Hazardous Waste Combustion Unit
Permitting Manual
COMPONENTS
How To Review A Trial Burn Report
U.S. EPA Region 6 Center for Combustion
Science and Engineering
Tetra Tech EM Inc.
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COMPONENT SIX
HOW TO REVIEW A TRIAL BURN REPORT
JANUARY 1998
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
CONTENTS
Section
ABBREVIATIONS AND ACRONYMS
BIBLIOGRAPHY
1.0 OVERVIEW OF TRIAL BURN REPORT REVIEW 6-1
1.1 RECOMMENDED REPORT FORMAT 6-5
1.2 ASSEMBLING THE REVIEW TEAM 6-7
1.3 DIVIDING THE DOCUMENT 6-9
2.0 REVIEWING GENERAL REPORT CONTENTS 6-11
3.0 REVIEWING THE EXECUTIVE SUMMARY 6-13
3.1 REVIEWING THE SUMMARY PRESENTATION OF STACK GAS
PARAMETERS AND EMISSION RATE RESULTS 6-15
3.2 REVIEWING THE SUMMARY OF KEY PROCESS SYSTEM
PARAMETERS AND RESULTS 6-17
3.3 REVIEWING THE SUMMARY OF PROBLEMS, SOLUTIONS, AND
DEVIATIONS FROM THE TRIAL BURN PLAN 6-18
3.4 REVIEWING CONCLUSIONS 6-19
4.0 REVIEWING CHAPTER 1—INTRODUCTION 6-20
5.0 REVIEWING CHAPTER 2—PROCESS DESCRIPTION 6-22
6.0 REVIEWING CHAPTER 3—TESTING PROGRAM OVERVIEW 6-28
7.0 REVIEWING CHAPTER 4—TEST OPERATING CONDITIONS 6-34
7.1 REVIEWING WASTE AND FUEL FEED RATE INFORMATION 6-35
7.2 REVIEWING RESIDUALS GENERATION RATE AND CHARACTERIZATION
INFORMATION 6-38
7.3 REVIEWING STACK GAS PARAMETER INFORMATION 6-39
7.3.1 Verifying Stack Gas Carbon Monoxide 6-40
7.3.2 Verifying Stack Gas Flow Rate 6-42
7.3.3 Verifying Stack Gas Oxygen Concentration 6-44
7.3.4 Verifying Air Pollution Control Equipment Inlet Gas Temperature 6-45
7.3.5 Verifying Combustion Unit Temperature 6-47
7.3.6 Verifying Air Pollution Control System Control Parameters 6-49
7.4 REVIEWING FUGITIVE EMISSIONS SOURCES AND MEANS OF
CONTROL 6-51
8.0 REVIEWING CHAPTER 5—PROCESS AND STACK GAS SAMPLING 6-52
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-i
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
CONTENTS (Continued)
Section Pas
8.1 REVIEWING SUMMARY OF SAMPLING LOCATIONS AND METHODS . . 6-53
8.2 REVIEWING SUMMARY OF WASTE AND FUEL FEED SAMPLING 6-54
8.2.1 Verifying Principal Organic Hazardous Constituent Feed Rate 6-57
8.2.2 Verifying Ash Feed Rate 6-58
8.2.3 Verifying Chlorine Feed Rate 6-61
8.2.4 Verifying Hazardous Metal Feed Rate 6-64
8.2.5 Verifying Combustion Unit Heat Input Rate 6-67
8.3 REVIEWING SUMMARY OF PROCESS RESIDUALS SAMPLING 6-70
8.4 REVIEWING STACK GAS SAMPLING SUMMARY 6-71
8.4.1 Reviewing Summary of Stack Gas Sampling Methods 6-72
8.4.1.1 Verifying Traverse Points 6-74
8.4.1.2 Verifying Stack Gas Velocity and Flow Determination 6-75
8.4.1.3 Verifying Gas Analysis for Carbon Dioxide, Oxygen, Excess
Air, and Molecular Weight 6-83
8.4.1.4 Verifying Method of Determining Moisture in Stack Gas 6-85
8.4.1.5 Verifying Method of Determining Particulates, Hydrogen
Chloride, and Chlorine 6-87
8.4.1.6 Verifying Volatile Organic Sampling Train Sampling Method
for Determination of Volatile Organics 6-89
8.4.1.7 Verifying Semivolatile Organic Sampling Train Sampling
Method for Determination of Semivolatile Organics 6-90
8.4.1.8 Verifying Sampling Method for Poly chlorinated
Dibenzodioxins and Poly chlorinated Dibenzofurans 6-91
8.4.1.9 Verifying Sampling Method for Multiple Metals 6-93
8.4.1.10 Verifying Sampling Method for Hexavalent Chromium 6-94
8.4.1.11 Verifying Sampling Method for Aldehydes and Ketones 6-96
8.4.1.12 Verifying Sampling Method for Organic Constituents Using
Tedlar® Bags 6-97
8.4.2 Reviewing Data Tables For Stack Gas Characteristics 6-98
8.4.3 Reviewing Data Tables for Emission Rates of Constituents of
Potential Concern 6-99
9.0 REVIEWING CHAPTER 6—LABORATORY PROCEDURES 6-101
9.1 REVIEWING THE SUMMARY OF ON-SITE ANALYTICAL PROCEDURES 6-103
9.2 REVIEWING THE SUMMARY OF OFF-SITE ANALYTICAL PROCEDURES6-105
10.0 REVIEWING CHAPTER 7—QUALITY ASSURANCE/QUALITY CONTROL
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-ii
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
CONTENTS (Continued)
Section Page
RESULTS 6-107
10.1 REVIEWING THE SUMMARY OF ON-SITE QUALITY ASSURANCE/
QUALITY CONTROL RESULTS 6-109
10.1.1 Stack Gas Samples 6-111
10.1.2 Process Samples 6-116
10.2 REVIEWING THE SUMMARY OF OFF-SITE QUALITY ASSURANCE/
QUALITY CONTROL RESULTS 6-118
11.0 REVIEWING CHAPTER 8—TRIAL BURN RESULTS SUMMARY AND PROPOSED
PERMIT LIMITS 6-120
11.1 REVIEWING DESTRUCTION AND REMOVAL EFFICIENCIES 6-123
11.2 REVIEWING CONTINUOUS EMISSION MONITORING SYSTEM
RESULTS 6-127
11.3 REVIEWING STACK GAS EMISSION RATE RESULTS 6-128
11.3.1 Reviewing Particulate Matter Emission Rate Results 6-129
11.3.2 Reviewing Hydrogen Chloride and Chlorine Gas Emission Rate Results 6-136
11.3.3 Reviewing Metal Emission Rate Results 6-139
11.3.4 Reviewing POHC Emission Rate Results 6-143
11.3.5 Reviewing PIC Emission Rate Results 6-144
11.3.6 Reviewing Total Organic Emission Rate Results 6-146
11.3.7 Reviewing Poly chlorinated Dibenzo-p-dioxin/Poly chlorinated
Dibenzofuran Emission Rate Results 6-150
11.4 REVIEWING PROPOSED PROCESS LIMITS 6-152
11.5 REVIEWING PROPOSED WASTE FEED LIMITS 6-154
11.6 REVIEWING PROPOSED AUTOMATIC WASTE FEED CUTOFF LIMITS . 6-156
11.6.1 Reviewing Parameters for Combustion Units 6-158
11.6.2 Parameters for Reviewing Air Pollution Control Systems 6-160
11.6.2.1 Reviewing Dry Scrubber Parameters 6-162
11.6.2.2 Reviewing Wet Ionizing Scrubber Parameters 6-163
11.6.2.3 Reviewing Venturi Scrubber Parameters 6-164
11.6.2.4 Reviewing Wet Scrubber Parameters 6-165
11.6.2.5 Reviewing Electrostatic Precipitator Parameters 6-166
11.6.2.6 Reviewing Baghouse (Fabric Filter) Parameters 6-168
11.6.3 Reviewing Other Associated Equipment Parameters 6-169
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
CONTENTS (Continued)
Section Page
11.7 REVIEWING PROPOSED DATA FOR USE IN THE RISK ASSESSMENT . . 6-171
12.0 REVIEWING THE APPENDICES 6-173
12.1 REVIEWING APPENDIX A—TRIAL BURN PLAN 6-175
12.2 REVIEWING APPENDIX B—QUALITY ASSURANCE PROJECT PLAN . . . 6-176
12.3 REVIEWING APPENDIX C— STACK SAMPLING REPORT 6-178
12.3.1 Reviewing U.S. EPA Method 0010 Field Data Sheets and Emission Rate
Calculations 6-180
12.3.2 Reviewing U.S. EPA Method 23 or 0023A Field Data Sheets and
Emission Rate Calculations 6-181
12.3.3 Reviewing U.S. EPA Method 0012 or 0060 Field Data Sheets and
Emission Rate Calculations 6-183
12.3.4 Reviewing U.S. EPA Method 0013 or 0061 Field Data Sheets and
Emission Rate Calculations 6-184
12.3.5 Reviewing U.S. EPA Method 0030 or 0031 Field Data Sheets and
Emission Rate Calculations 6-186
12.3.6 Reviewing Total Organics Field Data Sheets and Emission Rate
Calculations 6-188
12.3.7 Reviewing U.S. EPA Method 0050 or 0051 Field Data Sheets and
Emission Rate Calculations 6-190
12.4 REVIEWING APPENDIX D—PROCESS SAMPLING REPORT 6-192
12.4.1 Reviewing Raw Data 6-193
12.4.2 Reviewing Data Summary Calculations 6-195
12.5 REVIEWING APPENDIX E—THE QA/QC REPORT 6-196
12.5.1 Reviewing Field Sampling Quality Assurance/Quality Control Report. 6-198
12.5.2 Reviewing Laboratory Data Summary Report 6-201
12.5.3 Reviewing COC Forms 6-203
12.6 REVIEWING APPENDIX F—INSTRUMENT CALIBRATION RECORDS .. 6-204
12.6.1 Reviewing Calibration Records for Process Monitoring Equipment .. 6-205
12.6.2 Reviewing Calibration Records for Process Control Equipment 6-206
12.6.3 Reviewing Calibration Records for Continuous Emission Monitoring
Equipment 6-207
12.6.4 Reviewing Calibration Records for Stack Gas Sampling Equipment . . 6-209
12.6.5 Reviewing Calibration Records for Field Analytical Equipment 6-210
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-iv
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
CONTENTS (Continued)
Section Page
12.7 REVIEWING APPENDIX G—PERFORMANCE CALCULATIONS 6-211
12.8 REVIEWING APPENDIX H—FIELD LOGS 6-212
12.9 REVIEWING APPENDIX I—ANALYTICAL DATA PACKAGES 6-213
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-v
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
CONTENTS (Continued)
EXHIBITS
Exhibit Page
2.0-1 EXAMPLE TRIAL BURN TEST CERTIFICATION 6-12
5.0-1 EXAMPLE TABLE OF PROCESS MONITORS 6-24
5.0-2 EXAMPLE PROCESS DIAGRAM INDICATING MONITORING POINTS 6-26
5.0-3 DESIGN INFORMATION SUMMARY 6-27
6.0-1 DEVIATIONS SUMMARY 6-30
8.2.2-1 ASH INPUT RATE CALCULATION 6-59
8.2.3-1 CHLORINE INPUT RATE CALCULATION 6-62
8.2.4-1 METAL CONCENTRATIONS IN FEEDS AND INPUT RATES 6-65
8.2.5-1 HEAT INPUT RATE CALCULATION 6-68
8.4.1.2-1 EXAMPLE METHOD 0050 DATA FORM 6-76
8.4.1.2-2 STACK GAS VELOCITY CALCULATION 6-79
8.4.1.3-1 MOLECULAR WEIGHT DETERMINATION 6-84
8.4.1.4-1 MOISTURE CONTENT DETERMINATION 6-86
11.1-1 DESTRUCTION AND REMOVAL EFFICIENCY 6-126
11.3.1-1 REVIEWING PARTICULATE MATTER EMISSION RATE RESULTS 6-132
11.3.2-1 REVIEWING CHLORINE EMISSION RESULTS 6-137
11.3.3-1 REVIEWING METAL EMISSION RATE RESULTS 6-140
12.4.1-1 EXAMPLE LIQUID ORGANIC WASTE FEED SAMPLING DATA FORM 6-194
ATTACHMENTS
A MEMORANDUM ON TRIAL BURNS
B HOW TO REVIEW A TRIAL BURN REPORT CHECKLIST
C STACK GAS EMISSION CALCULATIONS
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-vi
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
AA
acfm
APCS
ASTM
AWFCO
BIF
Btu
Btu/lb
Btu/hr
CAA
CEMS
40CFR
C12
CO
CO2
coc
COPC
DC
DRE
dscf
dscfm
dscm
ESP
°F
FID
40CFR
ft3
ft3/hr
g/sec
GC
gph
gpm
gr/dscf
g/dscm
GRAY
H2O
HC1
HHV
HRA
ICP
IWS
kg/hr
kVA
L
lb
ABBREVIATIONS AND ACRONYMS
Atomic adsorption
Actual cubic feet per minute
Air pollution control system
American Society for Testing and Materials
Automatic waste feed cutoff
Boiler and industrial furnace
British thermal unit
British thermal units per pound
British thermal units per hour
Clean Air Act
Continuous emissions monitoring system
Title 40, Code of Federal Regulations
Chlorine gas
Carbon monoxide
Carbon dioxide
Chain of custody
Constituent of potential concern
Direct current
Destruction and removal efficiency
Dry standard cubic feet
Dry standard cubic feet per minute
Dry standard cubic meter
Electrostatic precipitator
Degrees Fahrenheit
Flame ionization detector
Title 40, Code of Federal Regulations
Cubic feet
Cubic feet per hour
Grams per second
Gas chromatography
Gallons per hour
Gallons per minute
Grains per dry standard cubic foot
Grams per dry standard cubic meter
Gravimetrically
Water
Hydrogen chloride
High heating value
Hourly rolling average
Inductively coupled plasma
Ionizing wet scrubber
Kilograms per hour
Kilovolt Ampere
Liter
Pound
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-vii
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Ib/min Pound per minute
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-viii
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
ABBREVIATIONS AND ACRONYMS (Continued)
Ib/hr Pound per hour
LHV Low heating value
m3/hr Cubic meters per hour
min Minute
MMBtu Million British thermal units
MS Mass spectrometry
N2 Nitrogen
ng/m3 Nanograms per cubic meter
O2 Oxygen
OSWER Office of Solid Waste and Emergency Response
PAH Polynuclear aromatic hydrocarbon
PCC Primary combustion chamber
PCDD/PCDF Polychlorinated dibenzopdioxin/polychlorinated dibenzofuran
PIC Product of incomplete combustion
PM Particulate matter
POHC Principal organic hazardous constituent
ppm Parts per million
ppmv Parts per million by volume
PQL Practical quantitation limit
PSD Particle size distribution
psi Pounds per square inch
psig Pounds per square inch
PST Performance specification test
QAPP Quality assurance project plan
QA/QC Quality assurance/quality control
RBP Risk burn plan
RBR Risk burn report
RCRA Resource Conservation and Recovery Act
SCC Secondary combustion chamber
scfrn Standard cubic feet per minute
SQL Sample quantitation limit
STP Standard temperature and pressure
SVOC Semivolatile organic compound
TBP Trial burn plan
TBR Trial burn report
TCO Total chromatographicable organics
THC Total hydrocarbon
TO Total organics
U.S. EPA U.S. Environmental Protection Agency
VOC Volatile organic compound
VOST Volatile organic sampling train
WAP Waste analysis plan
w.c. Water column
//g Microgram
//g/dscm Microgram per dry standard cubic meter
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-ix
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
AH Orifice meter differential
A? Differential pressure
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-x
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
BIBLIOGRAPHY
ASME. 1984. "Analytical Procedures to Assay Stack Effluent Samples and Residual Combustion
Products for PCDD/PCDF." Prepared for the U.S. Department of Energy and U.S. EPA.
Washington, D.C. December.
U.S. Environmental Protection Agency (EPA). Undated. "Quality Assurance Handbook for Air
Pollution Measurement Systems." Volume III. Stationary Source-Specific Methods. EPA-
600-R-94-038a.
U.S. EPA. 1989. "Sampling and Analysis Methods for Hazardous Waste Combustion." Arthur D.
Little, Inc. 600/8-84-002.
U.S. EPA. 1987. Seminar Publication. "Permitting Hazardous Waste Incinerators." EPA-6254-87-
017.
U.S. EPA. 1989. "Handbook: Guidance on Setting Permit Conditions and Reporting Trial Burn
Results." Office of Research and Development (ORD), Risk Reduction Engineering
Laboratory. Cincinnati, Ohio. EPA-625-6-89-019. January.
U.S. EPA. 1989. "Checklist for Reviewing Resource Conservation and Recovery Act (RCRA) Trial
Burn Reports." Revisions. Midwest Research Institute. Kansas City, Kansas. February 10.
U.S. EPA. 1989. "Handbook: Hazardous Waste Incineration Measurement Guidance Manual."
Office of Solid Waste and Emergency Response (OSWER). Washington, D.C. EPA-625-6-
89-021. June.
U.S. EPA. 1990. "Handbook: QA/QC Procedures for Hazardous Waste Incineration." Center for
Environmental Research Information (CERI). Cincinnati, Ohio. EPA/625/6-89/023. January.
U. S. EPA. 1990. "Methods Manual for Compliance with the BIF Regulations; Burning Hazardous
Waste in BIFs." OSWER. Washington, D.C. EPA/530-SW-91-010. December.
U.S. EPA. 1992. "Technical Implementation Document for (TID) EPA's Boiler and Industrial
Furnace Regulations." OSWER. Washington, D.C. EPA-530-R-92-011. March.
U.S. EPA. 1996. "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846,"
Third Edition. December.
U.S. EPA. 1996. "Guidance for Total Organics." Eastern Research Group, Inc. Draft Report.
Second Edition. March.
U.S. EPA. 1997. "Generic Quality Assurance Project Plan (QAPP)." Center for Combustion
Science and Engineering, Multimedia Planning and Permitting Division, U.S. EPA Region 6.
Dallas, Texas. December.
U.S. EPA. 1997. "Generic Trial Burn Plan (TBP)." Center for Combustion Science and Engineering,
Multimedia Planning and Permitting Division, U.S. EPA Region 6, Dallas, Texas. December.
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-xi
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
BIBLIOGRAPHY (Continued)
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous Waste Combustion
Facilities." Center for Combustion Science and Engineering, Multimedia Planning and
Permitting Division, U.S. EPA Region 6. Dallas, Texas. EPA-R6-098-002. January.
U.S. EPA. 1998. "Protocol for Screening Level Ecological Risk Assessment at Hazardous Waste
Combustion Facilities." Center for Combustion Science and Engineering, Multimedia Planning
and Permitting Division, U.S. EPA Region 6. Dallas, Texas. EPA-R6-098-003. January.
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-xii
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
1.0
OVERVIEW OF TRIAL BURN REPORT REVIEW
Regulations:
Guidance:
Explanation:
Check For:
No regulations are applicable to this section of the manual.
No specific references are applicable to this section of the manual.
The trial burn report (TBR) is a comprehensive document that (1) includes copies
of the trial burn plan (TBP) and trial burn quality assurance project plan (QAPP);
(2) completely summarizes all activities associated with the trial burn test; (3)
includes all supporting information needed to document the results of the trial
burn test; and (4) serves as the basis for the development of permit conditions,
discussed further in Component 7—How to Prepare Permit Conditions. The
TBR may be referred to as a risk burn report (RBR) if it summarizes activities
associated with risk burn testing. In this component, TBR and RBR can be used
interchangeably in most cases. Specific instances where a TBR and RBR differ
are highlighted
Attachment A is the U.S. Environmental Protection Agency (EPA) 1994
"Memorandum on Trial Burns," also referred to as "Guidance on Trial Burn
Failures." This memorandum offers guidance on evaluating the success or
failure of trial burns. Attachment B is a review checklist the TBR review team
leader can use to ensure that all sections of this component have been
considered. Attachment C includes spreadsheets (both in hard copy printout and
on diskette) that calculate stack gas emissions using trial burn stack sampling and
laboratory analytical data.
The TBR should include the following major elements. These elements are
discussed in more detail in the subsections of this component identified below:
Q Executive summary (see Section 3.0)
Q Introduction (see Section 4.0)
Q Process description (see Section 5.0)
Q Testing program overview (see Section 6.0)
Q Test operating conditions (see Section 7.0)
Q Process and stack gas sampling (see Section 8.0)
Q Laboratory procedures (see Section 9.0)
Q Quality assurance/quality control (QA/QC) results (see Section 10.0)
Q Trial burn results summary and proposed permit limits (see Section 11.0)
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-1
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Q Appendices
Q TBP and trial burn QAPP (see Sections 12.1 and 12.2)
Q Stack sampling report (see Section 12.3)
Q Process sampling report (see Section 12.4)
Q QA/QC report (see Section 12.5)
Q Instrument calibration records (see Section 12.6)
Q Performance calculations (see Section 12.7)
Q Field logs (see Section 12.8)
Q Analytical data packages (see Section 12.9)
As discussed in Sections 1.2 and 1.3 of this component, the TBR is typically
reviewed by a team of experts. During review of these sections, the TBR
review team should check for the following:
Q Verification that the trial burn test was conducted in accordance with the
approved TBP and trial burn QAPP
Q Verification that information included as appendices and attachments to
the TBR support the data summaries and conclusions presented in the
main body of the text
Q Verification that the report draws appropriate conclusions on the basis of
information collected during the trial burn test and risk burn test for the
following:
Q Combustion unit operation
Q Appropriate feed rates
Q Representative emission rates
Q Supportable risk assessment results
Q Verification that proposed permit conditions are supported by data
summaries
Example Reports: TBRs are prepared for numerous types of tests, may be referred to by different
titles, and can serve several different purposes. For example, a TBR may be
prepared for:
• Trial burn test report
• Demonstration test report
• Risk burn test report
• Emissions evaluation verification report
• Certification of compliance test report
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-2
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Example Concerns
for the Reviewer:
These reports can serve many different purposes, including:
• Establishing a comprehensive list of permit limits for a new
combustion unit
• Collecting information on the emission rates of constituents of
potential concern (COPC) under normal operating conditions
• Providing the information needed to establish an automatic waste
feed cutoff (AWFCO) limitation
Before beginning, the reviewer should understand why the facility has submitted
the TBR, including at least a cursory understanding of: (1) the permitting process
history leading to the trial burn review, (2) the concerns and objectives of other
key personnel involved in the permitting process, and (3) any concerns identified
during the trial burn test (typically identified in the field oversight report, see
Component 4— How to Conduct Trial Burn Test Oversight).
This level of understanding will enable each member of the TBR review team to
(1) complete his or her task with the necessary level of accuracy, and
(2) prepare comments that are effective and constructive. This is especially true
of staff who become part of the TBR review team because of a new position or
their particular expertise, but who have not been part of the ongoing review and
approval process for the TBP and trial burn QAPP before this point. The
combustion unit permitting process typically requires several years. Because of
the effort involved—after the TBP and QAPP have been negotiated and
approved—see Component 1—How to Review a Trial Burn Plan and
Component 2—How to Review a Trial Burn Quality Assurance Project
Plan—the ultimate objective of everyone involved in the process should be to
ensure the following:
• Successful trial burn test
• Well-written and documented TBR
• Permit conditions that protect human health and the environment
All members of the TBR review team must understand:
• The significance of each issue identified
• Effective strategies for preparing comments and collecting
additional information from the facility
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-3
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-4
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
1.1
RECOMMENDED REPORT FORMAT
Regulations:
Guidance:
Explanation:
Check For:
Title 40 Code of Federal Reputations (40 CFR) Part 270.62(b)(6) through (9)
40 CFR Part 270.66(d)(3), (4), and (5)
No specific references are applicable to this section of the manual.
A thorough Executive Summary presentation is the foundation for an effective
TBR review process. In the Executive Summary, the facility submitting the TBR
should present a brief presentation of the results concerning compliance issues.
A brief statement should explain if the data met the criteria specified in the
QAPP. The Executive Summary should also serve as a platform to introduce
problems and deviations that occurred or were identified. This information will
help the reviewer understand all major aspects of the TBR and prepare them to
conduct a comprehensive and efficient review. The TBR format should include
the sections identified in Section 1.0 of this component.
Q Executive Summary
Q List of key project personnel in the Introduction
Q Whether the TBR format follows the approved TBP
Q Comparison of test conditions to planned conditions
Q Detailed chemical and physical analysis of waste and process samples
Q Stack gas analysis for pollutants as planned, and emission rate
calculations for all pollutants
Q QA/QC discussion for all analytical results
Q Whether correct appendices are attached
Q Discussion of problems, delays, or changes from the approved TBP
Q Field data sheets
Q Emission rate calculations
Q Equipment calibration reports
Q Continuous emission monitoring system (CEMS) calibration and
performance specification test (PST) results
Q Process data
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-5
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Example Situation:
Example Action:
Q Problems and deviations, especially those affecting QA/QC
Lois and Clark were selected for the review of various TBRs. As Lois and
Clark started to review the TBR for the XYZ Company hazardous waste
incinerator, they noted that there was no Executive Summary. The lack of an
Executive Summary created instant review problems because a thorough report
presents all regulatory results in this summary section.
Continuing their review, Lois and Clark found that the report did not reference
the TBP or compare planned activities to actual activities. Also, with no
cross-referencing, it was necessary for Lois and Clark to review the hazardous
waste analysis, the principal organic hazardous constituents (POHC) that were
selected, and their concentrations in the waste streams. As a result, the TBR
review process was delayed repeatedly.
Finally, Lois and Clark noticed that the TBR lacked appendices presenting field
data and emission rate calculations, the QA/QC report, calibration reports, or
other information needed for a comprehensive technical review.
In sum, Clark found that the TBR was deficient in many areas. The TBR
appeared to have been prepared with no understanding of data management,
continuity, or results presentation.
After several attempts to obtain a correct and complete version of the TBR
failed, Clark issued an Administrative Order to the company to resubmit the TBR
with all required information and data. He further informed the company that it
could not operate at its proposed permit limits until a complete and
comprehensive report was reviewed and approved. The company was ordered
to operate at 85 percent of planned limits and was told that an oversight
contractor for the U.S. EPA would audit the facility every 10 days until the
report was approved, and that the company would be required to pay oversight
costs.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-6
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
1.2 ASSEMBLING THE REVIEW TEAM
Regulations: No regulations are applicable to this section of the manual.
Guidance: No specific references are applicable to this section of the manual.
Explanation: Because there is a wide variety of information presented in a TBR, several
disciplines working as a team are required to review a TBR. The official
assigned the responsibility as permit writer should be the team leader. The
following are suggested team members:
• Permit writer
Team leader; should be familiar with the regulations, the
technology, and the facility compliance record
• Chemist
Should be familiar with approved analytical methods, QA/QC
procedures, and sampling techniques
• Mechanical or chemical engineer
Should have experience with combustion technology, burner
design, principles of combustion, refractory types, air pollution
control system (APCS) operation and limitations, waste types
and combustion requirements, and field experience with
combustion unit operation
QA/QC control officer
Should be familiar with U.S. EPA QA/QC requirements for
waste analysis, process sample analysis, and stack gas pollutant
analysis. Can also contribute to blank, spike, and surrogate
analysis acceptance criteria, and check analytical calculations for
accuracy
• Toxicologist or risk assessor
Should be familiar with risk assessment protocols and procedures
as applied to hazardous waste combustion units. This team
member would be responsible for reviewing the risk assessment
results submitted as an addendum to the TBR
• Others, as special needs become known, who can be available to
help as needed
Check For: For each of the key members listed above, the following information should be
evaluated:
Q Team member credentials
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-7
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Q Team member availability
Q Team leader assignment
Q Schedule and meeting review
Q Potential conflicts of interest with team members or outside consultants
Example Situation: Lois and Clark were reviewing the memorandum assigning personnel
responsibility for review of various TBR sections for the XYZ Company
combustion unit. During the review, Lois noticed that John Doe (chemical
engineer) had been a former employee of the parent company of XYZ. Lois
knew this assignment could present a perceived conflict of interest.
Example Action: Lois prepared a memorandum strongly suggesting that a different engineer be
responsible for reviewing the engineering aspects of the XYZ combustion unit.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-8
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
1.3
DIVIDING THE DOCUMENT
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
No regulations are applicable to this section of the manual.
No specific references are applicable to this section of the manual.
TBRs are usually submitted to the permitting agency in several volumes. The
main volume, usually Volume I, contains the Executive Summary and
Introduction. The remaining volumes usually contain field data sheets for process
sampling, stack sampling, and traceability. Other volumes contain analytical data
and QA/QC results, in addition to gas chromatography/mass spectroscopy
(GC/MS) data. Some reports include appendices containing copies of the
analytical method, usually for various stack gas sampling methods and analysis
for volatiles, semivolatiles, poly chlorinated dibenzo-p-dioxins/
poly chlorinated dibenzofurans (PCDD/PCDF), metals, and other analytes.
After selecting all team members, the team leader should assemble the entire
review team and divide the submittal among team members. The submittal will
be divided based on areas of expertise. The team leader should establish a
sign-out sheet for each part of the report assigned to a team member.
Next, the team leader should specify due dates for return of the document and
the review comments. Each team member should clearly understand his or her
responsibility and the date the review is due.
Before meeting with the team, the team leader should check to confirm that all
volumes of the TBR have been received. Then, the individual section headings
should be checked against the list in Section 1.0 of this component to confirm that
all major sections are discussed.
Lois and Clark were reviewing the Executive Summary for the XYZ Company
combustion unit trial burn report and noticed that the POHC destruction and
removal efficiency (DRE) was 99.99 percent for test Condition 2, Run 2. This
result seemed odd, because all other POHC DREs were calculated out to six
decimal places. Lois checked the TBR for Condition 2, Run 2 analytical results
and found the POHC DRE calculated out to 99.9869 percent. The contractor
has rounded up to 99.99 percent in the Executive Summary. Lois reviewed U.S.
EPA's Guidance on Trial Burn Failures and developed a recommendation for
senior management based on the guidance policy and the facts of the case.
Because the POHC DRE had failed the established criteria for passing, and U.S.
EPA specifically prohibits rounding up for POHC DRE, Lois notified senior
management of this significant issue before dividing the report and completing the
detailed review. After completing the review of the entire report, Lois noted her
comments that test Condition 2 was invalid.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-10
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2.0
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
REVIEWING GENERAL REPORT CONTENTS
Regulations:
Guidance:
Explanation:
Check For:
Example Report:
Example Concerns
for the Reviewer:
40 CFR Part 266.103
40 CFR Parts 270.62(b)(6) to 270.62 (b)(9)
No specific references are applicable to this section of the manual.
A TBR is a comprehensive document that provides the reviewer an overview of
the facility and general operations. It may present some of the same information
contained in the TBP. It should contain an Executive Summary that presents the
results of the trial burn as briefly as possible. In general, a TBR contains specific
sections with appendices for data and process information. The following
"Check For" items comprise a general list of a TBR; there will be variations for
different combustion units.
Q Table of contents
Q Certification form
Q Appropriate sections (see list in Section 1.3 of this component)
Q Appendices
Generally, the TBR is formatted parallel to the TBP to facilitate report review.
An approved copy of the TBP, which is typically included as an attachment to
the TBR, should be consulted during TBR review. One of the most commonly
omitted sections of the report is a certification, signed by a corporate officer or
other authorized agent of the facility, certifying that the trial burn has been
conducted in accordance with the approved TBP. Exhibit 2.0-1, see page 6-12,
is an example certification.
It is rare that any major section of the report is omitted. Continuing with the
review process or writing a comment on this type of issue wastes time and
delays the permitting process. If a section is missing, the agency should decide
appropriate action before contacting the facility.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 2.0-1
EXAMPLE TRIAL BURN TEST CERTIFICATION
Certification
I certify, under penalty of law, that this document and all attachments were prepared under my direction
or supervision, in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system or those persons directly responsible for gathering information, the information submitted is, to the
best of my knowledge and belief, true, accurate, and complete. Furthermore, to the best of my
knowledge, the trial burn was conducted in accordance with the approved Trial Burn Plan, except as
noted in this document. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for violations.
Sam Pultaker Date
XYZ Stack Sampling Company
John Q. Citizen Date
Big Chemical Company
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-12
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
3.0
REVIEWING THE EXECUTIVE SUMMARY
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
The Executive Summary of the TBR should summarize the results of the trial
burn conducted for the facility. This section also briefly describes key process
system parameters and the results of the trial burn. It is important to note,
however, that any data presented in the Executive Summary should be thoroughly
evaluated when reviewing later sections of the TBR. It is common that data
summarized in the Executive Summary are not as detailed or accurate as data
presented in specific sections of the TBR.
It is suggested that the summary information be presented in table form. This
format facilitates locating information. In addition, clear references should be
provided to other sections of the TBR when supporting information can be found.
It is also recommended that a separate table be provided that identifies the trial
burn data input into the risk assessment.
Q Summary of stack gas parameters and emission rate results (see Section
3.1)
Q Key process system parameters and results (see Section 3.2)
Q Problems encountered during the trial burn test, solutions, and deviations
from the approved TBP (see Section 3.3)
Q Conclusions on the success in meeting TBP objectives (see Section 3.4)
While Clark was examining a table in the Executive Summary presenting stack
gas parameters, he noticed that the stack temperature was reported as 1,200°R.
The reported result was suspect, because he noticed that (1) the exhaust gas
stream did not pass through any control device or waste heat recovery unit, and
(2) the combustion chamber temperature was about 1,700°R. Clark turned to
the stack testing raw data forms in the appendix and discovered that the stack
gas temperature was recorded at about 1,200°F. It was obvious that the
readings were not converted from°F to°R, as presented in the Executive
Summary.
Example Action:
During the TBR review, it became evident to Clark that numerous data were
collected, numerous forms were completed, and numerous calculations and
numbers were reduced before presentation in the Executive Summary. In most
cases, it is worthwhile to begin the review from the appendix sections, follow raw
data reduction to calculations, and then verify reported results and associated
units before examining a summary of numbers.
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-13
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-14
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-15
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
3.1 REVIEWING THE SUMMARY PRESENTATION OF STACK GAS
PARAMETERS AND EMISSION RATE RESULTS
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
The Executive Summary section of the TBR should summarize stack gas
parameters and emission rate results.
The results discussed in the Executive Summary should be verified for accuracy
and consistency with the rest of the TBR data and results. At a minimum, check
for the following:
Q Whether the stack gas volumetric flow rate, corrected to dry standard
conditions, is presented
Q Whether test results represent the average of all runs conducted under a
specific test condition
Q Whether carbon monoxide (CO) concentration is reported on the basis of
dry parts per million by volume (ppmv), and corrected to 7 percent
oxygen (O2)
Q Whether the POHC DRE is accurate to at least four significant digits
(that is, 99.99 percent)
Q Whether all results are presented as numerical values (neither not
detectable nor "nondetect" is an acceptable result)
Q Whether the O2 concentration is reported on the basis of dry units of
volume percent
Q Whether the hydrogen chloride (HC1) emission rate is presented in
pounds per hour (Ib/hr)
Q Whether all pollutants are presented on the basis of dry units
Q Whether the particulate matter (PM) concentration is presented in grains
per dry standard cubic feet (gr/dscf) at 7 percent O2
Q Whether detection limits are reported along with emissions data and
identified as to the type of detection limit (for example, practical
quantitation limit [PQL] or sample quantitation limit [SQL])
Q Whether emissions data are presented in grams per second (g/sec) for
input into the risk assessment
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Q Whether any emission rates are adjusted for input into the risk
assessment and, if so, justification and data supporting the adjustment (for
example, using half the detection limit).
Example Situation: Clark noticed the following statement presented in a TBR, "Because Compound
X was not detected by the laboratory, the mass emission rate is 0 pounds per
hour."
Example Comments: Clark informed the company that if a compound is not detected by an analytical
method, the detection limit value should be used for all ensuing calculations.
Place a "<" (less than) symbol in front of the value, complete the calculations,
and report the result as a "<" value.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-17
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
3.2 REVIEWING THE SUMMARY OF KEY PROCESS SYSTEM PARAMETERS
AND RESULTS
Regulations:
Guidance:
Explanation:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
The Executive Summary section of the TBR may be used to summarize key
process system parameters and results because this information will be used to
establish operating limits. It is not necessary that the items under "Check For" be
included in the Executive Summary section, as long as they are included
elsewhere in the TBR.
Check For:
Example Situation:
Q Whether average, minimum, and maximum combustion zone
temperatures are presented
Q Whether waste feed stream and ancillary fuel mass flow rates are
presented
Q Whether excess O2 concentration is presented for all test runs
In reviewing the TBR Executive Summary, Lois noted that the excess O2
concentration in the flue gas stream measured by boiler and industrial furnace
(BIF) operations was significantly different from that recorded by the stack
sampling contractor. Typically, O2 concentration measured by testing companies
is reported on a dry basis. Process equipment mounted on an exhaust stack
usually measures O2 concentration on a wet basis. Measurements can be
compared only when both readings are on a consistent basis.
Example Comments: Lois quickly refers to the applicable section of the TBR and makes a note to
check for that specific issue in the text. The Executive Summary has
successfully informed Lois and prepared her for the detailed review of specific
issues in the body of the report.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-18
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
3.3 REVIEWING THE SUMMARY OF PROBLEMS, SOLUTIONS, AND
DEVIATIONS FROM THE TRIAL BURN PLAN
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
The Executive Summary section of the TBR should review any problems
encountered during the trial burn test, their solution, and any deviations from the
TBP. This summary is important, because the permit writers may not have
reviewed the TBP and QAPP. In addition, they may not be familiar with the
process, sampling and analytical methodologies associated with field decisions, or
the ramifications of altering the planned testing of objectives.
Q Any notation that alternative stack sampling procedures were used
Q Any notation that alternative laboratory procedures were used
Q All deviations from the proposed process operating conditions
Q Reduced performance and efficiency from ancillary equipment or control
devices
Q Changes in the targeted POHC
Lois reviewed (1) the Executive Summary of problems, solutions, and deviations;
and (2) the TBR and appendices. Lois notes that the facility developed a test
and QA/QC plan to incinerate carbon tetrachloride to demonstrate a DRE of
99.99 percent. A subcontractor was hired to provide spiking materials, and the
entire project was scheduled to accommodate all parties involved in the trial burn
test. At the conclusion of the trial burn test, it was discovered that the POHC
spike was monochlorobenzene rather than carbon tetrachloride.
Because of the potentially serious implications of this issue, Lois dedicates a
significant amount of time during her review determining whether the trial burn
test results can be salvaged for the use in developing permit limits. She notes
that the POHC DRE of monochlorobenzene was 99.99 percent—and because
monochlorobenzene is more difficult to incinerate than carbon tetrachloride—
Lois was able to recommend that the facility be permitted to operate at test
conditions demonstrated. Luckily, the regulatory agency was able to issue a
permit in spite of this significant deviation from the approved TBP.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-19
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
3.4
REVIEWING CONCLUSIONS
Regulations:
40 CFR Part 266.102
40 CFR Parts 266.104 to 266.107
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
No specific references are applicable to this section of the manual.
The Executive Summary section of the TBR should present conclusions about
the success of the trial burn test in meeting test objectives. The objectives
outlined in the TBP are initially identified so that test results can be used to
establish permit and operating conditions.
