchart can reduce on-site inspection time by improving
communication with the plant personnel and by facilitating the evaluation of
complex system performance problems. It is very useful in determining the
data that is extraneous and the records which can be ignored. Also, the
recording of some of the inspection data on the flowchart itself streamlines
B-20
-------
completion of the inspection report. A copy of the flowchart with inspection
notes should be attached to the inspection report so that there is no need to
retabulate the data. Also, a copy of the flowchart should be retained to allow
for more rapid pre-inspection file review before the next scheduled visit.
B-21
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APPENDIX C
INSPECTION CHECKLISTS
c-i
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C-2
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LEVEL 2 INSPECTION CHECKLIST
Date:
Time on-Site:
General Information
Plant Name
Address
ID. No.
(Street)
(City)
Plant Contact
Telephone No(a).
_
Zip code
Title
Emergency Information
In-Plant Emergency Contact
In-Plant Emergency Sirens/Codes
Pre-Insoection Meeting
Plant Personnel (Name)
(Name)
Title
Title
Scope of Inspection Discussed (Yes)
Confidentiality Discussed (Yes)
Records/Reports Requested (Yes)
Applicable Regs. Discussed (Yes)
Plant Operation Discussed (Yes)
Comments
(No)
(No)
(No)
(No)
-(No)
Records /Reports
All Required Records/Reports Available (Yes) _ (No)
All Required Records/Reports Complete (Yes) _ (No)
Comment on back
Comment on back
Post-Inspection Meeting
Plant Personnel (Name)
(Name)
Title
Title
Comments
Confidentiality Discussed (Yes)
Plant Operation Discussed (Yes)
(No)
(No)
Process Operating Conditions During On-Site Inspection
Unit
(Yes)_ (No)_
Startup/Shutdown
in Progress
Source Reporting Upset or
Malfunction in Progress (Yes) _ (No) _
Types of Fuels Burned
Processed MSW
RDF
Coal
Auxiliary Burners On
(Yes) (N0)_
(Yes) (No)
(Ves)~ (No)~
Unit
(Yes) _ (No)_
(Yes) _ (No) _
(Yes)_ (No) _
(Yes) _ (No) _
(Yes)_ (No)_
Unit
(Yes) _ (No)_
(Yes) _ (No) _
(Yes)
(Yes)
(Yea)
(No)
(No)
(No)
(Yes) _ (No) _ (Yes) _ (No) _ (Yes) _ (No) —
C-3
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COMBUSTION SYSTEM OPERATION! PRIMARY DATA AND INFORMATION
STREAM RATE
Unit Unit Unit_
Operating Rate (Pounds of _
Steam/Hr., 1-hour average)
During Inspection
Maximum Incinerator/Boiler
Steam Rate (Pounds of
Steam/Hr., 1-hour average)
Steam Flow Records (Describe any 1-hour time periods when the steam flow
exceeded the maximum rating of the units)
Unit Date Time Value
Unit Date Time Value_
Unit Date Time Value_
Unit Date Time Value_
Describe Excursions
FLUE GAS CO CONCENTRATION
Unit Unit Unit
CO Concentration During
During Inspection
(4-hour block average)
ALLOWABLE (50-150 PPM)
Carbon monoxide concentration data (Describe any 4-hour time periods when the
levels exceeded the -SO to 150 ppm limit) .
Unit Date Time Value ~
Unit Date Time Value
Unit Date Time Value_
Unit Date Time Value_
Describe Excursions
PARTICULATE CONTROL DEVICE INLET GAS TEMPERATURE
Air Pollution Control System
Inlet Temp. During Insp.
(4-hour block average)
ALLOWABLE 450 F
Particulate Control System Inlet Temp. Records (Describe any 4-hour time
periods when the levels exceeded 450 F [230 C])
Unit Date Time Value
Unit Date Time Value
Unit Date Time Value_
Unit Date Time Value"
Describe Excursions
INCINERATOR/BOILER EXIT GAS TEMPERATURE
Unit Unit Unit_
Minimum Instantaneous Value, F
Average Instantaneous Value, F
Maximum Instantaneous Value, F
OTHER INFORMATION
Bottom Ash Burnout
(Describe Ash)
Bottom Ash Fugitive
Emissions (Describe)
C-4
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COMBUSTION SYSTEM OPERATION: FOLLOW-UP DATA AND INFORMATION
COMBUSTION SYSTEM EXIT FLUE GAS OXYGEN CONCENTRATIONS
Unit Unit
Values During Inspection
4-hour block average,%
Minimum Instantaneous, %
Maximum Instantaneous, %
O2 Variability, (Describe)
COMBUSTION SYSTEM AIR SUPPLY PRESSURES AND DRAFT
Unit Unit Unit_
Values During Inspection (Inches of Hater)
Draft,
Undergrate Pressures
Plenum
Plenum
Plenum
Plenum
Plenum
Plenum
Overfire Air Pressures
Header
Header
Header
FUEL/ASH DISTRIBUTION ON GRATES (SLOPED GRATE AND SPREADER STOKER UNITS)
Unit Unit Unit
Describe Apparent Mal-
Distribution
BOTTOM ASH LABORATORY ANALYSES
Unit Sampling Date Loss-on-Ignition
Unit Sampling Date Losa-on-Ignition
Unit Sampling Date Loss-on-Ignition
C-5
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WASTE PREPROCESSINGt PRIMARY DATA AND INFORMATION
OBSERVED WASTE CHARACTERISTICS IN INCINERATOR CHARGING AREA
Describe types of wastes being, burned in significant quantities.
Prohibited Hastes
Vehicle Batteries
Other (List fi Describe)
Undesirable Wastes
Sources of Toxic Emissions
Waste Chemicals
Flammable Liquids
Asbestos
Other (List & Describe)
Wastes Contributing to Unscheduled Startup/Shutdown
Bulky Materials
Gas Cylinders
Other
General Observations
WASTE PREPROCESSING: FOLLOW-UP DATA AND OBSERVATIONS
On-Site Processing
(Describe general methods used and adequacy of waste preprocessing)
Off-Site Processing
Plant Name
Address (Street)
(City)
Plant Representative
Telephone Number
(Describe general methods used and the adequacy of waste preprocessing)
C-6
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POLLUTANT EMISSIONS: PRIMARY DATA AND OBSERVATIONS
CEM ANALYZER AND SAMPLE CONDITIONING SYSTEMS
Unit Unit Unit_
Fault Lights and Warning Flags (Describe)
Opacity
Sulfur Dioxide
Nitrogen Oxides
Carbon Monoxide
Oxygen (of CO2)
Zero/Span Values
Opacity, Observed
Drift
Sulfur Dioxide, Observed /
Drift
Nitrogen Oxides, Observed /
Drift /"
Carbon Monoxide, Observed /
Drift /"
Data Acquisition System Problems (Describe)
EXTRACTIVE GAS SAMPLE LINE AND CONDITIONING SYSTEM
Unit Unit Unit -
Inlet Sample Line Temperature
(Describe Insulation Surface Temp.
