J.
PLANT INSPECTION WORKSHOP -
TECHNIQUES FOR EVALUATING
PERFORMANCE OF AIR POLLUTION
CONTROL EQUIPMENT
Observing Compliance
Tests
U S ENVIRONMENTAL PROTECTION AGENCY
RESEARCH TRIANGLE PARK, NC 27711

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PLANT INSPECTION WORKSHOP
TECHNIQUES FOR EVALUATING PERFORMANCE
OF AIR POLLUTION CONTROL EQUIPMENT
Observing Compliance Tests
Compiled by
PEDCo Environmental, Inc.
505 South Duke street, Suite 503
Durham, North Carolina 27701
Contract No. 68-02-3512
PN 3525-9
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
AIR ENFORCEMENT BRANCH, REGION IV
345 Courtland Street, Northeast
Atlanta, Georgia 30365
February 1981

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FOREWORD
The agency field inspector is often involved in observing the conduct
of source tests performed by the company or private testing firms
for the purposes of demonstrating compliance with the applicable emission
standards. The primary function of the agency observer at the test site
is to see that the test is performed properly and that the process is
operated in a representative manner to assure the results will be a valid
assessment of the actual emission rate.
Although planning, coordination and evaluation of a complex com-
pliance test requires highly specialized skills and support from several
technical groups within the agency, the field inspector, because of his
familiarity with the plant facility, can be especially effective in monitoring
the operation of the process and control equipment during the test. Docu-
mentation of the process operation is of major importance in determining
the acceptability of the test results. The plant operator should be
encouraged to utilize good operating practices during the test, however,
it is not permissible to resort to specialized operating routines which
abnormally reduce emissions.
There are other valid reasons for the field inspector to witness
the compliance test. For example, process and control equipment operating
conditions and parameters recorded during the initial compliance test can
be used to establish baseline data for verifying and comparing conditions
observed in future inspections. Any significant deviations from these
baseline conditions noted later may indicate possible deterioration of

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equipment performance with a corresponding increase in emissions. For
the same reason it is also very useful to record stack or plume opacity
levels measured or observed during the test. Confirmation of low opacities
during test periods when the facility has been shown to be in compliance with
the emission standards provides a reliable reference point for comparison
of later opacity readings. Even though the facility may not be exceeding
the legal opacity limit, any detectable increase in opacity levels over a
period of time may indicate excessive emissions and signify the need for
a followup plant inspection and/or retesting.
A collection of papers, and other information describing the role
and function of the agency observer and procedures for documenting compliance
test conditions are included in this reference manual. While the material
does not attempt to address all of the administrative and technical
aspects of planning, conducting and evaluating a source test, practical
information is provided on techniques to be used by the field inspector
in observing compliance tests as well as extensive checklists for
recording data.
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TABLE OF CONTENTS
Page
1.	"The Role of the Agency Observer", paper adapted by
J. Jahnke from paper of same title by W. DeWees,
PEDCo Environmental, Inc.
2.	Appendix B-F, checklists for on-site observation of
compliance tests, revised by L. Pilcher, U.S. Army
Environmental Hygiene Agency
14
3.	"The Role of the Regulatory Agency Observer in a Source
Emission Test", paper by J. Feldman, presented at 1977
Air Pollution Association Meeting, Toronto, Ontario
4.	"Observer's Report", paper by W. DeWees, PEDCo Environ-
mental, Inc.	57
5.	Block diagram of test measurements and equations used
in deriving stack concentration estimates	73
6.	Simplified chart outlining test activities involved
in conducting an emission test, prepared by J. Jahnke,	75
Northrup Services
7.	Detailed flow diagram for planning and performing a
stack test, prepared by J. Jahnke, Northrup Services	77
8.	Source sampling calculation sheet, revised by W. DeWees,
PEDCo Environmental, Inc., based on calculation sheet	al
prepared by USEPA, Region VI, Dallas Office
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THE ROLE OF THE AGENCY OBSERVER*
Introduction
Air pollution control agency personnel who may not be directly in-
volved in the compliance sourse sampling process are often called upon
to evaluate source tests performed by environmental consultants or
companies. Since emission testing requires industry at their own ex-
pense to contact highly skilled source test teams, the source test ob-
server should be well prepared to insure that proper procedures are
followed and that representative data is obtained.
The main purpose for the Agency's observation of the compliance
test is to determine that the test data is representative. There are
other valid reasons to observe the test such as establishing baseline
conditions for future inspections, but the major emphasis is in the
evaluation of the acceptability of the initial compliance test.
The seven steps an agency generally uses for establishing the com-
pliance of a source with the Agency's regulatory requiremetrs are as
follows:
1.	Familiarization - The agency establishes contact with the
source and becomes familiar with operations, emissions and
applicable regulations.
2.	Schedule source test - This may be part of a compliance
schedule or Federal Standard of Performance for Stationary
Source Enforcement (NSPS).
3.	Establish methodology - Testing requirements should be
established and a testing plan developed by the agency
~Adapted by Jim Jahnke from: Supplemental Training for Tech-
nical Workshop on Evaluating Performance Tests" DSSE, EPA
by W. G. DeVfees. PEDCo - Environmental Specialists Inc.
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4.	Final Plan and test procedure development - A presurvey should be
conducted by a member of the testing team. A pretest meeting
between the agency, source representative and test team representa-
tive should be held to develop the final test plan.
5.	Actual compliance tests - observation of the facility operations
and testing methodology by the observers.
6.	Review of test data - determination of compliance and official
notification.
7.	Continuing enforcement of compliance - follow-up inspections
using data generated from source tests as baseline for comparison
purposes.
In order for data to be representative, there are five areas where
problems might develop in obtaining a sample representative of the source
emissions. If a question arises as to the Integrity of any one of these
areas, the compliance test may be considered non-representative. These
five areas are:
1. The process and control equipment must be operated in such a
manner as to produce representative atmospheric emissions.
2. The sample port and point locations must be repre-
sentatlve of the atmospheric emissions.	
3. The sample collected in the sample train
must be representative of the sample points
4. The sample recovered and analyzed
must be representative of the
sample collected in the sample
train. 	
5. The reported sample results
must be representative of
the recovered and analyzed
sample.	
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The source test to be monitored by the observer, then, is developed
and conducted by the source test team and observer in four major phases.
These phases are (1) preparation and planning, (2) conducting the test,
(3) recovery, transportating and analysis of sample (4) submitting report.
These phases are discussed below:
Preparation and Planning - In the initial phase of preparation and planning,
the agency must clarify for the source test team leader and process repre-
sentative all procedures and methods to be used during the entire testing
program.
The review of the compliance test protocol submitted by the plant
management or test consultant will explain the intended sampling plan
to the observer. Two of the more important items to be checked are any
deviations from standard sampling procedures and the proposed operation
of the facility during the compliance test.
Many types of process, sampling locations and pollutants may require
some modification to the standard sampling procedure. The agency must
determine if the modification will give equivalent and/or greater
measurement results than would be obtained with the standard method.
The other major determination to be made from the test protocol is
defining what constitutes normal operation of the facility. Example
checklists for power plants and electrostatic precipitators are presented
here:
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The plant representative should understand and agree to all facility
baseline conditions prior to the compliance testing, since the determination
of representative operation of the facility 1s for the protection of both
the Agency and the plant. The plant representative may suggest additonal
factors which should be considered as an upset condition and which would
not produce representative emissions.
The observer must be familiar with the process to be sampled. Whenever
possible, the Agency field inspector should be the "observer" for the pro-
cess and control equipment. If the process 1s large or complicated, the
observer may be aided by a process control engineer from the Agency. An
emission test run at the wrong process rating or without sufficient process
data will not constitute a valid test. Familiarity with the specific
process can be acquired through one or more of the many inspection manuals
prepared by the Environmental Protection Agency for this purpose. These
manuals will indicate the methods and devices employed 1n monitoring pro-
cess rates and/or weights.
The Source Test - Some compliance tests may be routine enough that a pre-
test meeting on the morning before sampling begins will be sufficient to
provide a complete understanding between all parties involved.
The review of the team leader's test protocol should have initiated
the formulation of the observer's sampling audit plan. The observer's
audit plan should contain the tentative testing schedule, facility base-
line conditions preparation or modification of observer's checklist, and
details for handling irregular situations that could occur during emission
testing.
The sample testing schedule should allow the observer to plan his
duties 1n a logical order and should Increase his efficiency 1n obtaining
all of the required data.
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The observer's teating forms normally should need little modification.
Any accepted modification to the normal sampling procedure should be
covered by additional checks from the observer.
The observer should be prepared to handle any non-routine situations
which could arise during sampling procedures. A list of potential problems
and their solutions should be made prior to the actual testing. The list
should also include the unacceptable limits for when the minimum
sampling requirements and process rating are not mett for instance, if
the sampling box is unable to maintain the filter at minimum temperature
or if a power plant was unable to maintain full load conditions because
of poor coal. The observer should also know who in his organization is
authorized to make decisions which are beyond his capability or authority.
The number of Agency personnel observing the performance test must
be adequate to ensure that the facility operation (process and control
equipment) is monitored and recorded in such a manner as to provide a
basis for the present and future evaluations. The observing team should
be able to obtain visible emission readings and transmissometer data for
comparison with measured emission rates and should be able to ensure that
the prescribed Agency testing methodology was followed.
The plant representative should be available during testing to answer
any questions which could arise about the process or to make needed
process changes. It should be understood that, if any problems arise, all
three parties would be consulted. Since the observer may approve or
disapprove the test, his intentions should be stated at the pretest meeting.
An ideal emission test would be one where representative data was gathered
and where no clarification of sampling procedure was required from the
sotirrp test leadar.
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Before actually proceeding with the test, the observor should
check the calibration forms for the specific equipment to be used.
These as a minimum should include calibration of the following:
1)	Pi tot tube
2)	Nomograph (if used)
3)	Dry Gas Meter
4)	Orifice Meter
If there is any question as to whether proper calibration procedures
were followed, the problem should be resolved before initiating the
test.
During the test, the outward behavior of the observer is of utmost
importance. He should perform his duties quietly, and thoroughly, and
with as little interference and conversation with the source test team
as possible. He should deal solely with the test supervisor and plant
representative or have a clear understanding with them should it become
necessary to communicate with the source test technicians or plant
operators. Conversely, he should exercise caution in answering queries
from the source test team technicians and plant operators directly and
refer such inquiries to their supervisor. He should, however, insure
that sampling guidelines are adhered to and inform the test team if
errors are being made.
Several checks must be made by the observer to ensure adherance
to the proper sampling procedures. To eliminate the possibility of
overlooking a necessary check, an observer's checklist should be used
for the sampling procedures and facility operation. An example of one
of these checklists is included below.
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To understand the relative importance of the measurement of parameters
of emisssion testing, the observer should know the significance of errors.
A discussion of errors is given in the Second part of this chapter.
Generally, it is best to have two agency observers at the source test.
If only one observer is present, however, the schedule given below should
be followed.
For the first Method 5 run, the observer should go to the sampling
site, after the facility is operating in the correct manner, to observe
the sample train configuration and the recording of the initial data.
The observer should oversee both the initial leak check and the final
leak check. When the observer is satisfied with the sample train pre-
paration, the test should be started. The observer should then observe
the sampling at the first port and the change over to the second port.
If he is satisfied with the tester's performance, then he should go
to a suitable point from the stack and read visible emissions for a six
minute period.
The facility operations should then be checked. This includes data
from fuel flow meters, operating monitors, fuel composition, F factors,
etc. Data from continuous emissions monitoring equipment such as
opacity monitors and SO2 analyzers should also be checked. This data
will be useful in evaluating the method 5 data. If the process and
control equipment have operated satisfactorily and the data recorded as
specified, the observer should make another visible emission reading
over a six minute period. The observer should then return to the
sample site to observe the completion of the test. The final readings
and the leak check after the completion of the test are two of the more
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improtant items to be checked. The transport of the sample train to the
cleanup area and the sample recovery should then be observed.
If the observer is satisfied with all sampling procedures observed
during the first run, then the time of the second run will be spent
observing the process monitors with the exception of checking the sampling
team at the end of the sampling period. During the second run, two six
minute visible emission readings should be made with a check of the
facility operations between readings. The observer should be satisfied
that the facility data recorded are truly representative of the faci-
lity operations.
A visual observation of the particulate buildup on the filter and
in the acetone rinse from the first two tests should be correlated to
the visible emission readings or transmissometer data. This comparison
of particulate collected will only be valid if the sample volumes were
approximately the same. If the particulate catch on the fiter and in
the acetone rinse for the second test was consistent or greater than
the visible opacity correlated to the first run then the observer might
spend more time overseeing the facility operations. If the second run
when correlated to the opacity 1s less than the first test, more time
might be placed on observing the emission test procedures for the third
run.
Irregardless on the main emphasis of the third run, the observer
should still perform certain observations. The observer should again
check all facility operations prior to testing. Two six minute visible
emission readings should be made with a check of the facility operation
in between. The sample recovery of all tests should be witnessed and
the apparent particulate catch conipared to the opacity readings. The
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additional time can be spent by the observer checking the suspected
weak points or problem areas.
Sample Recovery and Analysis - The observer should be present during
sample recovery. It is imperative that the sample recovery and analysis
be done under standard procedures and that each step be well documented.
The report may ultimately be subject to the requirements of the Rules of
Evidence. Therefore, the observer should have a sample recovery check-
list to ensure all tasks have been performed properly.
To reduce the possibility of invalidating the results, all of the
sample must be carefully removed from the sampling train and placed in
sealed, nonreactive, numbered containers. It is recommended that the
sample should then be delivered to the laboratory for analysis on the
same day that the sample is taken. If this is impractical, all the
samples should be placed in a carrying case (preferably locked) in
which they are protected from breakage, contamination, loss, or deteriora-
tion.
The samples should be properly marked to assure positive identifi-
cation throughout the test and analysis procedures. The Rules of
Evidence require impeccable identification of samples, analysis of which
may be the basis of future evidence. An admission by a lab analyst that
he could not be positive whether he analyzed sample No. 6 or sample No. 9,
for example, could destroy the validity of an entire report.
Positive identification also must be provided for the filters used
in any specific test. All identifying marks should be made before
taring. Three or more digits should suffice to ensure the uniqueness of
a filter for many years. The ink used for marking must be indelible and
unaffected by the gases and temperatures to which it will be subjected.
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If any other method of identification is desired, it should be kept in
mind that the means of identification must be positive and must not impair
the function of the filter.
Finally, each container should have a unique identification to
preclude the possibility of interchange. The number of a container should
be recorded on the analysis data sheet associated with the sample through-
out the test and analysis.
Samples should be handled only by persons associated in some way with
the task of analysis. A good general rule to follow is "the fewer hands
the better", even though a properly sealed sample may pass through a
number of hands without affecting its integrity.
It is generally impractical for the analyst to perform the field
test. The Rules of Evidence, however, require that a party be able to
prove the chain of custody of the sample. For this reason, each person
must have documented from whom he received the sample and to whom he
delivered it. This requirement is best satisfied by having each reci-
pient sign a standard chain of custody sheet that was initiated during
the sample recovery.
To preclude any omissions of proper procedures after the sample re-
covery, the observer should have a sample transport and analytical
checklist.
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Potential sources of error in the analysis lie in the contamination
of the sample, analyzinq equipment, procedures, and documentation of
results. Since the analysis is often performed at a lab, distant from
the plant site, the observer is often not present at the sample analysis.
If there is any question in the observer's mind about the analyst's
ability to adhere to good analytical practices in analyzing and in
reporting data, the observer has two recourses. The observer may be
present during analysis or he may require the analysis to be done by a
certified laboratory if one is available. However, this is an unneces-
sary burden and should not be done as a general rule.
During the analysis, any remaining portions of the sample should
remain intact and placed in a safe place until the acceptance of the
final report., Laboratory equipment, especially the analytical balance,
should have been calibrated immediately before the sample weighing.
The laboratory data and calculations must be well documented and kept in
such a manner that the Agency can inspect the recording of any analysis
upon request.
As noted in the lectures of this course, the observor should be
aware of analytical tricks that can be used to bring a marginal test to
within + 10% of 100% isokinetic. Care should be taken that the value for
the nozzle diameter or Cp does not change. Also, the weight of the im-
pinger catch and silica gel for the determination of B.._ should not be
changed to accomodate a % isokinetic value. It has been suggested that
to ensure an unbiased test, the observer could supply the source tester
with his own pre-weighed filter and pre-weighed amount of silica gel.
This may be extreme, but may be necessary in special cases.
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The Final Report - Upon completion of the compliance field test work, the
observer can begin the final task of determining the adequacy of the com-
pliance test data. The observer will be required to write an observer's
report for attachment with the source tester's report. The facility
operation, data and the field checklists should provide the observer with
sufficient information to determine the representativeness of the process
and control equipment operation and the sple collection. All minimum
conditions should have been met. If the observer suspects a bias 1n the
results this bias should be noted. A resulting bias that can only produce
emission results higher than the true emissions would not invalidate the
results if the plant was determined to be In compliance. Therefore, any
bias that may occur should be listed along with the suspected direction
of the bias.
The test team supervisor is responsible for the compilation of the
test report and is usually under the supervision of a senior engineer who
reviews the report for content and technical accuracy. Uniformity of
data reporting will enable the agency to review the reports In less time
and with greater efficiency. For this reason, a report format should be
given to the test team supervisor along with the other Agency guidelines.
The first review of the test report should be made by the observer.
The observer should check all calculations and written material for
validity. One of the greatest problems In compliance testing is in the
calculation errors made in the final report. Several agencies have gone
to the extreme of having the observer recalculate the results from the
raw data in order to more easily find any error. Errors should be noted
4.. Ky the observer. Although the conclusions in the
along with comments by the oDserver.
- nM- thP final authority, they should carry the
observer's report are not the tinai