Q Whether the POHC DRE was at least 99.99 percent
Q Whether the CO concentration, corrected to 7 percent O2, was less than
100 ppmv
Q Whether the HC1 emission rate was less than or equal to 4 Ib/hr and
within acceptable risk based limits
Q Whether the PM concentration was less than 0.08 gr/dscf at 7 percent
O2
Q Whether metals emission rates were within the allowable Tier limit and
within acceptable risk-based limits
Q Whether organic compound emissions (for example, products of
incomplete combustion [PIC] such as PCDDs and PCDFs) were within
acceptable risk-based limits
Q Whether emissions met all applicable air permit conditions
In reviewing the Executive Summary conclusions, Lois notes that the average
results from a trial burn test were reported as follows:
DRE = 99.999 percent
CO = 2.4 ppmv at 7 percent O2
HC1 = 3.7 Ib/hr
PM = 0.042 gr/dscf at 7 percent O2
Lois compared these results in the Executive Summary to all data results
provided in the TBR and compared the results to the standards presented in 40
CFR Parts 266.104 to 266.107. Based on her review, Lois quickly determined
that all of these results are within compliance limitations.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-20
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-21
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
4.0
REVIEWING CHAPTER 1—INTRODUCTION
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
This section provides introductory information to the trial burn conducted for the
facility. Generally, it includes facility background information; facility name,
address, and location; test date and times; who conducted the test; why the test
was conducted; and the report format.
This section should typically present no new information about the facility. This
section can be checked quickly by comparing it to the same set of information
presented in the TBP (typically included as Appendix A of a TBR) or the
information collected during the trial burn test (presented in the oversight report,
see Component 4—How to Conduct Trial Burn Test Oversight).
Q Background information
Q Facility name
Q Contact
Q Address
Q Telephone number
Q U.S. EPA identification number
Q U.S. EPA region
Q Person responsible for TBR
Q Company name
Q Address
Q Telephone number
Q Date
Q Person responsible for QA/QC
Q Title
Q Address
Q Telephone number
Q Why the test was conducted
Q Person conducting the test and project participants
Q Dates and times of the test
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Example Situation: In reviewing the TBR, Clark reads the following information:
"This report documents the results of the trial burn conducted on Boiler Al at
XYZ Chemical, Inc., U.S. EPA Identification No. LAD 100101231, located in
ABC Parish, Louisiana."
However, Clark noted that the TBP (Appendix A) contained the following
information:
"This trial burn plan is prepared for Boiler A2 at XYZ Chemical Inc., U.S. EPA
Identification No. LAD100101321, located in ABC Parish, Louisiana."
Example Action: To determine whether the test was conducted on Boiler No. Al or A2, Clark
reviewed other supporting documents (including the field data log sheet and
operation records). To resolve the discrepancy between identification numbers,
Clark reviewed the trial burn test oversight report.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-23
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
5.0 REVIEWING CHAPTER 2—PROCESS DESCRIPTION
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
40 CFR Part 266.103
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA/625/6-89/019. Chapter 5, Appendix B, and Appendix F.
A process description, including process design information, a summary of
process monitors and stack gas analyzers, and a schematic with process
monitoring points is generally included in the TBR. If the TBR does not include
any of these items, the TBP (typically included as Appendix A to the TBR)
should be reviewed for any missing information. The trial burn test oversight
report (see Component 4—How to Conduct Trial Burn Test Oversight) should
also be reviewed to gather this information. The trial burn test oversight may
sometimes contain more detailed, or the latest, information for various
parameters. Exhibits 5.0-1 through 5.0-3, see pages 6-24 through 6-27 are
examples of the type of information that may be presented in this section.
Q Brief process description of the combustion unit
Q Description of auxiliary equipment and unit operations associated with
the system (see Component 1—How to Review a Trial Burn Plan,
Section 3.0)
Q Design information summary table
Q Summary of process monitors and stack gas analyzers
Q Process diagram showing monitoring points
In reviewing Appendix A (of the TBP), Lois noted that the TBP included the
following information:
"The combustion unit primary combustion chamber (PCC) is
designed for an operating temperature of 800°F to 1,200°F,
whereas the secondary combustion chamber (SCC) is designed
for a temperature range of 1,000°F to 1,500°F. A residence
time of 2 seconds in each chamber is provided. The SCC
temperature will be measured upstream of any quench water
injection."
However, the TBR shows a measured PCC temperature of 1,400°F and a SCC
temperature of 900°F. The TBR does not indicate where the temperature in the
SCC was measured or whether a 2-second residence time was achieved in each
chamber.
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-22
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Example Action: The PCC operating temperature (1,400°F) is considerably higher than the design
temperature (800°F to 1,200°F). The reason for this design inconsistency should
be determined. The SCC temperature (900°F) during the trial burn is
considerably below the design temperature of 1,000°F to 1,500°F. This major
design inconsistency should be evaluated. Lois prepared a specific comment that
reads: "Specify whether the SCC temperature was measured upstream of any
quench water injection. If the temperature was measured upstream of quench
water injection, the reason for such a low temperature should be determined."
To provide additional information for evaluation of this issue, Lois also requested
that the residence time in each chamber be calculated on the basis of design
information provided for each chamber. That is, volume, total air flow rate, and
pressure.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-23
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 5.0-1
EXAMPLE TABLE OF PROCESS MONITORS
Parameter
High-Btu liquid waste feed
rate
Low-Btu liquid waste feed
rate
Auxiliary fuel flow
Sludge waste feed rate
Drummed solid waste
charge weight
Atomization steam
pressure
Rotary kiln temperature
SCC temperature
Quench inlet temperature
Quench discharge
temperature
Adsorber temperature
Ionizing wet scrubber
(IWS) inlet temperature
Rotary kiln pressure (draft)
SCC pressure (draft)
Rotary kiln speed
Quench water flow rate
Caustic water flow rate
Location of Monitor
lOA-Feed line to nozzle on SCC
lOB-Feed line to nozzle on PCC
1 1-Feed line to injector on SCC
12A-Fuel oil line to SCC
12B-Fuel oil line to kiln
13-Feed line to injector on kiln
14-Automatic weigh scale
at feed conveyor
ISA-Waste burner in SCC
1 SB-Waste burner in kiln
16-Kiln outlet
17-SCC
18-Quench inlet
19-Quench outlet duct
20-Adsorber inlet
21A-Inlet duct to IWS No. 1
21B-Inlet duct to IWS No. 2
22-Rotary kiln chamber
23-SCC
24-Kiln rollers
25-Quench water line
26-Caustic water line to
adsorber
Type of
Monitor
Mass flow meter
Mass flow meter
Mass flow meter
Mass flow meter
Weigh scale
Pressure
transducer
TypeR
thermocouple
TypeR
thermocouple
Type J
thermocouple
TypeJ
thermocouple
TypeJ
thermocouple
TypeJ
thermocouple
Pressure
transducer
Pressure
transducer
Tachometer
Orifice meter
Rotameter
Operating
Range
0 to 100
0 to 100
0 to 100
0 to 100
0 to 2,000
0 to 100
2,650
2,650
150 to 600
150 to 600
150 to 600
150 to 600
-5 to 5
-5 to 5
0 to 1.0
0 to 200
OtoSO
Units Recorded
in Process Log
Ib/min
Ib/min
Ib/min
Ib/min
Ib
pounds per square inch
gauge
°F
°F
°F
°F
°F
°F
in water (H2O)
inH2O
rotations per minute
gallons per minute
gpm
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-24
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
IWS water flow rate
27A-IWS water line to unit No.
1
27B-IWS water line to unit No.
2
Orifice meter
OtoSO
gpm
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-25
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBTI 5.0-1 (Continued)
EXAMPLE TABLE OF PROCESS MONITORS
Parameter
Oxygen
Carbon monoxide
Combustion gas flow rate
Combustion air flow rate
IWS electrical readings
Adsorber differential
pressure
Scrubber water blowdown
rate
Location of Monitor
27B-IWS water line to
unit No. 2
28-IWS outlet duct
29-Stack
30A-Air inlet duct to SCC
SOB- Air inlet duct to kiln
31A-PowerlinestoIWS
electrodes for unit 1
3 IB-Power lines to IWS
electrodesfor unit 2
32-Adsorber inlet and outlet
ducts
33-Sewer line to National
Pollutant Discharge Elimination
System treatment system
Type of
Monitor
Zirconium
oxide fuel
Cell in situ
nondestructive
infrared
Resistance
temperature
flow detector
Venturi meter
Voltmeter,
Pressure
transducer
Triangular weir
Operating
Range
Oto25
0 to 500
Oto 100,000
Oto20
0 to 200
Oto 20
Oto 12
Units Recorded
in Process Log
percent
parts per million
reference
valve
reference
valve
kiloVolts
milliAmps
inH2O
gpm
Notes:
Btu British thermal unit
gpm Gallons per minute
H2O Water
IWS Clonizing wet scrubber
Ib Pound
Ib/min Pounds per minute
PCC Primary combustion chamber
SCC Secondary combustion chamber
ppm Parts per million
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-26
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 5.0-2
EXAMPLE PROCESS DIAGRAM INDICATING MONITORING POINTS
Emergency
Relief Stack
'---' Reeirculated Scrubber Water
Secondary
Combustion
Chambers
Drammed Solids
Storing Area
Legend
I J Process Monitor
In NPDES System
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 5.0-3
DESIGN INFORMATION SUMMARY
Parameter
Units
Incinerator Identification
Installation date (year)
Type of incinerator
(diameter x length or height x width x length)
Inside dimensions
Cross-sectional area
Design heat release rate
Design heat release rate
Refractory thicknesssa
Refractory conductivity*
Refractory surface areaa
Cooled surface area
Design pressure
Identification fan capacity
Stack diameter
Stack height
APCS design information (as applicable)
Type(s) (such as quench, Venturi, and ESP)
Maximum inlet temperature
Minimum inlet temperature
Maximum inlet pressure
Minimum inlet pressure
Design pressure drop (range)
Design liquid flow (range)
Design gas flow (range)
Surface area (bags, plates)
Voltage (specify AC/DC)
Current
HC1 removal capacity
PCC
SCC
System
Burner
identification15
Atomizing
Type Waste stream(s) fluid pressure0
Type atomizing
fluid
Notes:
B Required for mass and energy balance
b Need only to identify burners used for waste
0 Explain, if different from design specifications
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-28
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
6.0
REVIEWING CHAPTER 3—TESTING PROGRAM OVERVIEW
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
The Overview of the Testing Program section of the report should summarize
trial burn objectives, the planned test program, actual testing conducted, and any
deviations from the approved TBP.
Q Trial burn objectives
Q Planned test program
Q Summary of actual testing performed
Q Deviations from the approved TBP
In reviewing the TBR, Clark checks the TBP to see whether all objectives
(percent DRE of designated POHC greater than or equal to 99.99 percent);
CO concentration less than 100 ppmv; and PM less than 0.08 gr/dscf) were met
during the actual trial burn.
Clark also reviews the TBP to see whether the testing program was conducted
(1) under specified test conditions; (2) at the documented mass feed rate; and
(3) at the proposed heat input rate. The testing program also identifies testing
methods used; Clark reviews the TBP to see whether specified methods were
used, and in doing so discovers a deviation between the TBR and the TBP.
The TBR must identify and explain deviations from the approved TBP, if any.
Examples of some deviations and their basis and impact are shown in Exhibit 6.0-
1 (see page 6-30). Any deviations should be reviewed for their impact on the
results.
Clark notes the deficiency and his recommendation for corrective measures in his
report, as follows:
"Deficiency: (see Exhibit 6.0-1, see page 6-30). This table states that specific
polynuclear aromatic hydrocarbons (PAH) showed high background levels in
samples from the MM5 train. However, the table does not identify the PAHs
that showed high background levels or list specific sample numbers that indicated
this anomaly.
"Recommendations: The table should list (1) all of the samples containing high
background levels of PAHs, and (2) the PAHs identified."
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-31
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 6.0-1
DEVIATIONS SUMMARY
Test Element
Deviation
Basis and Impact
STACK SAMPLING
Trial Burn Stack
Sampling Time
Trial Burn Stack
Sampling Sequence
Chromium
Sampling Train
Preparation
Chromium
Sampling Train
Operations
Addendum 1 of the TBP revised the testing program to allow up to 3 hours of stack gas testing. Initially, the Method
0050, hexavalent chromium, and formaldehyde trains were to be operated for 1 hour. This time was not changed. The
Method 0050 trains were initially scheduled to operate for 2 hours. During the first run of the trial burn, these trains were
operated for 2.6 hours. In subsequent runs, they were operated for 2.4 hours because of concerns regarding the amount of
waste feed available. The volatile organic sampling train (VOST) sampling time was adjusted in the trial burn to 40
minutes per tube, set at a rate of 0.5 L/min, instead of 20 minutes per tube, set at a rate of 0.25 liters per minute (L/min).
The methanol and Method 0040 trains were initially scheduled to be operated for 2 hours each. In the trial burn, the
methanol train was operated for 3 hours, and the Method 0040 train was operated for 2.5 hours.
The planned trial burn sequence specified that particulate sampling be conducted separately from aldehyde and hexavalent
chromium sampling. Instead, the particulate and formaldehyde and hexavalent chromium trains were operated
concurrently at the start of each run, in addition to the VOST, Method 0040, and Method 18 trains. The MM5 trains
were not started until the second half of the particulate train operation.
The TBP specified the use of a 0.1N potassium hydroxide (KOH) charging solution in the sampling train. A 1 N solution
was used instead.
In Run 5, at the last traverse point of the first port (traverse point 12), the probe KOH recirculation line detached. The
sample was collected for a short period without KOH being recirculated.
During Run 5, at the last traverse point (point 24), the probe tip fell off but did not break. This occurred because it was
necessary to tilt the sampling train up to remove it from the stack. During this tilting, the probe snagged on the port,
pulling the tip out. The preleak check had been good, and the leak check that was conducted after the probe was put back
on was good.
The additional sampling time was proposed to allow
an additional sample to be collected. The impact
was to further improve sampling train detection
limits. The facility evaluated the analytical results
from the last tube in the VOST train to ensure that
breakthrough did not occur.
Because stack traverse points overlap, the
particulate, and formaldehyde and hexavalent
chromium trains could not be operated concurrently
with the MM5 trains. This restriction extended the
total length of each test run but did not otherwise
affect the trial burn program. This deviation should
not change stack sampling results.
The change was based on previous experience. The
stronger solution had no impact on the analytical
program, as shown in the QC data presented in
Appendix E.
An additional 2 minutes were added to the total
sampling time as a conservative means of
accounting for the short period during which KOH
was not being recirculated. Adding the additional 2
minutes could bias the chromium emissions in Run
5, resulting in slightly higher results.
The probe incident was unanticipated. Considering
that the leak checks before and after the probe fell
off were good and the probe was in the stack, the
impact of this event is insignificant.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 6.0-1 (Continued)
DEVIATIONS SUMMARY
Test Element
Deviation
Basis and Impact
STACK SAMPLING (continued)
Method 0040
Train Operation
Method 18 Train
Operation
The Tedlar sample bag that was to be analyzed for Run 7 (Bag 1) was broken during the sampling train operation. The
second bag was collected successfully. The Tedlar bag sample that was analyzed for methanol in the stack gas was also
analyzed for volatile unspeciated mass, and the data point was salvaged.
During the trial burn, two bags, instead of three, were used to collect the sample.
Because the two samples are similar, there should
be no significant impact on data quality.
Appendix E contains information regarding the
analysis.
The purpose was to reduce the efforts of the
on-site QC operator. Analytical results were
consistent from bag to bag, so this deviation did
not affect the trial burn results.
PROCESS SAMPLING
Samples of Ash
Collection and
Analysis
Spark Arrester Ash
The TBP specified that 50 milliliters of feed sample be collected at 15-minute intervals to build a 1-liter sample and that
250 milliliters be used for ash analysis. About 150 milliliters were collected at 15-minute intervals to build a 1-gallon
composite sample, and 40 milliliters were used for ash analysis. After considerable ash variability was visually observed in
duplicate 40-milliliter vials, the 40-milliliter vial samples were determined to be nonrepresentative. The 500-milliliter
samples were analyzed. Results of both were reported.
The TBP specified that spark arrester ash samples be collected for various analyses. Only one sample of spark arrester
ash was obtained from the low-temperature test condition. There was insufficient ash to collect a sample from the second
test condition.
Transferring a part of the total sample to
40-milliliter sample vials did not provide a
representative sample. After this was discovered,
the 500-milliliter sample was analyzed instead to
provide a more representative sample, consistent
with the TBP minimum sample size of 250
milliliters. The increase in aliquot size and total
sample volume provided a more representative
sample.
This deviation has no impact on the trial burn
program, because no spark arrester ash — other
than the one sample — was generated.
MISCELLANEOUS
Determining
Correlation
Between Baghouse
Differential
Pressure and Ash
Loadings
Soot Blowing
Addendum 1 of the TBP specified that a test would be conducted to demonstrate the correlation between baghouse
differential pressure and stack flow at different baghouse ash loadings. This test was not conducted because it was not
possible to build up the required ash loading in the baghouse.
Soot blowing was planned for the third run in each test. Soot blowing was conducted throughout the second run of the
high-temperature test.
The test was designed so that the facility could
take credit for the variance of the baghouse
differential pressure with stack gas flow rate. The
alternative was to accept the differential pressure
from the test, with no allowance for flow rate
adjustment. Because the correlation between
baghouse differential and ash loading could not be
determined, the permit limit will be based on the
baghouse differential pressure demonstrated during
the trial burn.
Additional soot blowing was factored into the soot-
blowing equation used to correct metals and
particulate concentrations and emission rates.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 6.0-1 (Continued)
DEVIATIONS SUMMARY
Test Element
Deviation
Basis and Impact
MISCELLANEOUS (continued)
Trial Burn
AWFCO Setpoint
The TBP specified AWFCO limits that would be in effect during the trial burn. During the trial burn, the stack gas flow
rate, steam production, and baghouse differential pressure were revised.
An annuber stack gas flow meter was used to
determine the stack gas flow during the trial burn.
This unit was installed immediately before the trial
burn. Based on the characteristics of the annuber,
the flow limit was revised to 20,890 actual cubic
feet per minute (acfm).
The TBP did not specify a minimum baghouse
differential pressure. Before the trial burn, EPA
determined that a limit should be set. The limit
was set at 0.2 inch water column (w.c.).
The steam production limit was adjusted higher
because it was found that the unit could produce
more steam under trial burn conditions. The
maximum steam production limit was revised to
40,000 Ib/hr.
ANALYTICAL
VOST Audit
Methanol Train
Calibration Gas
A VOST audit was planned as part of the trial burn. Because of government contracting issues, a VOST audit was not
available.
The TBP proposed the use of Protocol 1 calibration gases for methanol analysis. Protocol 1 calibration gases could not
be obtained commercially. Instead, commercially obtained calibration gases used in the pretest were analyzed in triplicate
by the laboratory, and the average values used as the calibration rate.
The absence of a VOST audit does not have a
significant impact on the evaluation of the results.
The TBP includes matrix spike/matrix spike
duplicates and resin spikes for evaluating accuracy
and precision.
Method 18 specifies that prepared standards be
used for calibration. Trial burn calibration
standards were commercially prepared and were
analyzed (1) by a standard method to provide
accuracy, and (2) in triplicate to allow precision to
be evaluated. Therefore, the accuracy of the
standards was adequately demonstrated. This
deviation had no impact on trial burn results.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 6.0-1 (Continued)
DEVIATIONS SUMMARY
Holding
Time — Volatile
Total Organic
Condensate
Test Element
The shipment of the Method 0040 condensate samples from Run 8 were misrouted by the overnight carrier and arrived at
the laboratory 1 day late. When logged in, the temperature in the ice chest was found to be greater than the 4 °C
shipping temperature.
Deviation
Sampling results for this train are reported as a bag
sample portion and a condensate portion.
Condensate results from Run 8 are 4.4 percent of
the total volatile organics loading on the train.
For Runs 7 and 9, condensate results are 4.5, 4.5
percent of the train totals. Because Run 8 sample
results are consistent with the other samples from
the same test condition, there is no discernable
impact on the results.
Basis and Impact
ANALYTICAL (continued)
High Background
PAH
Concentrations on
XAD Resin
Use of Alternative
Sample
Low Matrix Spike
Recoveries for
Aldehydes
The samples from MM5 Train A showed high background levels of some PAHs. These levels presented some difficulties
in the evaluation of some data quality objectives associated with the constituents.
In the PAH analysis of the Run 7 sample from MM5 Train A (Sample B-1313), the sample was lost during the extraction
process. The Train B archive sample portion from Run 1 (B-1320) was used instead.
Laboratory matrix spike recoveries were outside the QC tolerances specified in data quality objectives. Matrix spikes
were performed on the first impinger of Runs 7 and 8. Recoveries for formaldehyde were 72 and 0 percent, respectively.
Recoveries for acataldehyde were 45 and 37 percent, respectively. Appendix E contains additional discussion. The
dinitrophenylhydrazine (DNPH) solution might have become deactivated when matrix spikes were added.
The constituents with high background problems
were not the constituents that will be evaluated as
benzo(a)pyrene toxicity equivalent in the human
health risk assessment. Therefore, high background
levels do not affect the risk assessment evaluation.
The trial burn was specifically designed so that a
portion of Train B could be used in the event of
problems with Train A. Therefore, this substitution
does not affect the test results.
These relatively poor matrix spike recoveries are at
sufficient levels for these data to be regarded as
representative of stack gas emissions of these
aldehydes. The acetaldehyde data will be used in the
human health risk assessment. Because
concentrations found in the samples were low, the
impact on the human health risk assessment will
probably be minor. However, the uncertainty
associated with low recoveries should be evaluated in
the risk assessment.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
7.0
REVIEWING CHAPTER 4—TEST OPERATING CONDITIONS
Regulations: 40 CFR Part 266.103
Guidance: No specific references are applicable to this section of the manual.
Explanation: During preparation of the TBP, the facility establishes the limits for the test and
process operating parameters, including specific operating parameters for the
APCS, to ensure that emissions of metals, HC1, chlorine gas (C12), PM, and
others are not likely to exceed allowable limits.
Check For: Review the TBR to see whether all operating parameters listed in the TBP are
recorded and are within established limits. Check for average, minimum,
maximum, and standard deviation of the values collected.
Q Waste and fuel feed rate information (see Section 7.1)
Q Process residuals generation rate and characterization information (see
Section 7.2)
Q Stack gas parameter information (see Section 7.3)
Q Fugitive emissions sources and means of control (see Section 7.4)
Example Situation: In comparing the TBP to the TBR, Lois and Clark ask that the facility explain
why parameters are not within established limits. Lois and Clark will then review
the explanation to ensure its validity. Sections 7.1 through 7.4 of this component
provide explanation for some operating conditions listed above.
Example Comments: Example comments for each listed operating condition are included separately in
Sections 7.1 through 7.4 of this component.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
7.1
REVIEWING WASTE AND FUEL FEED RATE INFORMATION
Regulations:
Guidance:
Explanation:
Check For:
40CFRPart264.345(b)
U.S. EPA. 1989. "Checklist for Reviewing RCRA TBRs." Revision 3.
February 10. Section III.
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 2 and Appendix F, Forms 3 and 4.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapters 3 and 5.
A hazardous waste feed rate limitation is required under 40 CFR Part 264.345(b),
mainly to minimize a potential loss of efficiency or unsafe situation caused by
overloading the combustion chamber. For maximum operating flexibility, two
levels of hazardous waste feed rate parameters should be maximized:
(1) combined feed rate of all hazardous waste feed streams, and (2) combined
feed rate of all pumpable hazardous waste feed streams. Also, the data logsheet
should be reviewed to see whether more than one type of auxiliary fuel, such as
natural gas, process gas, coal, or fuel oil, is fired.
The instantaneous and hourly rolling averages (HRAs) values for each of the
following parameters should be presented for each run of the trial burn test.
Q Maximum organic (high heating value [HHV]) liquid waste feed rate
Q Maximum aqueous (low heating value [LHV]) liquid waste feed rate
Q Maximum containerized waste (that is, container size and type) feed rate
Q Maximum sizes of containerized waste batches
Q Maximum feed rate of each waste type to each combustion chamber
Q Hazardous waste blending procedure, analysis of each waste before
blending, and blending ratio (only if more than one hazardous waste
stream is blended)
Q Review the data logsheets (units, rate) to assure that the results
presented are accurate and consistent
Q Solid waste feed rate
Q Auxiliary fuel feed rate
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
If the facility is reporting the results of a risk burn, additional data should be
provided. These data may include the following:
Q Average hazardous waste feed rate (each stream) for each risk burn run
Q Minimum and maximum hazardous waste feed rate (each stream) for
each risk burn run
Q Supporting data regarding normal operating conditions (may also be
submitted as part of the RBP)
Example Situation: Because hazardous waste feed parameters are set when the TBP is prepared,
Lois compares the TBR to the TBP to determine whether the feed rate during
the actual burn was consistent with proposed feed rates.
Lois notes that she needs the following information if hazardous waste is blended:
(1) hazardous waste feed rate information, including blending procedure; (2) a
detailed analysis of the hazardous waste before blending; (3) an analysis of the
material blended with the hazardous waste; and (4) the blending ratios.
Appendix D—Process Sampling Report should contain the process operating
data logsheet completed during the trial burn test. This logsheet should contain
the liquid waste feed rate measured at regular intervals during the trial burn test.
For consistency, the reviewer should compare liquid feed rate units (such as
pounds per minute [Ib/min], Ib/hr, and kilograms per hour [kg/hr]) reported with
those on the logsheet. Also, the data logsheet should be reviewed to see whether
more than one type of liquid waste is being fed to the combustion chamber.
If liquid waste feed is reported as a volumetric rate (gallons per hour [gph], cubic
meters per hour [m3/hr], or cubic feet per hour [ft3/hr]) on the data logsheet,
sample calculations should be included in the report, showing conversion from
volumetric feed rate to mass rate.
Example Action:
During her review of a TBR, Lois notes that the data logsheet contained in
Appendix D reports a value for the liquid waste feed rate in kg/hr, whereas the
TBR shows the same feed rate in Ib/hr. Lois asks that the facility verify the feed
rate units and present the waste feed rate value with the correct units.
She also notes that the TBP states that the maximum solid waste feed rate would
be set at 1,800 Ib/hr, whereas during the actual trial burn test, the solid waste
feed rate was 1,500 Ib/hr. She asks the facility to explain the lower feed rate.
Finally, Lois notes that the data logsheet (Appendix D) reported the auxiliary fuel
rate of natural gas in standard cubic feet per minute (scfrn), whereas the TBR
shows the auxiliary feed rate in Ib/hr. Lois makes a note to verify the auxiliary
fuel firing rate, and to request that the facility revise the TBR to reflect the
correct units if a problem is found.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-39
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-40
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
7.2 REVIEWING RESIDUALS GENERATION RATE AND CHARACTERIZATION
INFORMATION
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
No regulations are applicable to this section of the manual.
U.S. EPA. 1989. "Checklist for Reviewing RCRA TBRs." Revision 3.
February 10. Section IV.
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapters.
Samples of ash, process effluents (such as scrubber water), and solid residuals
(such as baghouse, spark arrester, and residual ash) should be collected and
analyzed for the compounds of concern identified by the TBP or RBP (for
example, PICs, POHCs, metals, or chlorine). The ash, process effluents, and
solid residual generation rate should also be calculated.
Q Ash, process effluents, and solids residuals identification
Q Sampling method
Q Sampling frequency (every 15 minutes and 1 hour composite)
Q Sampling duration (minimum 1 hour sampling time per run)
Q Sampling location
Q Ash, process effluents, and residual generation rate
Q Ash, process effluents, and residual analytical data
In reviewing the TBR, Clark read that an ash sample from the kiln was collected,
but analytical results did not show the presence of any compounds of concern.
Clark asks that the facility revise the TBR to describe how the ash sample was
collected (one grab sample per run is recommended). It should also present
(1) analytical results that identify the parameters analyzed, and (2) detection
limits.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-41
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7.3
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
REVIEWING STACK GAS PARAMETER INFORMATION
Regulations: 40 CFR Part 266.103
Guidance: U.S. EPA. 1989. "Checklist for Reviewing RCRA TBRs." Revision 3.
February 10. Section III.
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 2 and Appendix F, Forms 3 and 4.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapters 3 and 5.
Explanation: During the trial burn test, monitoring of several specific parameters is required.
Permit limits are set for these monitored parameters. These parameters—such
as CO concentration, stack gas flow rate, combustion temperature, APCS inlet
gas temperature, and pressure drop—are monitored because it is important to
ensure good combustion and APCS operating practices, and compliance with the
regulations.
Check For: Q CO emission levels, in ppmv, corrected to 7 percent O2 (see Section
7.3.1)
Q Stack gas flow rate and velocity at actual, dry standard, and 7 percent O2
conditions (see Section 7.3.2)
Q O2 levels in volume percent (see Section 7.3.3)
Q Inlet gas temperature to the dry APCS (see Section 7.3.4)
Q Combustion unit temperature (see Section 7.3.5)
Q APCS control parameters (see Section 7.3.6)
Example Situation: In reviewing the TBR, Clark verifies that it presents all stack parameters.
Sections 7.3.1 through 7.3.6 of this component include example sections for each
parameter.
Example Comments: Sections 7.3.1 through 7.3.6 of this component include example sections for each
parameter.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-42
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
7.3.1
Verifying Stack Gas Carbon Monoxide
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 266.103
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 2, and Appendix F and Form 6.
CO concentration in the flue gas is an indicator of combustion efficiency. High
CO emissions can result from insufficient combustion air, poor mixing, improper
atomization, or excessive organic compound volatilization.
Q CEMS CO concentration during the trial burn in ppmv (minimum of three
runs per test condition) corrected to 7 percent O2.
The following values should be provided for each run of the trial burn
test:
Q Minimum and maximum instantaneous concentrations
Q Minimum and maximum HRA concentrations
Q Standard deviation of instantaneous and HRA values
Q Average instantaneous and HRA values for all runs at each test
condition
Example Situation:
Q CEMS CO strip chart and original log recorded during testing
Q If dual CO CEMS are installed, confirm which monitor corresponds with
which strip chart or data set.
Generally, the permit target value for CO emissions is 100 ppmv, corrected to
7 percent O2.
In reviewing the TBR, Lois uses the following formula to check the CO
conversion at 7 percent O2:
CO = CO
2\-Y
where
COC
com
Y
Corrected CO level at 7 percent O2
Measured CO level
Measured O2 concentration in the stack gas on a dry-gas
basis
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
(14 and 21 are values used for conversion purposes)
Example Action: Lois uses the formula to review calculations for each run and to verify the
measured CO level by reviewing the strip chart and CO field log data sheet.
Also, she verifies that the measured O2 concentration is on a dry-gas basis.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-44
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
7.3.2 Verifying Stack Gas Flow Rate
Regulations: 40 CFR Part 266.103
Guidance:
Explanation:
Check For:
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 2, and Appendix F and Form 6.
Title 40 CFR Part 264.345(b)(4) requires that the permit specify an acceptable
operating limit using "an appropriate indicator of combustion gas velocity."
Combustion gas flow rate is a direct measurement of combustion gas velocity.
Combustion gas velocity is directly related to the gas residence time in the
combustion unit. Residence time is an important indicator of combustion unit
destruction efficiency and PIC formation. Stack gas flow rate is a common
indicator of combustion gas velocity. The stack gas flow rate is not always linear
in comparison to the actual combustion gas flow rate within the combustion
chambers. However, the stack gas flow rate is an easily monitored and reliable
measurement and is proportional to the actual combustion gas flow rate.
Q Stack gas flow rate and velocity (minimum of three runs per test
condition)
The following values should be provided for each run of the trial burn
test:
Q Minimum and maximum instantaneous concentrations
Q Minimum and maximum HRA concentrations
Q Standard deviation of instantaneous and HRA values
Q Average instantaneous and HRA values for all runs at each test
condition
Q Location of stack gas flow rate measurement
Q Whether stack gas flow rate is within limits of the TBP target and, if not,
an explanation for being outside the limits
Q Stack gas flow rate and velocity calculations, including water (H2O), O2,
nitrogen (N2), carbon dioxide (CO2), and CO levels in the flue gas
Q Stack gas flow rate values for actual, dry standard, and 7 percent O2
conditions.
Q Whether reported values are consistent with test operating data
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Example Situation: In reviewing the TBR, Clark notes that stack gas flow rate for three runs under
the same operating conditions were reported as 1,200, 1,300, and 1,800 (actual
cubic feet per minute (acfm) with an average of 1,433 acfm.
Example Action: Stack gas flow rates for all three runs should be close, because the runs are
theoretically conducted under the same operating conditions. Clark checked the
calculations and data logsheets to verify the reported value. He reviewed the
waste feed rate and auxiliary fuel rate O2 levels during these runs to determine
why the measured flow rates varied among runs.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-46
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
7.3.3
Verifying Stack Gas Oxygen Concentration
Regulations: 40 CFR Part 266.103
Guidance: U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 2, and Appendix F, Form 6.
Explanation: Complete combustion of POHCs and PICs requires the presence of sufficient
O2. The O2 level is measured in the flue gas as an indirect indicator of
combustion efficiency.
Measurement of O2 levels is also necessary to convert the CO concentration,
stack gas velocity and flow rate (and therefore the emission rate of COPCs) to
7 percent O2 levels based on actual O2 monitoring data.
Check For: Q O2 concentration in the flue gas during the trial burn (minimum of three
runs per test condition, on a dry-gas basis
The following values should be provided for each run of the trial burn
test:
Q Minimum and maximum instantaneous concentrations
Q Minimum and maximum HRA concentrations
Q Standard deviation of instantaneous and HRA values
Q Average instantaneous and HRA values for all runs at each test
condition
Q CEM O2 strip chart and original log recorded during the testing
Q Whether O2 levels during testing are within the limits of the trial burn
target and, if not, whether excursions beyond the limits are explained
Example Situation: In reviewing the TBR, Lois read that O2 levels for test Condition 1 for all three
runs averaged 7.7 percent, with a range of 7 to 8 percent; and that an operating
envelope of 7 to 8 percent will be used for actual operations. However, while
reviewing the continuous monitoring O2 strip chart scale, Lois could only find data
that indicated the O2 concentration ranged from 8 to 9 percent, with an average
of 8.8 percent.
Example Comments: Lois was confused because she could not determine what data the facility had
used to determine the proposed operating envelope. She developed a comment
requesting that the facility review actual O2 values and calculations and revise
the proposed operating envelope, as appropriate.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
7.3.4 Verifying Air Pollution Control Equipment Inlet Gas Temperature
Regulations: 40 CFR Part 266.103
Guidance:
Explanation:
Check For:
Example Situation:
No specific references are applicable to this section of the manual.
APCS inlet temperature is a regulated BIF parameter for which a limit must be
determined. Guidance recommends limiting APCS inlet gas temperature for all
combustion units because of its effect on (1) the formation of dioxin-like
compounds in dry APCS, (2) APCS performance, and (3) equipment
deterioration. Higher APCS temperatures would minimize condensation so that
less of the particulate-forming material could be collected. Temperatures
measured during the dioxin test runs should be closely evaluated during
development of permit limits to ensure that formation of these compounds will be
minimized. The reviewer should closely evaluate any APCS inlet temperature
greater than 400°F. The maximum temperature should not be higher than
specified by the manufacturer to ensure effective operation and to prevent
malfunction. Limiting inlet gas temperature applies to a variety of APCS,
including adsorbers, venturi scrubbers, baghouses, electrostatic precipitators, and
ionizing wet scrubbers.
Q Inlet gas temperature to the APCE during the trial burn test (minimum of
three runs per test condition)
The following values should be provided for each run of the trial burn
test:
Q Minimum and maximum instantaneous concentrations
Q Minimum and maximum HRA concentrations
Q Standard deviation of instantaneous and HRA values
Q Average instantaneous and HRA values for all runs at each test
condition
Q Continuous temperature strip chart or digital data recorded during the
testing
During review of the continuous temperature data, Clark noted that the average
inlet temperature to the APCS was 1,000°F, whereas design information
contained in the TBP indicated that the maximum design temperature of the
APCS is 950°F.
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Example Action: The actual temperature is higher than the design maximum temperature for the
APCS. Clark asks that the facility provide the manufacturer's actual APCS
design data and explain the higher temperature.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
7.3.5 Verifying Combustion Unit Temperature
Regulations: 40 CFR Part 266.103
Guidance: U.S. EPA. 1989. "Checklist for Reviewing RCRA TBRs." Revision 3.
February 10. Section III.
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 2, and Appendix F, Form 6.
Explanation: Combustion chamber temperature must be limited by both a minimum and
maximum value. A high combustion zone temperature can lead to increased
metals vaporization which may, in turn, increase emissions of hazardous metals.
Conversely, a low combustion zone temperature can lead to decreased
destruction efficiency for organic compounds, which may result in increased
emissions of hazardous organics constituents. During a trial burn test, the facility
should continuously measure combustion zone temperature; these continuous
values are used to calculate and record average 1-minute values. The 1-minute
values are used to calculate the following values for each run:
• Average
• Maximum
• Minimum
• Average HRAs
• Maximum HRAs
• Minimum HRAs
Standard deviations for each of these calculated values should also be presented.
Permit limits on minimum and maximum combustion zone temperatures for
conventional trial burn tests are typically calculated using the average HRAs
value from the three low-or high-temperature test runs. Permit limits based on
risk burn data will be based on the arithmetic mean of the lowest and highest
average HRAs values recorded during each of the three risk burn runs.
Development of permit limits for combustion zone temperature is discussed in
detail in Component 7—How to Prepare Permit Conditions.
If the combustion device contains both a PCC and an SCC, temperature should
be measured inside each chamber. Alternative temperature locations should be
as close to the combustion zone as is practical and must be upstream of any
quench water injection.
Check For: Q Combustion unit temperature during the trial burn (minimum of three runs
per test condition)
The following values should be provided for each run of the trial burn
test:
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Q Minimum and maximum instantaneous concentrations
Q Minimum and maximum HRA concentrations
Q Standard deviation of instantaneous and HRA values
Q Average instantaneous and HRA values for all runs at each test
condition
Continuous temperature strip chart recorded during testing
If dual thermocouples are installed, confirm which instrument
corresponds to which strip chart or data set
Whether trial burn temperatures are near target values established in the
TBP
Example Situation:
Example Action:
Q Verify all calculated values presented in the TBR
Lois reviews two average PCC temperatures 1,225 °F and 1,281 °F measured by
two probes located on opposite sides of the combustion chamber. She becomes
suspicious because of the large temperature difference, but based on the
instantaneous data the averages appear to be correct. A further detailed review
of the calibration data for the thermocouples indicates that, given the ±50°F
accuracy of the thermocouples used, the 56 °F difference between the two
values is acceptable.
Although Lois determines that the data is acceptable, so that future readers will
understand the reason for the temperature difference, she requests that the
facility add a detailed discussion to the TBR explaining (1) why the two average
values are so different, (2) how the calibration data support the difference, and
(3) why the data are acceptable.
Notes:
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COMPONENT 6— HOW TO REVIEW A TRIAL BURN REPORT
7.3.6 Verifying Air Pollution Control System Control Parameters
Regulations: 40 CFR Part 266. 103
Guidance: U.S. EPA. 1989. "Checklist for Reviewing RCRA TBRs." Revision 3.
February 10. Section III.
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 2, and Appendix F, Form 6.