as warm or cold)
Condenser Temperature, F
Sample Gas Flow Rates
Total
Sulfur Dioxide
Nitrogen Oxides
Carbon Monoxide
O or CO
Calibration Gas Cylinders (Pressure in psig/concentration)
Sulfur Dioxide _ / _ _ / _
Nitrogen Oxides
_
Carbon Monoxide _ /
CEM QUALITY ASSURANCE RECORDS AND REPORTS
Daily Calibration Drift Tests (Describe Any Deficiencies)
Quarterly Accuracy Tests (Describe Any Deficiencies)
Instrument Availability (Required: 75% of Days, 75% of Time/Day)
Unit Unit Unit_
Opacity
Sulfur Dioxide
Nitrogen Oxides _^______^_____ ^^__^__^____ ^____
Carbon Monoxide
O, or CO,
C-7
-------
DRY SCRUBBER SYSTEMS - PRIMARY DATA
Unit Unit Unit_
Alkali Feed Rate
Spray Dryer Inlet Gaa
Temperature, F
(Describe range of
values if varying
substant ially)
Spray Dryer Outlet Gas
Temperature, F.
(Describe range of
values if varying
substantially)
Dry Injection System
Heat Exchanger
Outlet Temperature, 1
(Describe range of
values if varying
substantially)
DRY SCRUBBER SYSTEMS: FOLLOW-UP DATA
Spray Dryer Nozzle
Pressures: Air, psig
Slurry, psig
PARTICULATE CONTROL DEVICEI PRIMARY DATA
Unit Unit Unit_
Visible Emissions (Attach
Method 9 Data Sheets)
Opacity CEM Data During
Method 9 Observation,
Condensing Plume (Yes) (No) (Yes) (No) (Yes) (No)
Inlet Gas Temperature
During Inspection (4-Hr.)
Inlet Gas Temperature (Instantaneous)
During Inspection
(Maximum/average) /
Outlet Gas Temperature (Instantaneous)
During Inspection
(Maximum/average/minimum)
C-8
-------
ELECXROSTATZC PRECIPZTAXORS: PRIMARY DATA
Unit Transformer-Rectifier Set Electrical Data- _
Primary Primary Secondary Secondary Spark
Voltage Current Voltage Current Rate
(Volts) (Amps) (Kilovolts) (Milliamps) (//min.)
Inlet
Field
Field
Field _
Outlet
Field
Unit Transformer-Rectifier Set Electrical Data
Primary Primary Secondary Secondary Spark
Voltage Current Voltage Current Rate _
-(Volts)- (Amps) (Kilovolts) (Milliamps) (#/min.)
Inlet
Field
Field
Field
Outlet
Field
Unit Transformer-Rectifier Set Electrical Data
Primary Primary Secondary Secondary Spark
Voltage Current Voltage Current Rate
(Volts) (Amps) (Kilovolts) (Milliamps) (#/min.)
Inlet
Field
Field
Field _
Outlet
Field
C-9
-------
ELECTROSTATIC PRECZPITATORSI FOIXOW-UP INSPECTION
Unit Unit Unit
General Physical Condition_ _~~ ___
(Obvious Corrosion) (Yea) (No) (Yes) (No) (Yes) (No)
(Air Infiltration) (Yes) (No) (Yes)_ (No) (Yes) (No)
Comments
Rappers
Frequency:
Plates, Inlet Field
Field
Field
Outlet Field
HV Frames, Inlet Field
Field
Field
Outlet Field
Rappers
Intensity:
Plates, Inlet Field
-Field
Field
Outlet Field"
HV Frames, Inlet Field
Field
Field
Outlet Field
C-10
-------
FABRIC FILTERSI PRIMARY INSPECTION DATA
Unit Unit Onit_
Baghouse Static Pressure
Drop, Inches of Hater
FABRIC FILTERS: FOLLOW-UP INSPECTION DATA
General Physical Condition
(Obvious Corrosion) (Yes) (No) (Yes) (No) (Yes) (No)
(Air Infiltration) (Yes) (No) (Yes) (No) (Yes) (No)
Comments
Pulse Jet Compressed
Air Pressure, psig
Diaphragm Valve Operation
(Estimate fraction
Inoperative)
Reverse Air Fan Operating _
(Yes) (No) (Yes) (No) (*es)_- (No)
Compartment Static Pressure
Drops During Cleaning,
(Inches of Water)
Compartment
Compartment
Compartment
Compartment
Compartment
Compartment
Clean Side Conditions
(Describe)
C-ll
-------
HEX SCRUBBER SYSTEMSI PRIMARY INSPECTION DATA
Unit Unit
Visible Emissions (Attach
Method 9 Data Sheets)
Opacity CEM Data During
Method 9 Observation,
Condensing Plume (Yea) (No) (Yea) (No) (Yes) (No)
Gas-Atomized Scrubber
Pressure Drop
(Inches W.C.)
Gas-Atomized Scrubber
Packed Bed Liquor pH
Wet Ionizer Scrubber, T-R Set Data
Unit Transformer-Rectifier Set Electrical Data
Secondary Secondary Spark
Voltage Current Rate
-KilovoLts) (Milliamps) (*/min.)
Inlet
Module
Module
Outlet'
Module
Unit Transformer-Rectifier Set Electrical Data
Secondary Secondary Spark
Voltage Current Rate
Kilovolts) (Milliamps) (#/min.)
Inlet
Module
Module
Outlet"
Module
Unit Transformer-Rectifier Set Electrical Data
Secondary Secondary Spark
Voltage Current Rate
Kilovolts) (Milliamps) (//rain.)
Inlet
Module
Module
Outlet"
Module
C-12
-------
WET SCRUBBER SYSTEMSI FOLLOW-UP INSPECTION DATA
Unit Unit Unit_
Gas Atomized Scrubber
Condenser/Absorber
Exit Gas Temperature
Gas Atomized Scrubber
Particulate Scrubber
Vessel Liquor Recirculation
Rates, gpm
Gas Atomized Scrubber
Presaturator Liquor
Solids Content
(Attach copies
of lab. tests)
Wet Ionizing Scrubber
Electrode Cleaning
Frequency
Wet Ionizing Scrubber
Packed Bed Liquor pH
Wet Ionizing Scrubber
Purge Air'Blower —
Operation
C-13
-------
NITROGEN OXIDES CONTROL SYSTEMS: PRIMARY INSPECTION DATA
Unit Unit Onit_
Visible Emissions (Attach _ _~
Method 9 Data Sheets)
Opacity CEM Data During
Method 9 Observation,
Condensing Plume (Yes) (No) (Yes) (No) (Yes) (No)
Inlet Gas Temperature (Instantaneous)
During Inspection
(min./average/max.) / /
Ammonia Feed Rate
Urea Feed Rate
NITROGEN OXIDES CONTROL SYSTEMS: FOLLOW-UP INSPECTION DATA
Injection Nozzle Conditions
Ammonia Pressure •
Carrier Gas Pressure
Urea Liquor Pressure
Oxygen Concentration
C-14
-------
SUPPLEMENTAL COMMENTS:
C-15
-------
APPENDIX D
DEFINITIONS
D-l
-------
D-2
-------
DEFINITIONS
Affected Facility - With reference to a stationary source, any
apparatus to which a standard is applicable.