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greatest amount of weight in the final decision concerning the repre
sentativeness of the test.
Due to the importance of the observer's report and the likelihood
that it will be used as evidence in court, the observer should use a
standard report format that will cover all areas of representativeness
in a logical manner. An example of an observer's report format is
presented here:
In addition to the determination of representative data for the com-
pliance test, the observer should report all conditions under which the
facility must operate in the future to maintain their conditional com-
pliance status. These conditions will be reported to the facility as
conditions of their acceptance.
These reports and the conditions of the compliance acceptance will
provide any Agency inspector sufficient data to conduct all future
facility inspection trips.
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APPENDIX B
EQUIPMENT NEEDED BY OBSERVER
1.	Tape Measure
2.	Dtal type caliper micrometer (accurate to 0.001")
3.	Nomograph
4.	Calibrated thermometer or thermocouple
5.	Rubber tubing (to connect to P1tot tube for leak check)
6.	Rubber tubing and stopper (to leak check metering system)
7.	Rubber tubing clamps (to clamp off H line for meter system leak check)
8.	Stopwatch
9.	Personal Protective Equipment
a.	Hardhat
b.	Safety Shoes
c.	Safety glasses
d.	Respiratory Protection
10.	Calculator
11.	Tools
a.	Phillips head screwdriver
b.	Flat-head screwdriver
c.	Pliers
d.	Wrench
12.	Literature
a.	USAEHA Guidelines for Observing and Evaluating Source Tests
b.	Applicable Emission Standards
c.	Applicable Sampling Procedures
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d.	Contractor's Test Protocol
e.	Equipment Specifications
f.	Nomographs (Entropy Env.}