Explanation: APCS control parameters must be recorded in order to set permit limits that will
maintain the particulate and acid gas removal efficiency demonstrated during the
trial burn. The TBR should include a continuous record of each control
parameter monitored (see below), as well as the following calculated values as
appropriate:
• Average
• Maximum
• Minimum
• Average HRAs
• Maximum HRAs
• Minimum HRAs
The standard deviation of each of these calculated values should also be
presented. The use of these values to establish permit limits is described in detail
in Component 7 — How to Prepare Permit Conditions.
Check For: Based on the type of APCS used, various control parameters must be recorded
during the trial burn test and reported in the TBR. Important control parameters
may include:
Q Baghouse and fabric filter
Q Inlet gas temperature
Q Pressure drop
Q Flue gas flow rate
Q Air-to-cloth ratio
Q Electrostatic precipitator
Q Inlet gas temperature
Q Direct current voltage
Q Flue gas flow rate
Q Venturi Scrubber
Q Inlet gas temperature
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Q Pressure drop
Q Liquid flow rate
Q Liquid to flue gas ratio
Q Maximum suspended solids
Q pH (if used for acid gas removal)
The reviewer should check to ensure that continuous data for each applicable
control parameter are included in the TBR. The reviewer should also verify all
calculated values.
Example Situation: In reviewing the TBR, Clark notes that the facility (1) uses a venturi scrubber as
an APCS, and (2) records inlet gas temperature and liquid flow rate as control
parameters.
Example Action: Clark notes that venturi scrubber pressure drop is a key control parameter,
indicating the performance of the system. Clark asks that the facility explain
why it does not measure this key parameter.
Notes:
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7.4
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
REVIEWING FUGITIVE EMISSIONS SOURCES AND MEANS OF CONTROL
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40CFRPart270.62(b)(6)
40 CFR Part 266.103
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapters.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapter 6.
Regulations require that fugitive emissions be controlled by (1) sealing the
combustion zone against fugitive emissions, (2) maintaining the combustion zone
pressure lower than atmospheric pressure, or (3) using an alternative means.
The objective of these requirements is to ensure that potentially toxic gases are
not emitted through leaking seals, access doors, expansion joints, or openings in
combustion devices.
Additional requirements for monitoring and controlling fugitive emissions are
highlighted in Component 3, Section 2.10, of this manual.
Q The existence of a fugitive emissions control system
Q Whether fugitive emission controls include the following:
Q Sealed combustion zone
Q Combustion zone pressure lower than atmospheric
Q Alternative fugitive emissions control scheme of periodic
monitoring used for systems operating at pressures higher than
atmospheric
Lois noted that the TBR did not contain any information on the fugitive emissions
control system for the combustion zone.
Lois reviews the design information contained in the TBP, as well as the process
monitoring and process description (see Section 5.0 of this component) portion of
the TBR for the combustion zone design and actual pressure. This pressure
should be lower than atmospheric pressure. If it is not, Lois will ask the facility
to identify the fugitive emission control system that was used.
Notes:
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8.0
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
REVIEWING CHAPTER 5—PROCESS AND STACK GAS SAMPLING
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 266.103
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapters.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapters.
Process and stack gas sampling results are used to develop permit limits. This
section of the TBR describes process and stack gas sample types, sampling
points, sampling methods, sampling frequency, and sample preparation methods.
It also contains APCS parameter sampling procedures.
Q Sampling locations and methods (see Section 8.1)
Q Waste and fuel feed sampling (see Section 8.2)
Q Process residuals sampling (see Section 8.3)
Q Stack gas sampling procedures (see Section 8.4)
Clark reviewed the TBP to ensure that all types of process and stack gas
sampling listed were conducted during the actual trial burn test. He also
reviewed various hourly analytical data to assure that waste feed stream
characteristics were consistent. Clark referenced Section IV of the Checklist for
Reviewing RCRA Trial Burn Reports to aid in the review of procedures for
process and stack gas sampling.
Based on his review of the TBP included as Appendix A to the TBR, Clark
learned that the sample from the gaseous waste feed stream was to have been
sampled once every 15 minutes and analyzed for the potential POHC of concern.
The TBR, including the analytical data, indicated that the gaseous waste stream
was sampled only once every hour.
Clark develops a comment asking that the facility explain why it did not sample
the gaseous stream once every 15 minutes. Clark states that if the composition
of the gas stream does not change and is regularly generated from the same
equipment, an hourly sample may be adequate. Therefore, Clark requests that
detailed statistical data be provided by the facility supporting the consistency of
the gaseous waste steam composition and the deviation from the TBP before he
can complete his assessment.
Notes:
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8.1
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
REVIEWING SUMMARY OF SAMPLING LOCATIONS AND METHODS
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 266.103
U.S. EPA. 1989. "Checklist for Reviewing RCRA TBRs." Revision 3.
February 10. Section IV.
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapters.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92011. Chapters.
This section of the manual summarizes locations and methods used for each
process sampling parameter.
Q Liquid waste feed sampling location and method
Q Solid waste feed sampling location and method
Q Auxiliary fuel feed sampling location and method
Q Gaseous waste feed sampling location and method
Lois reads in the TBR that "Liquid waste feed samples were collected at
15-minute intervals and composited over each run. Liquid waste feed samples
were collected from the incoming line to the feed tank." Is this procedure
acceptable?
No. More desirable locations for collecting the liquid waste feed include
(1) from a sampling port in the waste feed line just upstream of the burner, (2)
from a sampling port in the waste feed tank recirculation line, or (3) from the
feed tank itself (in that order). This method would provide a uniform, consistent
sample to compare to the sample collected from the incoming line to the tank.
Lois needs to review the oversight report and the TBP to (1) determine if the
alternative sampling location was approved, and (2) ensure that waste feed
samples collected at this location are representative of waste fed to the
combustion unit.
Notes:
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8.2
REVIEWING SUMMARY OF WASTE AND FUEL FEED SAMPLING
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 266.103
U.S. EPA. 1989. "Checklist for Reviewing RCRA TBRs." Revision 3.
February 10. Section IV.
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 5, Table 5-1, Table 5-4, and
Appendix F.
Waste feed and fuel feed must be analyzed for all parameters, as outlined in the
approved TBP. Analysis for ash, heating value, metals, viscosity, chlorine, and
POHCs is required, whereas analysis for other parameters may not be required.
Q Whether all hazardous waste feed streams are sampled
Q Whether all auxiliary waste feed streams are sampled
Q Whether all solid waste feed streams are sampled
Q Parameters analyzed (such as moisture, density, ash, viscosity, heating
value, and halides)
Q Sampling method
Q Sampling frequency (liquid waste: one every 15 minutes; solid waste:
one every 15 minutes for bulk solid waste, one representative grab
sample for containerized solid waste; auxiliary fuel feed: one per run)
Q Composite sampling method used if different waste streams are involved
Q Sampling location
Q Sampling duration (minimum 1 hour per run)
The following subsections further describe how to review the following
information:
Q POHC feed rate (see Section 8.3.1)
Q Ash feed rate (see Section 8.3.2)
Q C12 feed rate (see Section 8.3.3)
Q Hazardous metal feed rate (see Section 8.3.4)
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Q Combustion unit heat input rate (see Section 8.3.5)
Example Situation: Lois and Clark reviewed the waste and fuel feed sampling in the TBR and TBP.
The following are their observations:
• In reviewing the TBR, Lois and Clark note that one grab sample
of liquid waste was collected every 15 minutes and composited
into one sample for each run; however, the TBR does not
specify the sample volume, sampling location, or sampling
method.
• The TBR stated that representative samples from two different
solid waste streams were collected and analyzed for the
parameters of concern.
Lois and Clark review the TBR further to see whether auxiliary fuel feed
parameter sampling was conducted as outlined in the approved TBP. An
auxiliary fuel stream such as supplemental natural gas will not require extensive
parameter sampling, whereas a fuel oil-type auxiliary fuel stream (which may
contain a variety of volatile and semivolatile PICs or PIC-precursors) will require
more detailed parameter sampling. The TBR indicated that the facility uses fuel
oil number 2, supplied by XYZ Pipeline Company, as the auxiliary fuel. The TBR
also indicated that only one sample was analyzed during the entire stack test.
Example Action: Lois and Clark take the following actions:
• Lois and Clark ask that the facility specify the sample volume
(100 milliliters per grab sample every 15 minutes is
recommended), sampling location, and sampling method. If the
waste is fed to the BIF unit from a storage tank, the preferred
sampling location would be the recirculation line or the storage
tank.
• Clark reviews the TBR (Appendix D) to see whether the
frequency of sampling for these two solid waste streams is
identified and carried out in accordance with the approved TBR.
For containerized solid waste, grab representative samples from
each drum, composited into one sample for each run, are
recommended; for bulk solid waste, one grab sample collected
every 15 minutes, and composited into one sample for each run,
is recommended. Clark asks the facility to summarize this
information in the text.
• The preferred frequency of sampling for auxiliary fuel feed is
one per run. The analytical results for a single sample collected
during the trial burn test should be acceptable, provided that the
facility submits supporting information demonstrating that the
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characteristics of the fuel oil used at the facility are consistent
over time.
Notes:
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8.2.1
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Verifying Principal Organic Hazardous Constituent Feed Rate
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 266. 103
40 CFR Part 266. 104
No specific references are applicable to this section of the manual.
For all runs of the test condition designed to demonstrate DRE, 40 CFR Part
266.104 requires that the facility's permit specify POHCs among those
constituents listed in Part 261, Appendix VIII for each waste to be burned.
The TBR reviewer should check that all POHCs have been identified and verify
all POHC feed rate calculations.
Q Type of POHC measured in each waste during the trial burn
Q POHC feed rate of each waste during the trial burn
Q POHC mass rate calculations in the appendix of the report
The types and amount of POHCs in the waste are important to overall
combustion unit performance. The facility will evaluate the overall ability of the
combustion unit to destroy POHCs during the trial burn. Generally, organic
constituents that are the most difficult to combust are designated as POHCs
during preparation of the TBP.
Example Comments: Lois checked the TBP (typically included as Appendix A to the TBR) to see if
the POHCs identified in the waste feed were analyzed and feed rates calculated
during the trial burn. She found both factors consistent with the TBP.
Notes: _
Example Situation:
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_ COMPONENT 6— HOW TO REVIEW A TRIAL BURN REPORT
8.2.2 Verifying Ash Feed Rate
Regulations: 40 CFR Part 266. 103
Guidance:
Explanation:
Check For:
Example Section:
No specific references are applicable to this section of the manual.
Typically, the PM emission rate increases as the ash feed rate increases.
Therefore, excessive particulates and overloading of APCS are prevented by
setting limits on the maximum amount of ash in the feed streams.
Ash may consist of the following categories of materials:
• Sodium salts, especially sodium chloride
• Inorganic metal oxides
• Silicon-organic compounds, such as silanes or silicones
Exhibit 8.2.2-1, see page 6-59, shows step-by-step procedures for calculating or
verifying the ash feed (input) rate. For facilities such as cement kilns and
lightweight aggregate kilns that feed raw materials containing high amounts of
ash, this parameter is not applicable. In these cases, excessive PM emission
rates are controlled by placing a limit on maximum production rate.
The TBR reviewer should check that all feed streams have been accounted for
and verify all ash feed rate calculations.
Q Ash concentration in each feed stream
Q Flow rate of each stream containing ash
Q Ash feed rate calculations in the appendix of the report
Lois reviews the ash feed rate calculations presented in the report. During her
review, she notes that the ash feed rate is based on the ash content of the liquid
hazardous waste feed stream and the solid hazardous waste feed stream. The
ash content of the nonhazardous viscous waste is not included.
Example Comments: Lois prepares a comment requiring the facility to include the ash content of all
waste feedstreams—hazardous and nonhazardous—in their calculation of the ash
feed rate. Ash from any source that is introduced into the combustion unit will
affect the PM emission rate and APCS performance.
Notes:
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EXHIBIT 8.2.2-1
ASH INPUT RATE CALCULATION
Rates of ash input to the boiler or furnace must be calculated for each run. Ash input rates for each
stream will be calculated by multiplying the feed rate (pounds per hour) by the percent ash and dividing
the result by 100. The total ash input rate is then obtained by summing ash input rates for each waste
stream. (This calculation does not apply to cement or lightweight aggregate kilns.)
Summary:
(Line 1 x Line 2) + 100 = Line 3 for each feed stream
Line 3 + Line 3 + Line 3 + ... = Line 4 at the bottom
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EXHIBIT 8.2.2-1 (Continued)
MODE:
Ash Inputs
Run Number/Date
Line
No.
Feed Stream No. 1:
Feed rate (Ib/hr)
% Ash
Ash input (Ib/hr)
1
2
3
Feed Stream No. 2:
Feed rate (Ib/hr)
% Ash
Ash input (Ib/hr)
1
2
3
Feed Stream No. 3:
Feed rate (Ib/hr)
% Ash
Ash input (Ib/hr)
1
2
3
Feed Stream No. 4:
Feed rate (Ib/hr)
% Ash
Ash input (Ib/hr)
1
2
3
Feed Stream No. 5:
Feed rate (Ib/hr)
% Ash
Ash input (Ib/hr)
1
2
3
Feed Stream No. 6:
Feed rate (Ib/hr)
% Ash
Ash input (Ib/hr)
Total Ash Input (Ib/hr) =
1
2
3
4
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8.2.3
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Verifying Chlorine Feed Rate
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
Notes:
40 CFR Parts 266.103 and 266.107
No specific references are applicable to this section of the manual.
Typically, HC1 and C12 emission rates increase as the C12 feed rate increases.
The TBP should be reviewed to see whether all feed streams containing C12
were sampled and analyzed during the actual trial burn test. C12 feed rate
calculations should be checked for accuracy. Exhibit 8.2.3-1, see page 6-62,
shows step-by-step procedures for calculating or verifying the C12 feed input rate.
Q C12 concentration and flow rate of each waste stream containing C12
Q C12 feed rate calculations in the appendix of the report
Q Methods used to analyze for C12
In reviewing the TBR, Clark notes that the feed rate of the liquid waste stream
was 1,500 Ib/hr with 15 percent C12, and that the HC1 feed rate was 22.5 Ib/hr.
Clark determines that the C12 feed rate reported in the TBR is in error; the
reported C12 feed rate should be 225 Ib/hr (that is, 1,500 Ib/hr x 0.15 = 225 Ib/hr).
Clark asks that the facility correct this error in the TBR.
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EXHIBIT 8.2.3-1
CHLORINE INPUT RATE CALCULATION
Chlorine gas (C12) input rates must be calculated for each run. C12 input rates for each waste stream are
calculated by multiplying the feed rate (pounds per hour) by the percent C12 and dividing that result by
100. The total C12 input rate is then obtained by summing the C12 input rates for each waste stream.
Summary:
(Line 1 x Line 2) -^ 100 = Line 3 for each feed stream
Line 3 + Line 3 + Line 3 + ... = Line 4 at the bottom
To convert pounds per hour to grams per second for Line 5:
(Line 4 x 453.6) - 3,600 = Line 5
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EXHIBIT 8.2.3-1 (Continued)
MODE:
Chlorine Inputs
Run Number/Date
Line
No.
Feed Stream No. 1:
Feed rate (Ib/hr)
% Chlorine (C12)
C12 input (Ib/hr)
1
2
3
Feed Stream No. 2:
Feed rate (Ib/hr)
% C12
C12 input (Ib/hr)
1
2
3
Feed Stream No. 3:
Feed rate (Ib/hr)
% C12
C12 input (Ib/hr)
1
2
3
Feed Stream No. 4:
Feed rate (Ib/hr)
% C12
C12 input (Ib/hr)
1
2
3
Feed Stream No. 5:
Feed rate (Ib/hr)
% C12
C12 input (Ib/hr)
1
2
3
Feed Stream No. 6:
Feed rate (Ib/hr)
% C12
C12 input (Ib/hr)
Total C12 Input (Ib/hr) =
Total C12 Input (g/sec) =
1
2
3
4
5
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8.2.4
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Verifying Hazardous Metal Feed Rate
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
Notes:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
Typically, metal emission rates rise with increases in the feed rate of metal in
waste feed streams. The TBP should be reviewed to see whether all metals
potentially present in the feed streams were analyzed during the actual trial burn
test. Metal feed rate calculations should be checked for accuracy.
Exhibit 8.2.4-1, see page 6-65, shows step-by-step procedures for calculating or
verifying the metals feed rate.
Q Feed rate of each of the 10 BIF-regulated metals: antimony; barium;
lead; mercury; silver; thallium; arsenic; beryllium; cadmium; and
chromium; plus non-BIF-regulated metals: nickel; and selenium
Q Total feed stream input rate
Q Total hazardous waste feed stream input rate
Q Total pumpable hazardous waste feed stream input rate
Q Methods used to analyze metals
Q Calculations based on feed rate and metals concentration
During the TBR review, Lois discovered that waste feed analysis data indicated
that arsenic was present in three feed streams; however, calculations showed
that arsenic came from only two streams.
Lois asked that the facility (1) revise the arsenic feed rate reported values and
affected calculations, and (2) present a summary of the effects that the increased
arsenic feed rate would have on the proposed permit limits.
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.2.4-1
METAL CONCENTRATIONS IN FEEDS AND INPUT RATES
The following worksheet must be completed for each run. Each feed stream analyzed for metals is listed
on Line 1. The concentration of each metal contained in each feed stream is obtained from laboratory
analysis and entered on Line 3. To calculate the input rate for each metal (Line 4), multiply the
concentration of the metal (Line 3) by the feed rate for the particular waste stream (Line 2). That
product is then divided by 106 to convert to the proper units—pounds per hour. The first of the two metal
input rate columns is calculated by summing input rates for that particular metal for all feed streams. That
sum is then multiplied by 453.6 and divided by 3,600 to convert to grams per second for Column b.
Summary:
Line 4 = (Line 3 X Line 2) - 106
Column a = sum of all input rates for each metal
Column b = ([Column a x 453.6] - 3,600)
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EXHIBIT 8.2.4-1 (Continued)
MODE: -
WORKSHEET*. METAL CONCENTRATIONS JH USES AND tNTOT RATES
RUN No:
D*u:
Feed R*te QbAr)
SterlAc)
Inpyi rate (Ib/lu"}
Ancok (Al)
Concemniton (ul/g)
Input me (Hs/Jir)
Input file (Ib/br)
BcryOmm (B«)
Conn (ug/^
C.dmhan (Cd)
Input rate Ob/to)
Inpul one (!b/hr)
Mcrcnrjr (Hfi
Concentmion {"f/D
Input rate (Ib/hr)
LeadCPb)
Input nte (tb/hr)
Antrmooy
-------
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.2.5 Verifying Combustion Unit Heat Input Rate
Regulations: 40 CFR Part 266.103
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 2, and Appendix F, Form 4.
Temperature in the combustion unit is dependent on (among other variables such
as moisture content and excess air) heat created from the input of the auxiliary
fuel and waste feed stream. Because increased combustion zone temperatures
may lead to increased metals vaporization which may, in turn, increase emissions
of hazardous metals, it is necessary to measure the heat content of each feed
stream. Exhibit 8.2.5-1, see page 6-68, shows step-by-step procedures for
calculating or verifying the heat input rate.
Q Individual waste stream heat input rate
Q Auxiliary fuel stream heat input rate
Q Total heat input rate
In reviewing the TBR, Clark reads that the facility uses natural gas as auxiliary
fuel, and an natural gas analysis supplied by the pipeline company includes the
LHV and HHV for natural gas. A review of the heat input rate calculations
indicated that the facility used the LHV for the heat input rate contribution from
natural gas.
Because the calculated heat input rate will be used to establish a maximum heat
input rate limit, the use of the HHV will be more conservative, because for a
given natural gas flow rate, the HHV will represent the maximum actual heat
input. Clark asks that the facility revise the TBR to recalculate the heat input
rate for natural gas using the HHV instead of the LHV.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-72
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.2.5-1
HEAT INPUT RATE CALCULATION
Heat input rates to the boiler or furnace must be calculated for each run. Heat input rates for each feed
stream are calculated by multiplying the feed rate (pounds per hour) by the heating value (British thermal
units per pound). The total heat input rate is then obtained by summing heat input rates from each waste
stream.
Summary:
(Line 1 x Line 2) = Line 3 for each feed stream
Line 3 + Line 3 + Line 3 + ... = Line 4 at the bottom
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-73
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.2.5-1 (Continued)
MODE:
Heat Inputs
Run Number/Date
Line
No.
Feed Stream No. 1:
Feed rate (Ib/hr)
HV British thermal unit (Btu) per
pound
Heat input (Btu/hr)
1
2
3
Feed Stream No. 2:
Feed rate (Ib/hr)
HV (Btu/lb)
Heat input (Btu/hr)
1
2
3
Feed Stream No. 3:
Feed rate (Ib/hr)
HV (Btu/lb)
Heat input (Btu/hr)
1
2
3
Feed Stream No. 4:
Feed rate (Ib/hr)
HV (Btu/lb)
Heat input (Btu/hr)
1
2
3
Feed Stream No. 5:
Feed rate (Ib/hr)
HV (Btu/lb)
Heat input (Btu/hr)
1
2
3
Feed Stream No. 6:
Feed rate (Ib/hr)
HV (Btu/lb)
Heat input (Btu/hr)
1
2
3
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-74
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
\ Total Heat Input (Btu/hr) =
8.3
REVIEWING SUMMARY OF PROCESS RESIDUALS SAMPLING
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
Notes:
40 CFR Part 270.62
U.S. EPA. 1989. "Hazardous Waste Incineration Measurement Guidance
Manual." EPA-625-6-89-021. June. Section 3.4.6, Page 23.
Samples of process residual streams (for example, bottom ash, scrubber effluent,
or baghouse dust) are analyzed to determine the fate of POHCs during the DRE
portion of the trial burn and metals during the high temperature test. In some
cases, samples of these streams could be analyzed for metals or PICs to better
assess the fate of these constituents in the system.
Q Process residual sampling location and sampling frequency
Q Constituent/concentrations in each sample
Q Sample compositing techniques
Q Discussion of results compared to system performance
In reviewing the TBR, Lois notes that samples of bottom ash were not analyzed
for metals and POHCs of concern.
Bottom ash should have been analyzed for metals and POHCs of concern. Lois
writes a comment asking the facility to explain and justify the failure to analyze
the bottom ash sample.
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-75
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4 REVIEWING STACK GAS SAMPLING SUMMARY
Regulations: 40 CFR Part 266.103
Guidance: U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 5, and Appendix F, Forms 6
through 10.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapters.
Explanation: This section of the TBR summarizes the types of stack gas sampling that were
conducted during the trial burn.
Check For: The following subsections describe various aspects of stack gas sampling:
Q Sampling and analysis of stack gas during the trial burn test for
determination of specified parameters (see Section 8.4.1)
Q Data tables for stack gas characteristics (see Section 8.4.2)
Q Data tables for emission rates of constitutents of potential concern (see
Section 8.4.3)
Example Situation: The subsections that follow contain example sections for each stack gas sampling
parameter.
Example Comment: The subsections that follow subsections contain example comments for each
stack gas sampling parameter.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-76
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1
Reviewing Summary of Stack Gas Sampling Methods
Regulations:
Guidance:
Explanation:
40 CFR Part 60, Appendix A
40 CFR Part 266.103, Appendix IX to 40 CFR Part 266
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 5, and Appendix F, Forms 6
through 10.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapters.
This section of the manual summarizes the stack gas sampling methods used
during the actual trial burn test. Sampling stack gas method procedures are
described in 40 CFR Part 60, Appendix A; 40 CFR Part 266 Appendix IX; and in
SW-846.
Check For:
The reviewer should determine which methods were used for the indicated
parameter. Examples include:
Q 40 CFR Part 60, Appendix A, Method 1—Traverse Points (see Section
8.4.1.1)
Q 40 CFR Part 60, Appendix A, Method 2—Velocity and Flow Rate (see
Section 8.4.1.2)
Q 40 CFR Part 60, Appendix A, Method 3—CO2, O2, Excess Air,
Molecular Weight (see Section 8.4.1.3)
Q 40 CFR Part 60, Appendix A, Method 4—Moisture Content (see Section
8.4.1.4)
Q 40 CFR Part 60, Appendix A, Method 5, or Test Methods for Evaluating
Solid Waste, SW-846 Method 0050—PM (see Section 8.4.1.5)
Q Appendix IX to 40 CFR Part 266 or SW-846, Method 0050 or
Method 0051—HC1 and C12 (see Section 8.4.1.5)
Q Test Methods for Evaluating Solid Waste: SW-846
Method 0030 or SW-846 Method 0031—Volatile Organic Compounds
(VOC) (see Section 8.4.1.6)
Q Test Methods for Evaluating Solid Waste; SW-846
Method 0010—Semivolatile Organic Compounds (SVOC) (see Section
8.4.1.7)
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-77
-------
Example Situation:
Example Action:
Notes:
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Q 40 CFR Part 266, Appendix IX or SW-846, Method 23, or SW-846
Method 23A—PCDD/PCDF (see Section 8.4.1.8)
Q 40 CFR Part 266, Appendix IX, Section 3.1, Method 0012, or SW-846
Method 0060—Metals (see Section 8.4.1.9)
Q 40 CFR Part 266, Appendix IX, Section 3.2, Method 0013, or SW-846
Method 0061—Hexavalent Chromium (see Section 8.4.1.10)
Q 40 CFRPart 266, Appendix IV, Section 3.5, or SW-846 Method
0011—Aldehydes and Ketones (see Section 8.4.1.11)
Q SW-846 Method 0040—Organic Constituents from Combustion Sources
using Tedlar® Bags (see Section 8.4.1.12)
Note that Methods 0010 and 0040 are used to collect samples for the
measurement of unspeciated total organics (TO). Additionally, Methods 0010
and 23 or 0023 A may be combined—additional guidance of these procedures are
described in Component 4—How to Conduct Trial Burn Test Oversight.
Sampling methods listed in Appendix IX to 40 CFR Part 266 for BIF units should
be used only for the compounds identified by the method. Clark uses Appendix
IX for reference in reviewing TBRs. If certain parameter methods are not listed
in Appendix IX to 40 CFR Part 266, Clark uses 40 CFR Part 60, Appendix A and
SW-846, Test Methods for Evaluating Solid Waste.
Clark reviews the TBP and verifies that proposed sampling methods were used
during the actual trial burn test.
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-78
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.1 Verifying Traverse Points
Regulation: Title 40 CFR Part 60, Appendix A, U.S. EPA Method 1
Guidance:
Explanation:
Check For:
Example Section:
No specific references are applicable to this section of the manual.
Title 40 CFR Part 60, Appendix A, U.S. EPA Method 1 should be followed for
sample and velocity traverses. It should be used for all runs of all test conditions.
Stack gas is sampled at each traverse point to accurately measure the velocity
and flow rate of stack gas. U.S. EPA Method 1 traverse points selected should
meet the minimum requirements of; if these requirements cannot be met,
additional traverse points can be used for sampling as long as cyclonic flow
conditions are not present within the stack.
Q Stack and duct diameter or dimensions
Q Numbers of traverse points selected for PM and velocity traverses
(based on stack dimensions, location of sampling ports, and upstream and
downstream disturbance)
Q Absence of cyclonic flow
The following situation is encountered in the field:
Stack diameter =18 inches
Duct diameter upstream from flow disturbance to sample port = 1
Duct diameters downstream from flow disturbance to sample port = 4
Method 1 calculations indicate the following sample port locations:
Duct diameters upstream from flow disturbance to sample port = 2
Duct diameters downstream from flow disturbance to sample port = 8
Stack Diameter
>2 feet
1 to 2 feet
No. of
Traverse Points
12
Example Comments: Since the sampling port location does not meet the standard Method 1 conditions,
additional traverse points must be used, and the absence of cyclonic flow must be
verified. Clark checks to ensure that the sampling was conducted using 24
traverse points and that the absence of cyclonic flow was verified.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-79
-------
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.2 Verifying Stack Gas Velocity and Flow Determination
Regulation:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 60 Appendix A, U.S. EPA Method 2
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 5, and Appendix F, Form 6.
The average gas velocity in a stack is determined from the gas density and from
the measurement of the velocity head with a Type S pitot tube.
The stack gas velocity calculation method and all equations are provided in 40
CFR Part 60, Appendix A, Method 2 (see Section 5). It should be used for all
runs of all test conditions.
Exhibit 8.4.1.2-1, see page 6-76 provides an example Method 0050 field data
sheet form. Exhibit 8.4.1.2-2, see page 6-79, shows step-by-step procedures for
calculating velocity and flow rate.
Q Type of pitot tube
Q Pitot tube coefficient
Q Data sheet for velocity traverse (for each traverse point there should be
a measurement of the velocity head and stack temperature)
Q Sampling time (minimum of 2 hours for a composite sample per run)
Q Calculation of stack gas velocity under (1) actual and standard
temperature and pressure (STP) conditions, and (2) corrected to 7
percent O2
Q Calculation of stack gas flow rate under (1) actual and STP conditions,
and (2) corrected to 7 percent O2
In reviewing the TBR field logsheet, Lois notes that pitot tube 001 was used with
a pitot tube coefficient of 0.84, whereas the pitot tube calibration data package
indicates the coefficient for pitot tube 001 is 0.83.
Because the calibration data package shows a coefficient of 0.83 for pitot tube
001, this value should be used for calculation purposes. Lois asks that the facility
revise the calculations based on the revised coefficient.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-8
-------
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-81
-------
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.4.1.2-1
EXAMPLE METHOD 0050 DATA FORM
STACK TEST CALCULATIONS
Project:
Project No
Source
Run No.
Date
Sample Volume:
Sample Time
O2 Cone.
CO2 Cone.
TRAVERSE
POINT
NUMBER
1
i 2
3
4
5
6
7
a
9
1O
11
12
13
14
15
16
17
18
19
20
21
22
23
24
AVERAGE
^^M Barom.Ps,
H^^^^^^^^l Static Psr.: -O.O8 Ps:
Waste Boiler (MM5) Delta H <
6C
9: 1.7497 As:
Gamma: O.99O6 An:
Calculated
30.264
8.727
O.OOO524
^^^^^^^^| Pitot Coef.: O.84
76.825
144
4.2
12
StacK Dia.: 4O .in.
Nozzle Dia.: O.31 .in.
H2O Gain: 222.3 .ml
Part. Weight ,g
VELOCITY
DELTA P DELTA H
Actual Sq. Root
O.11
O.1
0.12
O.15
O.13
0.13
0.16
O.21
0.26
0.29
0.28
0.26
O.17
O.18
O.19
0.24'
0.23
0.21
0.16!
O.14|
0.15 |
0.171
O.14!
0.13
0.179583
DRY GAS METER
TEMPERATURE
Inlet Outlet
O.331662 O.59J 73 72
O.3162281 0.5
O.34641 0.6
0.387298 0
O.360555 1 0
3 74 73
A 76 | 74
8 78 1 75
7 79 75
O.36O555I O.7J 79 76
O.4 0.86 81 I 77 i
0.458258 1.1
2 82 i 77 !
O.5O99O2 1.39i 82 1 77:
O.538516; 1.55 1 82 76 1
O.52915 1.
5 ; 82 77
O.5O99O2 i 1 .39 82 77 \
O.412311 O.91 8O| 77'
0.424264 ! O.96 I 81 I 78
O.43589I 1.02 1 81 77 1
0.489898 i 1.28 1 82 77!
O.479583. 1.23| 83 i 77'
O.45825B 1.12 83 i 77!
0.4 O.86i 83 77;
O.374166: O.75 ! 81. 77
O.387298 O.8 SO 751
0.412311! O.91 81 ! 771
O.374166I O.75I 81! 76 >
O.36O555 O.7! 8O j 76,
O.419O47: 0.9608333 1 78.1875 '
STACK
TEMP.
287
275'
29O
298 |
30O
299
3O3I
3O4
3O4
303;
3O4
3O4
270'
270
276
301 '
304
3O4
3O3
3O5
3O3
305
303
302;
296.541 7 \
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-82
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.4.1.2-1 (Continued)
EXAMPLE METHOD 0050 DATA FORM
STACK TEST DATA SHEET
Barom. Psr.:
Static Psr.:
Delta H O:
Gamma:
Pilot Cocf.:
Stack Dia.:
Stack Area:
Pan Length:
Port Dia.:
Probe Liner:
Scnematic of Stack
TRAVERSE SAMPLING
POINT TIME
NUMBER Clock Sampla
vecocnv-
DELTA P DELTA H
XAD
TEMP.
GAS
SAMPLE
VOLUME
D"SY7jAS"M£TeiT~~f:(LTBPr
TEMPERATURE BOX
Inlet Outlet TEMP.
STACK LAST TRAiN~ ~
TEMP IMPINGER VACUUM
TEMP
Pttol impact: *"*
Pito^static: ~^ _
Train initial: c>.O-*>~ ^)
Train^tnai^fc1 OQi &
Train initial:^ C-C5"
Train FinaJ^fl;
Operator Signaturai
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-83
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.4.1 2-1 (Continued)
EXAMPLE METHOD 0050 DATA FORM
STACK TEST IMPINGER LAB DATA SHEET
PROJECT:
SOURCE:
TRAIN I.D.:
COLLECTED BY:
JOB NO.:
DATE:
TEST NO..
CHKD. BY:
1
2
3
4
?Se.J- ^.i. ^07.0
(pfe.A, k'13.0 0. i
b04-,u bCS.& 1.0
5-O -*» ^ . "^ O ' O yy"t
/ / o . / / tJ^^l J ftp , /
6
7
TOTAL ^^i.3
COMMENTS:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-84
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.4.1.2-2
STACK GAS VELOCITY CALCULATION
RAW DATA INPUT
FOR
EPA METHOD 0050 FLOW RATE CALCULATIONS
Plant Name:
Location:
Unit:
Condition:
Run No.
Variable Definition
Po - Average Meter Differential Pressure
Pb - Barometric Pressure
Tm - Average Dry Gas Meter Temperature
DGMC - Dry Gas Meter Correction Factor
Vlcg - Total Condensate Collected
Vm - Dry Gas Meter Sample Volume
T - Sampling Time Duration
%CO2 - Carbon Dioxide Concentration, Dry Basis
%Oi - Oxygen Concentration, Dry Basis
%CO - Carbon Monoxide Concentration, Dry Basis
Dn - Nozzle Diameter
Cp - Pilot Tube Coefficient
Dp - Avg.Sq. Root of Velocity Head
Ts - Average Stack Gas Temperature
Sp - Static Pressure of Gas Stream
D - Stack Diameter
XYZ Company
Anywhere, USA
BIFUNIT
NORMAL
ONE
Data Units
0.18 in. H2O
30.27 in.Hg
78.188 °F
0.9906 Dimensionless
222.3 grams
76.825 dcf
144.0 min
12.00 % Volume
4.20 % Volume
0.00 % Volume
0.3100 in.
0.84 Dimensionless
0.4190 in.H2O°5
296.5 °F
-0.08 in. H2O
40.00 in.
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-85
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.4.1.2-2 (Continued)
STACK GAS VELOCITY CALCULATION
COMPANY:
LOCATION:
SOURCE:
Variable
Cp
Vs
Qsd
Qact
Bws
Dp
Pb
Kp
Ts
Ms
Sp
Tstd
Pstd
CSA
Ps
Kl
K2
Pi
D
VELOCITY AND VOLUMETRIC FLOW RATE DETERMINATION
XYZ Company CONDITION:
Anywhere, USA TEST RUN:
BIFUNIT
VARIABLE LIST
Definition
Pitot Tube Coefficient
Stack Gas Velocity
Volumetric Flow Rate at Standard Conditions, Dry Basis
Volumetric Flow Rate, Wet Basis
Moisture Content
Avg. Sq. Root of Velocity Head
Barometric Pressure
Constant = 85.49 (ft)(lb/lb-mol)(in.HgA0.5)/(s)(°R)(in.H2O)
Average Stack Gas Temperature
Sample Gas Molecular Weight, Wet Basis
Static Pressure of Gas Stream
Absolute Standard Temperature (528)
Absolute Standard Pressure (29.92)
Stack Cross-Sectional Area
Absolute Stack Gas Pressure
Conversion Factor (13.6)
Conversion Factor (60)
Constant (3. 141 6)
Stack Diameter
TEST DATA
Variable Data Variable Data
Ms = 28.616 Dp = 0.4190
Bws= 0.1218 Pb = 30.27
Sp = -0.08 Ts = 756.5
NORMAL
ONE
Units
Dimensionless
ft/sec
dscfm
cfm
mole fraction
TT ^\®-5
in. H2O
in. Hg
°R
Ib/lb-mole
in. H20
°R
in. Hg
ft2
in. Hg
in. H20/in. Hg
sec/min
Dimensionless
in.
Variable Data
Cp = 0.84
D = 40.00
CALCULATIONS
Ps
Vs
Vs
CSA
Qact
Osd
Osd
Pb + (Sp/Kl) = 30.27 +(-0.08/13.6) =
(Kp)(Cp)(Dp)[(Ts)/(Ms)(Ps)r0.5
(85.49)(0.84)(0.4190)[756.5/(28.616)(30.26)]A0.5 = 28.13
(Pi)(DA2)/[(4)(144)] = (3.1416)(40.00)"2/[(4)(144)] =
30.26 in. Hg
ft/sec
8.73 ft2
(Vs)(CSA)(K2) = (28.13)(8.73)(60) = 14734.S cfm
(Qact)(l-Bws)(Tstd)(Ps) (14734.5)(1 - 0.1218)(528)(30.26)
(Ts)(Pstd) (756.5)(29.92)
9134.0 dscfm
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-8
-------
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.4.1.2-2 (Continued)
STACK GAS VELOCITY CALCULATION
FLOW RATE DATA SUMMARY
COMPANY:
LOCATION:
SOURCE:
Variable
%CO2
%co
%O2
%N2
Pb
Sp
Po
Ts
Tm
Vlcg
Vm
DGMC
Dp
Cp
D
Md
Ms
Ps
Pm
Vmstd
Vwstd
Bws
Bwd
CSA
Vs
Qact
Qsd
I
XYZ Company
Anywhere, USA
BIF UNIT
VARIABLE LIST
Definition
INPUT DATA SUMMARY
Carbon Dioxide Concentration, Dry Basis
Carbon Monoxide Concentration, Dry Basis
Oxygen Concentration, Dry Basis
Nitrogen Concentration, Dry Basis (gas balance)
Barometric Pressure
Static Pressure of Gas Stream
Average Meter Differential Pressure
Average Stack Gas Temperature
Average Dry Gas Meter Temperature
Total Condensate Collected
Dry Gas Meter Sample Volume
Dry Gas Meter Correction Factor
Avg. Sq. Root of Velocity Head
Pilot Tube Coefficient
Stack Diameter
RESULTS SUMMARY
Sample Gas Molecular Weight, Dry Basis
Sample Gas Molecular Weight, Wet Basis
Absolute Stack Gas Pressure
Absolute Dry Gas Meter Pressure
Dry Gas Meter Sample Volume, at Standard Conditions
Volume of Water Vapor Collected, at Standard Conditions
Moisture Content
Moisture Content
Stack Cross-Sectional Area
Stack Gas Velocity
Volumetric Flow Rate, Wet Basis
Volumetric Flow Rate, at Standard Conditions, Dry Basis
Isokinetic Sampling Rate
CONDITION:
TEST RUN:
Value
12.00
0.00
4.20
83.80
30.27
-0.08
0.18
756.5
538.2
222.3
76.825
0.991
0.419047
0.84
40.00
30.088
28.616
30.26
30.28
75.589
10.481
0.1218
12.18
8.73
28.13
14734.5
9134.0
95.74
NORMAL
ONE
Units
% Volume
% Volume
% Volume
% Volume
in. Hg
in. H2O
in. H2O
°R
°R
grams
dcf
Dimensionless
in. H20° 5
Dimensionless
in.