Analyzer - That portion of the CEMS that senses the pollutants and
generates an output that is a function of the opacity.
Auxiliary-fuel Firing Equipment - Equipment to supply additional
heat, by the combustion of an auxiliary fuel, for the purpose of
attaining temperatures sufficiently high (a) to dry and ignite the
waste material, (b) to maintain ignition thereof, and (c) to effect
complete combustion of combustible solids, vapors, and gas.
Baffle - A refractory construction intended to change the direction
of flow of the products of combustion.
Breeching - The connection between the incinerator and the stack.
Breeching By-pass - An arrangement of breeching and dampers to
permit the -intermittent use of two or more passages for products of
combustion to the stack or chimney.
Bridge-wall - A partition wall between chambers over which pass the
products of combustion.
Btu (British Thermal Unitl - The quantity of heat required to
increase the temperature of one pound of eater from 60 to 61
degrees Fahrenheit.
Burners
Primary - A burner installed in the primary combustion chamber
to dry and ignite the material to be burned.
Secondary - A burner installed in the secondary combustion
chamber to maintain a minimum temperature of about 1400 degrees
Fahrenheit. It may also be considered as an after-burner.
After-burner - A Burner located so that the combustion gases are
made to pass through its flame in order to remove smoke and
odors.
Burning Area - The horizontal projected area of grate,, hearth, or
combination thereof on which burning takes place.
Burning Rate - The amount of waste consumed, usually expressed as
pounds per square foot of burning area. Occasionally expressed as
Btu per hour per square foot of burning area, which refers to the
heat liberated by combustion of the waste.
D-3
-------
Calibration Drift fCDl - The difference in the GEMS output readings
from the upscale calibration value after a stated period of normal
continuous operation during which no unscheduled maintenance,
repair or adjustment took place.
Calibration Error - The difference between the opacity values
indicated by the GEMS and the known values of a series of
calibration attenuators (filters or screens) .
Capacity - The amount of a specified type or types of waste
consumed in pounds per hour. Also may be expressed as heat
liberated, Btu per hour, based upon the heat of combustion waste.
Checker-work - Multiple openings above the bridge-wall and/or below
the drop arch, to promote turbulent mixing of the products of
combustion.
Chute, charging - A pipe or duct through which wastes are conveyed
from above to the primary chamber, or to storage facilities
preparatory to burning.
Combustion Air
Underfire Air - Air introduced to the primary chamber through the
fuel bed.by natural, induced, or forced draft. 7
Overfire Air - Air introduced above or beyond the fuel bed by
natural, induced, or forced draft. It is generally referred to as
overfire air if supplied above the fuel bed through the side
walls and/or the bridge-wall of the primary chamber.
Stoichiometric Air - Air, calculated from the chemical
composition of waste, required to burn the waste completely
without excess air.
Excess - Air supplied in excess of theoretical air, usually
expressed as a percentage of the theoretical air.
Combustion Chamber
Primary - Chamber where ignition and burning of the waste occur.
Secondary - Chamber where combustible solids, vapors, and gases
from the primary chamber are burned and settling of fly ash takes
place.
Continuous Monitoring System - The total equipment required under
the emission monitoring sections in applicable subparts of 40 CFR
60 which is U£-.d to sample to condition (if applicable), to
analyze, and to provide a permanent record of em^~sions or process
parameters.
D-4
-------
Damper - A manual or automatic device used to regulate the rate of
flow of gases through the incinerator.
Barometric - A pivoted, balanced plate normally installed in the
breeching, and actuated by the draft.
Guillotine - An adjustable plate normally installed vertically in
the breeching, counterbalanced for easier operation, and operated
manually or automatically.
Butterfly - An adjustable, pivoted plate normally installed in
the breeching.
Sliding - An adjustable plate normally installed horizontally or
vertically in the breeching.
Data Recorder - That portion of the GEMS that provides a permanent
record of the analyzer output. The data recorder may include
automatic data-reduction capabilities.
Diluent Analyzer - That portion of the GEMS that senses the diluent
gas (e.g., CO, or O2) and generates an output proportional to the
gas concentration.
Draft - The pressure difference between the incinerator, or any
component part, and the atmosphere', which causes the products of
combustion to flow from the incinerator to the atmosphere.
Natural T The negative pressure created by the difference in
density between the hot flue gases and the atmosphere.
Induced - The negative pressure created by the action of a fan,
blower, or ejector, which is located between the incinerator and
the stack.
Forced - The positive pressure created by the action of a fan or
blower, which supplies the primary or secondary air.
Existing Facility - With reference to a stationary source, any
apparatus of the type for which a standard is promulgated in 40
CFR 60, and the construction or modification of which was commenced
before the date of proposal of that standard, or any apparatus
which could be altered in such a way as to be of that type.
Flv Ash - All solids including ash, charred paper, cinders, dust,
soot, or other partially incinerated matter, carried in the
products of combustion.
Flv Ash Collector - Equipment for removing fly ash from the
products of combustion.
Grate - A surface with suitable openings to support the fuel bed
and permit passage of air through the fuel. It is located in the
primary combustion chamber and is designed to permit the removal of
the unburned residue. It may be horizontal or inclined, stationary
or movable, and operated manually or automatically.
D-5
-------
Heat of Combustion - The amount of heat, usually expressed as Btu
per pound of as-fired or dry waste, liberated by combustion at a
reference temperature of 60 degrees Fahrenheit. With reference to
auxiliary gas, it is expressed as Btu per standard cubic-foot, and
to auxiliary oil as Btu per pound or gallon.
Heat Release Rate - The amount of heat liberated in the primary
combustion chamber, usually expressed as Btu per hour per cubic
foot.
Heating Value - Same as heat of combustion
Incinerator - Equipment in which solid, semi-solid, liquid or
gaseous combustible wastes are ignited and burned, the solid
residues of which contain little or no combustible material.
Malfunction - Any sudden and unavoidable failure of air pollution
control equipment or process equipment or of a process to operate
in a normal manner. Failures that are caused entirely or in part
by poor maintenance, careless operation, or any other preventable
upset condition, or any other preventable upset condition or
preventable equipment breakdown" shall not be considered
malfunctions.