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APPENDIX C
CHECKLIST FOR OPERATION OF PROCESS AND CONTROL EQUIPMENT
Location
Date
Observer's Name
Run No. _
A. Boilers, Steam Plants, Indirect Heat Exchangers.
1.	Equipment.
a.	Designation of facility (Bldg No., Boiler No.) __
b.	Designation of unit tested	__
c.	Rated capacity	_
d.	Capacity being tested
e.	Type of stoker	__
f.	Type combustion control	__
g.	Type of soot blowing (continuous, period)	__
h.	Unit operating controls (steam gauge, O2 CO2) _
1. Date of last calibration of operating controls
j. Type of air pollution control equipment	_
2.	Fuel.
a.	Type of fuel	__
b.	Method of measuring fuel Input	__
c.	Amount of fuel used during test	_
d.	Method of obtaining a fuel sample
e.	Date last calibration of fuel gauges
f.	Heat value of fuel (BTU/lb)
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g.	Ash content of fuel (X)		
h.	Sulfur content of fuel (X)		
3.	Operation
a.	Rate fuel burned		
b.	Heat input to boiler		
c.	Steam produced (obtain copy of steam charts)	__	
d.	Combustion recorders (obtain copies
where applicable)		
(1)	02 (*)
(2)	C02 (X)		
(3)	Opacity (X)		
(4)	Other		
e.	Soot blowing (time and duration)		
f.	Method used to determine heat input to
boilers (F-factor, steam flow, meter fuel input)		
Not
4.	Checklist	Yes	No	Required
a.	Was the operating rate 1n conformance
with that specified by the regulatory agency? 	 	 	
b.	Were the operating conditions
representative of the normal operating
conditions?
c.	Were fuel samples taken correctly?
d.	Were there any malfunctions, load
fluctuations or other conditions that would
increase emissions?
e.	Were opacity readings satisfactory
during the test?
f.	Have metering devices, I.e., fuel
input, steam flow been calibrated recently?
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Not
I No	Required
g. Was soot blowing conducted during
the test?		 		 	
h. Was the soot blowing during the
sampling conducted 1n accordance with the
regulatory agency's requirements?					 	
5. Comments, unusual operating conditions, and special	observations.
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Location
Date
Observer's Name
Run No.
B. Incinerators
1.	Equipment.
a.	Type of incinerator
b.	Capicity
c.	Auxiliary fuel type
d.	Control meters
e.	Type of air pollution control equipment
f.	Charging method (manual of automatic)
2.	Operation.
a.	Charging rate during testing
b.	Type of waste changed
c.	Temperature in primary chamber (range, avg)
d.	Temperature 1n secondary chamber (range, avg.)
e.	Amount of time primary burner on during test
f.	Amount of time secondary burner on during test
g.	Amount of auxiliary "fuel metered
3.	Checklist	Yes
a.	Was the operation of the incinerator
representative of normal operation?		
b.	Was the waste charged representative
of the waste normally changed?		
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Not
Yes	No Required
c. Was the Incinerator changed fit the
rate required by the regulatory tfificy?		 	
d. Was the auxiliary fuel metered or the
burners timed to determine the contribution of
COfc from the auxiliary fuel?
e. Were opacity readings satisfactory
during the test?
4. Comments, unusual operating conditions, and special observations.
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Location 	
Date 		
Observer's Name 	
Run No. 	
C. Process Equipment
1.	Equipment.
a.	Type of process		
b.	Raw materials		
c.	Product		
d.	Capacity of unit		
e.	A1r pollution control equipment		
2.	Operation.
a.	Production rate during test		
b.	Raw material Input during test		
Not
3.	Checklist	Yes	No Required
a.	Was the unit operated in a
representative manner?		 	 	
b.	Was the rate of operation 1n conformance
with the regulatory agency's requirements?		 	 	
c.	Was opacity readings satisfactory
during the test?		 	 	
d.	Were there any upset conditions during
the test that may invalidate the results?		 	 	
4.	Comments, unusual operating conditions, and special observations (e.g.
cyclical operation, batch process, continuous process).
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Location
Date
Observer's Name
Run No.
D. Electrostatic Precipitators
1.	Equipment Design Parameters
a.	Gas Volume (acfm)
b.	Gas Velocity (fps)
c.	Gas Temperature < F)
d.	Voltage (kW)
e.	Current (milHampere)
f.	Sparking rate (sparks/minute)
g.	Design Efficiency
h.	No. electrical fields in direction of flow
1. No. rappers In direction of flow
j. Method of cleaning plates
k. Rapping sequence
1. Hopper ash removal sequence
2.	Operation during test
a.	Gas volume (acfm)
b.	Gas Velocity (fps)
c.	Gas temperature (#F)
d.	Voltage (kW)
e.	Current (mllliamperes)
f.	Sparking rate (sparks/minute)
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g.	Electrical fields 1 h direction of flow		
h.	No. of rappers in direction of flow		
1. Rapping sequence		
j. Hopper ash removal sequence		
k. Temperature of flue gas to ESP		
Not
3.	Yes	No Required
a.	Was the ESP operation representative of
normal operation?		 	 	
b.	Were there any malfunctions that would
bias results high?		 	 	
4.	Comments, unusual operating conditions, and	special observations.
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Location
Date
Observer's Name
Run No.
E. Fabric Filters
1.	Equipment Design Parameters.
a.	Pressure drop across collection Just
before bag cleaning
b.	Pressure drop across collector just
after bag cleaning
c.	Gas volume to bag house (acfm)
d.	Type of cleaning
e.	Cleaning cycle
f.	Particulate removal sequence
g.	Last time filters Mere changed
h.	Design efficiency
1. Type of filter (material I size)
2.	Operation during test
a.	Pressure drop across filter just
before bag cleaning
b.	Pressure drop across filter just after
bag cleaning
c.	Gas volume to bag house (acfm)
d.	Cleaning cycle
e.	Particulate removal sequence
f.	Temperature of flue gas to bag house
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Not
3.	Checklist	Yes	No Required
a.	Was operation of filter representative
of normal operation?		 	 	
b.	Did filters malfunction during test? 	 	 	
4.	Comments, unusual operating conditions, and special observations.
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Location		
Date 		
Observer's Name	
Run No. 	
F. Wet Scrubbers
1.	Equipment Design Parameters
a.	Type of scrubber			
b.	Desgln efficiency		
c.	Pressure drop across scrubber (1n H2O)			
d.	Nozzle pressure (pounds/sq 1n)		
e.	Gas flow out of scrubber (acfm)		.
f.	Liquid flow rate to scrubber (gal/m1n)			
g.	Recirculation rate		
h.	Gas temperature of scrubber		
2.	Operation during test
a.	Pressure drop across scrubber (1n. H2O)			
b.	Nozzle pressure (pounds/sq. 1n.)			
c.	Gas flow out of scrubber (acfm)			
d.	Liquid flow rate to scrubber (gal/m1n)			
e.	Recirculation rate		_
f.	Gas temperature of flue gas to scrubber			
Not
3.	Checklist ^	^ Required
a.	Was the operation of the scrubber
representative of normal operation? 			 	
b.	Did scrubber malfunction during test?
26

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4. Comments, unusual operating conditions and special observations.
27

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Date 		
Observer's Name 		
Run No. 	
G. Mul ti eye lories (cyclones)
1.	Equipment Design Parameter
a.	Design efficiency		
b.	Pressure drop across collector (in. H2O)		
c.	Gas volume (acfm)		
d.	Gas temperature (F)
e.	No. dampers to sectionalize collection		
f.	Hopper ash removal sequence		
g.	Type of cyclone		
2.	Operation during test
a.	Pressure drop across collection (in. H2O)		
b.	Gas volume (acfm)		
c.	Gas temperature		
d.	No. of dampers closed during test
e.	Hopper ash removal sequence		
Not
3.	Checklist Yes	No Required
a.	Was the operation of the multicyclone
(cyclone) representative of normal
operation?		 	
b.	Were there any malfunctions or unusual
conditions that would bias results high?		
4.	Comments, unusual operating conditions and special observations.
28

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APPENDIX D
CHECKLIST FOR
SAMPLING LOCATIONS, PORTS AND POINTS
Location 	
Date	
Observer's Name	
Run No. 	
A.	Measurement and Calcualtions-
1.	Draw diagram of sampling location on back of this page.
2.	Stack cross section dimensions (measured).		
3.	Equivalent diameters (if stack is not round).		
4.	Number of sampling ports.		
5.	Location of ports.		
a.	Distance upstream of a disturbance.		
b.	Number of duct diameters upstream of a disturbance 	
c.	Distance downstream of a disturbance.		
d.	Number of duct diameters downstream of a downstream.	
5.	Number of sampling points required.		
6.	Number of sampling points per port.		__
Not
B.	Checklist	Yes	No Required
1.	Are the sampling ports properly located? 	 	 	
2.	Is the tester sampling at a sufficient
number of points?		 	 	
3.	Is the sampling port flush with the inside
of the stack?		
29

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4.	Has the breeching on stack been checked
to determine if it needs cleaning?
5.	If necessary, was the duct walls and
bottom cleaned?
6.	Is the duct diameter at least 12 inches
or the cross sectional area at least
113 square inches?
7.	Is cyclonic flow suspected?
8.	Was verification or absence of cyclonic
flow determined?
9.	For stacks 12-24 inches in diameter, is
the first sample point at least 0.5 inches (i
the nozzle diameter) from the stack wall?
10.	For stacks greater than 24 inches in
diameter is the first sample point at least
one inch from the stack wall?
11.	Are the sampling ports located at
least 2 stack diameters downstream and at
least 1/2 stack diameter upstream from a
flow disturbance?
12.	Do the sampling port locations and
number of sampling points meet the criterion
of the air pollution control regulatory
agency?
13.	Are there any special circumstances with
the stacks e.g., tapered, small,
eccentric-shaped stack?
14.	Mere any modifications made to the
criterion for sample point location?
15.	Were modifications to the location of
sampling ports approved by the regulatory
agency?
30

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APPENDIX E
CHECKLIST FOR OBSERVING SAMPLING PROCEDURES
Location
Date
Observer's Name
Run No.
A. Background Information
1.	Sampling Method
a.	Sampling method used
b.	Sampling Method required by state standard
2.	Equipment and Calibration.
a.	Draw schematic of sampling train on back of this page
b.	Condition of equipment
c.	Obtain copy of all calibration data
d.	Cp value for Pi tot tube
e.	AH@ of meter box
f.	Lining of probe
g.	Length of probe
h.	Nozzle diameter (as measured with micrometer)
3.	Pretest checks.
a.	Barometric Pressure (How determined?)
b.	Leak test rate (CFM @ 15 in. Hg)
c.	Nomograph set up
(1)	Estimated meter temperature (F)
(2)	Estimated value of Ps/Pm
31

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(3)	Estimated moisture content (X).
(4)	C-Factor
(6) Estimated stack temperature (F)
(6) Desired nozzle diameter
4.	Sampling
a.	Average time to reach isokinetic sampling rate
at each point
b.	How vms Orsat analysis performed (from Integrated
bag or stack)?
c.	Length of time each point sampled?
d.	If data sheets cannot be copied record the
following data:
(1)	Approximate stack temperature (F)
(2)	Nozzle diameter (Inch)
(3)	Volume metered (acfm)
(4)	Range of aP reading (1n. H0)
(5)	Average AP reading (1n. H2O)
(6)	Average dry gas meter temperature (F)
5.	Post-test checks
a.	Leak test rate
b.	Orsat data from check against ambient air
32