Ib/lb-mole
Ib/lb-mole
in. Hg
in. Hg
dscf
scf
mole fraction
% Volume
ft2
ft/sec
cfm
dscfm
%
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-87
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.4.1.2-2 (Continued)
STACK GAS VELOCITY CALCULATION
COMPANY:
LOCATION:
SOURCE:
Variable
I
Ts
Vmstd
Vs
T
An
Ps
Dn
Vlcg
Pi
Kl
K2
K3
K4
K5
Variable
Vmstd =
Vs =
Vlcg =
Ts =
An
An
ISOKINETIC SAMPLING DETERMINATION
XYZ Company CONDITION: NORMAL
Anywhere, USA TEST RUN: ONE
BIF UNIT
VARIABLE LIST
Units
Isokinetic Sampling Rate %
Average Stack Gas Temperature °R
Dry Gas Meter Sample Volume, at Standard Conditions dscf
Stack Gas Velocity ft/sec
Sampling Time Duration minutes
Cross-Sectional Area of Nozzle ft
Absolute Stack Gas Pressure in. Hg
Nozzle Diameter in.
Total Condensate Collected grams
Constant (3.1416) dimensionless
Conversion Factor (144) in /ft
Conversion Factor (100) Percent
Conversion Factor (17.64) °R/in. Hg
Conversion Factor (0.002669) Ha-ft3/ml-°R
Conversion Factor (60) sec/min
TEST DATA
Data Variable Data Variable Data
75.589 Ps= 30.26 K2 = 100
28.13 T= 144.0 K3= 17.64
222.3 Dn= 0.310 K4 = 0.002669
756.5 Kl = 144 K5 = 60
CALCULATIONS
(Pi)(Dnr2/[(4)(Kl)]
(3.1416)(0.310)A2/[(4)(144)] = 0.000524ft2
(K2)(Ts)[(Vmstd/K3) + (K4)(Vlcg)]
(K5)(Vs)(An)(Ps)(T)
(100)(756.5)[(75.589/17.64) + (0.002669)(222.30)]
(60)(28.13)(0.000524)(30.26)(144.0)
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.3 Verifying Gas Analysis for Carbon Dioxide, Oxygen, Excess Air, and Molecular Weight
Regulation: 40 CFR Part 60, Appendix A, Method 3
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
No specific references are applicable to this section of the manual.
A gas sample is extracted from a stack using one of the following techniques:
single-point grab sampling; single-point integrated sampling; or multipoint
integrated sampling. The gas sample is analyzed for CO, CO2, and O2. An orsat
or fyrite analyzer is used to measure dry molecular weight. This method should
be used for all runs of test conditions.
Exhibit 8.4.1.3-1, see page 6-84, shows step-by-step procedures for calculating
molecular weight.
Q Sampling method
Q Gas analysis method (Orsat or Fyrite)
Q Sampling time (minimum of 2 hours for composite sample per run)
Q Percent of CO, CO2, and O2
Q Molecular-weight calculations for each run
In reviewing the TBR, Lois notes that the average CO levels during the first run
was 90 measured as ppmv; however, the TBR molecular-weight calculations
sheet shows the percent CO value as zero.
The TBR molecular-weight calculations sheet for the first run should reflect the
actual concentration of 90 ppmv rather than the 0 percent that is indicated.
Although the percentage value will be very small, Lois asks that the facility
recalculate an accurate percent CO value. Percent CO is calculated as follows:
90 parts CO -. AA A AAri , ^^.
f- x 100 = 0.009 percent CO
106 parts total
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.4.1.3-1
MOLECULAR WEIGHT DETERMINATION
COMPANY:
LOCATION:
SOURCE:
Variable
Md
Ms
Bws
%CO2
%CO
%O2
%N2
0.32
0.28
0.28
0.44
18.0
MOLECULAR WEIGHT DETERMINATION
XYZ Company CONDITION:
Anywhere, USA TEST RUN:
BIF UNIT
VARIABLE LIST
Definition
Sample Gas Molecular Weight, Dry Basis
Sample Gas Molecular Weight, Wet Basis
Moisture Content
Carbon Dioxide Concentration, Dry Basis
Carbon Monoxide Concentration, Dry Basis
Oxygen Concentration, Dry Basis
Nitrogen Concentration, Dry Basis (gas balance)
Molecular Weight of Oxygen, divided by 100%
Molecular Weight of Carbon Monoxide, divided by 100%
Molecular Weight of Nitrogen, divided by 100%
Molecular Weight of Carbon Dioxide, divided by 100%
Molecular Weight of Water
TEST DATA
Variable Data Variable Data
Bws= 0.1218 %CO= 0.00
%N2= 83.80 %CO2= 12.00
%O2 = 4.20
NORMAL
ONE
Units
Ib/lb-mole
Ib/lb-mole
mole fraction
% Volume
% Volume
% Volume
% Volume
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
CALCULATIONS
Md
Md
Md
Ms
Ms
Ms
(0.44)(%CO2) + (0.32)(%O2) + (0.28)(%N2 + %CO)
(0.44)( 12.00) + (0.32)(4.20) + (0.28)(83.80 + 0.00)
30.088 Ib/lb-mol
(Md)(l - Bws) + (18.0)(Bws)
(30.088)(1 - 0.1218) + (18.0)(0.1218)
28.616 Ib/lb-mol
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.4 Verifying Method of Determining Moisture in Stack Gas
Regulations: 40 CFR Part 60, Appendix A, EPA Method 4
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
Notes:
No specific references are applicable to this section of the manual.
A gas sample is extracted from the stack at a constant rate; moisture is removed
from the sample stream and calculated either volumetrically or gravimetrically
(GRAY). Title 40 CFR Part 60, Appendix A, Method 4 lists detailed procedures
and the method for calculating moisture content in the stack gas. This method
should be used for all runs for all test conditions. Exhibit 8.4.1.4-1, see page
6-86, shows step-by-step procedures for calculating moisture content in flue gas.
Field data logsheet parameters included under "Check For" should be verified,
including the average value for each parameter. Calculations for each run should
also be verified for accuracy.
Q Field data sheets (for each traverse point, record sampling time stack
temperature, orifice meter differential (A H); meter reading for gas
volume; gas sample dry-gas meter inlet and outlet temperature; and
temperature of gas leaving condenser [last impinger])
Q Sampling time (minimum of 2 hours per composite sample per run)
Q Moisture calculations
Clark reads in the TBR field logsheet that Meter 2 was used with a dry-gas
meter calibration factor of 1.00273, whereas the dry-gas meter calibration data
package indicates this value to be 1.0273.
Because the calibration data package shows a dry-gas meter calibration factor of
1.0273 for Meter 2, Clark asks that the facility use this value for calculations.
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Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 8.4.1.4-1
MOISTURE CONTENT DETERMINATION
COMPANY:
LOCATION:
SOURCE:
Variable
Pm
Po
Pstd
Pb
Kl
K2
Tm
Tstd
DGMC
Vlcg
Vm
Vmstd
Vwstd
Bws
Bwd
Pm
Vwstd
Bwd
MOISTURE CONTENT AND SAMPLE VOLUME CORRECTION CALCULATIONS
XYZ Company CONDITION: NORMAL
Anywhere, USA TEST RUN: ONE
BIF UNIT
VARIABLE LIST
Definition Units
Absolute Dry Gas Meter Pressure in. Hg
Average Meter Differential Pressure in. HzO
Absolute Standard Pressure (29.92) in. Hg
Barometric Pressure in. Hg
Conversion Factor (13.6) in. HzO/in. Hg
Standard Volume H2O Vapor/Unit Weight Liquid (0.04715) ft3/g
Average Dry Gas Meter Temperature °R
Absolute Standard Temperature (528) °R
Dry Gas Meter Correction Factor Dimensionless
Total Condensate Collected grams
Dry Gas Meter Sample Volume dcf
Dry Gas Meter Sample Volume, at Standard Conditions dscf
Volume of Water Vapor Collected, at Standard Conditions scf
Moisture Content mole fraction
Moisture Content % Volume
TEST DATA
Variable Data Variable Data
Pb= 30.27 Tm= 538.2
Vm= 76.825 Po = 0.18
Vlcg= 222.3 DGMC= 0.991
CALCULATIONS
Pb + (Po/Kl) = 30.27 + (0.18/13.6) = 30.28 in. Hg
(Vm)(DGMC)(Pm)(Tstd) (76.825)(0.991)(30.28)(528)
(Pstd)(Tm) (29.92)(538.2)
(K2)(Vlcg) = (0.04715)(222.3) = 10.481 scf
(Vwstd) 10.481
(Vwstd) + (Vmstd) (10.481)+(75.589)
(Bws)(100%) = (0.1218)(100%) = 12.18 % Volume
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.5 Verifying Method of Determining Particulates, Hydrogen Chloride, and Chlorine
Regulation:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 60, Appendix A, Method 5
SW-846, Method 0050 or Method 0051
No specific references are applicable to this section of the manual.
Stack gases are sampled isokinetically from the source to collect PM on a glass
filter maintained at a temperature of 248 ± 25 °F, and to collect HC1 and C12 gas
in absorbing solutions. This method is typically used during all runs of all test
conditions. Particulate mass, which includes any material that condenses at or
above the filtration temperature, is calculated GRAY after combined water is
removed. The HC1 content of the absorbing solutions is quantitatively calculated
at the laboratory using ion chromatography.
Q Field data sheets (for each traverse point, record sampling time; vacuum
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Ensure data are collected at consistent interval throughout run—for
example, every 5 minutes.
Q Sampling train arrangement, as suggested in U.S. EPA Methods 0050
and 0051
Q Proper temperature maintenance (probe and filter at 248 ± 25 °F, train
exit gas less than 68°F)
Q Sampling time (minimum of 2 hours per composite sample per run)
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
Q Consistency with observations documented in the trial burn oversight
report
Title 40 CFR Part 60, Appendix A, Method 5 lists the procedure and methods for
calculating particulate concentration. U.S. EPA Method 0050 or 0051 should be
used to analyze for HC1 and C12.
Clark reviews the TBR to see whether the method used for PM, HC1, and C12
conforms to the methods specified in the approved TBP; Clark also verifies the
sampling train configuration. Sections 11.3.1 and 11.3.2 of this component
explain how to review PM, HC1, and C12 emission rates.
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.6 Verifying Volatile Organic Sampling Train Sampling Method for Determination of
Volatile Organics
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
SW-846 Method 0030
No specific references are applicable to this section of the manual.
A volatile organic sampling train (VOST) is used to sample VOCs or POHCs
(VOC designated for measurement and calculation of destruction and removal
efficiency) from stack gas samples. This method is typically used during the
DRE and risk burn test conditions. A known volume of air is collected and
passed through an absorbent medium (such as charcoal or Tenax®) contained in
glass tubes. These tubes or cartridges are sent to the laboratory for POHC
analysis.
Q Field data sheet showing sample volume and sampling duration (see
Section IV of U.S. EPA 1989 Checklist for Reviewing RCRA TBRs for
more details)
Q Sampling train configuration, as suggested in U.S. EPA Method 0030 or
U.S. EPA Method 0031
Q Minimum sampling time of 2 hours or 20 to 40 minutes per set of VOST
cartridges, with three to four sets VOST cartridges per run (typically,
four sets are collected, and three are analyzed; with one set saved as a
back up)
Q Calculations showing sample volumes corrected to standard conditions
Q Whether the samples were analyzed for the target VOC list identified in
the TBP (the VOC analyte list should include, at a minimum, all target
analytes for SW-846 U.S. EPA Method 3542)
Q Consistency with observations documented in the trial burn oversight
report
U.S. EPA Method 0030 lists the procedure for conducting VOST sampling. This
method should have been followed while conducting VOST sampling.
Clark reviews the TBR to see whether the VOST sampling method conforms to
the approved TBP. Clark also verifies the sampling train configuration. Sections
11.3.4 and 11.3.6 of this component explain how to review POHC and VOC
emissions rates.
Notes:
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Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.7 Verifying Semivolatile Organic Sampling Train Sampling Method for Determination of
Semivolatile Organics
Regulation:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
SW-846 U.S. EPA Method 0010
No specific references are applicable to this section of the manual.
An EPA modified Method 5 train—specified as U.S. EPA Method 0010—is
used to collect samples of SVOCs present in stack gas. This method is typically
used during all runs of the DRE and risk burn test conditions. A known volume
of air is collected and passed through a series of adsorbent medium (including
various impinger solutions and adsorbent resins such as XAD). The various
solutions and resin tubes recovered from the sampling train are sent to the
laboratory for SVOC analysis (both speciated analysis using Method 8270B and
unspeciated, using the procedure outlined in the Method for Total Organics).
Q Field data sheets (for each traverse point, record sampling time; vacuum
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Q Sampling train configuration, as suggested in U.S. EPA Method 0010
Q Maintenance of proper sampling train temperatures
Q Whether isokinetic calculations are within 90 to 110 percent
Q Minimum sampling time of 2 hours per run
Q Stack flow rate calculations
Q Consistency with observations documented in the trial burn oversight
report
See Section IV of the U.S. EPA 1989 Checklist for Reviewing RCRA TBRs for
more details.
U.S. EPA Method 0010, lists the procedures for conducting a SVOC sampling
train. This method should have been followed while collecting SVOC samples.
Lois reviews the TBR to see whether the method used to collect SVOC samples
conforms to the approved TBP. Lois also verified the sampling train
configuration. Sections 11.3.5 and 11.3.6 of this component explain howto
review SVOC emission rates.
Notes:
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Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.8 Verifying Sampling Method for Polychlorinated Dibenzodioxins and Polychlorinated
Dibenzofurans
Regulation:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 266, Appendix IX, Method 23
SW-846 Method 0023A
No specific references are applicable to this section of the manual.
Most combustion units have the potential to emit PCDDs and PCDFs; especially
those using dry PM control devices. This method is typically used for all runs of
the test condition used to collect risk assessment data. Stack gases are sampled
isokinetically to collect PCDD/PCDF on a particulate filter; XAD-2 adsorbent
resin, and adsorbent impinger solutions. Samples recovered from the sampling
train are analyzed in the laboratory for PCDD/PCDF content. This method may
be combined with a Method 0010 sampling train. Additional guidelines regarding
sampling train operation and recovery are described in Component 4—How to
Conduct Trial Burn Test Oversight.
Q Field data sheets (for each traverse point, record sampling time; vacuum;
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Q Sampling train configuration, as suggested in U.S. EPA Methods 23 and
0023A
Q Maintenance of probe exit temperature and filter compartment at
248 ± 25 °F during sampling
Q Whether gas enters sorbent tube module at or below 68 °F
Q Minimum sampling time of 3 hours per run
Q Whether isokinetic calculations are within 90 to 110 percent
Q PCDD/PCDF emission calculations
Q Consistency with observations documented in the trial burn oversight
report
U.S. EPA Method 23, 40 CFR Part 266, Appendix IX, lists procedures for
collecting PCDD/PCDF samples. Section 11.3.7 of this component explains how
to review PCDD/PCDF emission rates.
Clark reviews the TBR to see whether the method used to collect PCDD/PCDF
samples conforms to the approved TBP. Clark also verifies the sampling train
configuration.
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Center for Combustion Science and Engineering 6-98
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.9 Verifying Sampling Method for Multiple Metals
Regulations: 40 CFR Part 266, Appendix IX, Section 3.1, Method 0012
SW-846 Method 0060
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
Notes:
No specific references are applicable to this section of the manual.
Stack gases are sampled isokinetically to collect metals —antimony, arsenic,
barium, beryllium, cadmium, total chromium, nickel, lead, mercury, selenium,
silver, and thallium—on a filter and in absorbing solutions. This method is
typically used during the high temperature and risk burn test conditions. Metals
content of the samples are quantitatively determined at the laboratory using
inductively coupled plasma or atomic adsorption spectroscopy.
Q Field data sheets (for each traverse point, record sampling time; vacuum;
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Q Sampling train configuration, as suggested in referenced method
Q Maintenance of proper temperature (probe and filter at 248 ± 25 °F, train
exit gas below 68°F)
Q Minimum sampling time of about 3 hours composite per run
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
Q Metals emission rate calculations
Q Consistency with observations documented in the trial burn oversight
report
Titile 40 CFR Part 266 Appendix IX, Section 3.1 lists procedures for collecting
multiple metals samples. Section 11.3.3 of this component explains how to
review multiple metals emission rates.
Lois reviews the TBR to see whether the method used for multiple metals
collection conforms to the approved TBP. Lois also verifies the sampling train
configuration.
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Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.10 Verifying Sampling Method for Hexavalent Chromium
Regulations: 40 CFR Part 266 Appendix IX, Section 3.2, Method 0013
SW-846 Method 0061
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
No specific references are applicable to this section of the manual.
This method is typically used during all runs of the high temperature and risk burn
conditions, if necessary. Stack gases are sampled isokinetically to collect
hexavalent chromium in an absorbing solution. The hexavalent chromium content
of the sample is quantitatively determined using ion chromatography at the
laboratory.
Q Field data sheets (for each traverse point, record sampling time; vacuum;
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Q Sampling train configuration, as suggested in referenced method
Q Maintenance of proper temperature (probe and filter at 248 ± 25 °F, train
exit gas below 68°F)
Q Minimum sampling time of about 3 hours per run
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
Q Hexavalent chromium emission rate calculations
Q Consistency with observations documented in the trial burn oversight
report
Title 40 CFR Part 266, Appendix IX, Section 3.2 lists procedures for collecting
hexavalent chromium samples. Section 11.3.3 of this component explains how to
review multiple metals emission rates.
Clark reviews the TBR to see whether the method used for hexavalent
chromium conforms to the approved TBP. He also verifies the sampling train
configuration.
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Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.11 Verifying Sampling Method for Aldehydes and Ketones
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
Notes:
40 CFR Part 266 Appendix IX, Section 3.5
SW-846 U.S. EPA Method 0011
No specific references are applicable to this section of the manual.
This method is typically used during all runs of the risk burn test condition, if
necessary. Stack gases are sampled isokinetically to collect aldehydes and
ketones in an absorbing solution. The samples are analyzed using U.S. EPA
Method 8315, high performance liquid chromatography.
Q Field data sheets (for each traverse point, record sampling time; vacuum;
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Q Sampling train configuration, as suggested in U.S. EPA Method 0011
Q Maintenance of proper temperature (probe and filter at 248 ± 25 °F, train
exit gas below 68°F)
Q Whether isokinetic calculations are within 90 to 110 percent
Q Minimum sampling time of 2 hours per run
Q Stack flow rate calculations
Q Consistency with observations documented in the trial burn oversight
report
SW846 Method 0011 lists procedures for collecting aldehydes and ketones.
Clark reviews the TBR to verify that modifications to Method 0011, incorporated
into the approved TBP, were followed during the testing activities.
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.1.12 Verifying Sampling Method for Organic Constituents Using Tedlar® Bags
Regulations: SW-846 Method 0040
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
No specific references are applicable to this section of the manual.
This method is used during all runs of the risk burn test condition. A Tedlar® bas
is used to collect low-molecular weight PICs. A stack gas sample is drawn into
the bag. The bag contents are analyzed for total unspeciated organics by an on-
site field GC.
Q Field data sheets (stack gas velocity head, stack gas temperature,
condition temperatures)
Q Sampling train configuration, as outlined in Method 0040
Q Constant sampling rate
Q Minimum sample time of 60 minutes
Q Consistency with observations documented in the trial burn oversight
report
Lois notes that during the Method 0040 sampling for Run 3, the stack gas
temperature ranged between 280 and 300°F. Because the probe temperature
exceeded 284°F, Lois checked to see how the sampling probe was cooled, but
could find no discussion regarding this issue.
Although Lois could not find any discussion of probe cooling activities, she noted
during her review that although the stack gas temperature had exceeded 284°F,
the sampling probe and filter box had been maintained between 266 and 284°F, in
accordance with the method requirements. Since the proper temperature range
had been maintained, Lois did not anticipate a significant impact on the results,
however, she asked the facility to clarify whether probe cooling activities had
been used during the trial burn test.
Notes:
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Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.2 Reviewing Data Tables For Stack Gas Characteristics
Regulations: 40 CFR Part 266.103
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
Notes:
No specific references are applicable to this section of the manual.
Generally, tables are included in the TBR to summarize the stack gas
characteristics for each sampling method (particulate sampling train, metals
sampling train, hexavalent chromium sampling train, VOST, SVOC sampling
train, and PCDD/PCDF sampling train). These summary tables are prepared on
the basis of field data sheets and emission calculations presented in the stack test
report.
Q Summary table for each isokinetic sampling train, including sampling time,
corrected sample volume, stack gas temperature, moisture content, CO2
percent, O2 percent, stack gas velocity, stack gas flow rate, and percent
isokinetic achieved
Q Summary table for VOST including actual volume sampled, through the
sampling train, average meter temperature, and corrected volume
Clark verifies that the summary table includes average data for each run, in
addition to the average of all runs conducted for the same method. He also
reviews field data sheets completed during the trial burn test and checks the
calculations to verify that the data presented in the summary table are consistent.
Sections 8.4.1 through 8.4.1.10 of this component contain example sections for
each of the stack gas sampling methods that may have been used during the trial
burn.
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
8.4.3 Reviewing Data Tables for Emission Rates of Constituents of Potential Concern
Regulations: 40 CFR Part 266.103
Guidance:
Explanation:
Check For:
No specific references are applicable to this section of the manual.
The TBR generally contains summary tables that summarize the emission rates
of COPCs, which may include various metals, VOCs, and SVOCs (including
poly chlorinated aromatic hydrocarbons and poly chlorinated biphenyls) in addition
to PCDDs and PCDFs. The list of COPCs may also include compounds
designated as trial burn test POHCs. The number and variety of tables will
depend on the number and type of test conditions used by the facility. These
summary tables are based on field data sheets, analytical results, and calculations
presented in the stack test report. Summary tables presenting the calculations for
COPC emission rates (average, minimum, and maximum), standard deviation,
and 95th percentile values should be provided.
There is a difference between measured emission rates and the 95th percentile.
Emission rates are measurements, where the percentile is a calculation based on
the variance in the measurements. As an example, for three measurements with
2 degrees of freedom, the t statistic corresponding to Q as the 95th percentile is
2.920. The 95th percentile is computed as follows:
where:
where:
95th percentile = Mean + [(tQ 0 95)(s)/(n)1/2]
s
n
= t statistic corresponding to the 95th percentile
of a normal distribution
= sample standard deviation
= sample size
In cases where 3 runs of data are available (n = 3) the calculation simplifies to
95th percentile = Mean + (1.686)(s)
The number of standard deviations added to the mean is a function of sample
size. In some cases, the number of measurements may not be 3. In this case,
the appropriate statistic should be used.
This information may be collected during trial burn or risk burn test conditions.
The TBR should clearly indicate the basis for the emission rates
Q Summary tables calculated for COPC emission rates (average, minimum,
and maximum), standard deviation, and 95th percentile values for:
Q Hexavalent chromium
a vocs
a svocs
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Q PCDD/PCDF
Q Metals
Q PAHs
Q Aldehydes and ketones
Q HC1/C12
a PM
Example Situation: Lois verifies that the summary tables include the minimum, maximum, and
average, emission rates for each run, as well as the calculated standard deviation
and calculated 95 percentile UCL. She also reviews field data sheets completed
during the trial burn test and analytical results and emission calculations contained
in the TBR to verify that no errors appear in the summary table emissions data.
Example Action: Sections 8.4.1 through 8.4.1.10 of this component contain example comments for
each pollutant that may have been monitored during the trial burn.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
9.0 REVIEWING CHAPTER 6—LABORATORY PROCEDURES
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
40 CFR Parts 264.13 and 266.103
No specific references are applicable to this section of the manual.
It is important to focus the review of the laboratory procedures portion of the
TBR on (1) adherence to the approved TBP and approved QAPP sampling and
analysis procedures and (2) the presentation of clear and supportable
explanations of any deviations from these approved plans. The majority of the
effort in evaluating the appropriateness of the sampling and analysis methods is
expended during the TBP review period. Therefore, the effort during the TBR
review period should be centered around the laboratory's (or laboratories') ability
to follow the prescribed procedures. If the laboratory's procedures were
somehow flawed or deviations from the prescribed procedures were necessary,
then these issues should be presented, explained, and justified to the satisfaction
of the permit writer.
This section is broken down into two subsections: Section 9.1, Reviewing the
Summary of On-site Analytical Procedures, and Section 9.2, Reviewing the
Summary of Off-site Analytical Procedures. These subsections discuss items for
review with respect to the particular requirements for off-site and on-site
laboratories. Issues for reviewing the QA/QC results from laboratories are
discussed in Section 10.0.
For guidance on reviewing the TBP, please see Component 1—How to Review
a Trial Burn Plan and the U. S EPA Region 6 Generic TBP, Attachment A to
Component 2.
Q Reference to the approved TBP and approved QAPP
Q Laboratory QA/QC performance checks
Q Whether all proposed samples were collected
Q Whether all proposed analytical parameters were conducted
Q Any deviations from the approved TBP or QAPP
Q Any problems with sampling, analysis, or QA/QC checks
Clark reviewed the TBR in search of a section discussing on-site sample
analysis. He failed to find a section regarding on-site analysis. He knows that
many trial burns are designed so that the stack sampling contractor collects all
process and waste samples; prepares the chain-of-custody (COC) forms;
prepares the composites as necessary; packages the samples for shipment; and
ships samples to designated off-site laboratories.
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Example Action: Based on a rereview of the TBP, Clark determined that on-site analyses were
planned. He rereviewed the TBR to see if it clearly identified the samples, the
laboratories to which they were sent, and the type of analysis at each laboratory.
Upon finding this discussion unclear, Clark requested that the facility clarify
where all samples were collected and analyzed for parameters presented in the
TBP. Any deviations must be fully explained.
Notes:
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9.1 REVIEWING THE SUMMARY OF ON-SITE ANALYTICAL PROCEDURES
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Parts 264.13(b)(2) and 266.103
No specific references are applicable to this section of the manual.
On-site analysis conducted during the trial burn should be specifically identified in
the TBP. These analyses usually include viscosity, heat value, chloride content,
ash content, flashpoint, and density. These analyses may be conducted by the
facility because an on-site laboratory is already needed for QC purposes for a
manufactured product or to run analyses required by an environmental permit
(such as a RCRA permit or an NPDES permit). The TBP may also include
procedures for on-site analyses for metals and organic compounds. As long as
this approach was approved in the TBP, then the TBR review should focus on
the ability of the on-site laboratory to follow the approved procedures and meet
the QA/QC objectives. In this case, it is especially important to obtain proof of
third-party QA/QC validation.
The stack sampling contractor may also conduct on-site analysis of U.S. EPA
Method 0040 samples. These samples — collected in a Tedlar® bag — have a very
short holding time (72 hours) and are difficult to ship. Recent experience has
shown that an even shorter holding time may be appropriate. The analysis of
these samples involves the on-site setup and calibration of a GC system. The
TBR reviewer should ensure that all appropriate QA/QC data for the on-site GC
are included in the TBR. The TBR reviewer should also check the trial burn test
oversight report to ensure consistent reporting of the on-site analytical setup and
procedures
Q
Reference to approved TBP and QAPP
Q Reference to on-site analysis conducted by the facility
Q Reference to on-site analysis conducted by the sampling contractor
Q Discussion of QA/QC checks conducted by the on-site laboratory
Q Discussion of any deviations from approved TBP or QAPP
Example Situation: In reviewing the waste analysis section of the TBR, Clark reads:
"EPA Identification No. (I.D.) OKD 111222999, Trial Burn Report, Section
5, Waste Analysis. Section 5. 8. Waste Feed Characteristics. Samples of all
waste feeds (except lab packs) were collected before the POHC spiking material
was added and were analyzed to determine the concentration of the three
POHCs and the following general waste characteristics: heat value, ash, organic
C12, and viscosity.
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"Various tables in the report present the results."
Example Action: Clark notes that no reference is made to the TBP or methods used to conduct the
characterization, and that QA/QC procedures are not discussed. Clark cannot
evaluate the performance of the on-site laboratory because no data are presented
for comparing known results, and no data are presented for replicate analysis.
Clark asks that the facility address these issues in revisions to the TBR.
Notes:
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9.2 REVIEWING THE SUMMARY OF OFF-SITE ANALYTICAL PROCEDURES
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
When reviewing information on the off-site laboratory procedures, the permit
writer should focus on adherence to the approved TBP and QAPP and the
laboratory's ability to follow the prescribed procedures. If any deviations were
necessary, then the TBR should discuss them. Since the trial burn involves
collection of many different types of samples, is it common to use one or more
off-site laboratories for analyses. The TBR should identify (1) the samples
collected, (2) the laboratory each sample was shipped to, and (3) the analysis
conducted at that laboratory. All samples must be properly documented on the
completed chain of custody (COC) forms. The samples should be shipped to the
off-site laboratory as soon as possible because specific sample holding times
apply to all analytical methods.
Q Reference to the approved TBP and QAPP
Q Identification of off-site laboratory and analyses conducted
Q Presentation of completed COC forms
Q Discussion of any deviations from approved TBP or QAPP
Q Discussion of QA/QC checks conducted by the off-site laboratory
In reviewing the test results section of the Technical Report, Lois reads as
follows:
"EPA I.D. No. TXD 098642424. Technical Report, Section 5. Test Results.
Section 5. Test Results. This section presents, and briefly discusses, all test
results in the following order:
5.1 Waste Feed Characteristics
5.2 U.S. EPA Method 5 Test Data and Particulate Emissions
5.3 ORE for Volatile POHCs
5.4 ORE for Semivolatile POHCs
5.5 PCDD/PCDF Emission Results
5.6 HC1 and C12 Emission Rates and HC1 Removal Efficiency
5.7 Spray Dry Absorber/Fabric Filter Residue Analysis of
Incinerator Ash
5.8 Continuous Emissions Monitoring Data
5.9 Volatile PICs Emission Results
5.10 Semivolatile PICs Emission Results
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"Appendices to the Technical Report include the following:
• Presentations of sampling and analysis procedures
• List of samples collected
• MM5 calculations and PM results
• Contract laboratory results
• Results of various organic compounds
• Continuous emissions data
• Calibration data
• Traceability records
"These appendices provide the detail required to evaluate all analytical
procedures used for sample analysis during this trial burn."
Example Action: Lois reviewed all appendices to the technical report to see if the contractor
presented a copy of each analytical method used. Lois also confirmed that all
analytical methods agreed with those proposed in the TBP. However, Lois
commented to the facility that naming or numbering the pages in the appendices
would have greatly aided in cross checking information between the Technical
Report and the appendices.
Notes:
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10.0 REVIEWING CHAPTER 7—QUALITY ASSURANCE/QUALITY CONTROL
RESULTS
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Parts 264.13(b)(2)(3) and 266.103
No specific references are applicable to this section of the manual.
As with the review of the laboratory procedures, review of the QA/QC results
from the trial burn sampling and analysis program should focus on (1) adherence
to the approved TBP and approved QAPP sampling and analysis procedures and
(2) the presentation of clear and supportable explanations of any deviations from
these approved plans. The approved trial burn QAPP should have clearly
identified (1) the QA objectives, (2) QA/QC procedures, (3) acceptance criteria
for the sampling and analysis methods used during the trial burn, and (4) an
outline for the QA/QC information presentation in the TBR.
The TBR should contain, at a minimum, (1) all sampling and analysis field
records, (2) all calibration data (both laboratory and field equipment records), (3)
all precision and accuracy determinations associated with QA objectives (such as
surrogates, spikes, duplicates, and standards reference material), (4) all internal
audits, (5) all external audit results (if an external audit was conducted), and (6)
the data quality assessment report from the QA coordinator. This information is
generally presented as (1) QA/QC data collected during the trial burn (on-site),
see Section 10.1, and (2) QA/QC data collected during post-trial burn activities
(off-site), see Section 10.2.
For guidance on reviewing the trial burn QAPP, please see Component 2—How
to Review a Trial Burn Quality Assurance Project Plan and U.S. EPA Region 6
Generic QAPP, Attachment A to Component 2.
Q Reference to the approved QAPP
Q Assessment of data quality
Q Discussion out-of-specification data and QA/QC procedure deviations
Q Listing of equipment calibration frequency
Q Identification of QA/QC objectives, procedures, and results
Q Presentation of data analysis and validation procedures
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Example Situation: Clark noted the following statement while reviewing the QA/QC results portion
oftheTBR:
"All trial burn data met QA/QC objectives. There were no variances from data
quality objectives and all analytical results were within acceptance criteria."
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Example Comments: While the thought of a perfect trial burn data set was overwhelming, Clark
realized it was unlikely. Not only was the statement far reaching, it was also
unsupported. Clark requested that the facility backup the claim that the data met
all objectives with specific references to laboratory results and QA validation
comments.
Notes:
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10.1 REVIEWING THE SUMMARY OF ON-SITE QUALITY ASSURANCE/QUALITY
CONTROL RESULTS
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40CFRPart264.13(b)(2)
No specific references are applicable to this section of the manual.
On-site QA/QC activities would include any sampling and analysis data quality
measures surrounding stack gas samples (see Section 10.1.1) or process samples
such as waste feed or residual samples (see Section 10.1.2). The following
subsections specifically address these two types of samples.
Q Reference to approved TBP and QAPP
Q Documentation of QA/QC activity
Q Discussion of any deviations from approved procedures
The approved trial burn QAPP contained a laboratory QA plan. This document
defined the systems of QC and quality assessment that compose the QA program
for the on-site laboratory.
Major objectives of the on-site laboratory QA program were as follows:
• Use of appropriate methodologies
• Technically competent and well-trained personnel
• State-of-the-art instrumentation and equipment, properly
calibrated and maintained
• Adherence to well-defined standard analytical procedures
developed for good laboratory and measurement practices
• Analysis and assessment of QC samples, including matrix spike
samples, matrix spike duplicate samples, and blanks
• Internal auditing for compliance with standard procedures and
assessment of analytical method performance
Example Comments: In reviewing TBRs and supporting documentation, Lois and Clark confirmed that
all QA/QC data were presented so that the waste sample results could be
validated. In reviewing the QC results, Lois and Clark verified that the
discussion included (1) how or where matrix spikes are developed, and
(2) whether they are purchased and, if so, the company from which they are
purchased.
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Notes:
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10.1.1 Stack Gas Samples
Regulation:
Guidance:
Explanation:
Check For:
40 CFR Part 60 Appendix A, Method 5
40 CFR Part 266 Appendix IX
No specific references are applicable to this section of the manual.
Each trial burn requires some form of stack gas sampling. Some trial burns have
simpler stack gas sampling requirements, while others, such as a trial burn for a
commercial hazardous waste incinerator, require an extensive and complicated
stack gas sampling program. When reviewing the QA/QC results for the stack
gas sampling field results, it is imperative that the reviewer be familiar with the
QA/QC requirements for the various stack gas sampling methods used during the
trial burn. Any variations in the stack gas sampling protocol or QA/QC data
collection should have been approved in the TBP, or, at the very least, during the
pretrial burn meeting. Changes in QA/QC data collection should not come about
while the trial burn is in progress. The following "Check For" items detail the
field QA/QC data to be reviewed for the more common stack gas sampling
procedures.
Q U.S. EPA Method 1—Sample and Velocity Traverses
Q Stack/duct diameter or dimensions
Q Circular/rectangular
Q Location of sampling ports
Q Upstream/downstream disturbance
Q Number of traverse points
Q Absence of cyclonic flow
Q U.S. EPA Method 2—Stack Gas Velocity and Flow Rate Determination
Q Type of pitot tube
Q Data sheet velocity traverse
Q Pitot tube coefficient
Q Pitot tube inspection - documentation and date
Q Calculation of average stack gas velocity
Q Calculation of stack gas flow rate
Q Thermocouple calibration range and date
Q Barometer calibration date
Q QC procedures
Q U.S. EPA Method 3—Gas Analysis for CO2, O2, Excess Air, and
Molecular Weight
Q Sampling method—single point/multiple point, grab/integrated
sampling
Q Gas analysis method—Orsat or Fyrite analyzer (U.S. EPA
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Method 3) or continuous monitors (U.S. EPA Method 3A)
Q Field data sheet
Q Molecular weight calculation
Q Excess air calculation
Q Leak check for sampling/analyzer
Q QC procedures
Q U.S. EPA Method 4—Determination of Moisture in Stack Gases
Q Calibration sheets
Q Field data sheets
Q Constant sampling rate
Q Proper sampling rate
Q Stack properly traversed
Q Train temperature maintained below 68 °F
Q Pump/train leak checked
Q Weight of moisture determined
Q U.S. EPA Method 5/SW-846 Method 0050 or Method
0051—Particulate, HC1/C12
Q Calibration sheets
Q Field data sheets
Q Isokinetic calculations
Q Maintenance of proper temperatures
Q Sampling rate
Q Leak checks
Q Sample recovery documentation
Q Probe rinse procedures
Q Handling/distribution of samples for analysis
Q U.S. EPA Modified Method 5/SW-846 Method 0010—Semivolatile
Organics
Q Calibration sheets
Q Field data sheets
Q Isokinetic calculations
Q Maintenance of proper temperatures
Q Sampling rate
Q Leak checks
Q Sample recovery documentation for XAD resin
Q Sample recovery documentation
Q Probe rinse procedures
Q Handling/distribution of samples for analysis
Q Sample recovery documentation for blank sample collection
Q GC/flame ionization detector (FID) for unspeciated semivolatile
organics
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Q GRAY analysis for non-volatile compounds
Q U.S. EPA Method 0012/SW-846 Method 0060—Multiple Metals
Q Calibration sheets
Q Field data sheets
Q Isokinetic calculations
Q Maintenance of proper temperatures
Q Sampling rate
Q Leak checks
Q Sample recovery documentation
Q Probe rinse procedures
Q Handling/distribution of samples for analysis
Q Impinger solutions 1, 2, and 3 collected in a prelabeled sample
bottle
Q Impinger 4 liquid collected in an amber glass sample bottle
Q Impinger solutions 5 and 6 collected in an amber glass bottle with
a Teflon-lined lid
Q Visual inspections conducted
Q U.S. EPA Method 0013/SW-846 Method 0061—Hexavalent Chromium
Q Calibration sheets
Q Field data sheets
Q Isokinetic calculations
Q Maintenance of proper temperatures
Q Sampling rate
Q Leak checks
Q Sample recovery documentation
Q Probe rinse procedures
Q Handling/distribution of samples for analysis
Q Absorbing liquid continuously recirculated from first impinger
through the sample line
Q Probe maintained at a temperature below 200°F throughout
sampling
Q Probe ends capped before removing to recovery area
Q pH of impinger 1 above 8.5
Q Nitrogen bubbled through impinger train at 10 liters/minute for 30
minutes
Q Liquid in impingers 1, 2, 3, and 4 weighed and placed in an amber
glass sample bottle
Q Contents of container 3 filtered
Q U.S. EPA Method 0023/SW-846 Method 0023A—PCDD/PCDF
Sampling
Q Calibration sheets
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Q Field data sheets
Q Isokinetic calculations
Q Maintenance of proper temperatures
Q Sampling rate
Q Leak checks
Q Sample recovery documentation
Q Probe rinse procedures
Q Handling/distribution of samples for analysis
Q Nozzle sealed after being removed from the stack
Q U.S. EPA Methods 0030 and 0031—Volatile Organic Sampling Train
(VOST)
Q Calibration sheets
Q Sample volume
Q Sampling duration
Q Number of trap pairs per test run
Q Leak checks for each run or trap pair
Q Blank traps taken
Q Field data log/documentation for each pair
Q Trap storage and shipment
Q U.S. EPA Method 0040—Total Volatile Organics
Q Field GC for volatiles
Q U.S. EPA Method 7E—Determination of Nitrogen Oxides Emissions
from Stationary Sources
Q Leak check
Q Proper calibration gas with certificate of analysis
Q Record of calibration results
Q Zero span and calibration draft test
Q Data logged every 60 seconds
Q U.S. EPA Method 10—Determination of Carbon Monoxide Emissions
from Stationary Sources
Q Leak check
Q Proper calibration gas with certificate of analysis
Q Record of calibration results
Q Zero span and calibration draft test
Q Data logged every 60 seconds
Q Instrument measurement range
Q Performance specification test results
Q U.S. EPA Method 25 A—Determination of Total Gaseous Nonmethane
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Example Situation:
Example Action:
Organic Emissions Using a Flame lonization Analyzer
Q Leak check
Q Proper calibration gas with certificate of analysis
Q Record of calibration results
Q Zero span and calibration draft test
Q Data logged every 60 seconds
Q Instrument measurement range
Q Performance specification test results
Q CO and O2 CEMS
Q Verification of absence of leakage at CO and O2 sampling
location
Q Calibration gas concentration (zero and high-level)
Q Calibration gas certificate (confirm that CO protocol calibration
gases have not expired)
Q Calibration checks before each run and daily
Q Zero and span calibration drift test during trial burn
Q Sampling and analysis conducted every 15 seconds during trial
burn
Q Data logged every 60 seconds during trial burn
Clark was reviewing the data sheets for the stack gas sampling at the XYZ
Company RCRA trial burn. During the review, Clark noted that for six readings
from the U.S. EPA Method 23 data sheet the inlet to the XAD trap was 72°F or
higher. The method specifies the inlet temperature must be less than 68°F.