Optical Density Tool - A logarithmetic measure of the amount of
incident light attenuated. Optical density (D) is related to the
transmittance and opacity as follows: D = -Iog10 Tr = -Iog10(l-Op)
Opacity (OP) - The degree to which emissions reduce the
transmission of light and obscure the view of an object in the
background.
Operational Test Period - A period of time (168 hours) during which
the CEMS are expected to operate within the established performance
specifications without any unscheduled maintenance, repair, or
adjustment.
Path CEMS - A CEMS that measures the gas concentrations along a
path greater than 10 percent of the equivalent diameter of the
stack or duct cross section.
Point CEMS - A CEMS that measures the gas concentrations either at
a single point or along a path equal to or less than 10 percent of
the equivalent diameter of the stack or duct cross section.
Pollutant Analyzer - That portion of the CEMS that senses the
pollutant gas and generated an output proportional to the gas
concentration.
Reference Method fRMl - Any method of sampling and analyzing for an
air pollutant as described in Appendix A to 40 CFR 60.
D-6
-------
Relative Accuracy fRAl - The absolute main difference between the
gas concentration or emission rate determined by the CEMS and the
value determined by the Reference Methods plus the 2.5 percent
error confidence coefficient of a series of tests divided by the
mean of the Reference Method tests or the applicable emission
limit.
Response Time - The amount of time it takes the CEMS to display on
the data recorder 96 percent of a step change in opacity.
Run - The net period of time during which an emission sample is
collected. Unless otherwise specified, a run may be either
intermittent or continuous within the limits of good engineering
practices.
Sample Interface - That portion of the CEMS that protects the
analyzer from the effects of the stack effluent and aids in keeping
the optical surface clean.
Shutdown - The cessation of operation of an affected facility for
any purpose.
Scan Value - The opacity value at which the CEMS is set to produce
the maximum data., display output as specified in the lapplicable
subpart of 40 CFR 60.
Standard Conditions - A temperature of 293 K (68 F) and a pressure
of 101.3 Kilopascals (29.92 in. Hg) .
Startup - The setting in operation of an affected facility for any
purpose.
Transmissometer - That portion of the CEMS that includes the sample
interface and the analyzer.
Transmittance fTR) - The fraction of incident light that is
transmitted through an optical medium.
Upscale Calibration Valve - The opacity value at which a calibra-
tion check of the CEMS is performed by simulating an upscale
opacity condition as viewed by the receiver.
Zero Drift - The difference in the CEMS output readings from the
zero calibration value after a stated period of normal continuous
operation during which no unscheduled maintenance, repair, or
adjustment took place. A calibration value of 10 percent opacity
or less may be used in place of the zero calibration value.
D-7
-------
APPENDIX E
ACRONYMS AND SYMBOLS
E-l
-------
E-2
-------
ACRONYMS AND SYMBOLS
ACF Actual Cubic Feet
ACFM Actual Cubic Feet Per Minute
ASME American Society of Testing and Measurement
ASTM American Society of Testing and Measurement
ATM Atmosphere
BACT Best Available Control Technology
Btu British Thermal Unit
CAA Clean Air Act
CB Continuous Bubbler
CD Calibration Drift
CEM Continuous Emission Monitor or Continuous Emission
Monitoring
CEMS Continuous Emission Monitoring System
CFR Code of Federal Regulations
CGA Cylinder Gas Audit
CI Confidence Interval
CRM Certified Reference Material
CSA Coal Sampling and Analysis
DAS Data Acquisition System
DCO Delayed Compliance Order
DI Dry Injection
DS Dry Scrubber
EER Excess Emission Report
EMB Emission Measurement Branch
(Emission Standards and Engineering Division of EPA
EPA Environmental Protection Agency
ESP Electrostatic Precipitator
FFFSG Fossil-Fuel Fired Steam Generator
FGD Flue Gas Desulfurization
FR Federal Register
LAER Lowest Achievable Emission Rate
MD Mean Difference
MRF Material Recovery Facility
MWC Municipal Waste Combustor
MSW Municipal-type Solid Waste
MW Megawatts
NAAQS National Ambient Air Quality Standards
NBS National Bureau of Standards
NBS SRM NBS Standard Reference Manual
E-3
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NDIR Non-Dispersive Infrared Radiation
Nm3 Normal Cubic Meters
NOV Notice of Violation
NSPS New Source Performance Standards
OD Optical Density
OP Opacity
OPLR Optical Pathlength Ratio
ppm Parts Per Million
ppmv Parts Per Million, Volume
PS Performance Specification
PSD Prevention of Significant Deterioration
psig Pounds Per Square Inch, Gauge
PST Performance Specification Test
QA Quality Assurance Plan
QAD Quality Assurance Division
(Envrionmenatl Monitoring Support Laboratory of EPA)
QAP Quality Assurance Plan
QC Quality Control
RA Relative Accuracy
RAA Relative Accuracy Audit
RAT Relative Accuracy Test
RATA Relative Accuracy Test Audit
RDF Refuse Derived Fuel
RM Reference Method
SCF Standard Cubic Feet
SCFM Standard Cubic Feet Per Minute
SDA Spray Dryer Absorber
SIP State Implementation Plan
SSCD Stationary Source Compliance Division of EPA
STR Stack Taper Ratio
TCEMS Transportable Continuous Emission Monitoring System
TR Transmittance
UV ultraviolet
VOC Volatile Organic Compound
E-4
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APPENDIX F
BIBLIOGRAPHY
F-l
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F-2
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BIBLIOGRAPHY - MUNICIPAL WASTE INCINERATION
WASTE PREPROCESSING AND RECOVERY
Alpert, Joel E. and Mark Gould. Municipal Solid Waste
Composting State-of-the-Art. Presented at the 83rd Annual
Meeting & Exhibition of the Air and Waste Management
Association. Pittsburgh, Pennsylvania. June 1990.
Cooper, S.P. How to Protect Against Explosions in RDF Plants.
Power May 1989. PP. 45-48.
Glaub, John C. et al. The Design and Use of Trommel Screens for
Processing Municipal Solid Waste. Proceedings of the 1982
National Waste Processing Conference. New York, New York.
May 1982. PP.447-457.
Gibbs, D.R. and L.A. Kreidler. What RDF Has Evolved Into. Waste
Age. April 1989. PP.252-262.
Gould, Robert N. MRFs, Past and Future. Waste Age. July 1990.
PP.84-86.
Johnson, Randy and Carl Hirth. Collection Household Batteries.
Waste Age. June 1990. PP. 48-52.
Kenny Garry and Edward J. Sommer Jr. A Simplified Process for
Metal and Noncombustible Separation from MSW Prior to
Waste-to-Energy Conversion. Proceedings of the 1984 National
Waste Processing Conference. Orlando, Florida. June 1984.