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B. Checklist
Not
1.	Sampling Method	Yes	No Required
a.	Is the sampling method used the same
as required by the regulatory agency?		 	 	
b.	Did the regulatory agency approve any
alternate sampling procedures?		 	 	
2.	Equipment and Calibration
a.	Does the equipment meet the design
criteria of the sampling procedure as
required by the regulatory control agency? 			
b.	Has the P1tot tube been properly
calibrated?		 	
c. Does P1tot tube meet geometry standards
of EPA Method 5?
d. Is the probe lining appropriate for the
type of source and temperature of the
gas stream (see Method 5, para 2.1.2 40CFR60
as amended by 42 FR 41777)?
3. Pretest Check
a. Meter box level
b. Pitot tube Manometer (or magnahelic
guage) zeroed
c. Orifice manometer zeroed
d.	Probe markings correct
e.	Probe warmed-up along entire length
f.	Filter compartment preheated to proper
temperature (normally 248F + 25F)
g.	Thermometer 1n filter compartment
to determine temperature
h.	Implngers Iced down
i. Filter holder clean before test
33

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j.	Filter holder assembled correctly
k.	Filter clearly Identified
1.	Probe liner clean before test
m.	Nozzle clean
n.	Nozzle tip undamaged
o.	Implngers clean before test
p. Implngers 1n correct order and
correctly charged
q. P1tot lines leak checked
r. Does the P1tot line leak check?
s. Was the metering system leak checked?
t. Does C-Factor on nomograph equal
0.95 when AH@ - 1.80, Tm - 100F, %H20 - 10 %,
and Ps/Pm  1.00?
u. Does &P Reference on the nomograph
equal about 0.118 when 00.95, Ts  200F,
and Dn  0.375
v. Align aP - 1.0 with aH - 10 on the
nomograph. Does aP  0.01 align with
AH - 0.1?
w. Does stack thermometer check against
ambient temperature?
x. Was the gas sampling equipment
leak checked?
y. Was the gas sampling bag leak checked?
z. Was the gas sampling probe and liner
thoroughly purged with stack gas before
sampling?
34

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aa. Was the filter checked v1 sillily
against light for 1rregulaMt+tlr pinholes?
bb. Was the filter properly (and uniquely)
labeled?
cc. Was filter weighed to constant weight?
4. Sampling
a.	Was sampling begun Immediately
after probe was put 1n stack?
b.	if not, was the nozzle sealed
when the probe was 1n stack and
pump turned off?
c.	Did the nozzle scrape the stack
wall or the Inside of the port
opening?
d.	Is an effective seal made around
the probe at the port opening
(especially important if stack has
negative static pressure)?
e.	Is probe seal made without
disturbing flow inside stack?
f.	Is the probe moved to each point
at the proper time?
g.	Are probe markings adequate to
properly locate each point?
h.	Are nozzle and P1tot tube kept
parailed to stack wall at each point?
1. Was nozzle changed during run?
j. Is the data recorded completely
and in a permanent manner?
k. Is nomograph setting changed when
stack temperature changes significantly
(i.e., 10 % change)?
35

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1. Are velocity pressures UP)
recorded accurately?
m. Was static pressure determined
correctly?
n. Was the gas sample determined
correctly for the type of source (e.g.,
Integrated sample for an Incinerator, see
40 CFR 60, Subpart C through AA)?
o. Was the gas sampling bag leak
checked according to Method 3 (40 CFR 60)?
p. Were filters or any other components
changed during the test (1f yes,
explain 1n comment section)?
q. Old the observer obtain a copy
of the raw data sheets?
r. If Integrated Method 3 sampling
Is performed, 1s the bag sample taken
simultaneously with and for the total length
of time as the particulate sample run?
s. Was the sampling tube and sampling
volume equal to or greater than the minimum
sampling time specified 1n the test procedures
or required by the regulatory agency?
t. Was sampling time at each point
at least 2 minutes?
5. Post-test checks
a.	Is a leak test performed at
completion of the run at the maximum
vacuum encountered?
b.	Was Orsat analyzer leak checked
after analysis?
c.	Was Orsat analyzer checked against
ambient air?
36

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Not
Yes	M filflld8d
d.	Were the P1tot lines leajc
checked (mandatory)?	*		 	 	
e.	Was there breakthrough of the
silica gel?		 	 	
C. Comments, observations, and special conditions.
37

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APPENDIX F
CHECKLIST FOR OBSERVING SAMPLE RECOVERY AND ANALYSIS
Location 	
Date _____________
Observer's Name	
Run No. 	
Not
1. Checklist	Yes	No Required
a. Is the probe triple brushed
and rinsed?		 	 	
b.	Is the stainless steel or other metal
probe Uner brushed and rinsed six times?
c.	Was brush brought out too
quickly and sample lost?
d.	Are there any visible particles
on the filter (should be none)?
e.	Are there any brush bristles in
the probe washings?
f.	Was the probe adequately cooled
before sample recovery?
g.	Were the ends of the probe
capped before transporting to the
cleanup site?
h.	Is all external particulate
matter wiped off the probe before
sample recovery?
i.	Is the grease removed from the
probe before the end 1s capped?
j. Is the grease removed from the
inlet and outlet of the filter holder and the
the Inlet and outlet capped?
k. Is the nozzle removed before
cleaning the probe liner?
39

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1. Is the sample recovery site In an
area free of wind?
m. Are the wash bottles clean?
n. Are the brushes clean?
q. Are the brushes rusty and
bristles loose?
p. Are the recovery jars clean?
q. Is the reagent grade acetone used?
r. Is the filter recovery and handling
adequate?
s. Is the probe handling adequate?
t. Are the implnger handled
satisfactorily?
u. Was there breakthrough on the
silica gel?
v, Are acetone blanks (and water
If needed) taken?
w. Is the probe lining clean (after
nozzle is removed and probe held up to a
light source)?
x. Is the filter holder clean?
y. Is front half of filter holder
cleaned and particulates put with probe
washings?
z. Are the 1mp1ngers clean?
aa. Is the nozzle clean?
bb. Are the recovery jars adequately
labeled?
cc. Are the recovery jars sealed
tightly?
40

-------
dd. Is the liquid level marked on
the jars?		
ee. Are the recovery jars packed
adequately for transporting?		
ff. Is the sample recovery procedure
adequate?		
gg. Is the sample recovery procedure
for condenslbles adequate?		
2.	Other data.
a.	Grade of acetone used
b.	Specification for residue on evaporation for
the acetone
c.	Specification on chemicals used for condenslble
analyses
3.	Comments and observations.
41

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THE ROLE OF THE REGULATORY AGENCY OBSERVER
IN A SOURCE EMISSION TEST
by
J. B. Feldman
(Formerly with U. S. Environmental Protection
Agency, Region I, JF Kennedy Federal Bldg.
Boston, Mass. 02203)
Paper presented at 70th Annual
Air Pollution Control Association Meeting,
Toronto, Ontario, June 1977
ABSTRACT
From the technical and legal standpoint, the emission test is
the ultimate determination of compliance. While the test may be
manpower and equipment intensive as well as expensive, the results
of a test are of great significance to both the regulatory agency
and the source. The results often determine the course of future
litigation between the agency, the source, and control manufacturer.
Considering the significance attached ,to the results, it is im-
portant that the test be performed in a valid representative manner.
This paper describes the technical and administrative responsi-
bilities of the agency observer in efforts to assure the adequacy
of an emission test. It covers the observer's involvement from
initial coordination work, through the pretest survey and conference,
on-site testing activities, and report review. The relationship
between the observer, the source, and the test consultant are
discussed. The various procedures including questionnaires, forms
and on-site calculations used to effectively track and validate
a test program are described.
43

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77-12.6
Introduction
Historically, the involvement of regulatory agency personnel
in compliance testing activities has varied from a brief review of the
emission test report to total responsibility and performance for the test
program. The degree of involvement depended upon the resources available
within the agency and the relative significance of the source being tested.
The recent emphasis in the achievement of Ambient Air Ouality Standards
through restrictive source emission limitations has resulted in expanded
regulatory Involvement 1n the hundreds of emission tests performed each
year for compliance determination purposes. The complex nature of the
various samplinq methods coupled with extremely low emission standards,
has put added responsibilities on agency personnel to assure each test
is an accurate representation of a source's actual emissions.
The objective of this paper is to describe the technical and
administrative functions of the regulatory agency observer in his efforts
to assure the adequacy of a compliance test. It will discuss the proce-
dures necessary for implementing and coordinating a successful test pro-
gram from the regulatory standpoint.
Significance of an Emission Test
From the legal and technical standpoint, the emission test is
the ultimate determination of compliance. While opacity observations and
continuous monitoring instrumentations are used to determine how adequately
a source Is operated and maintained, it Is the emission test that deter-
mines 1f the Inherent design of a facility and its associated control
equipment can meet the emission standard.
For the most part, an emission test is equipment and manpower
Intensive. Because only a small fraction of the total exhaust flow can
be actually sampled, and many variables can be encountered in flowing
gas streams, complex test methods and extreme care must be exercised in
obtaining representative samples. Satisfactory sampling sites are usual-
ly found 1n logistically difficult locations, often hundreds of feet up
1n the stack. While the expense and effort involved 1n performing an
emission test can be considerable, it 1s Important to keep 1n perspec-
tive the significance of obtaining a valid representative sample. The
results of the test will determine the future course of regulatory
action. They will serve as legal evidence to both the regulatory
agency and the source as a demonstration of the compliance status of the
facility. Significant monetary decisions concerning control equipment
expenditures are often based upon the results of the compliance test.
44