Clark requested that XYZ Company review in a detail all U.S. EPA Method 23
sampling results and prepare a report discussing any analytical problems that
might be caused by the high inlet temperature. He also requested that XYZ
Company compare the U.S. EPA Method 23 results from all three sample runs to
determine if the data varied.
Notes:
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10.1.2 Process Samples
Regulations:
Guidance:
Explanation:
Check For:
Example Action:
40 CFR Part 266.103
40 CFR Part 270.62
No specific references are applicable to this section of the manual.
Each trial burn requires some form of process sampling. Some trial burns have
simpler process sample requirements, for example, a dedicated boiler with one
waste feed stream and one residual stream (the boiler ash). While other trial
burns require an extensive and complicated process sampling program, such as
for a cement kiln with many influent and effluent streams. As with the stack
gas samples, the QA/QC activities for the process samples should follow the
procedures prescribed in the approved QAPP. Changes in QA/QC data
collection should not come about while the trial burn is in progress. The following
"Check For" items detail the field QA/QC data to be reviewed for the process
sample sampling procedures.
Q Identification of all process samples collected
Q Identification of all QA/QC samples collected
Q Sample frequency
Q Sample volume
Q Sample container and storage conditions
Q Sample method
Q Sample traceability procedures
Q Any special sample preparation requirements
In reviewing the TBP (an appendix to the TBR), Clark reads:
"Samples to be collected during each test run will include all waste feeds, lime
slurry, spray dryer/filter residual solids, kiln ash, and stack gas. These test runs
will be conducted under one incinerator operating condition.
"High-Btu liquid waste will be sampled every 15 minutes by using a trap.
Samples will be composited into one sample at the end of the test.
"Aqueous waste will follow the same sampling and compositing as the high-Btu
liquid.
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"A grab sample of containerized solid waste will be collected using a scoop for
every other solid charge (drum) to the kiln. The sample will be composited and
split into three equal samples.
"Bulk solid waste will be sampled by using a scoop to collect several subsamples
from the containers. The sample will be mixed and split into three samples."
Example Situation:
The TBR stated that the procedures matched those approved in the TBP.
While reviewing the TBR, Clark noted that the facility sampled every other drum.
Because he knows that U.S. EPA guidance suggests that each drum fed to the
kiln be sampled, he reviews the TBP to see if this procedure was approved.
Upon review of the TBP, he realizes that he originally requested that every drum
be sampled prior to feeding to the kiln. The facility agreed in a letter to his
request, but the actual TBP was never revised. Clark requested that the facility
present a discussion on the variability of the drummed waste and its potential
impact on the trial burn results.
Notes:
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10.2 REVIEWING THE SUMMARY OF OFF-SITE QUALITY ASSURANCE/QUALITY
CONTROL RESULTS
Regulation:
Guidance:
Explanation:
Check For:
Example Situation:
Example Actions:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
The TBR should include, at a minimum, off-site QA/QC activities such as,
(1) all calibration data (laboratory equipment records), (2) all precision and
accuracy determinations associated with QA objectives (such as surrogates,
spikes, duplicates, and standards reference material), (3) all internal audits,
(4) all external audit results (if an external audit was conducted), and (5) the data
quality assessment report from the QA coordinator. Changes in QA/QC data
collection should not come about while sample analysis is in progress. The
following "Check For" items detail the data to be reviewed for off-site QA/QC
activities.
Q Sample traceability
Q Holding times
Q Feed stocks, fuel, and APCS residual sample analytical results
Q Stack gas sample analytical results
Q QC assessment
Q QA coordinator report
Clark was reviewing the PCDD/PCDF sample and audit results and noted that
the laboratory reported a recovery of 152 percent for one of the PCDF isomers.
Clark was concerned that this recovery was above the acceptable limits.
The sampling and analysis method used for identifying the stack gas
concentration of PCDDs and PCDFs requires the analysis of an audit sample.
The same analyst, analytical reagents, and analytical system must be used for
both the stack gas samples and the U.S. EPA audit sample.
The accepted criterion for accuracy is 50 to 150 percent recovery of this audit or
spiked surrogate. The criterion for precision is less than 40 percent relative
percent difference for the audit or surrogate spikes. If more than three
determinations are made the precision criterion drops to less than 35 percent
relative percent difference.
Because the audit sample indicates that the results may be biased high, Clark
determined that the calculated emission rates were probably higher than actual,
and therefore more conservative. He asked that the facility qualify the data and
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noted that the issue may result in a higher than actual calculated risk during the
HHRA process. Clark requested that the facility have the laboratory evaluate
the high recovery for one isomer on accuracy. He also requested that any
calculation changes from stack gas samples be documented and explained in
detail.
Notes:
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11.0 REVIEWING CHAPTER 8—TRIAL BURN RESULTS SUMMARY AND PROPOSED
PERMIT LIMITS
Regulations: 40 CFR Part 266.103
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section of the report should summarize trial burn performance results and
compare the results to TBP performance objectives. It should also summarize
proposed permit limits and the rationale for proposing those limits.
Depending on the design and complexity of the trial burn test (that is, the number
and variation of waste feed combinations and combustion unit and APCS
operating parameters), the proposed permit limits may be derived from one or
more test conditions. The TBR review team will need to review the TBP to
identify how each permit limit was to be determined.
However, while certain permit limits may be derived from only one test condition
(for example, APCS inlet temperature may be derived from the high temperature
test condition used to demonstrate compliance with the metals standards), this
should not preclude a facility from presenting all data from all test conditions (in
this case, APCS inlet temperature should be monitored and reported for all runs
of all conditions. This will allow the TBR test review team—and ultimately the
permit writer—to ensure that the proposed permit conditions are appropriate and
protective of human health and the environment.
Additional guidance regarding the development of permit conditions is included in
Component 7—How to Prepare Permit Conditions.
Check For: This chapter should include subsections on the following topics:
Q Destruction and removal efficiencies (see Section 11.1)
Q CEMS results (see Section 11.2)
Q Stack gas emission rate results (see Section 11.3)
Q Proposed process limits (see Section 11.4)
Q Proposed waste feed limits (see Section 11.5)
Q Proposed automatic waste feed cutoff limits (see Section 11.6)
Q Proposed data for use in the risk assessment (see Section 11.7)
While reviewing these sections of the TBR, the review team should check for the
following:
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Q Emission rate results summary for each run
Q DRE for each POHC (DRE test condition)
Q PCDD/PCDF emission rates (risk burn test condition)
Q Metals emissions rates (high temperature and risk burn test
conditions)
Q Hexavalent chromium emission rate (high temperature and risk
burn test conditions)
Q HC1/C12 emission rates (all test conditions)
Q CO concentration levels in flue gas (all test conditions)
Q VOC and SVOC emission rates (DRE and risk burn test
conditions)
Q Particle size distribution (PSD) (risk burn test condition)
Q TO emission rates for volatile, semivolatile, and GRAY fractions
(risk burn test condition)
Q Summary of the key trial burn operating conditions (these data should
include the following values for each run: minimum, maximum, average,
standard deviations, average HRAs, minimum HRAs, and maximum
HRAs)
Q Liquid waste feed rate
Q Combustion chamber temperature
Q Baghouse (or APCS) inlet temperature
Q Stack gas O2 concentration
Q Ash feed rate
Q Chloride feed rate
Q Metals feed rate
Q Baghouse differential pressure
Q Combustion gas velocity
Q Auxilliary fuel feed rate
Q Other APCS key parameters
Q Proposed permit limits
Q Maximum waste feed rate
Q Minimum and maximum combustion gas temperature
Q Maximum combustion gas flow rate
Q Minimum and maximum production rate
Q Minimum stack gas O2 concentration
Q Maximum baghouse inlet temperature
Q Minimum baghouse differential pressure
Q Maximum ash feed rate
Q Maximum chloride rate
Q Maximum BIF metals rate
Q Auxilliary fuel feed rates
Q Total pumpable waste feed rate
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Q APCS parameters
Sections 11.1 through 11.7 of this component provide more detailed information
for the parameters included under this "Check For" section.
Example Situation: Clark notes that the TBR for the boiler includes suggested permit limits for
minimum and maximum boiler furnace (combustion gas) temperature. While
steam production rates were monitored during the trial burn test (based on
Clark's review of the oversight report), no raw data or proposed permit limits are
presented in the TBR. However, a stated objective of the TBP was to establish
the operating envelope in terms of steam production rate during the trial burn.
Example Action: Clark asks that the facility revise this section of the TBR and related tables to
include proposed minimum and maximum steam production rates.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-131
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
11.1 REVIEWING DESTRUCTION AND REMOVAL EFFICIENCIES
Regulations:
40 CFR Part 264.343.
40 CFR Part 266.104
Guidance: U.S. EPA 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 3.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations. EPA-530-R-92-011. Chapters 2, 5, and 10.
Explanation: A DRE of 99.99 percent must be demonstrated during the trial burn test for each
POHC. DRE is calculated as the difference between the mass emission rate and
mass feed rate of each POHC. The DRE value of 99.99 percent must be
attained without rounding (that is, 99.987 cannot be rounded up to 99.99).
Check For: Q DRE of at least 99.99 percent for each POHC (during each run of the
DRE test condition) identified in the trial burn
Q DRE calculations, including POHC feed rate and POHC stack gas
emissions rate
Example Situation: On reviewing the TBR, Lois uses the following equation to verify the DRE for
each POHC.
DRE =
1 -
W
out
W
x 100
where
W out = Mass rate of the same POHC in stack gas (if POHC is present
in the incinerator ash or residue, the mass rate of POHC in the
ash and residue should be added to the stack gas POHC
emission rate)
W m = Mass feed rate of individual POHC in the hazardous
waste fired to the BIF unit
Example Comments: The mass of each POHC entering the BIF can be calculated by using waste feed
analytical results and waste feed mass flow rate to the BIF. The mass of each
POHC in the flue gas is calculated using the average stack gas flow rate
measured by an isokinetic sampling train and stack sample analytical results. For
compounds that are sampled using an isokinetic sampling train, the average
standard stack gas flow rate is used to calculate DRE. Exhibit 11.1-1, see page
6-126, shows DRE calculations for benzene. The following shows step-by-step
procedures for calculating the DRE based on the results presented in Exhibit
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-132
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
11.1-1, see page 6-126.
Benzene feed rate (Ib/hr) =
Average waste mass feed rate (Ib/hr) x
benzene concentration in percent/100
2,721x21.5/100
585 Ib/hr
Total benzene collected = Sum of all tube pairs as reported by
laboratory
606 + 478 + 481
= 1,565 nanograms (ng)
Stack gas sample volume (L) = 60.8 liter (from data sheet)
This is the volume of gas that passed through the sampling train.
Stack gas concentration of benzene in grams per day standard cubic
meter (g/dscm).
= 1,565 ng
x
1
60.8 L
x
dscm
-3 L
= 2.57 £-05
g
dscm
Average stack gas flow rate calculated
using Methods 1 through 4 = 10,310 dscf
Benzene emission rate (g/sec)
= 2.57 £-05
dscm
1A~iri ™^i o 0->i ir>-2 dscm min
x 10,310 —- x 2.832x10 x
mn
dscf 60 sec
= 1.25E-04 g/sec
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-133
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Bezene emission rate (Ib/hr)
rr 77) v QPP
1.25 £-04 -e- x —^— x 3600 —
sec 453.54g hr
= 0.000992 Ib/hr
D r>r>7- ^ fi Benzene out^ 1AA
Benzene DRE percent = (1 - ) x 100
Benzene in
585
100
= 99.99983%
Check and verify DRE for each POHC using the above procedures
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-134
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 11.1-1
DESTRUCTION AND REMOVAL EFFICIENCY
m m o
»4 ,
II
• ^
a «
JP.1
U
.2
'_o
C
<5 O
3* £Q
1?
•a l
S E
O CO
"u "5
39 Id
a £
c M 1C CC
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
11.2 REVIEWING CONTINUOUS EMISSION MONITORING SYSTEM RESULTS
Regulation:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 266.104
U.S. EPA 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapters 2 and 10.
Stack gas CO concentrations from a BIF burning hazardous waste should not
exceed 100 ppmv, corrected to 7 percent O2, on an HRA basis. For some BIFs
the 100 ppmv value may be exceeded, provided that the total hydrocarbon (THC)
level does not exceed 20 ppmv. The CEMS strip charts should be closely
reviewed to assess compliance with the 100 ppmv limit (or other limit as
appropriate)
Q Whether CO concentration, during testing (for each run, all test
conditions), corrected to 7 percent O2, is below 100 ppmv
Clark notes that the TBR summary table shows that the average CO
concentration in flue gas was 95 ppmv. A review of the field data logsheet and
strip chart also shows that the average CO concentration was 95 ppmv.
The CO concentration from a BIF unit should not exceed 100 ppmv, corrected to
7 percent O2 (unless the facility proposes to monitor THC). Results for CO
should also be presented after correction to 7 percent O2. Clark asks that the
facility clarify whether CO concentration was corrected to 7 percent O2 and, if
so, if the CO concentration was measured before or after the correction. Section
7.5.1 of this component contains the formula for correcting measured CO
concentration to 7 percent O2.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-136
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
11.3 REVIEWING STACK GAS EMISSION RATE RESULTS
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 266.103
U.S. EPA 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapters.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapters 5 and 10.
This section should summarize the stack gas emission rate for PM, particle size
distribution (PSD), HC1, and C12, metals, POHCs, PICs, organics, and
PCDD/PCDF for each run. Stack gas emission rate values should be calculated
for actual, dry standard during which this data is collected, and 7 percent O2
conditions.
This chapter of the TBR should include subsections regarding the following
topics:
Q PM and PSD results for each run (see Section 11.3.1)
Q HC1 and C12 emission rate results for each run (see Section 11.3.2)
Q Metals emission rate results for each run (see Section 11.3.3)
Q POHC emission rate results for each run (see Section 11.3.4)
Q PIC emission rate results for each run (see Section 11.3.5)
Q TO emission rate results for each run (see Section 11.3.6)
Q PCDD/PCDF emission rate results for each run (see Section 11.3.7)
This section discusses how to review the emission rate results for each of these
compounds. Sections 11.3.1 through 11.3.7 of this component include example
sections for each of the emission parameters
A summary table in the TBR reviewed by Lois shows PIC emission rates as 0
Ib/hr.
Example Comments: Although PICs were below the detection limits, PIC emission rates should be
calculated using the detection limit and the emission rate shown as a value less
than "<" the detection limit.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-137
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-138
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
11.3.1 Reviewing Particulate Matter Emission Rate Results
Regulations: 40 CFR Part 266.105
Guidance:
Explanation:
Check For:
No specific references are applicable to this section of the manual.
BIFs burning hazardous waste may not emit PM in excess of 180 micrograms
per dry standard cubic meter (//g/dscm) or 0.08 gr/dscf after correction to a
stack gas concentration of 7 percent O2. This data is typically collected during all
runs and all test conditions. The PM emission rate should be presented as the
maximum of three valid test runs for each test condition. The standard deviation
and the 95th percentile should also be presented so the reviewer can use this
information to assess the variability of the data collected. See Section 8.4.3 of
this component for guidance on calculating the 95th percentile.
The U.S. EPA 1992 TID guidance for BIFs recommends that soot blowing occur
during one run of each trial burn test. Particulate emissions measured during
these soot blowing runs should be corrected as follows.
E = [(Esbr-Enosb) x ((AS+BS)/AR) x (Cn/Ct)] + Enosb
Where
E = corrected emission rate
Esbr = average emissions during test run with soot blowing corrected to 7%
oxygen
Enosb = average emissions during test runs without soot blowing corrected to 7%
oxygen
A = hours of soot blowing during test run with soot blowing
B = hours without soot blowing during test run with soot blowing
S = normal number of hours of soot blowing per 24 hours
R = normal hours of operation per 24 hours
Cn = normal number of hours between cleaning cycles
Ct = number of hours between cleaning cycles during test
In situations involving no soot blowing, the particulate emissions measured during
all valid test runs must be less than the emissions standard of 0.08 gr/dscf. In
situations involving soot blowing, the measured particulate emissions during the
soot blowing run may exceed the emissions standard provided the corrected
emission rate is less than the emission standard.
Note: Every reviewer should also be aware and verify compliance with other
applicable PM limits from Clean Air Act (CAA) permits and regulations, since
more stringent PM limits are often applicable.
Q Whether emission rate is less than 180 //g/dscm (0.08 gr/dscf)
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-139
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Example Situation:
Q PM emission calculations
Q Whether isokinetic sampling results are acceptable (within 90 to 110
percent)
Q Appropriate correction for soot blowing
Exhibit 11.3.1-1, see page 6-132—-Worksheet 8 Data Reduction for U.S. EPA
Method 5 Sampling Train lists data collected during testing and shows step-by-
step procedures for calculating the particulate emission rate in Ib/hr.
In reviewing the TBR, Clark verifies that a field data log sheet average entry is
shown for each parameter being used in Worksheet 8 PM calculations. He also
verifies all calculations for accuracy.
The stack test report included in the TBR shows PM emissions rates of 3.21,
3.23, and 3.22 Ib/hr for Runs 1, 2, and 3, whereas the TBR summary table shows
PM emission rates of 3.41, 3.43 and 3.42 Ib/hr.
The stack test report for a similar on-site unit shows that PM emissions during
the three runs of the DRE test were as follows:
Example Action:
Run 1, 0.070 gr/dscf
Run 2, 0.060 gr/dscf
Run 3, 0.090 gr/dscf
At first glance, it appears that the emissions standards for PM was exceeded
during Run 3 and the trial burn was thus a failure. Reading further into the
report, however, Clark notes that soot blowing occurred during Run 3. Clark
reviews the test documentation in more detail and determines the following:
Duration of Run 3 = 3 hours
Length of soot blowing event during Run 3 (A) = 1 hour
Normal hours of soot blowing per 24 hours (S) = 3
Normal hours of operation per day (R) = 24
Normal hours between cleaning cycles = 8
Number of hours between cleaning cycles during test = 8
Clark's review of calculations confirms that the emissions indicated in the stack
test report (3.21, 3.23, and 3.22) are correct. He asks that the facility revise the
TBR summary table to reflect the correct values.
Clark applies the soot blowing correction factor as follows:
E = [(0.09 - ((0.07+0.06)/2)) x ((1)(3)
((0.07+0.06)/2))
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-140
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
= 0.074 gr/dscf
Clark's calculation shows that the corrected emission rate was less than the
standard. Clark, therefore, determined that the trial burn was a success with
regard to PM emissions.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-141
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 11.3.1-1
REVIEWING PARTICULATE MATTER EMISSION RATE RESULTS
WORKSHEET 9
DATA REDUCTION FOR METHOD S SAMPLING TRAINS
The following delves the formulas needed to complete this worksheet. If the testing staff normally
reduce the sampling data bymeans of a computer, these calculations would not need to be used. Each parameter » to
be recorded for each sampling train operated during each run.
Line 2: Final meter volume corrected by subtracting non-sample volumes as during port change leak checks.
Ltae 4: Refer to the Method 5 procedures for leak rales which are greater than 0.02 cubic feet per minute.
Line 5: (Line 2 - Line 1) x Line 3
Ltoc 6: Average of all meter temperatures recorded during sampling
Use 9: Line 7 + (Line 8 + 13.6)
Line 10: Average of Jl AH recorded during sampling
Line 1 1: Average of all lie square roots of the AP recorded during sampling
Ltoe 12: (Line 11)!
0;
(Line 5) x 17.64 x
Line 7 * (Liac 10 + 13.6)
-
Line 14
& Line 15:
Line 17:
Line 18:
Line W:
Line 2ft
Line 26:
Line 27:
Orsat analysis results for stack gas
If stack gas is not
saturated:
If stack gas is water
saturated:
0.047 x Line 16
Vapor pressure of water at stack temp.
-9
(0,047 x Lane 16) * Line D
Average of all stack temperatures recorded during sampling
(OJ2 x Line 14) + (0.44 x Line 15) + (0.28 I (100 - Line 14 - Use IS))
Liae 19 x (1-Line 17) + (18 x Line 17)
Circular, square, rectangular ._ etc
For Circular: (an*)* * * + m
For Square: (««) + »**
For Rectangle: (aris #1) x (axis #2) + 144
0221-Olrpf
G-20
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-142
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 11.3.1-1 (Continued)
REVIEWING PARTICULAR MATTER EMISSION RATE RESULTS
Luc 28:
line 29:
Line 30:
Luc 31:
Line 32:
UBC 34:
Line 35:
Line 36:
line 37:
line 38:
Line 18 * 460
5129.4 x Line 21 x Unc 11 * I 30 * Line" 5
0.0945 x
(Line 18 •» 460) x Line 13
Line 9 x (Ltee 28 * 6O) x A.
x (1
Where A. - (Line 23)2 * » * s76
Line 28 x Line 27
Line 30 x 17.64 x Line 19
- PH.- IK »460"
line 31 * (1 - Li»e I7)
15.43 x (Line 33 + Line O)
(14 x Line 34 ) + {21 - Line 14)
(Line 34 x 12) + Line 13
272.15 x Line 33 x Line 9
13 » (0,047 x Unc 16)) x (Line 18
Line 34 x Line 32 x 60
_—
smow
OZ21-OMI'
G-21
EXHIBIT 11.3.1-1 (continued)
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-143
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
REVIEWING PARTICULATE MATTER EMISSION RATE RESULTS
MODE:
TEST CONDITION:
RUN NO.:
DATE:
WORKSHEET 8: DATA REDUCTION FOR U.S. EPA Method 5 SAMPLING TRAIN
Line
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Parameter
Initial Meter Volume, cubic feet
Final Meter Volume, cubic feet
Meter Factor
Multiple Leak Checks
Net Meter Volume, cubic feet
Average Meter Temperature, F
Barometric Pressure, inches mercury (Hg)
Static Pressure, inches water
Stack Pressure, inches Hg
Average AH, inches water
Average Square Root of AP, inches water
Average AP, inches water
Gas Volume, dry standard cubic feet
Percent Oxygen
Percent Carbon Dioxide
Moisture Collected, milliliters
Fraction Water
Average Stack Temperature,°F
Dry Molecular Weight
Wet Molecular Weight
Pilot Coefficient
Sampling Time, minutes
Nozzle Diameter, inches
Stack Axis No. 1, inches
Stack Axis No. 2, inches
Stack Geometry
Stack Area, square feet
Stack Velocity, actual feet/min
Sampling Train
Particulate
Multiple Metals
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-144
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 11.3.1-1 (Continued)
REVIEWING PARTICULATE MATTER EMISSION RATE RESULTS
WORKSHEET 8: DATA REDUCTION FOR U.S. EPA Method 5 SAMPLING TRAIN (Continued)
Line
No.
29
30
31
32
33
34
35
36
37
38
Parameter
% Isokinetic
Flow Rate, actual cubic feet/min
Flow Rate, standard cubic feet/min
Flow Rate, dry standard cubic feet/min
Particulate Weight, grams
Particulate Loading, grains/dry standard cubic
feet
Corrected to 7% Oxygen
Corrected to 12% Carbon Dioxide
Particulate Loading, grains/cubic feet
Emission Rate, Ib/hr
Sampling Train
Particulate
Multiple Metals
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-145
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
11.3.2 Reviewing Hydrogen Chloride and Chlorine Gas Emission Rate Results
Regulation: 40 CFR Part 266.107
Guidance:
Explanation:
Check For:
Example Situation:
Example Action
Notes:
No specific references are applicable to this section of the manual.
BIF regulations (40 CFR Part 266.107) require that the facility meet permit limits
for HCl and C12 (Tier I, adjusted Tier I, Tier II, or Tier III). This data is typically
collected during all runs and all test conditions. Stack gas emission rate values
should be calculated for actual, dry standard, and 7 percent O2 conditions. The
HCl and C12 emission rate should be presented as the maximum of three valid
test runs for each test condition. The standard deviation and the 95th percentile
should also be presented so the reviewer can use this information to assess the
viability of the data collected. See Section 8.4.3 of this component for guidance
on calculating the 95th percentile.
Q Trial burn HCl and C12 emission rates (use field data and laboratory
results to see whether TBP objectives were met)
Q HCl and C12 emission rate calculations
Exhibit 11.3.2-1, see page 6-137—Worksheet 9—provides step-by-step
procedures for calculating HCl and C12 emission rates.
In reviewing the TBR, Lois verifies that field and data logsheet and Worksheet 9
entries are made for each parameter being used to calculate the C12 emission
rate. She also verifies all calculations for accuracy.
For Run No. 1, the field logsheet data shows that the dry meter gas volume was
31.51 ft3, whereas Worksheet 9 used for the C12 emission rate calculation shows
a stack gas sample volume of 39.40 dscf
Lois verifies that 31.51 ft3 of dry meter gas volume was collected during Run No.
1, as shown on the field data logsheet. Lois uses this value to verify the
calculations.
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-146
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 11.3.2-1
REVIEWING CHLORINE EMISSION RESULTS
WORKSHEET 9
CHLORINE EMISSION RESULTS
HO and 0, colons -us, be .**** *^*££ S±S
emission as m>
caustic solutions.
Summary:
Column c = Column a x Column b
Column c - (Column c + Column d) + 1,000
Column g - Column e x Column f + 60
Column h, line 1 » Column g x 1,03
Column i, Line 2 = Column g
RPFV014
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-147
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 11.3.2-1 (continued)
REVIEWING CHLORINE EMISSION RESULTS
MODE:
TEST CONDITION:
WORKSHEET 9. CHLORINE EMISSION RESULTS
Run # and
Date
Impinger
Solution
Condensate
Caustic
Condensate
Caustic
Condensate
Caustic
(a)
Chloride
Cone.
(mg/L)
(b)
Impinger
Volume (L)
(c)
Quantity
Found (mg)
(d)
Stack Gas
Sample
Volume
(dscf)
(e)
Cl Cone.
(g/dscf)
(f)
Stack Flow
(dscf/min)
(g)
Cl Emission
(g/sec)
(h)
HC1
Emission
(g/sec)
(I)
C12
Emission
(g/sec)
Line No.
1
2
1
2
1
2
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-148
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
11.3.3 Reviewing Metal Emission Rate Results
Regulations: 40 CFR Part 266.106
Guidance:
Explanation:
Check For:
Example Section:
No specific references are applicable to this section of the manual.
BIF regulations (40 CFR Part 266.106) require that the facility meet permit limits
for metal emissions (Tier I, adjusted Tier I, Tier II, or Tier III). This data is
typically collected during the high temperature and risk burn test conditions. Stack
gas emission rate values should be calculated for actual, dry standard, and 7
percent O2 conditions. The metals emission rate should be presented as the
maximum of three valid test runs for each test condition. The standard deviation
and the 95th percentile should also be presented so the reviewer can use this
information to assess the variability of the data collected. See Section 8.4.3 of
this component for guidance on calculating the 95th percentile.
Q Trial burn results for metal emissions to see whether TBP objectives
were met
Q Metal emissions calculations
Exhibit 11.3.3-1, see page 6-140—Worksheet 10—provides step-by-step
procedures for calculating metal emissions using field data and laboratory
analysis results.
Example Comments: Determining metal emissions during the trial burn is not required if the facility
meets Tier I or adjusted Tier I emission rate screening limits.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-149
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 11.3.3-1
REVIEWING METAL EMISSION RATE RESULTS
Worksheet 10
Analysis Results for Metals Sampling Train
The five portions of the MM5-M metals sampling train to be analyzed for metals are:
1. Acetone rinse
2. Nitric rinse
3. Filter
4. Condensate and nitric acid/peroxide impingers (back half)
5. Potassium permanganate/sulfuric acid impinger (mercury [Hg] only).
Worksheet 10 should be completed with results from laboratory analysis. Values below detection limits are assumed
to be zero, so that the totals represent amounts actually found, except when all component analyses for a run are below
detection limits. A "less than" value should then be reported.
The totals of each metal for each run are calculated by adding the five portions of the MM5-M sampling train. The
concentration (Line 7) is calculated by dividing this total by the sample volume obtained from Worksheet 8, Line 13. Finally, the
emissions value is calculated by multiplying the concentration by the stack flow rate, obtained from Worksheet 8, Line 32, and
dividing the product by 60 x 106.
Summary:
Line 6 = Line 1 + Line 2 + Line 3 + Line 4 + Line 5 (Hg only)
Line 7 = Line 6 + Worksheet 8, Line 13
Line 8 = Line 7 x Worksheet 8, Line 32 - (60 x 106)
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-150
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
MODE:
EXHIBIT 11.3.3-1 (Continued)
REVIEWING METAL EMISSION RATE RESULTS
Test Conditions:
WORKSHEET 10, ANALYSIS RESULTS FOR METALS SAMPLING TRAIN
Metal:
RunT
RunT
Ag
As
Ba
Be
Cd
Cr
Hg
Pb
Sb
Tl
Line No.
>Jo. /Date
Acetone Rinse, /^g
Nitric Rinse, /^g
Filter, /^g
Nitric Acid Impingers, /^g
KMnO4 Impingers, /^g
Total, /^g
Sample volume, dscf
Concentration /^g/dscf
Stack gas flow rate, dscf/s
Emissions, g/sec
NA
NA
NA
NA
NA
NA
NA
NA
NA
1
2
3
4
5
6
7
8
9
10
-------
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
MODE:
EXHIBIT 11.3.3-1 (Continued)
REVIEWING METAL EMISSION RATE RESULTS
Test Conditions:
WORKSHEET 10, ANALYSIS RESULTS FOR METALS SAMPLING TRAIN
Metal:
RunT
Ag
As
Ba
Be
Cd
Cr
Hg
Pb
Sb
Tl
Line No.
-------
COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
11.3.4 Reviewing POHC Emission Rate Results
Regulations: 40 CFR Part 266.104
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
No specific references are applicable to this section of the manual.
BIF regulations (40 CFR Part 266.104) requires that the DRE be demonstrated
during the trial burn for each POHC designated in the permit for each waste
feed. This data is collected at the DRE test condition. Stack gas emission rate
values should be calculated for actual, dry standard, and 7 percent O2 conditions.
The POHC emission rate should be presented as the maximum of three valid test
runs for each test condition. The standard deviation and the 95th percentile
should also be presented so the reviewer can use this information to assess the
variability of the data collected. See Section 8.4.3 of this component for
guidance on calculating the 95th percentile.
Q Trial burn results of POHC emissions to see whether TBP objectives are
met
Q POHC stack gas emission calculations (check field data logsheets and
analytical report)
Section 11.1 of this component presents POHC (benzene) emission rate sample
calculations. To calculate POHC in ash and residue, multiply the POHC
concentration in the ash and residue by the ash and residue generation rate,
respectively.
In reviewing the TBR, Clark notes that the analytical report shows a benzene
concentration of 5 nanograms, per sampling volume. The POHC emission rate
results for benzene, however, is presented as O.003 Ib/hr.
Clark asks that the facility revise the summary table to show the actual mass rate
for benzene.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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11.3.5 Reviewing PIC Emission Rate Results
Regulations: Not applicable to this section of the manual.
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
No specific references are applicable to this section of the manual.
If the gas temperature in the combustion zone of the combustion unit drops below
the minimum, gas leaving the combustion unit may still contain undestroyed
POHCs and hazardous PICs. Generally, the gas temperature in the combustion
zone is maintained to minimize PIC formation. PIC testing is conducted for
VOCs, SVOCs, and PCDD/PCDFs using U.S. EPA Methods 0030, 0031, 0010,
and 23 (or 0023 A). The presence of PICs in stack gas should be checked by
reviewing the results for those sampling trains. This data should be collected at
the risk burn test condition. Additionally, VOC and SVOC PIC and C12 data may
be available from the DRE test condtition, depending on the nature of the
POHCs used to demonstrate DRE.
The emission rate of each PIC should be presented as the maximum of the three
valid test runs for each test condition. The standard deviation and the 95th
percentile should also be presented so the reviewer can use this information to
assess the variability of the data collected. See Section 8.4.3 of this component
for guidance on calculating the 95th percentile.
VOC emission rates should be calculated using the average stack gas flow rate
measured by any isokinetic sampling trains operating during the same sampling
period. If no isokinetic sampling trains were operated while the VOST sample
was collected (for example, sequential sampling), the reviewer should carefully
review combustion unit operating conditions, select a test run where operating
conditions are comparable to those during the VOST run, and use the average
stack gas flow rate from the comparable test run to reduce the VOST field
sampling data. Stack gas emission rate values should be calculated for actual,
dry standard, and 7 percent O2 conditions.
Q VOC PICs emission rate based on VOST results
(U.S. EPA Methods 0030 and 0031)
Q SVOC PICs emission rate based on SVOST results
(sampling U.S. EPA Method 0010, analytical U.S. EPA Method 8270)
In reviewing the TBR, Clark notes that compounds D, E, and F were not
detected by the laboratory and that the average mass emission rate for these
compounds was reported as 0 Ib/hr. See Section 11.3.6 of this component for
example comments.
If a compound was not detected by an analytical method, the detection limit value
should be used for calculations. Clark asks that the facility insert a "<" (less
than) symbol in front of the value when reporting results in the TBR. See
Section 11.3.6 of this component for example comments.
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Notes:
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11.3.6 Reviewing Total Organic Emission Rate Results
Regulations: Not applicable to this section of the manual.
Guidance:
Explanation:
Check For:
Example Situation:
No specific references are applicable to this section of the manual.
In order to determine the total organic emission rate, three fractions of organic
compounds are added together: the volatile fraction of compounds with a boiling
point less than 100°C; semivolatile compounds with a boiling point range of
100°C to 300 °C; and nonvolatile compounds with a boiling point greater than
300°C. This data is collected at the risk burn test condition. Stack gas emission
rate values should be calculated for actual, dry standard, and 7 percent O2
conditions. The TO emission rate should be presented as the maximum of three
valid test runs for each test condition. The standard deviation and the 95th
percentile should also be presented so the reviewer can use this information to
assess the variability of the data collected. See Section 8.4.3 of this component
for guidance on calculating the 95th percentile.
Q Volatile organics emission rate of compounds determined using
U.S. EPA Method 0040 (SW-846)
Q Semiovolatile organics emission rate of compounds determined using
U.S. EPA Method 0010 (SW-846)
Q Nonvolatile organics emission rate of compounds determined using U.S.
EPA Method 0010 (SW-846)
The following method can be used as a guide to verify the total organics emission
rate calculation.
Review of the TBR indicated the following:
Sampling Method
Used/Compounds
0040/Volatile Organics
0010/Semivolatile
Organics
0010/Nonvolatile
Organics
Total Weight of
Organics as Reported
by the Laboratory
(nanograms)
1,565
3,130
1,043.3
Total Sample Volume of
Stack Gas through the
Sampling Train
(liters)
60.8
91.2
91.2
Stack gas flow rate calculated using methods 1 through 4 = 10,310 dscfm
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Stack gas concentration of all volatiles (g/dscm)
= 1,565 ng _J_ '
ng 60. 8L dscm dscm
g
Stack gas concentration of all semivolatiles (g/dscm)
_ 3,130 wg v 1 v 1x70- Z
wg 91.2 Z fifecm dscm
g
Stack gas concentration of all nonvolatiles (g/dscm)
1,043.3 ng 1 1x70 L 1 1 . „ AC
— - ^- x - x - = 1.14 £-05
ng 91.2 L dscm dscm
Volatiles emission rate (g/sec)
= 2.57 £-05 -5— x ^'"^ "^ x 2.832.10
min dscf 60 sec
= 1.25 £-04
sec
Semivolatiles emission rate (g/sec)
= 3.43 £-05 —^- x 10,310 =^L x 2.832 x 10
min dscf 60 sec
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1.66 £-04 --
sec
Nonvolatiles emission rate (g/sec)
1.14 £-05 —£— x 10,310 ^Lx 2.832 x 10"2 ^^
min dscf 60 sec
= 0.554 £-04 -8—
sec
Total organics emissions rate (g/sec)
volatiles emission rate + semivolatiles emission rate + nonvolatiles emission rate
= 1.25 £-04 + 1.66 £-04 + 0.554 £-04 = 3.464 £-04
sec
Total organic emissions rate (Ibs/hr)
= 3.464 £-04 -£- x — x 3,600 —
sec 453.54 g hr
= 2.75 £-03 —
hr
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Example Action: If all three fractions of the unspeciated mass are not detected, the detection limit
value should be used in any subsequent calculations. Lois asks that the facility
place a "<" (less than) symbol in front of the value when reporting results in the
TBR. If the mass of the volatile unspeciated organic compounds were below the
detection limit but the semivolatile and nonvolatile unspeciated mass fractions are
quantified, the semivolatiles and nonvolatiles emission rate should be added
together and the volatile organic emission contribution can be treated as 0 Ibs/hr.
Notes:
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11.3.7 Reviewing Poly chlorinated Dibenzo-p-dioxin/Poly chlorinated Dibenzofuran Emission
Rate Results
Regulation:
40 CFR Part 264.343
40 CFR Part 266.104
Guidance:
Explanation:
Check For:
No specific references are applicable to this section of the manual.
Regulations require that the emission rates of 2, 3, 7, 8-tetra- through
octa-PCDD/PCDF congeners be determined as part of the emission testing for
risk assessment purposes. Stack gas emission rate values should be calculated
for actual, dry standard, and 7 percent O2 conditions. The PCDD/PCDF
emission rate should be presented as the maximum of three valid test runs for
each test condition. The standard deviation and the 95th percentile should also be
presented so the reviewer can use this information to assess the variability of the
data collected. See Section 8.4.3 of this component for guidance on calculatinag
the 95th percentile.