Riser, Jonathan V.L. ...The Rest of the Story is Good! Waste
Age. November 1989. PP. 44-52.
Morgan, D.G. Everything You Never Knew About Magnetic
Separation. Waste Age. July 1987. PP.110-112
Peluso, Richard A. and Ernest H. Ruckert III. A Look at Waste
Transfer Options. Waste Age. January 1989. PP. 115-122.
Roos, Charles E. Is Lead a Big Problem? Waste Age. February
1988. PP. 54-56.
Russell, Stuart H. Pre-Processing, Not RDF. Waste Age. August
1989. PP. 165-169.
F-3
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BIBLIOGRAPHY - WASTE PREPROCESSING AND RECOVERY
Waste Age. An EPA View of * Feasibility'. Waste Age. May 1989.
PP 32-34.
Waste Age. Plant Vendors Are Pushing Recycling! Waste Age.
July 1989. PP.127-129.
BIBLIOGRAPHY - AIR POLLUTION CONTROL
Andersen 2000 Inc. Emission Control Systems for Incinerators.
Andersen 2000 Inc. Peachtree City, Georgia. Tr-89-900239.
February 1989.
Andersen 2000 Inc. Venturi Scrubbers for Fine Particulate
Emission Control. Andersen 2000 Inc. Peachtree City Georgia.
Bulletin #78-900075. Revision B. December 1982.
Brabham, E. and J. Norton. Modern Air Pollution Control
Retrofits: The Potential for Recovery of the Incinerator Itself.
Proceedings of the 1984 National Waste Processing Conference.
Orlando, Florida, June 1984. PP. 401-411.
Brady, Jack D. Understanding Venturi Scrubbers for Air Pollution
Control. Plant Engineering. September 30, 1982.
Burnett, G.F. and B.E. Basel. The Status of Dry Scrubbing in the
United States. Presented at the 78th Annual Meeting of the Air
Pollution Control Association. Detroit, Michigan. June 1985.
Cannall, A. L. et al. Effects of Recent Operating Experience on
the Design of Spray Dryer FGD Systems. Presented at the 78th
Annual Meeting of the Air Pollution Control Association.
Detroit, Michigan. June 1985.
Clarke, Marjorie. Emissions Control: A Never-Ending Quest.
Waste Age. January 1986. PP.83-94.
Clarke, Marjorie. Emission Control Technologies for Resource
Recovery. Presented at the 79th Annual Meeting of the Air
Pollution Control Association. Minneapolis, Minnesota. June
1986.
Clarke, Marjorie. How Planf Operators Can Minimize Emissions.
Waste Age. December 1987. PP. 156-168.
Clarke, Marjorie T. Minimizing Emissions and Improving Operation
of Waste-to-Energy Facilities. Presented at the 80th Annual
Meeting of the Air Pollution Control Association. New York, New
York. June 1987.
F-4
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BIBLIOGRAPHY - AIR POLLUTION CONTROL
Couppis, Evis C. Will Smaller Plants Get Scrubbers? Waste Age.
March 1988. PP.119-126
Delleney R.D. and P.K. Beekely. Process Instrumentation and
Control in SO2 Scrubbers. Electric Power Research Institute.
Report No. CS-3565. June 1984.
Donnelly, J.R. Design Considerations for MSW Incinerator APC
Systems Retrofit.Presented a the 83rd Annual Meeting & Exhibition
of the Air & Waste Management Association. Pittsburgh,
Pennsylvania. June 1990.
Donnelly, J.R. et al. Design Considerations for Resource
Recovery Spray Dryer Absorption Systems. Presented at the 79th
Annual Meeting of the Air Pollution Control Association.
Minneapolis, Minnesota. June 1986.
Donnelly, J.R. et al. Joy/Niro SDA Systems for MSW Incineration,
European Operating Results. Presented at the 80th Annual
Meeting of APCA. New York, New York, June 1987.
Eklund, A.G. and_D. M. Golden. Laboratory Characterization of
Dry Sodium and Calcium In-Duct Injection By-Products.~ Presented
at the 83rd Annual Meeting & Exhibition of the Air & Waste
Management Association. Pittsburgh, Pennsylvania. June 1990.
Ensor, David S. Ceilcote Ionizing Wet Scrubber Evaluation.
USEPA. Office Of Research and Development. Washington DC.
EPA-600/7-79-246/ November 1979.
Ferguson, W.B. et al. Equipment Design Considerations for the
Control of Emissions from Waste-to-Energy Facilities. Presented
at the 79th Annual Meeting of the Air Pollution Control
Association. Minneapolis, Minnesota. June 1986.
Flakt Canada Ltd. and Environment Canada. The National
Incinerator Testing and Evaluation Program: Air Pollution Control
Technology. Summary Report. Report EPS 3/UP/2. September 1986.
Flynn, Bernard L. et al. Effect of Product Recycle on Dry Acid
Gas Emission Control. Proceedings of the 1984 National Waste
Processing Conference. Orlando Florida. June 1984. PP.385-396.
Foster, John T. Design and Start-up of a Dry Scrubbing System
for Solid Particulate and Acid Gas Control on a Municipal
Refuse-Fired Incinerator. Presented at the APCA Specialty
Conference on Thermal Treatment of Municipal, Industrial and
Hospital Wastes. Pittsburgh Pennsylvania. November 1987.
F-5
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BIBLIOGRAPHY - AIR POLLUTION CONTROL
Holland, O.L. and J.D. Means. Utilization of Hydro-Sonic
Scrubbers for the Abatement of Emissions from Hazardous
Industrial, Municipal & Bio-Medical Wastes. John Zink"Company.
Tulsa Oklahoma. Technical Paper 7802A. 1988.
Jordan, Richard. The Feasibility of Wet Scrubbing for Treating
Waste-to-Energy Flue Gas. Journal of the Air Pollution Control
Association. April 1987. Volume 37. Number 4. PP. 422-423.
Kapner, Mark et al. An Evaluation of Alternative Emission
Control Systems for Refuse-to-Energy Plants. Presented at the
80th Annual Meeting of APCA. New York, New York. June 1987.
Karlsson, Hans T. et al. Activated Wet-Dry Scrubbing of SO2.
Journal of the Air Pollution Control Association. January 1983.
Volume 33, No 1. PP. 23-28.
Kroll, Peter J. and Peter Williamson. Application of Dry Flue
Gas Scrubbing to Hazardous Waste Incineration. Journal of the
Air Pollution Control Association." November 1986. Volume 36.
No. 11. PP. 1258-1268.
Makansi, Jason. New Processes Enhance the In-Duct
Emissions-Control Option. Power. July 1988.
Makansi, Jason. Traditional Control Processes Handle New
Pollutants. Power. October 1987. PP.11-19.