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77-12.6
In the case where control equipment guarantees are Involved, the results
may determine the future course of litigation between the source and Its
equipment vendor.
Considering the significance attached to the compliance test,
it 1s imperative 1t be performed 1n a satisfactory manner and the valid
representative data are obtained. The following sections will discuss
the various aspects Involved 1n coordinating and Implementing a success-
ful test program, with particular emphasis on the role of the requlatory
agency observer.
Initial Coordination
Generally, most source tests are performed at the specific
request of the regulatory agency or as a result of established adminis-
trative regulations. Once the requirement for testing has been estab-
lished, 1t 1s the obligation of the requlatory agency to Inform the
source what will be expected, considering the burden of actually per-
forming the sampling usually rests with the source and/or its test
consultant. It 1s at this point where the regulatory agency observer
should Initiate the conmunicatlon process, specifying to the source
the general test procedures and requesting Information In return con-
cerning the specific application of these methods. Exhibit 1 contains
a suggested Pretest Informational Questionnaire for Implementing this
communication process. While standardized test methods have been estab-
lished, the application of these methods and the defining representative
operating conditions Is often unique to each facility. The Questionnaire
references the test procedures and regulations used by the aqency, thus
giving the source a starting point from which It can determine Its appli-
cability and testing requirements. It requests specific responses from
the source concerning the operation of the process, how the qeneral test
methods will be applied, what sampling and process data will be collected,
along with chain of custody and quality assurance procedures.
Satisfying the Informational requirements of the Questionnaire
serves several Important purposes benefiting all the parties Involved 1n
the test program. The Information supplied as well as requested In the
document alerts the source to the general requirements of the aqency.
The response of the source will serve as the basic test protocol from
which further specific matters concerning the test program may be dis-
cussed. The regulatory observer should review the Information submitted
by the source, familiarize himself with the operation of the facility,
and check to see if the test plan submitted as a result of the Question-
naire satisfies all legal and technical requirements.
45

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77-12.6
Pretest Conference
Assuming all the parties Involved in the test proqram now have
a basic understanding of the test plan, the next step Involves finalizinq
the plan at the pretest conference. Here, the involved parties (aqency,
source, test consultant), can personally discuss the specifics of the "test
program, resolve any ambiguities or problems concerning test methodology,
and establish representative process operatlnq conditions for the test
period. At the meeting, each party should deslqnate a prime contact,
through which any problems or communication can be appropriately dir-
ected as the test program prooresses.
The meeting should be held at the source and should Include a
survey which will allow all parties to become familiar with the physical
set up and operation of the facility. Dependlnq upon the complexity of
the source and the test program, 1t should take place anywhere from
several days to several weeks prior to the scheduled test date. This
will allow adequate time for any modifications or Installation of sup-
port equipment which may be required to accomodate the sampling appara-
tus. The format of the meeting should include a survey of the facility
followed by a discussion covering the Information contained 1n the Pre-
test Questionnaire. Since the regulatory observer will be making the
ultimate decisions concerning the adequacy and acceptability of the
test plan, he should play a lead role 1n dlrectlnq the discussion.
While standardized methods have been established for compliance
tests, the application of these methods may vary from source to source.
Most regulations grant aqency Dersonnel some flexibility In approving minor
modification to the methods to accomodate special circumstances. In
approving such modifications by giving consideration to the practicality
of a situation, the regulatory observer must assure himself that the
validity of the test both from the technical and leqal standpoint will
not be sacrificed. The pretest conference provides the forum where these
situations as well as others can be discussed and resolved, 1n an effort
to assure an orderly successful test program. Above all, the meeting
should preclude any problems from arising due to a lack of comnun1cat1on
between the Involved parties.
On-site Testing Activities
The primary function of the regulatory observer at the test site
1s see the tests are performed properly and that the process 1s operated
in a representative manner In an effort to assure the results will be
46

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77-12.6
a valid assessment of the actual emission rate. From the aqency stand-
point, the observer has the responsibility to insure the legal and tech-
nical aspects of the test are sufficiently satisfied. This Involves
constant monitoring and evaluation of the test procedures and orocess
operating parameters.
Prior to actually initiating the sampllnq, It 1s recommended
all parties meet briefly to review the current status of the test pro-
gram and to discuss any unforeseen problems that might have arisen since
the pretest conference. It should be recognized by all Involved parties
that the intent of the observer 1s not to look over the shoulder and
criticize the work of the test personnel but to Indicate if there are
any problems in the procedures or process operatinq conditions which
might sacrifice the validity of the test results. If such a situation
occurs, the observer should promptly Inform the appropriate contact
person so the nature of the problem can be discussed and clarified
prior to continuation of the test program. In this respect, It 1s
Important to all parties that any problems be brouqht to liqht at
this point, to avoid any after-the-fact difficulties from arising,
considering the significance of the tests. Generally, where the
Involved parties have an understand1ng?the test plan along with
each other's responsibilities and objectives, most problems at the
test site can be promptly settled in a professional manner. The
value of the pretest conference becomes evident at this point, 1n
that most significant problems will have already been addressed and
clarified prior to Initiation of the actual sampling.
After each test run, 1t Is recommended all Involved parties
review the test and process data to assure 1t Is complete and no
obvious discrepancies exist. The observer will qenerally carry a
log book for recording significant events and some of the test and
process data for his own purposes. It 1s usually the responsibility
of the test personnel and source to obtain a complete log of all perti-
nent data for preparation of, and Inclusion Into, the report document.
The purpose of performing the on-site post test data review 1s
to determine if any additional tests or measurements will be required
prior to disassembling and packing up the test equipment. It will pre-
clude situations where several days after conclusion of the test, while
performing the data reduction calculations, the sampled volume 1s found
to be Inadequate or the sampHnq rate 1s non-1sok1net1c. This presents
an embarrassing situation to the test consultant, flndlnq that the
statutory requirements of the test method along with his obligation
to his client are not truly fulfilled. Furthermore, the aqency 1s out
Into an awkward position, having to decide whether to accept or reject
the test results because of questionable validity. While some minor
47

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77-12.6
Inconsistences in the method can be tolerated to an extent with tech-
nical justification, when the results of a test are marqinal in com-
parison to the standard, this becomes an uncomfortable situation for
all involved parties.
In order to preclude the above situation from occurrinq, the
on-site data review is recommended. In the case of particulate testing,
where an Isokinetic sampling rate must be satisfied, an abbreviated set
of calculations can be performed within minutes with a pocket calculator
to determine 1f the rate 1s in the general ballpark. Exhibit 2 is a
typical calculation sheet used for this purpose. The procedure involves
calculation of an average velocity head square route (V5P)ave, and measur-
ing the volume of condensed impinger water and the silica qel weight gain
on-site. Other parameters such as average temperatures, pressures, mole-
cular weights, which their relative accuracy is not extremely critical to
the Isokinetic calculation, are "eyeballed" from the field data sheet.
While the isokinetic value calculated is not truly exact, 1t is usually
accurate enough to flag any significant variations, where a more detailed
analysis can be performed. The use of this sheet In special test situa-
tions (high moisture, high stack pressure or vacuum, unique flue gas con-
stituents) 1s subject to caution.
Access by the observer to the above field data at the conclusion
of the tests for purposes of performing this isokinetic calculation should
be understood by the Involved parties. The few minutes It takes to per-
form the computations is of benefit to all parties. It precludes the
possibility of a complete retest of the facility at a future date due to
unrecognized sampling deficiencies at the site.
Review of the Emission Test Report
The emission test report should contain all pertinent data con-
cerning the test program. In addition to reoortinq the results, 1t should
include descriptions of the source, the sampling and analytical methodology
used, the process operating conditions, all field data and calculation
methods. It should be representative of a quality engineering or scien-
tific report, its contents presented in an understandable, orderly manner.
Since the report will serve as evidence to both the agency and the source
as a demonstration of the compliance status of the facility, It 1s Impor-
tant 1t be complete 1n content and adequate in quality. Exhibit 3 (Emis-
sion Test Reporting Requirements) contains a suqgested format and content
for a typical emission test report. It is recommended these requirements
be sent to the source with the Pretest Informational Questionnaire (Exhibit 1).
48

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77-12.6
This will provide the source with an overall understanding of all sub-
mittal requirements at the onset and should help assure the adequacy
of the test program.
The observer will usually review the test report to determine
if it is adequate in content and if the results, as reported, are valid.
This involves an overall review of the supporting data contained 1n the
report, along with his Independent observations taken at the test site.
As a check on the calculation procedures used to process the field and
analytical data, it 1s recommended the results be independently calcu-
lated directly from the field and laboratory data. In the event of a
discrepancy in results, the observer should perform a detailed analysis
of the input parameters and calculation methods used by both parties,
to determine where the problem lies. Upon completion of the review,
the observer should appropriately contact the source to Inform them
of his findings, and to discuss any discrepancies or Inadequacies which
might be present.
Summary and Conclusions
1.	The achievement of National Ambient A1r Ouallty Standards throuqh
restrictive source emission limitations has resulted In significant numbers
of source emission tests being performed for compliance determination pur-
poses.
2.	From the legal and technical standpoint, the emission test 1s
the ultimate determination of compliance, the result of which determines
the future course of regulatory action. The need to obtain accurate repre-
sentative emission measurements through the use of complex test methods
has resulted in Increased responsibilities on the part of the agency
observer to assure the tests are adequately performed.
3.	In order for a test program to be successful, a significant
amount of communication, coordination, and cooperation between the
Involved parties (agency, source, test consultant) Is required. The
agency observer should play a major role 1n brining these various needs
together, to assure all regulatory aspects will be satisfied.
4.	The Pretest Informational Questionnaire and the Pretest Confer-
ence provide vehicles through which the corrmunlcatlon and planning pro-
cesses of the test program can be effectively Implemented.
5.	On-site data review and quick check calculations should be per-
formed Immediately after each test, to assure statutory sampling criteria
have been satisfied.
49

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77-12.6
6.	In an effort to assure the adequacy of the emission test report,
the agency should establish minimum reDortinq requirements. The review
of the report should .include an independent evaluation, starting with
the field data.
Disclaimer
The content and recommendations included in this report are
those of the author. They may not necessarily reflect the views or
policies of the U.S. Environmental Protection Agency.
50