Q Trial burn results of PCDD/PCDF emissions
Q PCDD/PCDF emission calculations
Q ORE of 99.9999 percent for PCDD/PCDFs
Example Situation: In reviewing the TBR, Clark uses the following equation to verify the
PCDD/PCDF emission rate:
MR = 1.323 x 10E-4 x C x Qs
where
MR
C
1.323xlO-4
Qs
C can be estimated as follows:
mass emission rate of PCDD/PCDF (Ib/hr)
concentration of dioxins and furans on dry basis,
(mg/dscf)
conversion factor
dry volumetric flow rate at standard conditions
(dscfrn)
where
K
Kxm/Vm(std)
10-3 (mg/kg)
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m = mass of dioxins and furans in samples (//g)
Vm = dry gas volume, measured by the dscf
Example Comments: Clark calculates the same number, verifying the results; no comment is
necessary.
Notes:
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11.4 REVIEWING PROPOSED PROCESS LIMITS
Regulations: 40 CFR Part 266.102
Guidance: U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapters.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapters.
Explanation: Regulations require that the permit specify process operating limits and risk based
limits to include the following:
• Maximum average emission rate for each metal during the trial
burn (high temperataure test condition)
• Feed rate of total and pumpable hazardous waste (lower of the
maximum value measured during the DRE and high temperature
test conditions)
• Fuel feed rates (high temperature test condition)
• Feed rate of metals in each hazardous waste stream (high
temperature test condition)
• Total feed rate of C12 and chloride in total feed streams (lower of
the maximum value measured during the DRE and high
temperature test conditions)
• Maximum combustion gas temperature (high temperature test
condition)
• Minimum combustion gas temperature (high temperature test
condition)
• Maximum flue gas temperature at the inlet to the PM control
device (high temperature test condition)
• Combustion gas velocity (DRE test condition)
• Maximum device production rate (high temperature test
condition)
• Minimum device production rate (DRE text condition)
• Appropriate controls on operation and maintenance of the
hazardous waste filtering system and any part of the APCS
(various)
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• Allowable variation in BIF system design, including any APCS
operating procedures (various)
• Risk based limits (risk burn test condition)
Additional guidance regarding the development of permit conditions is included in
Component 7 — How to Prepare Permit Conditions.
Check For: Q Maximum (average during test run) emission rate of each metal
Q Feed rate of metals in each hazardous waste stream
Q Total feed rate of C12 and HC1 in total feed streams
Q Fuel feed rates
Q Maximum combustion gas temperature
Q Minimum combustion gas temperature
Q Maximum flue gas temperature at the inlet to the PM control device
Q Combustion gas velocity
Q Maximum device production rate
Q Minimum device production rate
Q APCS parameters
Subsections that follow contain procedures for reviewing proposed waste feed
limits, AWFCO limits, combustion unit parameters, and APCS parameters.
Sections 11.5, 11.6, 11.6.1, 11.6.2, and 11.6.2.1 through 11.6.2.6 of this
component include the example comments for review of key process limits.
In reviewing the TBR, Clark notes that the liquid waste feed contains a large
amount of chloride; however, the TBR did not propose any process limits for
chloride.
Clark asks that the facility propose maximum chloride feed rate limits on the
basis of the actual trial burn or dispersion modeling conducted using trial burn
data.
Example Situation:
Example Action:
Notes:
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11.5 REVIEWING PROPOSED WASTE FEED LIMITS
Regulations:
Guidance:
Explanation:
40 CFR Part 266.102
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapters.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapters.
A hazardous waste feed rate limitation is required mainly to minimize a potential
loss of efficiency or unsafe situation from overloading the combustion chamber
and entire combustion unit treatment system. For maximum operating flexibility,
the waste feed rate is maximized during both the DRE and high temperature test
conditions.
General guidelines for setting permit limits for waste feed are as follows:
• The maximum feed rate of each LFfV waste stream to each
combustion chamber should be the feed rate of that stream at the
minimum temperature trial burn point
• The maximum feed rate of each medium heating value or HHV
waste stream should be the maximum feed rate of that stream
for any trial burn point
• The maximum size of containerized waste charged to the
combustion chamber should be the maximum demonstrated for
any trial burn point
U.S. EPA 1989 Guidance on Setting Permit Conditions lists three approaches for
setting waste feed limits, including: (1) single waste/single operating condition -
single point; (2) multiple waste/multiple operating conditions - multiple point; and
(3) multiple waste/single operating condition - universal. The first approach
(single point) applies where only one waste is burned under a single operating
condition. The permit objective may be satisfied by setting limits on the specific
type of waste to be incinerated.
The second approach is to set multiple limits for each set of operating
parameters. For example, when drummed waste is burned with liquid wastes A
and B, then one set of operating conditions applies. When drummed waste is
burned with liquid wastes C and D, then a second set of operating conditions
applies. Each mixture of waste must be defined in the permit under this scenario.
Under the third approach, the intention is to develop one set of operating
conditions that allows a facility to burn a relatively broad range of wastes. This
approach is most complex; however, it offers the greatest operating flexibility.
This approach allows the combustion of a relatively wide variety of wastes but at
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conditions that are generally more severe than most of these waste streams
require.
Additionally, annual average permit limits may be established based on data from
a risk burn conducted at normal conditions. To develop these additional permit
conditions, the minimum and maximum HRAs values demonstrated during the
risk burn test are used.
Check For: Q Whether waste feed rate is the proposed permit limit set at maximum
feed rate (review feed rate data of trial burn)
Q Whether the proposed permit limit is established as a single, 1-hour rolling
average
In reviewing the TBR, Lois notes that the BIF unit combusts LHV waste and
that testing was conducted at minimum and maximum temperature scenarios.
The feed rate at the minimum temperature was 45.3 Ib/min, whereas the feed
rate at the maximum temperature was 47 Ib/min. The facility asked to set the
maximum feed rate at 47 Ib/min.
Example Situation:
Example Action:
The maximum feed rate limits of each LHV waste stream should be the feed
rate of that stream at the minimum temperature trial burn; therefore, a maximum
permit limit should be 45 Ib/min (unless the permittee desires to and can publicly,
legally, and technically defend a higher feed rate limit than what was
demonstrated). Lois asks that the facility justify the proposed limit of 47 Ib/min.
Notes:
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11.6 REVIEWING PROPOSED AUTOMATIC WASTE FEED CUTOFF LIMITS
Regulations:
Guidance:
Explanation:
Check For:
40 CFR 264.345(f)
40 CFR Part 266.102
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 2.
U.S. EPA. 1992. "Technical Implementation Document for U.S. EPA's BIF
Regulations." EPA-530-R-92-011. Chapter 4.
Facilities are required to have AWFCO systems that engage immediately when
operating conditions deviate from those established during the trial burn test.
Generally, limits for the following parameters are established as AWFCOs:
• Maximum CO concentration in stack gas
• Maximum production rate
• Maximum feed rate of total hazardous waste
• Maximum feed rate of pumpable hazardous waste
• Maximum combustion zone temperature
• Maximum flue gas temperature entering a PM control device
• Limits on key APCS operating parameters
The AWFCO limits are set as HRAs limits based on average data collected
during either the DRE or high temperature test conditions.
This chapter of the TBR should include subsections that address:
Q Combustion unit parameters (see Section 11.6.1)
Q APCS parameters (see Section 11.6.2)
Q Parameters for other associated equipment (see Section 11.6.3)
During review of these subsections, the TBR review team should check for the
following:
Q AWFCO limits
Q Whether AWFCO limits are established for the parameters listed above
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Example Situation: In his TBR review, Clark concluded, in part, that:
"This limit is actually a combination of two AWFCO limits (both in Ib/hr of waste
feed). AWFCO 1, based on the highest average heat input rate from the two
test conditions (23.0 million Btu/hr [MMBtu/hr]); and AWFCO 2, based on the
maximum waste feed rate demonstrated during TC-2 (45.3 lb/min]).
"According to the TBP, AWFCO 1 will be varied according to the heat content
of the waste stream being fed (23.0 MMBtu/hr divided by the heat content) to
determine a pound-per-minute waste feed rate limit, not to exceed 45.3 lb/min.
The relationship between the two AWFCO limits—which are combined to set a
single, HRAs AWFCO for each waste stream—is poorly explained in Section
6.1. In addition, the combination of different units (for example, hours and
minutes) may result in an improper calculation of the AWFCO in the future."
Example Action:
Clark asks that the facility revise the proposed limits section of the TBR to
include a more detailed discussion of the relationship between AWFCOs 1 and 2
for the waste feed rate limit. He also asks that the facility use consistent units in
the revisions for values that will be used in the same equation.
Notes:
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11.6.1 Reviewing Parameters for Combustion Units
Regulations: 40 CFR Part 266.102
Guidance: No specific references are applicable to this section of the manual.
Explanation: 40 CFR Part 266.102(e) requires that the following operating requirements (not
inclusive) be specified in the permit:
• Appropriate indicator of combustion gas velocity
Gas residence time in the combustion chamber
Combustion gas flow rate
Combustion air flow rate
• Combustion chamber temperature
The regulations specifically require that suitable interlocks be provided to shut off
the hazardous waste feed if the combustion unit temperature drops below a value
specified in the permit ([40 CFR Part 264.345(f)]. For maximum operating
flexibility, combustion gas velocity (flow rate) is set at as a maximum value to
control (1) gas residence time in the combustion chamber, (2) control gas
throughout the system to minimize back pressure at joints and seals, (3) gas flow
rate through the APCS to ensure that it is not overloaded, and (4) ash carryover
from the combustion chamber to the APCS. This value is determined from the
maximum average value (instantaneous or HRAs) measured during the DRE test
condition of the trial burn test.
Combustion chamber temperature also must to be limited because (1) an increase
in combustion zone temperature may lead to increased metals vaporization, which
may, in turn, result in increased emissions of hazardous metals; and (2) a
decrease in combustion zone temperature may lead to increased PIC emissions.
For maximum operational flexibility (worst-case emissions), the combustion unit
temperature is bounded by minimum and maximum average values
(instantaneous or HRAs) measured during the DRE and high temperature test
conditions.
AWFCO limits for combustion chamber temperature are based on the average
minimum and maximum operating temperatures at which a successful test
(minimum of three runs) occurred. The AWFCO should be set so that the waste
feed is cut off when the temperature exceeds these values.
Check For: Q Whether the proposed permit limit for combustion gas velocity is set at
the maximum combustion gas velocity (review gas velocity data during
the appropriate test conditions of the trial burn)
Q Whether proposed permit limits for combustion chamber temperature are
set at minimum and maximum combustion unit temperatures measured
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during the appropriate test conditions of the trial burn
Whether the proposed permit limits are established as both instantaneous
andHRA
Example Situation:
The limits on flue gas velocity should be based on the maximum combustion gas
flow rate measured during the trial burn. This flow rate measurement should be
taken at the minimum temperatures observed during the test to ensure that the
condition includes the lowest temperatures and shortest residence time that still
achieves acceptable combustion unit performance.
In reviewing the TBR, Clark noted that the permit limit for maximum combustion
gas velocity is based on the stack gas flow rate demonstrated in the trial burn,
with the highest combustion gas flow. Low and high temperatures averaged 15.4
and 14.2 acfm. Therefore, the facility is recommending a 1-hour HRA limit of
14.2 acfm.
Example Action:
The permit limit is generally based on low temperature flow measurement data;
therefore, a limit of 15.4 acfm should have been proposed. Clark asks that the
facility explain the reasoning for proposing the limit at 14.2 acfm.
Notes:
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11.6.2 Parameters for Reviewing Air Pollution Control Systems
Regulations: 40 CFR Part 266.103
Guidance: No specific references are applicable to this section of the manual.
Explanation: Various APCSs are used depending on whether it is necessary to control PM,
acid gas, or both. Permit limits for APCS parameters for PM and acid gas are
based on data collected during the trial burn.
Permit limits for APCS parameters should be set from the results of the
appropriate test condition of the trial burn. This approach will maintain
compliance while allowing adequate operational flexibility. For example, permit
limits for APCS parameters relating to particulate collection should be set from
the trial burn test at the maximum average inorganic ash feed rate and the
maximum average flue gas flow rate, because the ash feed rate determines the
load to the APCS, and an increase in the flue gas flow rate may increase PM
entrainment.
Check For: The following subsections should be included (if applicable to the APCS
employed):
Q Dry scrubber parameters (see Section 11.6.2.1)
Q Wet ionizing scrubber parameters (see Section 11.6.2.2)
Q Venturi scrubber parameters (see Section 11.6.2.3)
Q Wet scrubber parameters (see Section 11.6.2.4)
Q Electrostatic precipitator parameters (see Section 11.6.2.5)
Q Baghouse (fabric filter) parameters (see Section 11.6.2.6)
Q Other associated equipment parameters (see Section 11.6.3)
The following items should be evaluated by the TBR review team:
Q Proposed permit limits for APCS parameters
Q Trial burn monitoring data for APCS parameters to confirm that
proposed permit limits reflect actual APCS monitoring parameters
Q Whether proposed permit limits for APCS parameters are established as
HRAs
Example Section: An example section for each type of APCS is included in Sections 11.6.2.1
through 11.6.2.6 and 11.6.3 of this component.
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Example Comments: Example comments for each type of APCS are included in Sections 11.6.2.1
through 11.6.2.6 and 11.6.3 of this component.
Notes:
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11.6.2.1 Reviewing Dry Scrubber Parameters
Regulation: 40 CFR Part 266.103
Guidance:
Explanation:
Check For:
No specific references are applicable to this section of the manual.
This section does not apply if the facility does not have a dry scrubber as part of
its APCS. For worst-case emissions, dry scrubber parameters are set at the
minimum average caustic feed rate and the maximum average flue gas flow rate,
and are typically based on data from successful runs of the DRE test condition of
the trial burn. Dry scrubber permit limits are based on the ratio of the flow rate
of the absorbent slurry to that of the acid gas, and is stated as "the system should
not be operated at a caustic or lime feed rate of less than X Ib lime to Y Ib HC1."
Q Minimum average caustic feed rate
Q Maximum average flue gas flow rate
Example Situation: In reviewing the TBR, Lois notes the following table:
Example Action:
Notes:
Run Number
Average
Flue gas flow
(acfm) rate
Average
Caustic feed
(Ib/hr) rate
1
51
3.8
2
53
4.2
3
53
3.9
The TBR proposed a permit limit of 3.8 Ib/hr of caustic feed rate.
The TBR should have proposed a permit limit of 3.9 Ib/hr minimum caustic feed
rate, because this rate is the lowest at maximum flue gas flow rate. Lois asks
that the facility explain the reasoning behind the proposed feed rate permit limit.
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11.6.2.2 Reviewing Wet Ionizing Scrubber Parameters
Regulation: 40 CFR Part 266.103
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
No specific references are applicable to this section of the manual.
This section does not apply if the facility does not have wet ionizing scrubbers as
part of its APCS.
The wet ionizing scrubber combines the collection principles of the electrostatic
precipitator (ESP) with the acid gas removal of a conventional packed-bed
scrubber. In the wet ionizing scrubber, incoming particles are charged in a small
ionized section with high-voltage direct current (DC) power. Charged particles
are scrubbed in the packed-bed section.
For worst-case emissions, parameters for the wet ionizing scrubber are generally
set at (1) minimum HRAs liquid to flue gas ratio; (2) minimum HRAs scrubber
blowdown; (3) minimum average pH level of scrubber water; (4) minimum
average electric power to the precipitator plates; and (5) maximum gas flow rate,
typically based on data collected during successful runs at the DRE test condition
of the trial burn.
Q Minimum average liquid to flue gas ratio
Q Minimum average scrubber blowdown from the system or maximum
suspended solids content of scrubber water
Q Minimum average pH level of the scrubber
Q Minimum average electric power, in kilovolt amperes (kVA) or applied
voltage, to precipitator plates
Q Maximum average flue gas flow rate
In reviewing the TBR, Clark notes that the facility has proposed permit limits for
only two parameters for the wet ionizing scrubber: minimum liquid flow rate
and minimum DC voltage.
The parameters listed under "Check For" are typically included as permit limits;
however, the facility proposed permit limits for only two parameters. Clark
reviews the TBR to determine if all of these parameters were measured during
the trial burn in accordance with the TBP, and develops independent permit limit
recommendations for the other three parameters.
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Notes:
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11.6.2.3 Reviewing Venturi Scrubber Parameters
Regulation: 40 C Part 266.103
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section does not apply if the facility does not have venturi scrubbers as part
ofitsAPCS.
For worst-case emissions, the liquid-to-gas ratio and the differential gas pressure
across the venturi scrubber are set at a value based on the average minimum
value measured during the successful runs completed at the DRE test condition
of the trial burn.
Check For:
Example Situation:
Example Action:
Q Minimum average differential gas pressure limit across the venturi
scrubber (the differential pressure is measured by applying pressure taps
on each side of the venturi, connected to a differential pressure [A?]
transducer)
Q Minimum average liquid-to-gas ratio limit
Q pH level limit
Q Maximum total suspended solids
Q Minimum APCS inlet temperature (dry units)
Lois reviews the TBR to see whether the above parameters included under
"Check For" were monitored and recorded during the trial burn. She also
reviews proposed permit limits for the venturi scrubber to see whether they
reflect the minimum average differential gas pressure across the venturi
scrubber, minimum average liquid-to-gas ratio, and pH levels recorded during trial
burn.
Lois reviews trial burn APCS monitoring data to confirm that the A? in the permit
limit is based on the minimum average A? recorded. Typically, the higher the A?,
the greater the efficiency; therefore, for greater flexibility, A? is set at a minimum
value.
Notes:
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11.6.2.4 Reviewing Wet Scrubber Parameters
Regulations: 40 CFR Part 266.103
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section does not apply if the facility does not have a wet scrubber as part of
its APCS.
For worst-case emissions, wet scrubber parameters are set at the minimum
average caustic feed rate and the maximum flue gas flow rate typically measured
during the successful runs at the DRE test condition of the trial burn.
Check For:
Example Situation:
Example Action:
Q Minimum average liquid-to-gas ratio limit
Q Maximum average flue gas flow rate limit
Q pH level limits for scrubber effluent
Q Maximum average inlet temperature
Q Maximum total suspended solids
Clark reviews the TBR to see whether the above parameters included under
"Check For" were monitored and recorded during the trial burn. He also reviews
proposed permit limits for the wet scrubber to see whether they reflect the
minimum average liquid-to-gas ratio, maximum average flue gas flow rate, and
pH levels measured during the trial burn test.
Clark notes that since the wet scrubber is used for PM and acid gas control,
permit limits are proposed to include minimum liquid-to-gas ratio and maximum
flue gas flow rate.
Acid gas removal efficiency in the wet scrubber relates directly to the pH of the
scrubber effluent. Clark asks that (1) the facility include pH levels for setting
wet scrubber permit limits, and (2) the pH limits be based on levels recorded
during the actual trial burn.
Notes:
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11.6.2.5 Reviewing Electrostatic Precipitator Parameters
Regulations: 40 CFR Part 266.103
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section does not apply if the facility does not have ESPs as part of its
APCS.
The ESP is a well-established device for participate control and is used in very
large combustion unit installations. ESPs remove particles by charging them and
then collecting them on oppositely charged plates. Collection efficiency increases
with increasing applied voltage and decreases with increasing gas flow rate.
For worst-case emissions, ESP parameters are set at minimum electric power to
precipitator plates, maximum flue gas flow rate, and maximum average inlet
temperature, based on values measured during the successful runs at the DRE or
high temperature test conditions of the trial burn.
Check For:
Example Situation:
Q Minimum electric power, in kVA or applied voltage, to precipitator plates
Q Maximum average flue gas flow rate
Q Maximum average inlet temperature
Lois reviews the TBR to see whether electric power and flue gas flow rate were
monitored and recorded during the trial burn. She also reviews proposed ESP
permit limits to see whether they reflect maximum average flue gas flow rate and
minimum electric power.
In reviewing the TBR, Lois notes the following table:
Run Number
Flue Gas Flow
(acfm) Rate
Electric
Power to
Plates (kVA)
1
89
2.8
2
93
2.9
3
88
2.7
4
91
2.7
5
92
2.7
The TBR proposed permit limits of 2.7 minimum kVA and a flue gas flow rate of
93 acfm.
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Example Action: Collection efficiency increases with increasing applied voltage. However, to
assure the minimum required collection efficiency, the permit limit should be set
at minimum kVA at it's corresponding flue gas rate—not the maximum flue gas
flow rate demonstrated during trial burn testing. Therefore, the permit limit
should be set at 2.7 minimum kVA and 92 acfrn, instead of the 93 acfrn
proposed. Lois asks that the facility revise the proposed permit limit.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
11.6.2.6 Reviewing Baghouse (Fabric Filter) Parameters
Regulations: 40 CFR Part 266.103
Guidance: No specific references are applicable to this section of the manual.
Explanation: This section does not apply if the facility does not have a baghouse (fabric filter)
as part of its APCS.
Filters remove particles by collecting them on filter fibers or on previously
collected particles. The most commonly used types are fabric filters, in which
gas flows through parallel arrangements of filter bags. Bags are periodically
cleaned by shaking or reversing the air flow. Filter efficiency increases with
increasing pressure drop.
In addition to the maximum average inlet temperature, for worst-case emissions,
permit limits for a baghouse (fabric filter) are set at minimum average pressure
drop based on the data collected during the successful runs completed at the high
temperature test condition of the trial burn.
Check For: Q Minimum average pressure drop, as set by the TBP
Q Maximum average inlet temperature
Q Air-to-cloth ratio
Example Situation:
Q Cleaning cycle
Clark reviews the TBR to see whether the pressure drop was monitored and
recorded during the trial burn. He also reviews the proposed permit limit to
determine if it reflects the minimum average pressure drop observed during the
actual trial burn test.
Clark notes that permit limits for fabric filters would be set to include the
minimum average differential pressure of 1.5 pounds per square inch (psi) and
that the bags would be cleaned once every 3 hours
Example Comments: Normally, a facility need only specify the minimum average differential pressure
across fabric filters as a permit condition; however, the facility may also include
the cleaning cycle as part of proposed permit limits.
Notes:
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11.6.3 Reviewing Other Associated Equipment Parameters
Regulations: 40 CFR Part 266.103
Guidance:
Explanation:
Check For:
No specific references are applicable to this section of the manual.
Different types of APCSs are used depending on whether it is necessary to
control PM, acid gas, or both. Permit limits for APCS parameters for PM or
acid gas are based on the data collected during the trial burn. Section 11.6.2 of
this component lists APCS parameters for most commonly used equipment. This
section explains how to review other associated equipment parameters, which
mainly includes equipment not specifically mentioned in Section 11.6.2 of this
component and other parameters formulated on the need to ensure that
combustion unit operation adheres to good combustion and APCS operating
practices. These latter parameters are based on manufacturer's design and
operating specifications rather than trial burn settings. These parameters are
established independent of trial burn data.
Q Parameters from trial burn data (Group A and B parameters)
Q Cyclones
Q Inlet gas temperature
Q Gas velocity
Q Pressure drop
Q Absorber
Q Inlet gas temperature
Q Scrubber liquid flow rate
Q Scrubber liquid inlet and outlet pH
Q Nozzle pressure
Q Recirculation and blow down rate
Q Induced- or forced-draft fan
Q Volumetric flow rate
Q Temperature
Q Pressure
Q Horsepower
Q Packed-bed scrubber
Q Liquid-to-gas ratio
Q Scrubber liquid pH
Q Scrubber liquor blowdown rate
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Q Parameters independent of trial burn (Group C parameters)
Q APCS inlet gas temperature
Q Maximum total heat input for each chamber
Q Liquid injection burner settings
Q Maximum viscosity of pumped waste
Q Maximum burner turndown
Q Minimum atomization fluid pressure
Q Minimum waste heating value
Q Minimum and maximum nozzle pressure to scrubber
Example Situation: In reviewing the TBR, Lois notes that flue gases from the combustion unit are
routed to the wet scrubber, and that the average inlet gas temperature to the wet
scrubber was 600°F. The wet scrubber was stack tested, and the flue gas
temperature was reported at 700°F.
Example Action: The wet scrubber cools the flue gases; therefore, the wet scrubber outlet
temperature should be considerably lower than the inlet scrubber temperature.
The reported value of 600°F as the inlet temperature appears to be very low.
Lois checks the combustion chamber temperature monitoring data to see why
600°F was reported. Based on her review, she finds that the inlet temperature
should have been reported as 1066°F. She asks the facility to correct this
apparent transcription error from the raw data.
Notes:
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11.7 REVIEWING PROPOSED DATA FOR USE IN THE RISK ASSESSMENT
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
Example Action:
40 CFR Parts 266.104, 266.106, and 266. 107
No specific references are applicable to this section of the manual.
Trial burn or risk burn data are collected specifically to conduct human health and
ecological risk assessments. These risk assessments ensure the protection of
human health and the environment. This data can be collected (1) during normal
operating conditions (risk burn data) or (2) at the DRE and high temperature test
conditions (trial burn data) depending on the facility and specific requirements
identified during the TBP development process.
For each run, the TBR or RBR should summarize the average emission rate for
each constituent identified below, calculated at actual, dry standard, and 7
percent O2 conditions.
Q VOC emission rates including PICs, during each run
Q SVOC emission rates including PICs, during each run
Q PAH emission rates during each run
Q Emission rates for other organic compounds that may be of concern,
such as aldehydes, during each run
Q Metal emission rate during each run
Q HC1 and C12 emission rates during each run
Q PCDD and PCDF emission rates during each run
PSD
a
TO emission rates
Using emission rate data, a risk assessment is conducted to determine if
emissions are greater than a level that may create unacceptable risk. U.S. EPA
Region 6 1998 risk protocol documents include specific procedures for
completing the risk assessment process at hazardous waste combustion units.
This process includes air dispersion modeling, fate and transport modeling, and
risk calculation.
As part of the TBR review process, Clark reviews and evaluates for accuracy
actual stack parameters such as stack gas temperature, stack gas velocity, and
stack gas volumetric flow rates to be used in the risk assessment.
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Notes:
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12.0 REVIEWING THE APPENDICES
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 60, Appendix A
40 CFR Part 266
40 CFR Part 266, Appendix IX
40 CFR Part 270
No specific references are applicable to this section of the manual.
TBR appendices contain all raw test data, field notes, test plans, calculations, and
supporting documentation. They also contain performance and QA/QC
information. The appendices usually make up the bulk of a TBR, and therefore
consume the greatest amount of review time. The review of the main text of the
report is a check that the information contained in the report appendices has been
accurately summarized.
Q The TBP and QAPP would have been submitted and approved prior to
conducting the trial burn. They may or may not be resubmitted as
appendices; however, if they are not included as appendices to the TBR,
they should be obtained for use in the TBR review (see Sections 12.1
and 12.2).
Q Stack sampling report (see Section 12.3)
Q Process sampling report (see Section 12.4)
Q QA/QC report (see Section 12.5)
Q Instrument calibration records (see Section 12.6)
Q Performance calculations (see Section 12.7)
Q Field logs (see Section 12.8)
Q Analytical data packages (see Section 12.9)
During a review of information on waste feed composition, Clark ensures that the
following documentation is available for cross-referencing and validation of
reported information to verify targeted constituents, approach, methodology,
guidance, and limitations: (1) TBP, (2) trial burn QAPP, (3) process sampling
report, (4) QA/QC report, and (5) analytical data packages.
Clark uses each document for specific information: (1) the TBP outlines waste
feed analysis requirements and parameters; (2) the QAPP outlines sample
handling, traceability, and reporting criteria; (3) the process sampling report
provides detailed information concerning sampling frequency and locations of
samples collected during the test; (4) portions of the QA/QC report will verify
SQLs and target analysis criteria in support of waste feed analytical procedures;
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and (5) analytical data packages will provide detailed information concerning
sample history and raw test data obtained during sample preparation and analysis.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.1 REVIEWING APPENDIX A—TRIAL BURN PLAN
Regulations: 40 CFR Part 270.66
40 CFR Appendix A
Guidance: No specific references are applicable to this section of the manual.
Explanation: The TBP should be an appendix to the TBR so that the reviewer can
cross-reference information and targeted approaches to the testing program.
Component 1—How to Review a Trial Burn Plan, presents TBP elements.
Check For: Q The TBP must have been submitted and approved prior to the trial burn;
it may or may not be resubmitted as an appendix to the TBR; however,
at a minimum, it should be obtained for use in the TBR review
Q Letters of correspondence between the BIF facility and the regulatory
agency
Q Notices of deficiency and responses
Q Letter from U.S. EPA stating that the TBP is acceptable for
implementation
Example Section: The TBP should be thoroughly reviewed, and all participants in the trial burn
process—test personnel, field observers, process personnel, and permitting
officials—should understand its key components. With this background and
understanding, the TBP will assist the TBR reviewer complete the assigned task.
Example Comments: Component 1— How to Review a Trial Burn Plan, provides examples and
comments on how to review the TBP.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.2 REVIEWING APPENDIX B—QUALITY ASSURANCE PROJECT PLAN
Regulations: 40 CFR Part 270.62(b)(2)
40CFRPart270.66(c)
Guidance: No specific references are applicable to this section of the manual.
Explanation: U.S. EPA QA policy requires that every monitoring and measurement project
have an approved trial burn QAPP. This document should contain—in specific
terms—policies, organizational adaptations, overall objectives, functional
activities, and QA/QC activities designed to achieve data quality goals of the
project or operation. The trial burn QAPP must be prepared by the organization
responsible for the project work, usually the stack sampling contractor, and
approved by the appropriate federal, regional, or state agency.
The trial burn QAPP and TBP should be considered companion documents and
should be reviewed simultaneously. (For this reason, the trial burn QAPP is
often appended to the TBP.)
Check For: Q The trial burn QAPP should have been submitted and approved prior to
the trial burn, it may or may not be resubmitted as an appendix to the
TBR; however, as a minimum, it should be obtained to assist in the TBR
review.
Q Sixteen essential elements of a trial burn QAPP include:
Q Title page with provisions for approval signatures
Q Table of contents
Q Project description
Q Project organization and responsibility
Q QA objectives for later measurement, in terms of precision,
accuracy, completeness, representativeness, and comparability
Q Sampling procedures
Q Sample custody
Q Calibration procedure and frequency
Q Analytical procedures
Q Data reduction, validation, and reporting
Q Internal QC checks and frequency
Q Performance and system audits and frequency
Q Preventive maintenance procedures and schedules
Q Specific routine procedures to be used to assess data precision,
accuracy, and completeness of specific measurement
parameters involved
Q Corrective action
Q QA reports to management
Q Document control indicator in the top right corner of each page
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Q How the trial burn QAPP is contained in the overall plan (incorporated
into the TBP or separate from it)
Example Section: The trial burn QAPP will describe the accuracy, precision, and data quality
objectives for the trial burn test program, including measurement device
calibration and tolerance criteria; test methodology criteria; and analysis protocol
for the laboratory facilities.
Example Comments: Component 2—How to Review a Trial Burn Quality Assurance Project Plan,
provides examples and comments on review of the trial burn QAPP.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.3 REVIEWING APPENDIX C— STACK SAMPLING REPORT
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
Stack gases are sampled isokinetically at multiple points within a stack for
SVOCs, PCDD/PCDFs, PM, HC1, C12, and metals. VOCs and combustion
gases are sampled at a constant rate at a single point.
Field data sheets and emission rate calculations should be presented for the
following sampling methods if they are part of the trial burn:
U.S. EPA Method 0010—SVOCs
U.S. EPA Method 23 or 0023A—PCDD/PCDFs
U.S. EPA Method 0012 or 0060—Metals
U.S. EPA Method 0013 or 0061—Hexavalent chromium
U.S. EPA Method 0030 or 0031—VOST
• U.S. EPA Method 0040—Unspeciated volatile organics
U.S. EPA Method 0050 or 0051—PM/HCl/chlorine
• Particle size distribution
See Section 10.1.1 of this component for a detailed listing and critical elements of
all applicable methods.
The TBR should include the following subsections:
Q U.S. EPA Method 0010 field data sheets and emission rate calculations
(See Section 12.3.1)
Q U.S. EPA Method 23 or 0023A field data sheets and emission rate
calculations (See Section 12.3.2)
Q U.S. EPA Method 0012 or 0060 field data sheets and emission rate
calculations (See Section 12.3.3)
Q U.S. EPA Method 0013 or 0061 field data sheets and emission rate
calculations (See Section 12.3.4)
Q U.S. EPA Method 0030 or 0031 field data sheets and emission rate
calculations (See Section 12.3.5)
Q Total organics field data sheets and emission rate calculations (See
Section 12.3.6)
Q U.S. EPA Method 0050 or 0051 field data sheets and emission rate
calculations (See Section 12.3.7)
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During review of these subsections, the TBR review team should evaluate the
following:
Q Field data sheets for each sampling method used during the trial burn
Q Emission rate calculations, in consistent units for each method used
during the trial burn
Q Calibration records for pretest and post-test calibration of all methods
and sampling equipment
Q All calibration records for calibration equipment
Example Situation: When reviewing TBRs, Lois verifies that all stack sampling reports present the
preceding information with appropriate calculations of emission rates.
Example Action: Lois follows Section IV of the U.S. EPA 1989 Checklist for Reviewing RCRA
Trial Burn Reports for reviewing RCRA TBRs to confirm that data sheets are
complete and accurate.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.3.1 Reviewing U.S. EPA Method 0010 Field Data Sheets and Emission Rate Calculations
Regulations: 40 CFR Part 266.103
Guidance:
Explanation:
Check For:
Example Situation:
No specific references are applicable to this section of the manual.
Stack gases and participate pollutants are sampled isokinetically for SVOCs in a
multicomponent sampling train. Principal components of the train include a high-
efficiency glass or quartz-fiber filter and a packed bed of porous polymeric
adsorbent resin. The filter is used to collect organic-laden participate material,
and the porous polymeric resin is used to adsorb semivolatile organic species.
Semivolatile species are defined as compounds having boiling points between
about 100 and 300°C. Use of the Method 0010 sampling train for the collection
of TO emission rate data is described in Section 12.3.6.
A separate field data sheet must be prepared for each sampling run, and this
sheet must record each traverse point and sampling time. Critical columns for
temperature should be carefully reviewed.
Q Field data sheets indicating traverse points sampling time; vacuum; stack
temperature; velocity head; pressure differential across orifice meter;
gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser
Q Filter temperature of 248 ± 25 °F
Q Gas temperature entering the sorbent-trap of less than 68 °F
Q Isokinetic sampling rate of 90 to 110 percent
Q Stack flow rate calculations
Q Minimum sample column calculations
Q SVOC emission rate calculations
In reviewing the TBR, Clark notes that during one test, the filter holder
temperature exceeded 273 °F for more than 20 minutes of sampling.
Example Comments: Clark asks that the facility note the excursion in the stack sampling report and
that its potential impact on data quality be discussed.
Notes:
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Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.3.2 Reviewing U.S. EPA Method 23 or 0023A Field Data Sheets and Emission Rate
Calculations
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 266.103
No specific references are applicable to this section of the manual.
The sampling parameters and sampling train are essentially the same as
described in Section 12.3.1 of this component.
Q Field data sheets indicating traverse points; sampling time; vacuum; stack
temperature; velocity head; pressure differential across orifice meter;
gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser
Q Minimum sample volume required for DRE measurement is 106 dscf;
this volume can be used as the absolute minimum for PCDD/PCDF
sampling
Q Filter temperature of 248 ± 25 °F
Q Gas temperature entering the sorbent-trap of less than 68 °F
Q Isokinetic sampling rate of 90 to 110 percent
Q Stack flow rate calculations
Q Minimum sample column calculations
Q PCDD/PCDF emission rate calculations
Q Demonstrated experience of the analyst in the use of air sampling
methods for PCDDs, PCDFs
In reviewing the TBR, Clark closely examines the field data sheet for each
sampling run that will be used for PCDD/PCDF analysis. The sampling time
needed to obtain the necessary minimum sample gas volume must be clearly
presented.
To verify the calculation, Clark uses the formula presented in the TBR for
calculating the minimum sampling time:
0.5
0.85 x 0.1
= 6.25 hr
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where 0.5 = analytical detection limit for compound (ng)
0.85 = sample volume (m3/hr)
0.1 = desired stack gas concentration detection limit (ng/m3)
The correct result is 5.9 hours. Clark asks that the facility revise the TBR to
reflect the correct result.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.3.3 Reviewing U.S. EPA Method 0012 or 0060 Field Data Sheets and Emission Rate
Calculations
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 60 Appendix A, MM5
40 CFR Part 266 Appendix IX
No specific references are applicable to this section of the manual.
At a minimum, stack gases are sampled isokinetically for the 10 BIF metals
antimony, arsenic, barium, beryllium, cadmium, total chromium, lead, mercury,
selenium, silver, and thallium. The metals content of the sample is quantitatively
determined at the laboratory by using ICP or AA spectroscopy.
Q Field data sheets (for each traverse point record: sampling time; vacuum;
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger])
Q Maintenance of proper temperature (probe and filter at 248 ± 25 °F, train
exit gas below 68°F)
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
Q Metals emission rate calculations
In reviewing the TBR, Lois examines all data sheets for metal emission sampling
to determine method compliance. The composition of the sampling train
apparatus is the same as that used for U.S. EPA Method 5 particulate sampling,
with the same temperature limitations.
If any of the recorded temperatures exceed limits in the method, Lois verifies
that the TBR presents the possible effects on data quality. She is familiar with
the U.S. EPA 1989 Checklist for Reviewing RCRA Trial Burn Reports and
follows the method requirements checklist carefully.
Notes:
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12.3.4 Reviewing U.S. EPA Method 0013 or 0061 Field Data Sheets and Emission Rate
Calculations
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
40 CFR Part 60 Appendix A, MM5
SW-846 Method 0061
40 CFR Part 266.102(e)(4)
No specific references are applicable to this section of the manual.
This method applies to the determination of hexavalent chromium emissions from
hazardous waste incinerators, BIFs, and other waste combustion sources. The
sampling train, constructed of Teflon components, has been evaluated only at
temperatures below 300°F. Hexavalent chromium emissions are collected
isokinetically from the source. To eliminate the possibility that the level of
hexavalent chromium will be reduced between the nozzle and impinger, emission
samples are collected with a recirculating train, in which the impinger reagent is
continuously recirculated to the nozzle. Impinger train samples are analyzed for
hexavalent chromium by an ion chromatograph equipped with a post-column
reactor and a visible wavelength detector. The pH in the first impinger must be
greater than 8.5 and is to be determined at the end of the sampling run.
Q Field data sheets (for each traverse point records: sampling time;
vacuum; stack temperature; velocity head; pressure differential across
orifice meter; gas sample volume; gas sample dry-gas meter inlet and
outlet temperature; and temperature of gas leaving condenser [last
impinger])
Q Maintenance of proper temperature (probe and filter at 248 ± 25 °F, train
exit gas below 68°F)
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
Q Hexavalent chromium emission rate calculations
Q First impinger pH
After hexavalent chromium sampling has been completed, the technician should
record the pH of the first impinger on field data sheets. If nothing is recorded,
hexavalent chromium analytical results are suspect.
In reviewing the TBR field data sheets, Clark notes that at the end of Run 1, the
technician checked the pH of the first impinger and found it to be 8.3. The
solution was analyzed for hexavalent chromium, but in Runs 2 and 3, the first
impinger was checked for pH during port change, and additional solution was
added to maintain a minimum pH of 8.5. All analytical results appeared to be
satisfactory.