Marschall, H.L. et al. Retrofitting Air Pollution Controls to
Existing Incinerators. Presented at the 82nd Annual Meeting &
Exhibition of the Air and Waste Management Association. Anaheim,
California. June 1989.
Mcllvaine, Robert W. Control Technology for MSW Incinerator
Applications. Presented at the 79th Annual Meeting of the Air
Pollution Control Association. Minneapolis, Minnesota. June
1986.
Mcllvaine, Robert W. et al. Emissions Control Options in
Waste-to-Energy Plants. Waste Age. January 1987. PP. 69-79.
Mills Daryl R. Air Pollution Control of Municipal Solid Waste
Incinerators. Presented at the 77th Annual Meeting of the Air
Pollution Control Association. San Francisco, California. June
1984.
Moller, Jens Thousig and Ove B. Christiansen. Dry Scrubbing of
Hazardous Waste Incinerator Flue Gas by Spray Dryer Absorption.
Presented at the 77th Annual Meeting of the Air Pollution Control
Association. San Francisco, California. June 1984.
F-6
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BIBLIOGRAPHY - AIR POLLUTION CONTROL
Holier, Jens Thousig and Ove B. Christiansen. Dry Scrubbing of
Municipal Waste Incinerator Flue Gas by Spray Dryer Absorption.
Presented at the 77th Annual Meeting of the Air Pollution'Control
Association. San Francisco, California. June 1984.
Mo Her , Jens Thousig. Dry Scrubbing of MSW Incinerator Flue Gas
By Spray Dryer Absorption: New Developments in Europe. Presented
at the 78th Annual Meeting of the Air Pollution Control
Association. Detroit, Michigan. June 1985.
Mutke, Reinhold. Slash Emissions From Refuse Firing. Power.
December 1981. PP. 63-64.
Noddin, E. Lee and Abraham Turkson. Performance Characteristics
of P84 Composite Fabrics in Dust Collectors. Presented at the
83rd Annual Meeting & Exhibition of the Air & Waste Management
Association. Pittsburgh, Pennsylvania. June 1990.
O'Connell, Wilbert L. et al. Emissions and Emission Control in
Modern Municipal Incinerators. Proceedings of the 1982 National
Waste Processing Conference. New York, New York. May 1982. PP.
285-297.
Offen, G.R. et al. Assessment of Dry Sorbent Emission Control
Technologies. Part II. Applications. Journal of the Air
Pollution Control Association. August 1987. Volume 37. No.8.
PP. 968-980.
Parquet, David and Richard T. Wipfler. Application of the
Electroscrubber Filter to a Municipal Solid Waste Incinerator
Project. Proceedings of the 1982 National Waste Processing
Conference. New York, New York. May 1982. PP. 299-304.
Petersen, H. Hoegh. Electrostatic Precipitators for Resource
Recovery Plants. Proceedings of the 1984 National Waste
Processing Conference. Orlando Florida. June 1984.
Reason, John. Design/Operating Ideas. Power. August 1986. PP.
82-83.
Schifftner, Kenneth. Condensing Flue-Gas Scrubbers Vie for
Gas-Cleanup Duties. Power. May, 1988.
Schifftner, Kenneth. Flux Force Condensation Scrubbers for
Utilization on Municipal Solid Waste Incinerators. Presented at
the Joint ASME/IEEE Power Generation Conference. Dallas Texas.
October 1989.
Schifftner, Kenneth and Ronald Patterson. Wet Scrubber Dry End
Product. Pollution Engineering. November 1989. PP. 70-73.
F-7
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BIBLIOGRAPHY - AIR POLLUTION CONTROL
Teller, Aaron J. Effective Reduction of Emissions from Resource
Recovery Operations. Environmental Progress. May 1989^ Vol.8,
No.2. PP. 102-106.
Teller, A.J. Emission Control System for MSW Incineration in
Resource Recovery - New Developments. Presented at the 77th
Annual Meeting of the Air Pollution Control Association. San
Francisco, California. June 1984.
Waste Age. How Industry Controls Waste-Burning Emissions. Waste
Age. April 1988. PP. 344-346.
Weaver, Edwin H. et al. Air Pollution Control Strategies for
Refuse to Energy Projects. Presented at the 80th Annual Meeting
of APCA. New York, New York. June 1987.
Weaver, Edwin H. Municipal Refuse Incineration Emissions Control
Utilizing a Dry Scrubber Electrostatic Precipitator System.
Presented at the IGCI Form'88 Air Pollution Controls on Waste
Incinerators: Recent Operation Experience. Washington DC.
November 1988.
Weaver, Edwin H. Recent Operating Experiences of Air -p'ollution
Control systems at MSW Facilities. Presented at the 83rd Annual
Meeting & Exhibition of the Air & Waste Management Association.
Pittsburgh, Pennsylvania. June 1990.
Widico, M.J. and P.H. Dharagalkar. Dry Flue Gas Desulfurization
Process for Various Coals. Presented at the 78th Annual Meeting
of the Air Pollution Control Association. Detroit, Michigan.
June 1985.
BIBLIOGRAPHY - CONTINUOUS EMISSION MONITORS
C-E Environmental, Inc. APTI Course SI:476B, Continuous Emission
Monitoring Systems: Operation and Maintenance of Gas Monitors.
Self Instructional Handbook. Purchase Order No. BC0061. October
1989. Draft.
Cone, Laurie, and George Walsh. Evaluation of CO and THC
Analyzers for Waste Incinerator Emission Measurement. EPA
Contract No. 68-02-4442. Draft.
Doyle, Brian W. Relation of Continuous Measurements to
Incinerator Emissions. Presented at the 78th Annual Meeting of
the Air Pollution Control Association. Detroit, Michigan. June
1985.
F-8
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BIBLIOGRAPHY - CONTINUOUS EMISSION MONITORS
Jahnke, James and Aidina G.J. Handbook, Continuous Air
Pollution Source Monitoring Systems. Technology Transfer.
EPA 625/6-79-005. June 1979.
Jahnke, James. APTI Course SI:476A. Transmissometer Systems -
Operation and Maintenance, An Advanced Course.
Self-instructional Handbook. EPA 450/2-84-004. September 1984.
Revised March 24, 1986.
Makansi, Jason. Move Toward Process Control for CEM Natural But
Slow. Power. August 1989. PP.9-16.
Nelsen, Jim. Continuous Measurement of HCL Emissions from
Municipal Solid Waste Incineration Facilities. Presented at the
Air Pollution Control Association International Specialty
Conference on Thermal Treatment of Municipal, Industrial, and
Hospital Wastes, Pittsburgh Pennsylvania,
November 3-6, 1987.
Peeler, James. CEMS Performance Specifications and Quality
Assurance Requirements for Municipal Waste Combustion Facilities.