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77-12.6
Exhibit 1. Pretest Informational questionnaire
PRETEST INFORMATIONAL REQUIREMENTS
In order to establish uniform reoulrements and help ensure
proper test methods and procedures are utilized, the information
specified below must be submitted to (Indicate regulatory agency
office) at least 30 days prior to the scheduled test data. After
review of the information, a pretest conference will be scheduled by
the agency to discuss and finalize the test plan. In the event of any
major deficiencies or discrepancies in the test protocol, the company
and/or test consultant will be notified prior to the conference. Sub-
mittal of this Information will minimize the possibility of a test
rejection as a result of improper sampling or data collection proce-
dures.
Testing shall be performed In strict accordance with proce-
dures specified in the Code of Federal Regulations, Title 40, Part 60,
Apoendix A, Standards of Performance for New Stationary Sources, as
amended (or as stipulated by the control agency). A satisfactory test
shall consist of three repetitive runs. Any variations In the sampling
or analytical procedures must be indicated In the pretest Information
and receive approval from this office prior to testing.
1.	Identification and a brief description of the source
to be tested. The description should Include:
a)	type of Industrial process or combustion facility
b)	type and quantity of raw and finished materials
used In the process
c)	description of any cyclical or batch operations
which would tend to produce variable emissions
with time.
d)	basic operating parameters used to regulate the
process
e)	rated capacity of the process.
2.	A brief description of the air pollution control equipment
associated with the process Including:
a)	type of control device
b)	operating parameters
c)	rated capacity and efficiency
d)	ultimate disposal of wastes.
51

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77-12.6
3.	Type of pollutant to be sampled (particulate, N0X, S02,
hydrocarbon, etc.).
4.	A description of the emission samDlinq eguinment includ-
ing a schematic diaqram of the samplinq train.
5.	A description of the samplinq and analysis Drocedures.
Reference standard methods, if applicable. Indicate any
proposed variations with justification.
6.	A sketch with dimensions indicating the flow of exhaust
gases from the process, throuqh the control equipment and
associated ductwork to the stack.
7.	According to Method 1, 40 CFR 60:
a)	An elevation view with dimensions of the stack
configuration indicating the location of the
sampling ports and distances to the nearest
upstream and downstream flow interferences.
b)	A cross-sectional sketch of the stack at the
sampling location with dimensions indicating
the location of the samplinq traverse points.
8.	Estimated flue qas conditions at samplinq location, includ-
ing temperature, moisture content, and velocity pressure.
9.	A description of the orocess operating conditions or ranqes
during which the tests will be run, alonq with backqround
Information substantiating the conditions are representa-
tive of maximum normal operation.
10.	A description of the process and control equipment oceratinq
data to be collected during the sampling period.
11.	Copies of the field data sheet form to be used durinq the
tests.
12.	Names and titles of personnel who will be performing the
tests.
13.	A description of the procedures for maintaining the integrity
of the samples collected, including chain of custody and
quality control assurance.
52

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77-12.6
14.	Calibration sheets for the dry gas meter, orifice meter,
pitot tube, and any other equipment or analytical pro-
cedures which require calibration.
15.	A list of prewelqhed filters to be used during particulate
emission testing, Including Identification and tare weights.
(Requirements 14 and 15 must be submitted prior to actual
testing, but do not have to be Included with the pretest
Information.)
53

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77-12.6
Exhibit 2. Isokinetic On-Site Quick Check
Source:
Date:
Run No.
(each traverse point)
Total
No. Points
(>J \P)ve
"Eyeball" Average
"Eyeball" Average
"Eyeball" Average
Ts =	460 + F = R
Tm =	460 + F = OR
j\H =
VI =	ml. gain impingers *
=	wt. gain si 1ica gel =
Ms =	27 to 30 (Use 29 for most boilers)
An 	D^/183.35 =	nozzle diameter, inches
Pbar 29.9 Ps (usually) 9 = Sample time, minutes
Vm std = Vm (17.7n(pbar + ZW13-6)
Tra
Vw std = 0.0474 (VI)
	_ Vw std	
wo = Vw std + Vm std
Check Rwo calculated vs.
Bwo nomograph
Vs - 85.40 (Cp)/^ItrS')ave
Ts[ (0.00267 )V1 + 77^-] 1.667
d Vs Ps An :
90 < i 5 110 7
54

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77-12.6
Exhibit 3. Emission Test Reporting Requirements
The emission test report should contain all pertinent data con-
cerning the tests including a description of the process and operating
conditions under which the tests were made, the results of the tests,
and test procedures. While the exact format of the report will vary
depending upon the type and objective of the tests, Indicated below Is
a suggested format containing required Information.
1.	Introduction
a)	Identification, location, and dates of tests.
b)	Purpose of tests.
c)	Brief description of source.
d)	Name and affiliation of person 1n charge of tests.
2.	Summary of results
a)	Operating and emission data.
b)	Comparison with applicable emission regulations.
3.	Source description
a)	Description of process Including ooeratlon of emis-
sion control equipment.
b)	Flow sheet (If applicable).
c)	Type and quantity of raw and finished materials
processed durinq the tests.
d)	Maximum normal rated capacity of the process.
e)	Description of process instrumentation monitored
during the test.
4.	Sampling and analytical procedures
a) Description of sampling train and field procedures.
bl Description of recovery and analytical procedures.
c)	Sketch indicating sampling port locations relative
to process, control equipment, upstream and down-
stream flow disturbances.
d)	Sketch of cross-sectional view of stack Indicating
traverse point locations.
5.	Test results and discussion
a)	Detailed tabulation of results Including process,
operating conditions, flue gas conditions.
b)	Discussion of significance of results relative
to operating parameters and emission regulations.
c)	Discussion of any divergencies for normal sampling
procedures or operating conditions which could have
affected test results.
55

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OBSERVER'S REPORT*
The observer's report is usually written in two segments.
The first segment is written as soon as possible after the
observer returns from the field testing. This allows maximum
recollection of events for summarizing all notes, checklists,
logs and other data. The field testing evaluation portion of
the observer's report is written independently of the source
test report and will provide a separate accounting of the
tests. The observer's determination of representativeness of
data could not be influenced at this time by the measured
pollutant values.
The second segment of the observer1s report is written
upon the receipt of the emission test report which will
probably be 30 to 60 days later. This portion of the ob-
server's report deals with the review of the source test report
to determine its acceptability. The main emphasis of the
procedures to be presented will deal with the first segment of
the observer's report for writing the field evaluation summary.
The review of the source test report is covered in "Source
Testing Reports Suggested Format and Review Procedures", EPA
Contract 68-01-3172, Task 5.
*
Paper by W. DeWees included in Compliance testing observation
and evaluation workshop manual - Volume III, Administrative
Aspects of Performance Tests, prepared for Division of
Stationary Source Enforcement, U.S. Environmental Protection
Agency.
57

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The source test report documents all events and data
gathered by the emission testers, and the observer's report
documents the sequence of events as he perceived them. The
observer's report will accompany the source test report
through the entire agency's review procedure.
Since the observer may not be present during the final
determination of the acceptibility of the compliance test
and or may not perform the review of the compliance test
report, a diliqent effort must be put forth to provide an
accurate picture of representativeness of the field test
work. The observer should also be aware that a logged entry
of an event by one party usually takes legal precedence over
another party that witnessed the same event without an entry
into a log.
The observer's representativeness evaluation of field
testing will be based on the sampling procedures and facil-
ity operating conditions that were agreed upon through the
use of a test protocol and pretest meeting. The facility
operation conditions include the established baseline con-
ditions for the process and the air pollution control equip-
ment. The standard sampling procedures include calibration,
sample collection/ sample recovery, and sample analysis.
All operating conditions and standard procedures should be
58

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agreed upon prior to the compliance field testing. No
additional restrictions and or conditions should have to be
placed on the facility or emission testers after the field
testing begins.
Reporting Requirements
The observer's report should be written with the idea
that the report will be used as evidence in court and will
be presented to layman. Because the final legal decision on
compliance may be made by individuals with little or no
knowledge of emission testing, the observer's report must be
clear, concise, traceable to the proper point in time, and
present all documentation of materials, discussions, and
decisions used to form the basis for determining the re-
presentativeness of compliance test data. The observer's
summary and presentation of data must demonstrate the facil-
ity's and test team's performance or non-performance of all
established baseline conditions and procedures.
The inability of the facility or test team to meet all
the established conditions will not always invalidate the
test. Many conditions may either produce only a small
percentage error or will tend to always bias the resultB in
the same direction. If the facility was in violation then
biases which produce higher values would still be acceptable
59

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to the agency but would be brought up in court by the facil-
ity to invalidate the test.
Although the observer determines only representative-
ness of compliance test data, not compliance with control
regulations, the observer should be aware that the only
conditions for which the test would be acceptable to the
facility and agency are: (1) compliance or violation with no
biases, (2) compliance with known high bias, and (3) viola-
tion with known low bias(s). For this reason if biases are
known to the observer, he should explain the source of the
error and the magnitude and direction on the results if
known or determinable.
A standard observer's report format as shown in Figure
1 should be used to provide uniformity and efficiency in
report preparation and ease of use by other agency per-
sonnel. The observer's report format should be tailored to
the source test report which has been designated by the
agency for ease in comparison and review.
The data collection and reporting procedures will not
be the same for every agency. The agency should only re-
quire the testers and facility to collect data that will be
used by the agency. For any process and control equipment
data collection requirements the agency should be able to
justify in court that the data will be used for some pur-
poseful meaning within the agency.
60

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OBSERVER'S REPORT FORMAT
COVER
1.	Plant name and location (Federal AQCR)
2.	Source sampled
3.	Date sampled
4.	Testing firm
5.	Control agency
CERTIFICATION
1.	Certification by observer(s)
2.	Certification by author if not observer
3.	Certification by key agency personnel
INTRODUCTION
1.	Agency name
2.	Purpose for observer's report
3.	Purpose for test
4.	Plant name, location and process type
5.	Test dates
6.	Pollutants tested
7.	Applicable regulations
8.	Agency sections and personnel directly involved
SUMMARY OF REPRESENTATIVENESS OF DATA
1.	Compliance test protocol
2.	Calibration of sampling equipment
Figure 1. Observer's report format.
61

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3.	Process data
4.	Control equipment data
5.	Sampling procedures
6.	Sample recovery procedures
7.	Analytical procedures
8.	Compliance test report
FACILITY OPERATION
1.	Description of process and control device
2.	Baseline conditions
3.	Observer's facility data (checklists)
4.	Representativeness of process and control device
5.	Baseline conditions for agency inspector
SAMPLING	PROCEDURES
1.	Acceptability of sample port and point locations
2.	Compliance test protocol
3.	Calibration of sampling equipment
4.	Observer's sampling data (checklist)
5.	Representativeness of sampling
6.	Observer's sample recovery data (checklist)
7.	Representativeness of recovered sample
8.	Observer's analytical data
9.	Representativeness of sample
COMPLIANCE TEST REPORT
1.	Introduction
2.	Summary of results
3.	Facility operation
Figure 1. (cont.)
62