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Example Comments: The pH can be adjusted by adding additional sodium hydroxide solution to the
impinger or by starting with a higher normality solution to account for acid gas
neutralization during sampling.
Notes:
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12.3.5 Reviewing U.S. EPA Method 0030 or 0031 Field Data Sheets and Emission Rate
Calculations
Regulations:
Guidance:
Explanation:
Check For:
40CFRPart266.103(e)(2)
No specific references are applicable to this section of the manual.
This method is for sampling VOCs in stack gas. This method is appropriate for
sampling VOCs having a boiling point below 100°C.
This method collects a 20-liter sample of stack gas drawn at a rate of 0.5 liters
per minute by using a glass-lined probe and a VOST. The gas stream is cooled
to 68 °F, and VOCs are collected on two or three sorbent resin traps for Method
0030. The first trap contains about 1.6 grams of Tenax®, and the second trap
(back trap) contains about 1 gram each of Tenax® and petroleum-based
charcoal. For Method 0031 the first two traps contain Tenax®, while a third trap
contains Anasorb®.
Q Sample collection rate
Q Temperature of gas stream entering first trap
Q Leak checks
Q Identification of O-rings
Q Identification of sample cartridge storage conditions
Q Qualifications of sampling personnel
Q Holding time for VOST tubes from time and day of collection to time and
day of analysis
In reviewing the TBR, Lois reviews all data sheets to determine recorded
temperatures, sampling rate, and leak checks. She follows the activity column in
"Checklist for Reviewing RCRA Trial Burn Reports" for critical functions during
VOST operation. Lois pays close attention to the time and date of sample
collection and analysis; the holding time is very short for VOST tube analysis.
During review of VOST results, Lois notices that Run 1 samples were collected
on May 1 and analyzed on May 19. This delay was not noted in the report as a
holding time violation. A comparison of all VOST results showed Run 1 results
to be 50 percent lower than other results.
Example Comments: In her report, Lois documents this difference and recommends that VOST testing
be repeated.
Example Section:
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Notes:
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12.3.6 Reviewing Total Organics Field Data Sheets and Emission Rate Calculations
Regulations: 40 CFR Part 266.10
Guidance:
Explanation:
Check For:
Example Situation:
No specific references are applicable to this section of the manual.
The characterization of emissions from hazardous waste combustion units should
include quantification of the mass emission rate of TO. TO is the combination of
three fractions of organic compounds, grouped by boiling points; Group 1—boiling
point <100°C; Group 2—boiling point 100°C to 300°C; and Group 3—boiling
point >300 °C.
A field GC with a FID is used to analyze an integrated Tedlar® bag sample for
organics with boiling points below 100°C. For compounds boiling between
100°C and 300°C and 300°C or higher, samples collected using a U.S. EPA
Method 0010 sampling train are analyzed by (1) integrating the total mass under
the GC curve (total chromatographicable organics [TCO]) and (2) GRAY after
evaporation of all free liquid, respectively.
This combination of two sampling and three analytical techniques provides the
investigator with the total mass of all speciated and unspeciated recoverable
organic material. The mass of organic material that remains after correction for
the speciated organic compounds is used to estimate risk from unspeciated
organic emissions.
Q U. S. EPA Method 0040 field data sheets
Q Field GC results
a U.S. EPA Method 0010 field data sheets
Q TCO results
a GRAY results
Q Unidentified organics emission rate calculations
Q Experience in sampling and analysis techniques
Data from the three analytical determinations are collected and added to obtain a
TO value for the sample.
In reviewing the TBR, Clark notes that the following table presents risk burn
results:
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Run
Number
1
2
-3
3
4
Average
Semivolatile
Chrom ato graphic able
Organics
(mg/m3)
3.051
0.589
1.365
1.668
Volatile
Chrom ato graphic able
Organics
(mg/m3)
8.965
0.467
0.493
3.308
Total
Chrom ato graphic able
Organics
(mg/m3)
4.976
Example Action:
Clark notes that the math is correct and that the results are representative for a
waste-fired boiler using exempt process waste on a unit having no quench or
scrubber. Revisions to the guidance for conducting risk assessments at RCRA
combustion units have recently included the requirement that TO be measured.
However, no GRAY results of the nonvolatile fraction are reported. Clark asks
that the facility revise the table to include this information.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.3.7 Reviewing U.S. EPA Method 0050 or 0051 Field Data Sheets and Emission Rate
Calculations
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 60 Appendix A, U.S. EPA Method 5
U.S. EPA Method 0050, Test Methods for Evaluating Solid Waste, SW-846
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-6-89-019. Chapter 2, Table 5-1, Table 5-4, and
Appendix F.
Stack gases are sampled isokinetically from the source to collect PM on a glass
filter maintained at a temperature of 248 ± 25 °F, to collect HC1 and C12 gas in
absorbing solutions. Particulate mass, which includes any material that
condenses at or above the filtration temperature, is determined GRAY after
removal of combined water. Chloride content of the absorbing solutions is
quantitatively determined at the laboratory by using ion chromatography.
Q Field data sheets for each traverse point recording the following:
Q Sampling time
Q Vacuum
Q Stack temperature
Q Velocity head
Q Pressure differential across orifice meter
Q Gas sample volume
Q Gas sample dry -gas meter inlet and outlet temperature
Q Temperature of gas leaving condenser (last impinger)
Q Maintenance of proper temperature (probe and filter 248 ± 25 °F, train
exit gas below 68 °F)
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
Example Situation:
Example Action:
Lois and Clark are reviewing field data sheets for U.S. EPA Method 0050
sampling and notice that the oven temperature was recorded at 284 °F for several
sampling points. Lois remembers that the method states that the oven
temperature should not exceed 273 °F. If the temperature is too high, some
condensible organics will volatilize and not be collected. If the temperature is too
low too many compounds will be condensed on the filter, inaccurately reflecting
the amount of PM in the stack gas.
Lois asks the sampling contractor to explain why the data were not rejected for
the run during which oven temperature was above the maximum allowable value.
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Notes:
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12.4 REVIEWING APPENDIX D—PROCESS SAMPLING REPORT
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 266.103
40 CFR Part 270.62(b)(2)(iii)
No specific references are applicable to this section of the manual.
An appendix to the QA/QC report should describe how process waste samples
were collected during the trial burn. This appendix can be cross-referenced to
the TBP to determine whether planned samples were collected by using
procedures and equipment presented in the TBP.
The TBR should include subsections on the following:
Q Raw data (see Section 12.4.1)
Q Data summary calculations (see Section 12.4.2)
The TBR review team should evaluate these section for the following
information:
Q Sampling equipment, as proposed in the TBP
Q Sampling data forms to see whether location, method, frequency, and
presentation agree with TBP
Q Responsibility assignments
Finally, raw data should be spot-checked against data included in the trial burn
oversight report.
In reviewing TBR process sampling reports, Clark verifies inclusion of brief
sections containing an introduction, a list of responsibilities, any remedial actions
taken, the physical method, the procedure described, and any references used.
The section on the method is important because it discusses equipment used to
collect each sample; the procedure section describes, in detail, how each sample
was collected and preserved.
Clark verifies that the process sampling report presents the sampling process and
determines whether it followed the TBP.
Notes:
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12.4.1 Reviewing Raw Data
Regulations: 40 CFRPart 270.62(b)
Guidance:
Explanation:
Check For:
No specific references are applicable to this section of the manual.
As part of the appendix on process sampling, the TBR must include copies of all
process sampling data forms. These forms are usually preprinted for each
process sampling station, giving the location, method, frequency, and method of
preservation. There are identifiers on the form for the run number, data, and
samplers. The form must be completed by the technician collecting the sample.
Q Sampling location
Q Sampling method
Q Sampling frequency
Q Sample preservation
Q Run number, data, and sampler identity
Q Sample identification
Raw data should also be spot-checked against data collected during the trial burn
oversight
An example of a liquid organic waste feed sampling data form is included as
Exhibit 12.4.1-1, see page 6-194. In reviewing data form, Lois and Clark want
the following information: (1) contractor identity; (2) facility tested; (3) sample
location; (4) sampling method; (5) sampling frequency; (6) sample preservation
method; (7) run number; (8) date; (9) sampler; and (10) the grab sample number
and time.
Example Action: Lois and Clark expect all TBRs to contain data forms similar to this example.
Notes:
Example Situation:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
EXHIBIT 12.4.1-1
EXAMPLE LIQUID ORGANIC WASTE FEED SAMPLING DATA FORM
LIQUID ORGANIC WAS I K FEED SAMPLING DATA
I [Project No.
Client/Sourcu:
Suuicu I ovation:
SAMPI ING LOCATION: In-lino, valved tap oif tco in feed line leading directly to the dedicated injoollon no?7le In tho primary
combustion chamber Of ihe incinerator syslom. Teo is in 90° bond in feed line whcro feed flow w downwnrd to tee and
horizontal away from tee. Sample flow is downward from tee. Tap located upstream from the point of POHC spike injection
Into tho feed line and is within 1 6 feet of the injection nok/le.
SAMPLINO METHOO; Tap and connactlons to f«od linn purflod with an adequate amount of fond <«pprax. 100 mL«) to
dloplecc oocumulatod material ImmorJIiiUly prior to Mch fMnplinO- Samples uolloctod into and onmpoaltod with • gle*» banker
to transfer a minimum of 5O-mL. but equal volume incromenw Into 32 oz. precleanod, amber class bottles marked for equal
volume graduations; and <1O-mL amhflr glass VOA vials filled from the beaker. Bottles sealed will, Teflon*-linod scraw caps
and vials seatod with 'I oflon*-linsd septa. All sample containers stored In ice chests during sampling.
SAMPLING FREQUENCY; One [1) composite sample (sample, no. XXO16) from increments taknn and two (2) VOA vials filled
every 1 5 mimitos commencing at the start of tliti run. Snmplinu conducted continually accorrtino to a predeturmined schedule
extupt tor any adjustments made for port changes on the stack and dolays incurrod during the run as noted below.
SAMPLE POLSLRVATION: All samples stored at near water ica temperature (i.e., 4°C).
Sampler!;): _|
Run No. _
Feed Tnnk No.
Composite Sample Number:
Composite Sample Designation:
> 010 ,
svoc."
CHrab
No. Timo
6 1£.OO
10
11
12
(O41
,' .GA|?'B1-
VOC VOA i rCAl'BT - VOA
VOA Samplo ',"VOA ' Sample
Number ' No Number
S O17
^ ois
I 019
1 020
1 O21
.. Jt°*?
i GALQT1
"
a
10
1 1
12
IOZ3
IO24
C025
vv
' - 1 •
-2 ". .
3 "
*
5
6
7
8
9
1O
11
12
,\t O29~
" 1 030
I 031
| 032
/ 033
IO34
» 036
1 036
] O37
V)3rf
oVs
A
XX041 andXX042 arc pr.parod
(i.e., compoBitnd) after iho run*
.__ Interruni ions/Comments ._
•POSTSAMPLING OPERATIONS: GAI.BI Sample VOA vials composited by transferring contents of vials to ,1 16 O7.
procleanod, amber Blast bottlo (Sample Number (041), thon mixiny and transferring a poaion of the mixture in a 4O-ml
^umbor glasc VOA vial (Sample Numbor ( 042) leavina no headspaca. Bottle *«»led with "I oflon«-llncd screw cap and vial
sealed with Teflon^-linod BCpljim. Samples stored si near water ice temperature (i.o., 4"C).
Relinquished By
^CLOAS>vx,wri)
IUMIIUI o.wro Nove
Received By n
:f b, 1 99G)
Dote/Time
APPENDIX c
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12.4.2 Reviewing Data Summary Calculations
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
Notes:
40 CFR Part 266.103
40 CFR Part 270.62
No specific references are applicable to this section of the manual.
For each major measurement parameter, a brief description of the following
should be included:
• Data reduction scheme for nonroutine methods, including all validation
strips and equations used to calculate final results
• List of all final experimental data to be reported in the TBR
• List of all QC data to be reported in the TBR
All reportable test and QC data must be identified. Data summary calculations
should be clear and easy to follow.
Q Presentation of summary calculations
Q Whether summary calculations are complete
Q Whether summary calculations are accurate
In reviewing data summary calculations (supporting documentation to the TBR),
Lois reads as follows:
"All data will be recorded on a digital storage device for qualitative and
quantitative data reduction. All data will be reviewed from the time samples are
collected through analytical data reduction, to determine whether they are
reusable."
Lois asks that the facility provide example calculations based on actual data for
all results of analysis for critical parameters, particularly the DRE of POHCs and
stack emissions.
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.5 REVIEWING APPENDIX E—THE QA/QC REPORT
Regulations: 40 CFR Part 266.103
40 CFR Part 270.62
Guidance: No specific references are applicable to this section of the manual.
Explanation: The trial burn QAPP should outline the QA/QC information from the trial burn
that will be reported; this information includes the 16 elements presented in
Section 12.2 of this component. The TBR should contain all field records, all
calibration data (analytical and field), all precision and accuracy determinations
associated with QA objectives (such as surrogates, spikes, duplicates, and
standard reference material), all internal audits, and the data quality assessment
report from the QA/QC coordinator.
In general, the following QA/QC information should be provided:
• Sample traceability
• Holding times
• Waste, fuel, and APCS sampling
• Stack gas sampling
• Analysis
• QC assessment
• QA/QC coordinator report
Check For: This section of the TBR contain subsections that include the following:
Q Field sampling QA/QC report (see Section 12.5.1)
Q Laboratory QA/QC report (see Section 12.5.2)
Q COC forms (see Section 12.5.3)
The TBR review team should evaluate the following aspects of this information:
Q Formal presentation of the 16 trial burn QAPP elements
Q QA/QC information on items listed in the explanation
Q Consistency between TBP, trial burn QAPP, and TBR presentation
Example Situation: In reviewing the TBR, Clark reads as follows:
"Section 6—Sampling Procedures During the Test Burn
"6.1 Procedures - The sampling procedures to be used in this program are
described in Section 5 of the TBP and Appendix A of Volume 3. This section
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
provides information on the adequacy of the sampling and analysis methods for
demonstrating incinerator performance."
Example Action: Clark notes Section 6.1 provides a good cross-reference to the TBP and
Appendix A, and he is able to quickly locate planned and actual activities.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.5.1 Reviewing Field Sampling Quality Assurance/Quality Control Report
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 60 Appendix A, MM5
40 CFR Part 266 Appendix IX
No specific references are applicable to this section of the manual.
These documents list, and contain checklists for, stack QA/QC procedures for
gas sampling.
Using the checklists, the reviewer should evaluate the following:
Q U.S. EPA Method 1
Q Absence of cyclonic flow
a U.S. EPA Method 2
Q Thermocouple calibration range and date
Q Barometer calibration range
Q U.S. EPA Method 3
Q Leak check for sampling
Q Leak check for analyzers
Q U.S. EPA Method 4
Q Calibration sheets for vacuum gauge
Q Calibration sheets for thermocouples
Q Calibration sheets for dry-gas meter
Q Proper sampling rate
Q Pump leak checked
Q Leak check on train
Q Train temperature less than 68 °F
Q U.S. EPA Method 5
Q Calibration sheets for sampling nozzle, pitot tube, dry-gas meter
and thermometers/thermocouples
Q Leak checks for sample line and pitot lines
Q Proper sampling rate
Q Adequate total sampling time (2-hour minimum) and sampling
time at each point
Q Proper temperature maintained (probe and filter 240 ± 25 °F,
train exit gas less than 68°F)
Q Sampling rate within 90 to 110 percent of isokinetic
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Q U.S. EPA Modified Method 5 (U.S. EPA Method 0010) for semivolatile
organics
Q Sample recovery documentation for XAD tubes
Q Sample recovery documentation for blank sample collection
Q Calibration sheets for sampling nozzle, pitot tube, dry-gas meter
and thermometers/thermocouples
Q Leak checks for sample line and pitot lines
Q Proper sampling rate
Q Adequate total sampling time (2-hour minimum) and sampling
time at each point
Q Proper temperature maintained (probe and filter 240 ± 25 °F,
train exit gas less than 68°F)
Q Sampling rate within 90 to 110 percent of isokinetic
Q U.S. EPA Methods 0012 and 0060 - Determination of Metals Emissions
from Stationary Sources. Review method for QA/QC procedures and
proper sample collection, transfer, and train component cleanup
Q U.S. EPA Methods 0030 and 0031 for volatile organics
Q Leak checks for the train
Q Calibration sheets for dry gas meter and thermocouples
Q Sampling volume, duration, and leak checks for each trap pair
recorded
Q Trip blanks collected
Q Field data logsheets for each trap pair available
Q U.S. EPA Method 0040 - Total Organics Measurement. Review method
for QA/QC procedures and field analytical requirements
Q U.S. EPA Methods 0050 and 0051 - Sampling Method for PM, HC1 and
C12. Check method for QA/QC, sampling requirements, transfer and
train cleanup
Q COandO2CEMS
Q Leak checks for CO and O2 sampling locations
Q Calibration gas concentration (zero and high level)
Q Calibration gas certificate (whether CO protocol calibration
gases have expired)
Q Whether calibration checks are performed before each run and
daily
Q Whether zero and span calibration drift test is performed during
trial burn
Q Whether sampling and analysis are conducted every 15 seconds
during trial burn
Q Whether data are logged every 60 seconds during trial burn
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Example Situation: In reviewing the sampling equipment calibration data (an appendix to the TBR),
Lois checks data sheets for traverse point location, velocity traverse data
(includes cyclonic flow check), sampling nozzle calibration check data sheet,
aneroid barometric calibration check, U.S. EPA Method 5 metering console
calibration with critical orifice, console calibration worksheet, console post-test
checklist, pyrometer calibration data form, Type S pitot tube inspection data
forms, and other stack sampling data forms.
Example Action: Lois notes that the TBR does not present all calibration data needed for stack
sampling equipment; missing are the dry-gas meter calibration data and flow
meter calibration data. Lois asks that the facility add the information to the TBR
appendix.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.5.2 Reviewing Laboratory Data Summary Report
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 266.103
40 CFR Part 270.62
No specific references are applicable to this section of the manual.
All reportable test and QC data must be identified. QC data are often neglected
in TBRs, but they are vital to assessing overall data quality.
The trial burn QAPP should outline QA/QC information from the trial burn,
including: (1) all field records; (2) all calibration data (analytical and field);
(3) all precision and accuracy determinations associated with QA objectives
(such as surrogates, spikes, duplicates, and standard reference material); (4) all
internal audits; (5) the data quality assessment report from the QA Coordinator;
and (6) a detailed discussion outlining the method used to determine SQLs for all
analytical methods used.
Precision and accuracy determinations should be clearly presented, with all
results calculated. Any value that falls outside the data quality objective should
be flagged in data tables and discussed in the text in terms of the affect of the
apparent problem on overall sample results.
Q Identification of all reportable data
Q Presentation of field records
Q Calibration data
Q Precision and accuracy results
Q Internal audit results
Q Data quality assessment report
Q SQL determination summary
Q Flagged data with discussion
Example Situation: In reviewing the TBR, Clark reads as follows:
"Section 6.1. Performance Audit Results"
"Performance audit samples were prepared and analyzed with the field test
samples as a measurement of accuracy. The samples were intended to provide
an independent verification of accurate calibration or to simulate actual test
samples (that is, audit samples that are prepared and analyzed concurrently with
test samples). With a few minor exceptions, the results of performance audit
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samples were within normal calibration tolerances and data quality objectives of
the QAPP."
Example Action: Although the report acknowledges that there were exceptions to meeting the
performance audit goals, it does not discuss the overall significance of these
exceptions. Clark asks that the facility include a discussion addressing this issue.
Notes:
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12.5.3 Reviewing COC Forms
Regulations: 40 CFR Part 266.62
Guidance:
Explanation:
Check For:
No specific references are applicable to this section of the manual.
An essential part of any sampling and analytical scheme is ensuring the integrity
of the sample from collection to data reporting. The possession and handling of
samples should be traceable from the time of collection through analysis and final
disposition. This documentation of the sample history is referred to as COC.
COC documentation is necessary if there is any chance that analytical data, or
conclusions based on analytical data, will be used in litigation. In cases where
litigation is not involved, many COC procedures are still useful for routine control
of sample flow.
Q Completed forms
Q Signatures
Q Sample identification
Q Other information, as required
Example Situation: In reviewing the TBR, Lois reads as follows:
Example Action:
Notes:
"7.5. Section Transfer and Shipment of Samples—When transferring possession
of samples, individuals relinquishing and receiving those samples will sign, date,
and note the time on the field sample custody record. This record documents
sample transfer from the field sample custodian, often through another person or
commercial carrier, to the laboratory sample custodian or analyst."
Lois determines that the attached Sample Traceability Record and Sample
Condition at Receiving Laboratory forms meet the basic requirements of a
COC form and enables her to track the sample from collection to analysis.
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12.6 REVIEWING APPENDIX F—INSTRUMENT CALIBRATION RECORDS
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
40 CFR Part 60 Appendix A
No specific references are applicable to this section of the manual.
During a trial test, many types of instruments, equipment, and measuring devices
are used to measure and record source operational characteristics, physical
parameters, and scientific data. These devices are used to measure data
associated with the process, control device, ancillary unit operations, and
sampling test equipment.
The TBP and trial burn QAPP should identify each measuring device and discuss
its calibration content and tolerance.
Q Process monitoring equipment calibration records (see Section 12.6.1)
Q Process control equipment calibration records (see Section 12.6.2)
Q Emission monitoring equipment calibration records (see Section 12.6.3)
Q Stack gas sampling equipment calibration records (see Section 12.6.4)
Q Field analytical equipment calibration records (see Section 12.6.5)
The TBR review team should closely check this information for consistency with
the trial burn oversight report.
In reviewing the TBR, Lois locates a list of test devices and tolerance criteria
requirements in the TBP and trial burn QAPP. She uses these lists to verify that
all calibration records contained in the TBR are presented and that targeted
tolerance criteria are satisfied.
Lois notes that the TBR presents all of the following, in accordance with U.S.
EPA trial burn test requirements: (1) all instruments, monitors, equipment, and
measuring devices identified in the TBP, and (2) calibration factors, tolerance
values, and adjustment values outlined in the trial burn QAPP.
Notes:
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.6.1 Reviewing Calibration Records for Process Monitoring Equipment
Regulations: 40 CFR Part 266.104(b)
40CFRPart266.105(a)
40 CFR Part 266.106(1)
40 CFR Part 266.107
40 CFR Part 270.62(b)(ii)(F and J)
Guidance:
Explanation:
Check For:
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-89-019. Chapters.
For U.S. EPA to approve testing and sampling activities, the TBP must identify
various equipment and measuring devices used to monitor process equipment.
The manufacturers of these devices generally calibrate them before sale and
installation in the process. U.S. EPA requires that these devices be maintained
and operated in accordance with manufacturer procedures, to ensure that valid
and reproducible results can be obtained and verified. In addition, the devices
must be calibrated before a trial burn test, and the calibration information and
procedure must be documented to verify conformance with the TBP and trial
burn QAPP.
Q List of process monitoring equipment and measurement devicesoutlined
in the TBP
Q Identification and response criteria of each process monitoring device
outlined in the trial burn QAPP
The TBR review team should closely check this information for consistency with
the information presented in the trial burn oversight report.
In reviewing the TBR, Clark noted that the TBP identified process monitoring
equipment devices in tabular form, and that the trial burn QAPP presented the
tolerance range and sensitivity requirements for each monitoring device in tabular
form. These two tables were photocopied and readily available during review of
the calibration records appendix section of the TBR. Clark used the tables to
verify calibration records, including forms and worksheets, and found that
tolerance and sensitivities were within proposed specifications.
Example Comments: Use of the process monitoring equipment list outlined in the TBP and equipment
specifications outlined in the trial burn QAPP assists Clark in a timely and
organized approach to verify calibration records.
Notes:
Example Situation:
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12.6.2 Reviewing Calibration Records for Process Control Equipment
Regulations: 40 CFR Part 266.103
40 CFR Part 266.104(b) and (c)
40 CFR Part 266.105
40 CFR Part 266.106
40 CFR Part 266.107
40 CFR Part 270.62
40 CFR Part 270.66
Guidance:
Explanation:
Check For:
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial
Burn Results." EPA-625-89-019. Chapters.
The TBP must identify devices used to monitor and measure process control
equipment in a manner similar to the preceding section for reviewing process
monitoring equipment calibration records.
Q List of the process control equipment measuring devices outlined in the
TBP
Q Calibration records
Q Identification and response criteria of each process control equipment
device outlined in the trial burn QAPP
The TBR review team should closely check this information for consistency with
the trial burn oversight report.
To review the calibration records for the process control equipment, Lois located
the tabulated summary of process control monitoring equipment in the TBP and
the tabulated summary of calibration criteria in the trial burn QAPP. She then
prepared a photocopy of each table, and began to review the calibration records
presented in the trial burn test report—verifying that each device and calibration
value was present and within the proposed specifications.
Example Comments: Lois found that the use of these tables assisted her in conducting a complete and
thorough review of the measuring devices and the calibration records. She did
not note any problems.
Notes:
Example Section:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.6.3 Reviewing Calibration Records for Continuous Emission Monitoring Equipment
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 60 Appendix A
No specific references are applicable to this section of the manual.
The use of CEMS by the test firm should follow the procedures outlined in the
appropriate U.S. EPA reference methods. The reference test methods and
parameters commonly measured during a trial burn test are as follows:
U.S. EPA Reference Method
3A
6C
7E
10
25A
Parameters
O2 and CO2
Sulfur dioxide
Nitrogen oxides
CO
Total hydrocarbons
Before and after the test period, the CEMS is calibrated with reference gas
standards. The response of the monitor to the gas standards is used to verify
calibration error, zero drift, calibration drift, and sampling system bias tolerance
criteria outlined in each U.S. EPA reference method.
Q Monitor calibration error for all gases
Q Zero drift of the monitor
Q Calibration drift of the monitor
Q Sample system bias of the monitor
The TBR review team should closely check this information for consistency with
the trial burn oversight report.
The stack sampling company measured O2 concentration, with a CEMS using
U.S. EPA reference Method 3A. The calibration results after the test period
were found to be as follows:
Zero drift
Calibration drift =
Calibration error (zero gas)
Calibration error (mid-range gas)
Calibration error (high-range gas)
= 1 percent of the span
1.5 percent of the span
= 1 percent of the span
= 1 percent of the span
= 1 percent of the span
Sampling system bias (mid-range gas) = 2 percent of the span
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Example Comments: The calibration criteria of an O2 CEMS according to U.S. EPA reference U.S.
EPA Method 3A are as follows:
Zero drift = < ± 3 percent of the span
Calibration drift = < ± 3 percent of the span
Calibration error (zero gas) = < ± 2 percent of the span
Calibration error (mid-range gas) = < ± 2 percent of the span
Calibration error (high-range gas) = < ± 2 percent of the span
Sampling system bias (mid-range gas) = < ± 5 percent of the span
Based on a comparison of the O2 monitor response to the calibration gases and
the criteria of U.S. EPA reference method 3 A, the monitor satisfies all criteria
requirements of the methodology.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-219
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.6.4 Reviewing Calibration Records for Stack Gas Sampling Equipment
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 266 Appendix IX
40 CFR Part 60 Appendix A
No specific references are applicable to this section of the manual.
The regulations require measurement devices to meet design criteria, tolerance
specifications, and various calibration protocols. The U.S. EPA reference
methods require the stack testing company to provide calibration records or
worksheets of pitot tubes, thermocouple, dry gas meter, barometer, nozzle, and
other devices used for trial burn test projects.
Q Pitot tube calibration form
Q Thermocouple calibration form
Q Dry-gas meter calibration form (pretest and post-test)
Q Barometer calibration form
Q Sample train nozzle calibration form
Lois notes that the stack sampling company provided a calibration record form
for a barometer used during the trial burn test. The barometer was calibrated
against the barometric readings at a nearby weather bureau, at an identical
elevation relative to sea level.
Example Comments: The barometric pressure at the weather bureau and the readings of the field
barometer were identical at the same elevation. Since the calibration of the field
barometer is considered complete and satisfactory for a trial burn test, Lois
determined that the field readings were insufficient since at the test site were at
the same elevation as the weather bureau.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-220
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COMPONENT 6— HOW TO REVIEW A TRIAL BURN REPORT
12.6.5 Reviewing Calibration Records for Field Analytical Equipment
Regulations:
Guidance:
Explanation:
Check For:
No regulations are applicable to this section of the manual.
No specific references are applicable to this section of the manual.
Many source testing companies use portable and field analytical equipment on
location during trial burn tests. This equipment may include gas chromatography,
pH meter, conductivity meter, and spectrometers. The use of these instruments
on location facilitates evaluating emissions during testing, reducing or eliminating
sample shipment, and reduces laboratory turnaround times.
Calibration, precision, accuracy, and completeness requirements of the
methodology must be consistent with the trial burn QAPP and TBP objectives.
Q Pre- and post-test calibrations
Q Sampling system bias evaluations
Q Equipment performance and percent recovery
Q Spike and matrix spike evaluations
A source testing company uses a pH meter to continuously monitor the pH of the
first impinger of a hexavalent chrome sampling train. Before and after the test
run, the pH meter is calibrated with known buffer solutions at pH 4 and pH 7 to
show that the instrument is maintaining stability and precision over the test
sampling period.
Example Comments: According to the hexavalent chrome test methodologies, the pH of the absorbing
solution must be greater than 8.5 after the test run is completed. Although the
testing company calibrated the instrument appropriately; the calibration range
should have been a pH of 7 to 10, Lois asks the facility to include in the TBR a
discussion of the impacts of this deviation.
Notes:
Example Section:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-221
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.7 REVIEWING APPENDIX G—PERFORMANCE CALCULATIONS
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 266.104
No specific references are applicable to this section of the manual.
BIFs burning hazardous waste must achieve a DRE of 99.99 percent for all
POHCs in the waste feed, and the DRE of 99.99 percent must be demonstrated
during the trial burn for each POHC. Rounding up to achieve the required DRE
is not allowed.
Q DRE calculations
Q DRE of at least 99.99 percent for each POHC (during each run)
identified during the trial burn
Q DRE of at least 99.9999 percent for PCDD/PCDFs, if applicable
The DRE for each POHC can be verified by using the following equation:
where
DRE = (1 -
W =
"out
W
T * ir
W
out
) x 100
W.
mass feed rate of one POHC in stack gas before
release to the atmosphere
mass feed rate of same POHC in the hazardous waste
fired to the BIF
Example Comments: The mass of each POHC entering the BIF can be calculated using the waste
feed analytical results and mass feed rate to the BIF. The mass of POHCs in
the flue gas can be calculated on the basis of (1) the average stack gas flow rate
for the isokinetic sample train from which the sample was collected, and (2) the
analytical results from stack samples. For VOCs (which are collected on a
nonisokinetic sampling train), the average stack gas flow rate for isokinetic
sampling trains operating at the same time should be used.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-222
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.8 REVIEWING APPENDIX H—FIELD LOGS
Regulations:
Guidance:
Explanation:
No regulations are applicable to this section of the manual.
No specific references are applicable to this section of the manual.
It is customary for field logs to be maintained during a trial burn test. Notes may
be logged by the source testing field team leader, facility coordinator, regulatory
agency observer, or an independent third-party monitor. Field log information
may contain information related to operation upsets, test problems, equipment
failures, and various forms of checklists.
Check For:
Notes or logs by program coordinator, unit operation, process, or control
room operators of the facility
Notes or logs recorded by source testing company coordinator, field
crew leader, and equipment operators
Notes, logs, or checklists taken by U.S. EPA, state regulatory, and
contracted oversight observers
Field notes, logs, or checklists prepared by an independent third-party
auditor
Example Section:
During the review of a TBR, Clark observed that project participants were listed
in tabular form. He also looked at the oversight report appendix presenting field
log notes and discovered that the U.S. EPA-subcontracted observer had
recorded all facility and test personnel involved during the trial burn test on a day-
by-day basis.
Example Comments: It was simple to cross check the project participant list in the TBR by comparing
the tabulated list with the handwritten field notes recorded by the subcontracted
observer present on the test day. Clark did not note any discrepancies.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
12.9 REVIEWING APPENDIX I—ANALYTICAL DATA PACKAGES
Regulations:
Guidance:
Explanation:
Check For:
Example Section:
40 CFR Part 270.62(b)(2)(I)(A - D)
No specific references are applicable to this section of the manual.
The appendix of a TBR contains the reports and analytical data information
prepared by the laboratory contracted to analyze waste feed, process, and stack
gas samples. A thorough and careful review of laboratory analytical data
packages contained in the TBR appendix will facilitate and streamline the
verification of test results. In addition, all laboratory QA/QC information is
presented, and expected and targeted criteria can be compared and verified with
this complete QA/QC information.
Q Analytical data package for waste feed parameters
Q Analytical data package for process samples
Q Analytical data package for stack gas samples
Q Information presented in the data packages for:
Q Sample identification name and number
Q Analytical method followed
Q Matrix type
Q Date, time, and location of sample collection
Q Person responsible for sample collection and recovery
Q Temperature of sample when received
Q Result of the sample analysis and units associated with the
number valve
Q Method detection limit and sample quantitation limit
Q Spike results
Q Spike recovery
Q Matrix spike results
Q Duplicate matrix spike results
Q Whether the QA/QC objectives of the TBP were met and satisfied
Q Whether the QA/QC objectives of the trial burn QAPP were met and
satisfied
Clark was comparing BIF metal stack test emission results against the laboratory
report contained in the appendix. His comparison showed different concentration
results, and further examination revealed that the units associated with the
reported values were different. Based on the units outlined in the laboratory
report, Clark calculated the metal emissions and concluded that the results
presented were incorrect.
U.S. EPA Region 6
Center for Combustion Science and Engineering
6-224
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COMPONENT 6—HOW TO REVIEW A TRIAL BURN REPORT
Example Comments: Clark prepared a comment requesting that the facility recalculate the metal
emission.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 6-225
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ATTACHMENT A
MEMORANDUM ON TRIAL BURNS
(11 Sheets)
-------
United States Solid Waste and
Environmental Protection Emergency Response EPA530-F-94-023
Agency (5305) July 1994
&EPA Memorandum on
Trial Burns
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m
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JUL - 5 KXM OFFCEOF
wwv. *J KXJH SOLO WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: Guidance on Trial Burn Failures
FROM: Michael Shapiro, Directory^"
Office of Solid Waste
TO: Hazardous Waste Management Division Directors
Regions I-X
The purpose of this memorandum is to clarify EPA's policy on
trial burns for incinerators and boilers and industrial furnaces
(BIFs) under the Resource Conservation and Recovery Act (RCRA),
and to address issues that have recently been raised regarding
trial burn failures. These issues include: 1) what constitutes a
successful trial burn; 2) how to handle invalid data; 3) what
constitutes an unsuccessful trial burn; 4) how to handle a
request for a trial burn retest; and 5) how to restrict
operations after an unsuccessful trial burn.
The policies set out in this memorandum are not final agency
action, but .are intended solely as guidance. They are not
intended, nor can they be relied upon, to create any rights
enforceable by any party in litigation with the United States.
EPA officials may decide to follow the guidance provided in this
memorandum, or to act at variance with the guidance, based on an
analysis of specific site circumstances. The Agency also
reserves the right to change this guidance at any time without
public notice.
Purpose of a Trial Burn
A trial burn serves several purposes. It is used to
determine whether a facility can meet the required performance
standards for either hazardous waste incinerators (40 CFR
264.343) or BIFs (40 CFR Part 266 Subpart H), and to determine
the operating conditions that should be. set in the permit. A
trial burn is also used by the permit writer to determine the
need for and establish other limits or requirements on a site-
specific basis under the "omnibus" authority of RCRA Section
3005(c)(3). This guidance will consider the term "performance
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standards" to include both regulatory performance standards and
such site-specific standards imposed through the omnibus
authority. Until continuous emission monitors (CEMs) are
available, setting permit operating conditions based on the
results of trial burns is the best method of assuring compliance
with the regulations.
A trial burn typically consists of a series of "tests". A
trial burn test (or combination of tests) should be done for each
set of operating conditions for which the facility desires to be
permitted. Three "runs" should be performed for each test. Each
run of a test should be conducted at the same nominal operating
conditions. In general, each run of a test should be passed for
the test to be considered successful and for the facility to be
permitted to operate at that set of conditions.
Facilities will often perform multiple tests during the
trial burn in order to develop all applicable permit operating
conditions. For example, facilities will usually perform a
minimum and a maximum temperature test, since decreasing
temperatures tend to decrease organics destruction, and
increasing temperatures tend to increase metals emissions due to
an increase in volatility. These tests, if successful, will
determine the temperature boundaries between which the facility
can operate in compliance with the destruction and removal
efficiency (DRE) and metal emissions standards.
During a trial burn, a facility's general strategy is
typically to operate at conditions that will give it a broad
range of permit operating conditions. The permit writer should
take great care in reviewing the trial burn plan to assure that
the test conditions meet the regulatory requirements. According
to 40 CFR 270.62 (b)(5) for incinerators and 40 CFR 270.66(d)(2)
for BIFs, the trial burn plan can only be approved if 1) it is
likely to determine if the performance standards can be met, 2)
it does not present an imminent hazard to human health or the
environment, and 3) it will help to determine the necessary
operating requirements. In determining if the performance
standards can be met in the trial burn, permit writers should use
their experience and best engineering judgement to make sure that
the trial burn represents "good operating practices". EPA
believes that a trial burn plan that allows or incorporates sub-
standard operating practices is less likely to demonstrate
compliance with required performance standards than a plan based
on a well-operated unit. The Combustion Emissions Technical
Resource Document (CETRED), which helps to define best operating
practices for various categories of hazardous waste combustors,
can assist in determining good operating practices. Engineering
judgement and generally accepted industry practices for achieving
good mixing, adequate temperatures and residence times, adequate
oxygen, steady-state operation, and minimization of fugitive
emissions can also be used in this evaluation. Additionally, in
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reviewing and approving a trial burn plan, the permit writer may
find it useful to examine the facility's compliance history and
past operating history when applicable.
What Constitutea a Successful Trial Burn
A trial burn is successful only if enough tests are passed
so that the permit writer can establish a complete set of
operating conditions in the permit to assure compliance with
applicable performance standards. A successful trial burn test
generally consists of passing three separate runs at the same
nominal operating conditions. If a test is successful, the
facility would be allowed to operate under the tested conditions.
In general, failing any performance standard in any one of the
three runs constitutes a failure of that test. If a test fails,
the facility should not be permitted to operate under the failed
conditions.
A facility may fail an individual test (or several tests) at
particular operating conditions during the trial burn; however,
if sufficient tests are passed such that applicable permit
operating conditions can be established from the successful
tests, then the trial burn is still considered successful. For
example, for a facility where maximum and minimum temperature
limits are necessary, the facility would typically have to pass
both a minimum temperature test and a maximum temperature test,
along with any other necessary tests, for the trial burn to be
successful.
Facilities can receive final permit conditions for only
those conditions that they passed in the trial burn or that are
set independent of the trial burn (e.g., Tier I metal limits,
which are discussed later in this document). Thus, in a case
where a facility passed some tests and failed others, it is
important to be able to distinguish the difference between the
successful and unsuccessful conditions. Final permit conditions
should be written to allow the facility to operate at the
successful conditions while excluding the unsuccessful ones.
Additionally, the permit writer should be sure to set monitoring
and recording requirements in the permit to assure that operating
conditions are being met.