U.S. EPA Contract. No. 68D0055, Work Assignment No. 15. Draft.
September 25, 1989.
Peeler, James et al. Inspection Guide for Opacity Continuous
Emission Monitoring Systems (CEM's). Draft Report. EPA Contract
No. 68-02-4462. September 1987.
Peeler, James. Recommended Quality Assurance Procedures for
Opacity Continuous Emission Monitoring Systems. USEPA.
Stationary Source Compliance Division. Office of Air Quality
Planning and Standards. Washington. DC. Contract No.
68-02-3962. Work Assignments 2-52 and 3-101. February 1986.
Porter, Timothy. Experience in Design, Installation,
Certification and Operation of Continuous Emission Monitors at
Resource Recovery Facilities.
Shanklin, Scott et al. Evaluation of HCL Measurement Techniques
at a Hazardous Waste Incinerator. EPA Contract No. 68-02-4442.
Shanklin, Scott et al. Evaluation of HCL Measurement Techniques
at Municipal and Hazardous Waste Incinerators. Presented at Air
& Waste Management Association Specialty Conference on Continuous
Emission Monitors. Chicago, Illinois. November 1989.
Shanklin, Scott et al. HCL CEMS: Feasibility and Reliability for
Municipal Waste Combustors. Presented at the 82nd Annual Meeting
of the Air Pollution Control Association, Anaheim, California,
June 25-30, 1989.
F-9
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BIBLIOGRAPHY - COMBUSTION
Bo ley, G.L. and M.L. Smith. Start-up and Operations of the
Mid-Connecticut Resource_Recovery Project. Presented at the
International Conference on Municipal Waste Combustion.
Hollywood, Florida. April 1989.
Bretz, Elizabeth. Energy From Wastes. Special Section. Power.
March 1989. PP W1-W30.
Clunie, Jeffrey F., et al. The Importance of Proper Loading of
Refuse Fired Boilers. PP. 169-177. Proceedings of the 1984
National Waste Processing Conference. Orlando, Florida. June
1984.
Cross, Frank, Phil O'Leary, and Patrick Walsh. Lesson Two.
Waste-to Energy Systems. The Menu. Waste Age. February 1987.
PP 52-60.
Ducey, R. A. et al. 20 Common Problems Found in Small
Waste-to-Energy Plants. Waste Age. May 1985. PP 50-53.
Ferguson, W.B. Jr. et al. Equipment Design Considerations for
the Control of Emissions from Waste-to Energy Facilities.
Presented at the 79th Annual Meeting of the Air Pollution Control
Association. Minneapolis, Minnesota. June 22-27, 1986.
Foster, John T. et al. Design and Start-up of a Dry Scrubbing
System for Sol-id Particulate and Acid Gas Control on a Municipal
Refuse-Fired Incinerator. Presented at the APCA Specialty
Conference on Thermal Treatment of Municipal, Industrial and
Hospital Wastes. Pittsburgh, Pennsylvania, November 1987.
Golemberwski, Mark A. et al. Environmental Assessment of a
Waste-to Energy Process: Braintree Municipal Incinerator.
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Grimse, Virginia M. Industry is Burning More Solid Waste. Waste
Age. April 1988. PP 336-344.
Hahn, Jeffrey et al. Fugitive Particulate Emissions Associated
wirh MSW Ash Handling - Results of a Full Scale Field Program.
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Waste Management Association. Pittsburgh Pennsylvania. June
1990.
Hartman, R. Michael. Air Emission Test results at the
Mid-Connecticut Resource Recovery Facility. Presented at the
American Society of Mechanical Engineers Industrial Power
Conference. Houston, Texas.
October 1988.
F-10
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BIBLIOGRAPHY - COMBUSTION
Hasselriis, Floyd. Minimizing Trace Organic Emissions from
Combustion of Municipal Solid Waste by the Use of Carbon
Monoxide. Proceedings of the 1986 National Waste Processing"
Conference. Denver, Colorado. June 1986.
PP. 129-144.
Hasselriis, Floyd. Variability of Municipal Solid waste and
Emissions From Its Combustion. Proceedings of the 1984 National
waste Processing Conference. Orlando Florida, June 1984. PP.
331-344.
Haverland, Rick A. Multi-Fuel Technology. Proceedings of the
1986 National Waste Processing Conference. Denver. Colorado1.
June 1986. PP. 31-39.
Henry, W.M et al. Inorganic Compound Identification of Fly Ash
Emissions From Municipal Incinerators. Project Summary. USEPA.
Environmental Research Laboratory. Research Triangle Park,
EPA-6—/S3-82-095 August 1983.
Kiser, Jonathan V.L. What Do You Do With Ash? Waste Age.
August 1989. PP._157-162.
Makansi, Jason. Carbon-in-Flyash Monitors Shed New Light on
Plant Performance. Power December 1989. PP. 43-45.
Makansi, Jason. Coal/Biomass Cofiring, Fluid Beds Resurrect Old
Steam Plant. Power, August 1988. PP 73-75.
Makansi, Jason. Plants Meet Challenges, Reap Benefits of On-Site
Waste Firing. Power. December 1987. PP. 17-20.
Makansi, Jason Traditional Control Processes Handle New
Pollutants. Power. October 1987. PP. 11-18.
MaiIan, George. A History and Description of the 1800 TPD SEMASS
Waste-to Energy Project in Rochester, Massachusetts. Presented
to the International Specialty Conference of the American
Pollution Control Association. Pittsburgh, Pennsylvania,
November 1987.
Marks, Charles H. Incinerator Model Uses Lotus. Waste Age.
December 1987. PP. 90, 188-189.
Masley, Ed. Co-Operation Works in Virginia. Waste Age.
December 1987. PP. 45-53.
F-ll
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BIBLIOGRAPHY - COMBUSTION
Offer. G. R. et al. Assessment of Dry Sorbent Emission Control
Technologies. Part II. Applications. Journal of the Air
Pollution Control Association. August 1987. Volume 37, Number
8. PP. 968-980.
Power. Energy From Waste: On-site heat recovery incineration.
Special Section. Power. March 1987. PP. W1-W15.
Reason, John. Next Step for Waste-to-Energy: Better
Availability, Efficiency. Power, July 1986. PP 17-24.
Rehm, Fred R. et al. The Effect of Coal/d-RDF Co-Firing on Stack
Emissions at Milwaukee County Institutions' Power Plant.
Proceedings of the 1982 National Waste Processing Conference.
New York-/ New York. May 1982. PP. 97-105.
Smith, M.L. Early and Current Systems Utilizing Refuse Derived
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Spleen, Tony. SPSA's RDF Plant Comes On-Line. Waste Age.
December 1987. PP 53-56.