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4.	Sampling procedures
5.	Appendices
APPENDICES
A.
Copy of pertinent regulations
B.
Related correspondence
C.
Compliance test protocol
D.
Observer's checklists
E.
Observer's test log
F.
Other related material
Figure 1. (cont.)
63

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The following is a discussion of each reporting re-
quirement and guidelines to supplement the outline. (Figure
1)
Cover
The cover should indicate the name and location of the
plant tested, along with a description for the specific
source sampled. A date containing the month and year should
be included to discriminate this report from a previous test
or retest of the same process. The name and address of the
testing firm (or agency) who conducted the test should be
given. Finally the name and address of the responsible
agency.
Certification
The report should be certified by a minimum of two
individuals. The observer(s) should certify that the facil-
ity operations and sampling procedures were performed during
their direct observation and general guidance. The author
of the report, if not the observer, should certify that all
data and conclusions are authentic and accurate. The last
certification should be by a key person within the agency
certifying that he has reviewed the report and that the
conclusions are accurate and supporable.
Introduction
The introduction should explain to the reader the
purpose and content of the report. All parties involved
64

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should be identified along with their duties and respon-
sibility. The plant name, location and process type should
be given. The applicable regulations, important regulation
dates or descisions, sampling and analyticol procedures, and
facility operating procedures should be given to provide the
basis for the report.
A detailed explanation of all procedures and guidelines
is not warranted but should be referenced. If presented in
court the introduction would include sufficient information
to provide understanding of the purpose for the compliance
test and agency's review.
Summary of Representativeness of Data
Since the purpose of the report is to determine the
representativeness of the observed compliance test the
report should not make a direct statement with regard to
compliance with the performance regulations. The observer
may indirectly make a compliance judgement by presenting the
degree of realiability of the compliance test but this
statement will be directed toward the acceptability of the
compliance test and report.
A summary of representativeness of the facility opera-
tions, sampling and analytical procedures, and the evalua-
tion of the source test report should be presented. The
facility operations include the determination of whether the
65

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process operating conditions were within the limits set by
the agency and the control equipment was operated in a
normal manner. The sampling and analytical procedures
should include any deviation from the written and agreed
upon procedures. The evaluation of the source test report
should include any inaccuracies or deficiencies of com-
pliance test data presentation.
All deviations from the set procedures and conditions
should be initialed into the summary. The expected mag-
nitude and direction of the bias for each deviation should
be given if known or determinable. As previously mentioned
the compliance test may contain a known bias and still be
acceptable to the agency and facility.
All unusual occurances which were logged by the ob-
server should also be mentioned. These occurances would
include such things as process upsets, exclusion of tests,
restart of tests, and extreme weather conditions.
Most errors or inaccuracies presented in the report by
the observer should not come as a suprise to the testers or
the facility. The observer's purpose is not just to deter-
mine representativeness of one compliance test data, but to
aid the facility and testers in obtaining representative
test data. In this way the actions and decisions by the
agency and facility can be expedited to achieve the main
goal of compliance.
66

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Facility Operations
Facility operations are composed of the process opera-
tions and air pollution equipment operation. Most control
agencies have a good working knowledge of air pollution
equipment operations. The direct effect on emissions for
various process operations is not usually known by the
agency because detailed studies have not been made to
provide the needed data. The facility operating procedures
presented must be tailored to the agency's laws, regulations
and definitions.
The agency normally defines the facility operations.
The process is generally operated at its normal maximum
operating capacity during testing. This capacity normally
produces the greatest steady state emissions. The process
after the compliance determination is then allowed to oper-
ate at any condition which does not exceed some percentage
above normal maximum capacity as long as the process is not
modified.
If the agency uses process and control equipment oper-
ating conditions as an enformcement tool, then the documenta-
tion of the facility operations during the compliance test
will become part of the performance regulations.
Conditions for process and air {pollution equipment
operations must be established for the compliance test and
must be adhered to by the facility after the compliance
test.
67

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The first portion of this section should present the
basis for the evaluation of the representativeness of the
facility operation during the compliance test. The baseline
conditions for the process operations established by the
agency and agreed upon by the facility prior to the com-
pliance field testing should be presented. The observer
should base his determination on these conditions and not
on a post test after thought. After the basis for a re-
presentativeness determination has been presented, the ob-
server's process checklist and test log should provide
sufficient data to demonstrate representativeness or non-
representativeness of process operations. Any deviation
from the prescribed conditions should be presented along
with the expected effect on the emissions or results. Any
statement or conclusion of non-representativeness of process
operation with established conditions should have been
documented to include the event, time and participants.
References should also be used whenever possible to help
support the baseline conditions set by the agency that have
not been met or that may be challanged at a later data.
The baseline conditions for the control equipment are
normally established from the facility request, since it is
usually to their advantage to optimize the control equipment
operation. Since the agency may deem that the baseline
68

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condition for the control equipment must be met during all
future operations, the facility may desire to operate the
control equipment at less than maximum efficiency to reduce
operating expenses. The agency could not normally invali-
date the compliance test from the control equipment opera-
tion stand point, unless the control equipment was operated
in such a manner as to reduce the emissions only during the
testing period.
If specified by agency regulations, the conditions set
for and during the compliance test must be continually met
to demonstrate compliance. The process operating conditions
established for the test and the control equipment operating
conditions set by the test would then be presented in the
report to aid in future inspections.
Sampling and Analytical Procedure
The applicable sampling and analytical procedures
should be referenced and presented in the Appendix since
these procedures may be revised from time to time. Any
additional quality assurance procedures or modifications to
the prescribed procedures requested and agreed upon by the
agency and emission testers, and the test protocol submitted
by the emission testers should also be presented in the ap-
pendix.
69

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A detailed written explanation of all the sampling and
analytical procedures should not be presented in the text.
The observer's field testing checklists should provide suf-
ficient information for all check points by the observer to
demonstrate compliance with the prescribed procedures. Any
procedures or events that did not conform with the pre-
scribed procedures should include a detailed explanation of
the deviation and it's expected impact on the test results.
The observer should again, as with the facility operation,
aid the emission testers in adhering to the prescribed
procedures. Many errors, if caught in time, will have
little or no effect on the final results.
Any reported on-site sampling or analytical errors should
have been discussed with the emission testing supervisor at
the earliest opportunity.
All cheklists, errors, and unusual occurances should be
presented in the following chronological order:
1.	Calibration of sampling equipment
2.	Acceptibility of sample point and point locations
3.	Sample train preparation
4.	Sample collection
5.	Sample recovery
6.	Sample transport
7.	Sample analysis
70

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All unusual events, non-prescribed procedures and
errors should have been immediately logged along with the
respective time and participants. These bias should not be
presented in the text without proper documentation. All
statements of biases should be based on written legal and
technical procedures and not on the suspections of the
observer. If the observer feels that the equipment has not
been calibrated properly then an independant check should be
made. The observer should not state that in his opinion he
feels that the equipments was not calibrated sufficiently.
Review
A detailed explanation of the compliance test report
and calculations review procedures are included in "Source
Testing Reports Suggested Format and Review ProceduresEPA
Contract 68-01-3172 Task 5.
71

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0
Mtot Tube
Itoder Isokinetic conditions c  c
S fl
Isokinetic Rate
Orifice Meter
Dry Gas Meter



 <'"V >.

n
%  	. i.
\ r\ \  *i ' J"
-  / 1",v>
 (l-V.)  l _ T. , 
" L
\ '' II *
PolIwtant
Collector
Figure 1. Schematic o Isokinetic Sampling Technique

-------
Calibrate Equipment
.Nozzles
Probe Heater
.DGM
.Orifice Meter
.Meter Console
.Pilot Tubes
.Nomograph
Estimate C02
Concentration
Using Fyrite
Prepare To Take
Integrated Sample
Of Flue Gas During
Entire Duration
lOf Test
Analyze Using
Orsat
ISOURCE TEST OUTLINE!
Assemble Sampling Train
Leak Test
.Pitot Lines
Meter Console
.Sampling Train
8l3"Hg.
.Mark Dry And Deslcate
Filtera To Constant
(felght
Assemble In Filters And
Seal Until Ready To Use
Calculate Sample Point
Jslng Method 1
T
Do Preliminary Temperature
And Velocity Traverie
Estimate HjO In Duct
Oeing Wet Bulb-Dry Bulb
I Set dp Nomograph Or Calculator!
Pill Out Data
.Date .DGM Re
.T1m .Test T
Sheet
edlng
tae At Each Point


Monitor Boiler
Operation
Monitor At Each Test Point
.DGM - On Time
.AP
.Appropriate AK
.Stack Temperature
.Sample Case Temperature
.Impinger Temperature	
Record Fuel Feed
Rate And Production
Rate
Stop Teat And Record
.Final DGM
.Stop Time
.Motes On Sampling And
Appearance of Sample
I
Leak Test At Highest Vacuum
Reached During Test
5mp1 ciun-1/g
.Probe t Nozzle .ifeO
.Filter	 .Silica Gel
Ctlculntfl
.Moisture Content Of Gas
.Molecular Height Of Gas (Dry 4 Wet
.Average Cas Velocity
X isokinetic
Pollutant Mas* Rate
(concentration and ratio of areas)
T
Write Report
Reprinted from Source Sampling Workbook
Air Pollution Training Institute, EPA
75

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I FLOW 01ACRAX FOR PLANNING ANOI
PtRFOSMlNG A STACK TEST I
OETERMINE NECESSITY OF A SOURCE TEST
. Decide on data requtrd
, Determine that source test will
give this data
Analyze cost
EACH STACK TEST SHOULD 8E
CONSIOEREO AN ORIGINAL
SCIENTIFIC EXPERIMENT
STATE SOURCE TEST OBJECTIVES
Process evaluation
. Process design data
. ReguI atory compliance
DESIGN EXPERIMENT
. Develop* sampling approach
. Select equipment to meet
test objectives
. Select sampling method
. Select analytical method
. Evaluate possible errors on
biases and correct sampling
approach
. Determine manpower needed for
test
. Determine time required for test
with margin for breakdown*
. Thoroughly evaluate entire experiment
with regard to applicable Stat* and
Federal guidelines
RESEARCH LITERATURE
. iasic Process operation
. Type of Pollutant
emitted from process
. Physical state at
source conditions
. Probable points of
emission from process
. Read sampling reports
from other processes
ISamoled:
1)	Problem to expect
2)	Estimates of veriables
a.	H,0 vapor
b.	Tteperatur* at
Mure*
. Study analytical procedures
ueed for processing test
samples
PRE-SURVEY SAMPLMS SITE
(1)	 Locate noteIs and restaurants
In area
(2)	. Contact plant personnel
(3)	. Inform plant personnel of teiting
objectives and requirements for
completion
(I) . Note process operation*
(5)	. Note shift charges
(6)	. 0*tannine accessibility of
sampIIng sice
(7)	 Inspect sampling site
(I) . Evaluate safety
(9) . Determine port locations and
applications to methods I and 2
(12/23/71 Federal Register)
(10)	. Locate electrical power supply
to site
(11)	. Locate rest races end food at
plant
(12)	. Drawings, photograph*, or
blueprints of sampling site
(I))	. Evaluate applicability of
sampling approach from experiment
design
(II)	. Note any special equipment needed
Reprinted from
Source Sampling
Workbook
Air Pollution
Training Institute
EPA
CALIPRATE EQUIPMENT
. DEH
. Orifice meter
. Oetannine console AHg
. Noxsles
. Thermometers and
thermocouples
. Pressure gauges
. Orsat
 PI tot tube and prob*
. Nomographs	
ARRIVAL AT SITE
Noti'y plant and
PINAL IIE TEST PLANS
. Incorporate presurvay into experiment
design
. Submit experiment design for approval by
Indust ry and Regu I a tory Agency
. Set test dates and duration
regulatory agency
personnel
Review test plan wlth
all concerned
Check weather forecasts
Confirm process opera-
ting parameters In
control room
PREPARE EQUIPMENT FOR TEST
. Assemble end confirm operation
. Prepare for shipping
. Include spare parts and reserve eouioment
CONFIRM TRAVEL AND SAMPLE TEAM ACCOMMODATIONS AT SITE
CONFIRM TEST DATE ANO PROCESS OPERATION
Fine I step before travel arriving
at site
SAMPLING FOR PARTICULATE tMMISSIONS
. Carry equipment to sampling site
. Locate electrical connections
. Assemble eauioment
r
PREPARE FILTERS AW
>EACfNtS
Hark filters with In-
soluble Ink
Oesleate to constant
weight
Record weights In
permanent laboratory
file
Copy file for on sit*
record
Measure delonlxed
distilled N0 for
Inpingers *
Weigh silica gel
Clean sample storage
containers
OETEftntNE APPROXIMATE
MOLECULAR WEIGHT OF STACK
6AS USINC FYRITE ANO
NOMOGRAPHS
APPROXIMATE H,0 VAPOR
CONTENT OF STACK GAS
77

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i
PRELIMINARY CAS VELOCITY TRAVERSE
	Attach thermocouple or ChertnoincCer to
pitot-probe assembly
. Calculate sample point* from guidelines
outlined In method I and 2 Of Federal
h|lilr
	\}irk ttl tot-probe
. Traversa duct for velocity profile
. RecordAP's and temperature
. Record"duct static pressure
RECORD ALL INFORMATION
QW OATA SHEETS
Sample case number
Meter console number
Probe length
Barometric pressure
Nozzle diameter
C factor
Assumed HjO
Team supervisor
Observers present
Train teak test rate
General comments
Initial OGM dial
readings 	
USE HOMOGRAPH Oft CALCULATOR TO SIZE NOZZLE
AND PETERHINE c FACTOR
. Adjust for molecular weight and pilot
tube Cp
. Set K pivot point on nomograph	
LEAK TEST COMPLETELY ASSEMBLED SAMPLING TRAIN
g 15" Hg VACUUM ANO MAXIMUM LEAK RATE OF 0.02 CFM
I NOTIFY ALL CONCERNED THAT TEST IS ABOUT TO START
8			
| CONFIRM PROCESS OPERATING PARAMETERS |
n
TAKE INTEGRATED SAMPLE
OF STACK GAS FOR ORSAT
MALTS IS (OR PERFORM
MULTIPLE FYRITE READINGS
ACROSS DUCT)
8
ANALYZE STAitK GAS FOR 
tONSTITUEMf GASES
 Determine molecuIar
weight
. COj and 02 concen-
tratlon for F-factor
calculations
START SOURCE TEST
. Record start time - Military bete
. Record gas velocity
. Oetermine AH desired from nomograph
. Start pump and set orifice meter
differential manometer to desired AM
. Record
1.	Sample point
2.	Time from zero
3.	OGM dial reading
*. Desired AH
5. Actual AH
t. All temperatures OGH, stack, sample case
. Maintain Isokinetic AM at all times
. Repeat for all points on traverse
PREPARE OTHER TRAINS
FOR REMAINING SAMPLING
F,
IMONITOR PROCESS RATe""|
IrAKE MATERIAL SAMPLES f
If
NECESSARY

CONTROL ROOM OATA
AT CONCLUSION OF TESrRECORO
. Stop time - military base
. Final DGM
. Any pertinent observations on sample
LEAK TEST SAMPLE TRAIN
. Test at highest vacuum (In Hg) achieved during
test
. leak rate should not exceed 0.02 CFM
. Note location of any leak If possible
REPEAT PROCEEDING STEPS FOR THREE PARTICULATE
SAMPLES
REPACK EQUIPMENT AFTER
SAMPLING IS COMPLETED
SAMPLE CLEAN-UP AND RECOVERY
. Clean samples In laboratory or other clean
rea removed from site and protected from
the outdoors
. Note sample condition
. Store samples In quality assurance container*
. Hark and label all samples
.. Pack carefully for shipping If analysis It
not done on site
ANALYZE SAMPLES
. Follow Federal Register or State guidelines
. Document procedures and any variation*
employed
	. Prepare Anelytlcal Report Oata
T
I
79

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t
CALCULATE
. Moisture content of stack gat
. Molecular weight of gas
. Volumes sampled ac standard condition*
. Concentration/Standard voluna
. Control device efficiency
. Volumetric flow rate of stack gas
. Calculate pollutant mass rate	
UHITt IHPORT
. Prepare as possible legal document
. Simmer I ze results
 Illustrate calculations
. Slve calculated results
. Include all raw data(process  test)
. Attach descriptions of testlnf and
analytical Methods
. Signatures of analytical and test
personnel
 
ttll HNM WITMIK MINIMUM TiMC flUMt TO
IMTtMfTCQ fMTIlt
81

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Company_
Test Team
Test Date
Observer
SOURCE SAMPLING CALCULATION SHEET
	 Address 	
Address
(1) WATER VAPOR VOLUME: (Vw_st
-------
(3) MOISTURE CONTENT: (B )
w
'Vstd1
B = t,I		y X 100
( m-std' * w-std'
Vw-std
V
m-std
Run
Run
Run









scf
scf
Run
Run
Run






(4) GAS ANALYSIS: (Md)

Run
Run
Run






co2 =



%
II
CSJ
O



%
CO =



%
N2 -



%
%C02 x 0.44 =
%0? x 0.32 =
%C0 x 0.28 =
%H2 x 0.28
=
Run
Run
Run


















#/#-mole, dry
(5) GAS MOLECULAR WEIGHT: (Mg)
Ms  (Md" "	+ 18(w>
Ms -
Run
Run
Run






#/#-mole, wet
34

-------
(6) ABSOLUTE STACK PRESSURE (Ps)
p = p + stat
s bar 13.6
Ps *
Run
Run
Run






"Hg.
(7) STACK VELOCITY: (V$)
vs-ag * 85.48lv9|^$*f
(ip)avg
Ts-avg
Ps
Run
Run
Run


















"Hg.
#/#-mole
s-avg
Run
Run
Run






fps
85

-------
(8) ISOKINETIC VARIATION: (I)	y
l^T^JDO.OOaWV,) + W + TTl)]
(P>XAn)	
I =
s-avg
m
s-avg
0
A
Run
Run
Run






Run
Run
Run



























R
ml
cf
fPs
"Hg.
min.
sq. ft.
(9) PARTICULATE CONCENTRATION: (c)
M =
n
m-std
R = A / B =
Run
Run
Run












mg.
scf
c = 35,310(R)
= 0.0154(R)
= 2.205 x 10"6(R) =
Run
Run
Run












mlcrograms/cubic meter, normal
grains/std. cubic foot
pounds/std. cubic foot
86

-------
(10) VOLUMETRIC FLOW RATE (Actual):(Q)
For circular ducts
Q 47-' (W'V2
For rectangular ducts
Q  (L)(W)(Vs.avg) x 60
s-avg
Ds
L
M
_a_-
Run
Run
Run















Run
Run
Run






acfm
(11) VOLUMETRIC FLOW RATE (Standard Conditions): (Q^)
17.65(1  ^)(,)(P,)
Q"d	V.vg
fps
ft.
ft.
ft.
Q
P.
s-avg
Run
Run
Run















%
acfw
"H.
'std
Run
Run
Run






scfto, dry
87

-------
(12) POLLUTANT MASS RATE: PMR
PMRc = 1.323 x 10"4(R)(Qst(J)
std
Run
Run
Run









scfm
PMR =
	c
Run
Run
Run






lbs/hr
For circular ducts
PMR, =
Q
1.323 x 10'4(Mn) (D$\2
For rectangular ducts
PMR =
a
1.323 x 10"4(M )(L)(W)
n
M =
Ds =
D =
n
L =
W =
A_ =
Run
Run
Run
























mg.
min.
ft.
ft.
ft.
ft.
sq. ft.
PMR. =
u
Run
Run
Run






lbs/hr
88

-------
(13) ISOKINETIC CHECK:
I  PMR-/PMR x 100 -
o C
Run	
Run	
Run	



(14) "F" FACTOR CALCULATION
E - 2.205 x ,0-6(R)(F) (^9 j)

Run	
Run	
Run	
R 



F -



2"



lun	
Run	
Run	



lb/MM Btu
89

-------