Schanche, Gary W._and Kenneth E. Griggs. Features and ^Operating
Experiences of Heat Recovery Incinerators. Proceedings of the
1986 National Waste Processing Conference. Denver, Colorado.
June 1986. PP. 55-64
Scheieger, Bob. Design Simplicity, Dedicated Staff Enable Steam
plant Burning Unprepared Municipal Refuse to Achieve Near 80%
Availability. Power. February 1983. PP. 136-138.
Sigg, Alfred. Combustion Process Control in Rotary Kiln
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of the Air & Waste Management Association. Pittsburgh,
Pennsylvania. June 1990.
Sweetnam, Richard J. Trends in Waste-To-Energy Waste Age.
November 1989. PP.39-41.
Walsh, Patrick et al. Lesson Five, Residue Disposal From
waste-to-Energy Facilities. Waste Age. May 1987. PP. 57-63.
Waste Age. Rehab of Incinerator Meets Air Standards and Reuses
Wastewater. Waste Age. May 1985. PP 104-105
F-12
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BIBLIOGRAPHY - TESTING
Halle, Clarence L. and Judith C.. ftarr-is^. Guidelines for Stack
Testing of Municipal Waste Combus.tiio_n .Facilities. USEPA. OffSlpe
of Research and Development. Washington D.C. EPA-600/8->8"-68l5i
June 1988.
Monroe, E.S. Quicker, Cheaper Testing of Incinerator
Performance. Chemical Engineering. -February 21, 1983,
PP. 69-71.
Nolan, Michael and Arthur Marshall. Incinerator Emissions:
Units, Correction and Conversion. Pollution Engineering-. May
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Smith, Walter S. et al. Compliance Testing at Municipal S
Waste and Hazardous Waste Incinerators. Presented at the.'€(3:ra
Annual Meeting & Exhibition of the Air & Waste Management
Association. Pittsburgh, Pennsylvania. June 1990.
BIBLIOGRAPHY - NOX CONTROL
Beachler, David S. et al. Nitrogen Oxide (NOx) Emission Rates
From Three Waste-to-Energy Plants Using Westinghouse a1 Conner
(Rotary) Combustors. Presented at the 83rd Annual Meeting &
Exhibition of the Air & Waste Management Association.
Pittsburgh, Pennsylvania. June 1990.
Clarke, Marjorie J. Minimizing NOx. Waste Age. November l^SSS
PP. 132-137.
Hahn, Jeffrey. Innovative Technology for the Control of Air
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National Waste Processing Conference. Denver Colorado. June
1986. PP. 9-16.
Hofmann John E. et al. Nox Control for Municipal Solid Waste
Combustors. Presented at the 83rd Annual Meeting and Exhibition
of the Air & Waste Management Association. Pittsburgh,
Pennsylvania. June 1990.
Hurst, Boyd E. and C. Martin White. Thermal DeNOx: A Commercial
Selective Noncatalytic NOx Reduction Process for Waste-to-Energy
Applications. Proceedings of the 1986 National Waste Processing
Conference. Denver, Colorado. June 1986. PP. 119-127.
Jones D.G. et al. Urea Injection Nox Removal in European
Coal-Fired Boilers and MSW Incineration Plants. Presented at the
83rd Annual Meeting & Exhibition of the Air & Waste Management
Association. Pittsburgh, Pennsylvania. June 1990.
F-13
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Pompelia, Mick. NOx: How Much of a Concern? Waste Age.
.November .1989. PP. 123-128.
BIBLIOGRAPHY - GENERAL
Catalaho, Lee. EPA td.Limi^ Air f Emissions From Mew Incinerators
by ..1990."" Power. September '1987." :P. 7.
Clarke, Marjorie. Air Pollution Control Status Report. Waste
Age. .November 1987. PP. 102-117.
Clarke/, Marjorie. How Plant Operators Can Minimize Emissions.
Wasfce Age. .December 1987. PP. 156-170
Clay, Don R. Is New Legislation Needed ON Incinerator Air
Emissions? Waste Age. June 1988. PP. 40-46.
Clearwater, Scott W. and Martin J. Marchaterre. The Effects of
Proposed Environmental Regulations on Waste-To- Energy
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the Air & Waste Management Association. Pittsburgh,
Pennsylvania. June 1990.
Commoner, Barry et al. The Origins and Methods of Controlling
Polychlorinated Dibenzo-p-Dioxin and Dibenzofuran Emissions From
MSW Incinerators. Presented at 78th Annual Meeting of the Air
Pollution Control Association. Detroit, Michigan. June 1985.
Cross, Frank, Phil O'Leary and Patrick Walsh. Lesson Four. Air
Quality Protection for Waste -to-Energy Facilities. Waste Age.
April 1987. PP. 162-172.
cur lee, T. Randall. Plastic Waste and The Potential For Waste
Minimization. Presented at the 83rd Annual Meeting & Exhibition
.of the Air & Waste Management Association. Pittsburgh,
Pennsylvania. June 1990.
Delbello, Alfred B. and R. Stephen Lynch. MSW Composting: Glut
or., -Guarantee? Waste Age. January 1990. PP. 59-62
Dougherty, Ralph C. and Humberto Collazo-Lopez. Reduction of
Qrganp-chlorine Emissions from Municipal and Hazardous Waste
Incinerators. Environmental Science and Technology. Volume 21,
Dumber 6, 1987. PP. 602-604.
.Drum, .Donald A. Chemistry of Municipal Solid waste Incineration.
'presented at the 79th Annual Meeting of the Air Pollution Control
Association. Minneapolis, Minnesota. June 1986.
F-14
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BIBLIOGRAPHY - GENERAL
Fred C. Hart Associates, Inc. Conclusions of New YorJc"sr'StudY on
Dioxins and MSW Incineration. Waste Age. November 1984.
PP.25-30.
Hahn, Jeffrey L. Dioxin Emissions Erqm Modern, Mass .Fired,
Stoker/Boilers for Use in Wast'e-feo-EnecgV Risk Assessments.
Presented at the 79th Annual Meeting of the Air Pollution Control
Association. Minneapolis, Minnesota. June 1986.
Hay, D.J. et al. The National Incinerator Testing and'Evaluation
Program: An Assessment of a>Two-rStage Incineration b>..Pilot
Scale Control. Presented at the 79th Annual Meeting :of tHe'Air
Pollution Control Association. Minneapolis, Minnesota; Jtme"
1986.
Henry W.M. et al. Inorganic Compound Identification of" Fly Ash
Emissions From Municipal Incinerators. USEPA. Environmental,
Sciences Research Laboratory. Office of Research and
Development. Research Triangle Park, North Carolina. Contract
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Hurley, Richard._. Scales Are Not Simple. Waste Age. March 1988.
PP. 149-156.
Jozewicz, Wojciech and Gary T. Rochelle. Fly Ash Recycle in' Dry
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