Final permit conditions will directly reflect the successful
operating conditions from the trial burn. Due to unforeseen
circumstances that may arise during trial burns, the trial burn
conditions may deviate somewhat from the conditions specified in
the trial burn plan. If this situation occurs, and the trial
burn was successful, the operating conditions in the permit
should be the conditions demonstrated during the trial burn, not
the conditions from the trial burn plan. In other words, for
conditions that are set based on the trial burn, a facility will
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be permitted to operate only at those conditions that have been
demonstrated successfully during the trial burn.
Facilities may perform several tests during a trial burn in
an attempt to have different sets of operating conditions for
different sets of wastes {i.e., "campaign burning"). If a
facility fails a particular test, it may still be permitted to
operate on those waste streams and at those conditions that were
successfully demonstrated, provided that sufficient data are
available from the passed tests to set all necessary permit
operating conditions. If trial burn results do not provide
sufficient data to enable the Agency to set permit conditions
which assure compliance with the performance standards, then the
trial burn would not be considered successful.
How to
Id Data
In limited situations, the Agency believes it may be
appropriate to use data from two successful runs as the basis to
determine that a trial burn test was successful when
circumstances beyond the owner/operator's control caused the
invalidation of a third run. An invalid run is different from a
failed run. A failed run occurs when the data show
nonconformance with the performance standards under a particular
set of operating conditions. An invalid (or inconclusive) run
occurs when data problems (for example, resulting from breakage
of a sample tube in a laboratory) make comparison with the
performance standards impossible; neither conformance nor
nonconformance with the standards has been shown in these cases.
Such situations would include sampling and analysis problems, but
not operational problems, which are presumed to be within the
control of the owner/operator.
The criteria permit writers should use in accepting two runs
as a successful trial burn test are listed below.
a) Only one run contains invalid data. If two or more
runs contain invalid data, then the test should be
considered inconclusive and should not be used to set
operating conditions (i.e., the test should not be
considered successful).
b) No data from any run shows failure. For example, if
during a trial burn test, one run passes for DRE, one
run fails for DRE, and one run has invalid data for
DRE, then that test should be considered a failure.
c) The data from the two successful runs should show a
reasonable degree of precision and margin of
compliance.
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d) There should be no reason to believe (based on
operating data, observation of stack emissions, etc.)
that the invalid run was less likely to be in
compliance than the other two runs. Immediate
reporting by the facility of an incident which might
invalidate a run (e.g., QA/QC outside of control
limits) lends more credence to the claim of invalidity
than if the facility waits until all analytical results
are in and emission calculations have been made.
e) A detailed written description of the circumstances
resulting in the invalidation of data related to any
test should be submitted to, and reviewed by, the
Agency.
Generally, two valid runs should not be accepted as a
successful trial burn test when the owner/operator had direct
control over the situation that caused the third run to be
invalidated. The trial burn test should be considered
unsuccessful if neglect and/or carelessness of either the
owner/operator or those conducting the testing/analysis caused
the invalidation of a run.
What Conatitutea an Unflueeeaaful Trial Bum
A trial burn is unsuccessful either because it showed a
failure to meet the performance standards, or it was
inconclusive. A trial burn is considered a failure when enough
tests have failed (i.e., show a failure to meet performance
standards) such that a full set of operating conditions
representing compliance cannot be-set in the permit.
A trial burn failure is different from failure of a trial
burn test. A test failure shows nonconformance with the
standards at one set of operating conditions; however, a facility
may still be permitted to operate if it passes one or more trial
burn tests at other operating conditions. A trial burn failure
occurs when enough tests have failed such that a full set of
operating conditions representing compliance cannot be set in the
permit. The results of a failed trial burn should not be used to
establish final permit operating conditions. Following a failed
trial burn, the permitting authority should take one or more of
the following actions, as appropriate: 1) take steps to restrict
operations (as discussed later in this document); 2) begin
processing a denial of the facility's permit application (for an
interim status facility); 3) initiate proceedings to terminate
the facility's permit (for a new facility); 4) authorize a trial
burn retest (also discussed later in this document).
An entire trial burn (like a trial burn test) may be
considered inconclusive. An inconclusive trial burn occurs when
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data problems have arisen such that neither conformance nor
nonconformance with the performance standards can be shown. The
results of an inconclusive trial burn may not be used to
establish final permit operating conditions. Following an
inconclusive trial burn, the permitting authority should take one
or more of the following actions, as appropriate: 1) take steps
to restrict operations (as discussed later in this document)-2)
begin processing a denial of the facility's permit application
(for an interim status facility); 3) initiate proceedings to
terminate the facility's permit (for a new facility); 4)
authorize a trial burn retest (also discussed later in this
document).
Facilities may choose not to test for certain parameters and
be permitted at the Tier I or Adjusted Tier I feed rate screening
limits established in the BIF rule (56 FR 7134, February 21,
1991), if appropriate. These parameters include metal emissions
(40 CFR 266.106), and hydrogen chloride (HC1) and chlorine gas
(C12) emissions (40 CFR 266.107). The Tier I and Adjusted Tier I
feed rate screening limits are based on the assumption that all
metals, HC1, or C12 (depending on the parameter) fed into the
system are emitted (i.e., no partitioning into the bottom ash
and no removal by any air pollution control device). This case
is the most conservative scenario possible and produces the most-
stringent feed limits in the permit. The Adjusted Tier I feed
rate screening limits also allow for site-specific dispersion
modeling. Although directly applicable only to BIFs, these
provisions are generally applied to incinerators as well through
the Agency's omnibus permitting authority, where necessary to
protect human health and the environment.
Facilities that test for these parameters and fail, or show
inconclusive results, should not be permitted to operate under
the tested conditions. Instead, a permit for the facility (if
one is issued) should limit the facility to the Tier I or
Adjusted Tier I feed rate screening limits. For example, a
permit for a facility that does not meet the HC1 or Cl, standard
when tested under higher chlorine feed rates should limit the
chlorine and chloride input to the equivalent of 4 Ibs HCl/hr
the Tier I limit, or the Adjusted Tier I limit, as applicable.
Similarly, a permit for a facility that does not meet the
metals emissions standards during high temperature testing should
limit the metals input into the system to the Tier I or Adjusted
Tier I feed rate screening limits (see 56 FR 7171, February 21
1991) .
It should also be noted that, where the trial burn did not
demonstrate compliance with the HC1, Clz, or metal emissions
standards, the permit may specify allowable chlorine or metals
feed rates that are more restrictive than the Tier I or Adjusted
Tier I limits, based on a site-specific risk assessment which
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considers both direct and indirect exposure pathways to a wide
range of pollutants. In this case, the same assumption
concerning stack emissions should be applied (that is, the
assumption of no partitioning or removal).
How to Handle a Retmeat For a Trial Burn Reteat
Facilities that fail or conduct an inconclusive trial burn
test or tests may request a retest and submit a revised trial
burn plan. The permitting authority would review and approve or
deny such a request. For a permitted incinerator or BIF (new or
renewal), this request would be processed through the permit
modification procedures in accordance with 40 CFR 270.42. The
revised trial burn plan can only be approved if 1) it is likely
to determine if the performance standards can be met, 2) it does
not present an imminent hazard to human health or the
environment, and 3) it will help to determine the necessary
operating requirements (see 40 CFR 270.62(b)(5) for incinerators
and 40 CFR 270.66(d)(2) for BIFs). In the case of a request for
a trial burn retest following a trial burn test failure, the
applicant should conduct an investigation into the reason for the
failure, and make substantive changes in its proposed trial burn
plan which would be expected to prevent failure from reoccurring.
A facility should not be allowed to retest unless it has made
changes to its process (i.e., design and/or operating
conditions), that are likely to correct the problems encountered
in the failed trial burn test. A facility should not be allowed
just to "take its chances* on passing a retest under the same
conditions. The first failed test indicates that, at best, the
unit would not be in compliance some of the time when operated at
those conditions, and that those conditions should therefore not
be incorporated into a permit.
As opposed to a trial burn test failure, an inconclusive
test would not necessarily require changes to be made to the
process prior to allowing a retest. The test could be repeated
under the same conditions as the previous test, but with special
attention paid to the situation that caused the original test to
be inconclusive. During the retest, all attempts should be made
to prevent that situation from reoccurring.
There is no set limit on the number of retests allowed under
EPA regulations, so long as after each unsuccessful test the
above criteria are met and the trial burn plan is revised and
approved (through a permit modification for a new incinerator or
BIF) prior to any retesting. The same criteria recommended for
the design and conduct of initial trial burns are also
recommended for all retests (i.e., three runs for each trial burn
test, etc.).
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Facilities that wish to conduct a trial burn retest after an
unsuccessful test should expeditiously submit a comprehensive
request consistent with the guidance discussed above. If a
complete request is not promptly submitted, it is appropriate for
the Agency to start permit denial proceedings. The Agency's
decision to discontinue or delay permit denial proceedings will
be highly dependent on the adequacy of any retest request and the
Agency's ability assure compliance with applicable regulations
during the interim period.
For facilities that fail a trial burn test for only the HC1,
C12, particulate, or metal emissions standards, EPA believes it
may be appropriate in some cases to authorize a retest for these
failed performance standards without simultaneous DRE testing.
This decision would depend on the nature of the design or
operating modifications made for the retest. If the
modifications would not adversely impact DRE (e.g., addition of
pollution control equipment), then HC1, particulate, and/or metal
tests are sufficient. In this case, operating conditions should
be identical to those of the original trial burn test for all
parameters other than those related to the modifications which
were made. In contrast, if the design or operating modifications
made by the facility in order to retest for the HC1, C12,
particulate, or metals emissions standards have the potential to
affect DRE, then DRE should be retested along with the standards
that were not demonstrated.
The permit writer should ensure that operating conditions
during a trial burn retest are consistent with the overall scheme
of the trial burn plan so that all successful tests can be used
in conjunction to establish final operating conditions.
How to Restrict Operations Aftar an Paaueeeaaful Trial Bum
Permitting authorities should move expeditiously, in
appropriate cases, to restrict operations (to the extent that
regulatory and statutory authorities allow) after receiving
information that a facility conducted an unsuccessful trial burn
(i.e., a trial burn failure or an inconclusive trial burn).
Permits for new incinerators and BIFs should be written with
a provision that would restrict post-trial burn operations if a
facility conducts an unsuccessful trial burn. The Agency
recommends that such permits contain the following conditions: 1)
the permittee must notify the Regional Administrator within 24
hours of making a determination that the incinerator or BIF
failed to achieve any of the performance standards in any run of
any test, and 2) upon the request of the Regional Administrator,
the permittee shall feed waste and operate the incinerator or BIF
only under restricted conditions as specified by the Regional
Administrator. (A similar condition is recommended in the
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incinerator module of the model permit, except the second portion
of the condition provides that, upon the request of the Regional
Administrator, the permittee shall cease feeding hazardous waste
to the incinerator. The new recommended language covers the case
where a complete shutdown is required, while providing clearer
authority in cases where some, but not all, tests were
successful.) The permittee then has the option of applying for a
permit modification pursuant to 40 CFR 270.42 to conduct a new
trial burn pursuant to 40 CFR 270.62(b) for incinerators or 40
CFR 270.66 for BIFs. if an already-issued permit does not have
such a provision in it, and the trial burn is unsuccessful, then
EPA may still be able to modify the permit to restrict operations
based on 40 CFR 270.41(a) (2) or 40 CFR 270.4Kb) (1), or terminate
the permit based on 40 CFR 270.43(a)(3). The appropriate
authorities should be invoked to assure that operations during
the post-trial burn period will achieve compliance with the
performance standards.
With respect to interim status BIFs, EPA regulations
establish certain performance standards that must be met at all
times when there is hazardous waste in the unit (40 CFR
266.103(c)(1)). Standards for carbon monoxide, total
hydrocarbons, particulate matter, metals emissions, and hydrogen
chloride and chlorine gas emissions are included in the
regulations. If trial burn data from an interim status BIF
indicate failure to comply with any of these standards, then
under appropriate circumstances the permitting agency may be able
to restrict operations under RCRA Section 3008 or Section 7003.
With respect to interim status incinerators that fail their
trial burns, regulatory agencies should either move as quickly as
possible to cause the incinerators to cease operations by denying
their permits (or, if appropriate, through RCRA Section 7003
actions), or, if appropriate, authorize trial burn retests. This
guidance also applies to interim status BIFs that fail their ORE
standard during the trial burn, since the DRE standard generally
does not apply to BIFs during interim status.
EPA has recently proposed a rule which would provide
explicit authority to restrict operations at interim status
facilities after a failed or inconclusive trial burn (59 FR
28680, June 2, 1994). During the post-trial burn period, interim
status facilities would only be able to operate under conditions
that passed and were demonstrated to meet the applicable
performance standards, and only if the successful trial burn data
are sufficient to set all applicable operating conditions. If
finalized as proposed, this regulation would provide additional
authority to restrict operations at interim status facilities
following a failed or inconclusive trial burn.
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For more background on issues such as permit conditions
trial burn measurements, and validity of data, permit writers may
consult the following guidance documents.
Guidance on Setting Permit Conditions and Reporting Trial
Burn Results; January 1989.
Hazardous Waste Incineration Measurement Guidance Manual-
June 1989. '
Quality Assurance/Quality Control (QA/QC) Procedures for
Hazardous Waste Incineration, January 1990.
If your staff have any questions on this trial burn failure
guidance or how to obtain other guidance materials, they may call
Andy O'Palko at (703) 308-8646, or Sonya Sasseville at (703) 308-
8648 *
cc: Waste Combustion Permit Writers Workgroup
Dev Barnes
Matt Hale
Matt Straus
Fred Chanania
Susan Bromm
Susan O'Keefe
Office of Regional Council RCRA Branch Chiefs, Regions I-X
Brian Grant, OGC
10
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ATTACHMENT B
HOW TO REVIEW A TRIAL BURN REPORT REVIEW CHECKLIST
(46 Sheets)
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1.0 OVERVIEW OF TRIAL BURN REPORT REVIEW
The TBR should include the following major elements. These elements are discussed in more
detail in the subsections of this component identified below:
Q Executive summary (see Section 3.0)
Q Introduction (see Section 4.0)
Q Process description (see Section 5.0)
Q Testing program overview (see Section 6.0)
Q Test operating conditions (see Section 7.0)
Q Process and stack gas sampling (see Section 8.0)
Q Laboratory procedures (see Section 9.0)
Q Quality assurance/quality control (QA/QC) results (see Section 10.0)
Q Trial burn results summary and proposed permit limits (see Section 11.0)
Q Appendices
Q TBP and trial burn QAPP (see Sections 12.1 and 12.2)
Q Stack sampling report (see Section 12.3)
Q Process sampling report (see Section 12.4)
Q QA/QC report (see Section 12.5)
Q Instrument calibration records (see Section 12.6)
Q Performance calculations (see Section 12.7)
Q Field logs (see Section 12.8)
Q Analytical data packages (see Section 12.9)
As discussed in Sections 1.2 and 1.3 of this component, the TBR is typically
reviewed by a team of experts. During review of these sections, the TBR
review team should check for the following:
Q Verification that the trial burn test was conducted in accordance with the
approved TBP and trial burn QAPP
Q Verification that information included as appendices and attachments to
the TBR support the data summaries and conclusions presented in the
main body of the text
Q Verification that the report draws appropriate conclusions on the basis of
information collected during the trial burn test and risk burn test for the
following:
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Q Combustion unit operation
Q Appropriate feed rates
Q Representative emission rates
Q Supportable risk assessment results
Q Verification that proposed permit conditions are supported by data
summaries
1.1 RECOMMENDED REPORT FORMAT
Q Executive Summary
Q List of key project personnel in the Introduction
Q Whether the TBR format follows the approved TBP
Q Comparison of test conditions to planned conditions
Q Detailed chemical and physical analysis of waste and process samples
Q Stack gas analysis for pollutants as planned, and emission rate
calculations for all pollutants
Q QA/QC discussion for all analytical results
Q Whether correct appendices are attached
Q Discussion of problems, delays, or changes from the approved TBP
Q Field data sheets
Q Emission rate calculations
Q Equipment calibration reports
Q Continuous emission monitoring system (CEMS) calibration and
performance specification test (PST) results
Q Process data
Q Problems and deviations, especially those affecting QA/QC
1.2 ASSEMBLING THE REVIEW TEAM
For each of the key members listed above, the following information should be evaluated:
Q Team member credentials
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Q Team member availability
Q Team leader assignment
Q Schedule and meeting review
Q Potential conflicts of interest with team members or outside consultants
1.3 DIVIDING THE DOCUMENT
Before meeting with the team, the team leader should check to confirm that all volumes of the
TBR have been received. Then, the individual section headings should be checked against the list
in Section 1.0 of this component to confirm that all major sections are discussed.
2.0 REVIEWING GENERAL REPORT CONTENTS
Q Table of contents
Q Certification form
Q Appropriate sections (see list in Section 1.3 of this component)
Q Appendices
3.0 REVIEWING THE EXECUTIVE SUMMARY
Q Summary of stack gas parameters and emission rate results (see Section
3.1)
Q Key process system parameters and results (see Section 3.2)
Q Problems encountered during the trial burn test, solutions, and deviations
from the approved TBP (see Section 3.3)
Q Conclusions on the success in meeting TBP objectives (see Section 3.4)
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3.1 REVIEWING THE SUMMARY PRESENTATION OF STACK GAS PARAMETERS
AND EMISSION RATE RESULTS
The results discussed in the Executive Summary should be verified for accuracy and consistency
with the rest of the TBR data and results. At a minimum, check for the following:
Q Whether the stack gas volumetric flow rate, corrected to dry standard
conditions, is presented
Q Whether test results represent the average of all runs conducted under a
specific test condition
Q Whether carbon monoxide (CO) concentration is reported on the basis of
dry parts per million by volume (ppmv), and corrected to 7 percent
oxygen (O2)
Q Whether the POHC DRE is accurate to at least four significant digits
(that is, 99.99 percent)
Q Whether all results are presented as numerical values (neither not
detectable nor "nondetect" is an acceptable result)
Q Whether the O2 concentration is reported on the basis of dry units of
volume percent
Q Whether the hydrogen chloride (HC1) emission rate is presented in
pounds per hour (Ib/hr)
Q Whether all pollutants are presented on the basis of dry units
Q Whether the particulate matter (PM) concentration is presented in grains
per dry standard cubic feet (gr/dscf) at 7 percent O2
Q Whether detection limits are reported along with emissions data and
identified as to the type of detection limit (for example, practical
quantitation limit [PQL] or sample quantitation limit [SQL])
Q Whether emissions data are presented in grams per second (g/sec) for
input into the risk assessment
Q Whether any emission rates are adjusted for input into the risk
assessment and, if so, justification and data supporting the adjustment (for
example, using half the detection limit).
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3.2 REVIEWING THE SUMMARY OF KEY PROCESS SYSTEM PARAMETERS AND
RESULTS
Q Whether average, minimum, and maximum combustion zone
temperatures are presented
Q Whether waste feed stream and ancillary fuel mass flow rates are
presented
Q Whether excess O2 concentration is presented for all test runs
3.3 REVIEWING THE SUMMARY OF PROBLEMS, SOLUTIONS, AND DEVIATIONS
FROM THE TRIAL BURN PLAN
Q Any notation that alternative stack sampling procedures were used
Q Any notation that alternative laboratory procedures were used
Q All deviations from the proposed process operating conditions
Q Reduced performance and efficiency from ancillary equipment or control
devices
Q Changes in the targeted POHC
3.4 REVIEWING CONCLUSIONS
Q Whether the POHC DRE was at least 99.99 percent
Q Whether the CO concentration, corrected to 7 percent O2, was less than
100 ppmv
Q Whether the HC1 emission rate was less than or equal to 4 Ib/hr and
within acceptable risk based limits
Q Whether the PM concentration was less than 0.08 gr/dscf at 7 percent
O2
Q Whether metals emission rates were within the allowable Tier limit and
within acceptable risk-based limits
Q Whether organic compound emissions (for example, products of
incomplete combustion [PIC] such as PCDDs and PCDFs) were within
acceptable risk-based limits
Q Whether emissions met all applicable air permit conditions
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4.0 REVIEWING CHAPTER 1—INTRODUCTION
Q Background information
Q Facility name
Q Contact
Q Address
Q Telephone number
Q U.S. EPA identification number
Q U.S. EPA region
Q Person responsible for TBR
Q Company name
Q Address
Q Telephone number
Q Date
Q Person responsible for QA/QC
Q Title
Q Address
Q Telephone number
Q Why the test was conducted
Q Person conducting the test and project participants
Q Dates and times of the test
5.0 REVIEWING CHAPTER 2—PROCESS DESCRIPTION
Q Brief process description of the combustion unit
Q Description of auxiliary equipment and unit operations associated with
the system (see Component 1—How to Review a Trial Burn Plan,
Section 3.0)
Q Design information summary table
Q Summary of process monitors and stack gas analyzers
Q Process diagram showing monitoring points
6.0 REVIEWING CHAPTER 3—TESTING PROGRAM OVERVIEW
Q Trial burn objectives
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Q Planned test program
Q Summary of actual testing performed
Q Deviations from the approved TBP
7.0 REVIEWING CHAPTER 4— TEST OPERATING CONDITIONS
Review the TBR to see whether all operating parameters listed in the TBP are recorded and are
within established limits. Check for average, minimum, maximum, and standard deviation of the
values collected.
Q Waste and fuel feed rate information (see Section 7.1)
Q Process residuals generation rate and characterization information (see
Section 7.2)
Q Stack gas parameter information (see Section 7.3)
Q Fugitive emissions sources and means of control (see Section 7.4)
7.1 REVIEWING WASTE AND FUEL FEED RATE INFORMATION
The instantaneous and hourly rolling averages (HRAs) values for each of the following
parameters should be presented for each run of the trial burn test.
Q Maximum organic (high heating value [HHV]) liquid waste feed rate
Q Maximum aqueous (low heating value [LHV]) liquid waste feed rate
Q Maximum containerized waste (that is, container size and type) feed rate
Q Maximum sizes of containerized waste batches
Q Maximum feed rate of each waste type to each combustion chamber
Q Hazardous waste blending procedure, analysis of each waste before
blending, and blending ratio (only if more than one hazardous waste
stream is blended)
Q Review the data logsheets (units, rate) to assure that the results
presented are accurate and consistent
Q Solid waste feed rate
Q Auxiliary fuel feed rate
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If the facility is reporting the results of a risk burn, additional data should be
provided. These data may include the following:
Q Average hazardous waste feed rate (each stream) for each risk burn run
Q Minimum and maximum hazardous waste feed rate (each stream) for
each risk burn run
Q Supporting data regarding normal operating conditions (may also be
submitted as part of the RBP)
7.2 REVIEWING WASTE GENERATION RATE INFORMATION
Q Ash, process effluents, and solids residuals identification
Q Sampling method
Q Sampling frequency (every 15 minutes and 1 hour composite)
Q Sampling duration (minimum 1 hour sampling time per run)
Q Sampling location
Q Ash, process effluents, and residual generation rate
Q Ash, process effluents, and residual analytical data
7.3 REVIEWING STACK GAS PARAMETER INFORMATION
Q CO emission levels, in ppmv, corrected to 7 percent O2 (see Section
7.3.1)
Q Stack gas flow rate and velocity at actual, dry standard, and 7 percent O2
conditions (see Section 7.3.2)
Q O2 levels in volume percent (see Section 7.3.3)
Q Inlet gas temperature to the dry APCS (see Section 7.3.4)
Q Combustion unit temperature (see Section 7.3.5)
Q APCS control parameters (see Section 7.3.6)
7.3.1 Verifying Stack Gas Carbon Monoxide
Q CEMS CO concentration during the trial burn in ppmv (minimum of three
runs per test condition) corrected to 7 percent O2.
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The following values should be provided for each run of the trial burn
test:
Q Minimum and maximum instantaneous concentrations
Q Minimum and maximum HRA concentrations
Q Standard deviation of instantaneous and HRA values
Q Average instantaneous and HRA values for all runs at each test
condition
Q CEMS CO strip chart and original log recorded during testing
Q If dual CO CEMS are installed, confirm which monitor corresponds with
which strip chart or data set.
Generally, the permit target value for CO emissions is 100 ppmv, corrected to
7 percent O2.
7.3.2 Verifying Stack Gas Flow Rate
Q Stack gas flow rate and velocity (minimum of three runs per test
condition)
The following values should be provided for each run of the trial burn
test:
Q Minimum and maximum instantaneous concentrations
Q Minimum and maximum HRA concentrations
Q Standard deviation of instantaneous and HRA values
Q Average instantaneous and HRA values for all runs at each test
condition
Q Location of stack gas flow rate measurement
Q Whether stack gas flow rate is within limits of the TBP target and, if not,
an explanation for being outside the limits
Q Stack gas flow rate and velocity calculations, including water (H2O), O2,
nitrogen (N2), carbon dioxide (CO2), and CO levels in the flue gas
Q Stack gas flow rate values for actual, dry standard, and 7 percent O2
conditions.
Q Whether reported values are consistent with test operating data
7.3.3 Verifying Stack Gas Oxygen Concentration
Q O2 concentration in the flue gas during the trial burn (minimum of three
runs per test condition, on a dry-gas basis
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The following values should be provided for each run of the trial burn
test:
Q Minimum and maximum instantaneous concentrations
Q Minimum and maximum HRA concentrations
Q Standard deviation of instantaneous and HRA values
Q Average instantaneous and HRA values for all runs at each test
condition
Q CEM O2 strip chart and original log recorded during the testing
Q Whether O2 levels during testing are within the limits of the trial burn
target and, if not, whether excursions beyond the limits are explained
7.3.4 Verifying Dry Air Pollution Control Equipment Inlet Gas Temperature
Q Inlet gas temperature to the APCE during the trial burn test (minimum of
three runs per test condition)
The following values should be provided for each run of the trial burn
test:
Q Minimum and maximum instantaneous concentrations
Q Minimum and maximum HRA concentrations
Q Standard deviation of instantaneous and HRA values
Q Average instantaneous and HRA values for all runs at each test
condition
Q Continuous temperature strip chart or digital data recorded during the
testing
7.3.5 Verifying Combustion Unit Temperature
Q Combustion unit temperature during the trial burn (minimum of three runs
per test condition)
The following values should be provided for each run of the trial burn
test:
Q Minimum and maximum instantaneous concentrations
Q Minimum and maximum HRA concentrations
Q Standard deviation of instantaneous and HRA values
Q Average instantaneous and HRA values for all runs at each test
condition
Q Continuous temperature strip chart recorded during testing
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Q If dual thermocouples are installed, confirm which instrument
corresponds to which strip chart or data set
Q Whether trial burn temperatures are near target values established in the
TBP
Q Verify all calculated values presented in the TBR
7.3.6 Verifying the Air Pollution Control System Control Parameters
Based on the type of APCS used, various control parameters must be recorded during the trial
burn test and reported in the TBR. Important control parameters may include:
Q Baghouse and fabric filter
Q Inlet gas temperature
Q Pressure drop
Q Flue gas flow rate
Q Air-to-cloth ratio
Q Electrostatic precipitator
Q Inlet gas temperature
Q Direct current voltage
Q Flue gas flow rate
Q Venturi Scrubber
Q Inlet gas temperature
Q Pressure drop
Q Liquid flow rate
Q Liquid to flue gas ratio
Q Maximum suspended solids
Q pH (if used for acid gas removal)
The reviewer should check to ensure that continuous data for each applicable
control parameter are included in the TBR. The reviewer should also verify all
calculated values.
7.4 REVIEWING FUGITIVE EMISSIONS SOURCES AND MEANS OF CONTROL
Q The existence of a fugitive emissions control system
Q Whether fugitive emission controls include the following:
Q Sealed combustion zone
Q Combustion zone pressure lower than atmospheric
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Q Alternative fugitive emissions control scheme of periodic
monitoring used for systems operating at pressures higher than
atmospheric
8.0 REVIEWING CHAPTER 5—PROCESS AND STACK GAS SAMPLING
Q Sampling locations and methods (see Section 8.1)
Q Waste and fuel feed sampling (see Section 8.2)
Q Process residuals sampling (see Section 8.3)
Q Stack gas sampling procedures (see Section 8.4)
8.1 REVIEWING SUMMARY OF SAMPLING LOCATIONS AND METHODS
Q Liquid waste feed sampling location and method
Q Solid waste feed sampling location and method
Q Auxiliary fuel feed sampling location and method
Q Gaseous waste feed sampling location and method
8.2 REVIEWING SUMMARY OF WASTE AND FUEL FEED SAMPLING
Q Whether all hazardous waste feed streams are sampled
Q Whether all auxiliary waste feed streams are sampled
Q Whether all solid waste feed streams are sampled
Q Parameters analyzed (such as moisture, density, ash, viscosity, heating
value, and halides)
Q Sampling method
Q Sampling frequency (liquid waste: one every 15 minutes; solid waste:
one every 15 minutes for bulk solid waste, one representative grab
sample for containerized solid waste; auxiliary fuel feed: one per run)
Q Composite sampling method used if different waste streams are involved
Q Sampling location
Q Sampling duration (minimum 1 hour per run)
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The following subsections further describe how to review the following
information:
Q POHC feed rate (see Section 8.3.1)
Q Ash feed rate (see Section 8.3.2)
Q C12 feed rate (see Section 8.3.3)
Q Hazardous metal feed rate (see Section 8.3.4)
Q Combustion unit heat input rate (see Section 8.3.5)
8.2.1 Verifying Principal Organic Hazardous Constituent Feed Rate
Q Type of POHC measured in each waste during the trial burn
Q POHC feed rate of each waste during the trial burn
Q POHC mass rate calculations in the appendix of the report
8.2.2 Verifying Ash Feed Rate
Q Ash concentration in each feed stream
Q Flow rate of each stream containing ash
Q Ash feed rate calculations in the appendix of the report
8.2.3 Verifying Chlorine Feed Rate
Q C12 concentration and flow rate of each waste stream containing C12
Q C12 feed rate calculations in the appendix of the report
Q Methods used to analyze for C12
8.2.4 Verifying Hazardous Metal Feed Rate
Q Feed rate of each of the 10 BIF-regulated metals: antimony; barium;
lead; mercury; silver; thallium; arsenic; beryllium; cadmium; and
chromium; plus non-BIF-regulated metals: nickel; and selenium
Q Total feed stream input rate
Q Total hazardous waste feed stream input rate
Q Total pumpable hazardous waste feed stream input rate
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Q Methods used to analyze metals
Q Calculations based on feed rate and metals concentration
8.2.5 Verifying Combustion Unit Heat Input Rate
Q Individual waste stream heat input rate
Q Auxiliary fuel stream heat input rate
Q Total heat input rate
8.3 REVIEWING SUMMARY OF AIR POLLUTION CONTROL SYSTEM GENERATED
WASTE
Q Process residual sampling location and sampling frequency
Q Constituent/concentrations in each sample
Q Sample compositing techniques
Q Discussion of results compared to system performance
8.4 REVIEWING STACK GAS SAMPLING SUMMARY
The following subsections describe various aspects of stack gas sampling:
Q Sampling and analysis of stack gas during the trial burn test for
determination of specified parameters (see Section 8.4.1)
Q Data tables for stack gas characteristics (see Section 8.4.2)
Q Data tables for emission rates of constitutents of potential concern (see
Section 8.4.3)
8.4.1 Reviewing Summary of Stack Gas Sampling Methods
The reviewer should determine which methods were used for the indicated parameter. Examples
include:
Q 40 CFR Part 60, Appendix A, Method 1—Traverse Points (see Section
8.4.1.1)
Q 40 CFR Part 60, Appendix A, Method 2—Velocity and Flow Rate (see
Section 8.4.1.2)
Q 40 CFR Part 60, Appendix A, Method 3—CO2, O2, Excess Air,
Molecular Weight (see Section 8.4.1.3)
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Q 40 CFR Part 60, Appendix A, Method 4—Moisture Content (see Section
8.4.1.4)
Q 40 CFR Part 60, Appendix A, Method 5, or Test Methods for Evaluating
Solid Waste, SW-846 Method 0050—PM (see Section 8.4.1.5)
Q Appendix IX to 40 CFR Part 266 or SW-846, Method 0050 or
Method 0051—HC1 and C12 (see Section 8.4.1.5)
Q Test Methods for Evaluating Solid Waste: SW-846
Method 0030 or SW-846 Method 0031—Volatile Organic Compounds
(VOC) (see Section 8.4.1.6)
Q Test Methods for Evaluating Solid Waste; SW-846
Method 0010—Semivolatile Organic Compounds (SVOC) (see Section
8.4.1.7)
Q 40 CFR Part 266, Appendix IX or SW-846, Method 23, or SW-846
Method 23A—PCDD/PCDF (see Section 8.4.1.8)
Q 40 CFR Part 266, Appendix IX, Section 3.1, Method 0012, or SW-846
Method 0060—Metals (see Section 8.4.1.9)
Q 40 CFR Part 266, Appendix IX, Section 3.2, Method 0013, or SW-846
Method 0061—Hexavalent Chromium (see Section 8.4.1.10)
Q 40 CFRPart 266, Appendix IV, Section 3.5, or SW-846 Method
0011—Aldehydes and Ketones (see Section 8.4.1.11)
Q SW-846 Method 0040—Organic Constituents from Combustion Sources
using Tedlar® Bags (see Section 8.4.1.12)
Note that Methods 0010 and 0040 are used to collect samples for the
measurement of unspeciated total organics (TO). Additionally, Methods 0010
and 23 or 0023 A may be combined—additional guidance of these procedures are
described in Component 4—How to Conduct Trial Burn Test Oversight.
8.4.1.1 Verifying Traverse Points
Q Stack and duct diameter or dimensions
Q Numbers of traverse points selected for PM and velocity traverses
(based on stack dimensions, location of sampling ports, and upstream and
downstream disturbance)
Q Absence of cyclonic flow
8.4.1.2 Verifying Stack Gas Velocity and Flow Determination
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Q Type of pitot tube
Q Pitot tube coefficient
Q Data sheet for velocity traverse (for each traverse point there should be
a measurement of the velocity head and stack temperature)
Q Sampling time (minimum of 2 hours for a composite sample per run)
Q Calculation of stack gas velocity under (1) actual and standard
temperature and pressure (STP) conditions, and (2) corrected to 7
percent O2
Q Calculation of stack gas flow rate under (1) actual and STP conditions,
and (2) corrected to 7 percent O2
8.4.1.3 Verifying Gas Analysis for Carbon Dioxide, Oxygen, Excess Air, and Molecular Weight
Q Sampling method
Q Gas analysis method (Orsat or Fyrite)
Q Sampling time (minimum of 2 hours for composite sample per run)
Q Percent of CO, CO2, and O2
Q Molecular-weight calculations for each run
8.4.1.4 Verifying Method of Determining Moisture in Stack Gas
Q Field data sheets (for each traverse point, record sampling time stack
temperature, orifice meter differential (A H); meter reading for gas
volume; gas sample dry-gas meter inlet and outlet temperature; and
temperature of gas leaving condenser [last impinger])
Q Sampling time (minimum of 2 hours per composite sample per run)
Q Moisture calculations
8.4.1.5 Verifying Method of Determining Particulates, Hydrogen Chloride, and Chlorine
Q Field data sheets (for each traverse point, record sampling time; vacuum
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Ensure data are collected at consistent interval throughout run—for
example, every 5 minutes.
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Q Sampling train arrangement, as suggested in U.S. EPA Methods 0050
and 0051
Q Proper temperature maintenance (probe and filter at 248 ± 25 °F, train
exit gas less than 68°F)
Q Sampling time (minimum of 2 hours per composite sample per run)
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
Q Consistency with observations documented in the trial burn oversight
report
8.4.1.6 Verifying Volatile Organic Sampling Train Sampling Method for Determination of
Volatile Organics
Q Field data sheet showing sample volume and sampling duration (see
Section IV of U.S. EPA 1989 Checklist for Reviewing RCRA TBRs for
more details)
Q Sampling train configuration, as suggested in U.S. EPA Method 0030 or
U.S. EPA Method 0031
Q Minimum sampling time of 2 hours or 20 to 40 minutes per set of VOST
cartridges, with three to four sets VOST cartridges per run (typically,
four sets are collected, and three are analyzed; with one set saved as a
back up)
Q Calculations showing sample volumes corrected to standard conditions
Q Whether the samples were analyzed for the target VOC list identified in
the TBP (the VOC analyte list should include, at a minimum, all target
analytes for SW-846 U.S. EPA Method 3542)
Q Consistency with observations documented in the trial burn oversight
report
8.4.1.7 Verifying Semivolatile Organic Sampling Train Sampling Method for Determination of
Semivolatile Organics
Q Field data sheets (for each traverse point, record sampling time; vacuum
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Q Sampling train configuration, as suggested in U.S. EPA Method 0010
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Q Maintenance of proper sampling train temperatures
Q Whether isokinetic calculations are within 90 to 110 percent
Q Minimum sampling time of 2 hours per run
Q Stack flow rate calculations
Q Consistency with observations documented in the trial burn oversight
report
See Section IV of the U.S. EPA 1989 Checklist for Reviewing RCRA TBRs for
more details.
8.4.1.8 Verifying Sampling Method for Polychlorinated Dibenzopdioxin/Polychlorinated
Dibenzofuran
Q Field data sheets (for each traverse point, record sampling time; vacuum;
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Q Sampling train configuration, as suggested in U.S. EPA Methods 23 and
0023A
Q Maintenance of probe exit temperature and filter compartment at
248 ± 25 °F during sampling
Q Whether gas enters sorbent tube module at or below 68 °F
Q Minimum sampling time of 3 hours per run
Q Whether isokinetic calculations are within 90 to 110 percent
Q PCDD/PCDF emission calculations
Q Consistency with observations documented in the trial burn oversight
report
8.4.1.9 Verifying Sampling Method for Multiple Metals
Q Field data sheets (for each traverse point, record sampling time; vacuum;
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Q Sampling train configuration, as suggested in referenced method
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Maintenance of proper temperature (probe and filter at 248 ± 25 °F, train
exit gas below 68°F)
Minimum sampling time of about 3 hours composite per run
Whether isokinetic calculations are within 90 to 110 percent
Stack flow rate calculations
Metals emission rate calculations
Consistency with observations documented in the trial burn oversight
report
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8.4.1.10 Verifying Sampling Method for Hexavalent Chromium
Q Field data sheets (for each traverse point, record sampling time; vacuum;
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry -gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Q Sampling train configuration, as suggested in referenced method
Q Maintenance of proper temperature (probe and filter at 248 ± 25 °F, train
exit gas below 68 °F)
Q Minimum sampling time of about 3 hours per run
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
Q Hexavalent chromium emission rate calculations
Q Consistency with observations documented in the trial burn oversight
report
8.4.1.11 Verifying Sampling Method for Aldehydes and Ketones
Q Field data sheets (for each traverse point, record sampling time; vacuum;
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry -gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger]).
Q Sampling train configuration, as suggested in U.S. EPA Method 001 1
Q Maintenance of proper temperature (probe and filter at 248 ± 25 °F, train
exit gas below 68 °F)
Q Whether isokinetic calculations are within 90 to 110 percent
Q Minimum sampling time of 2 hours per run
Q Stack flow rate calculations
Q Consistency with observations documented in the trial burn oversight
report
8.4.1.12 Verifying Sampling Method for Organic Constituents Using Tedlar® Bags
Q Field data sheets (stack gas velocity head, stack gas temperature,
condition temperatures)
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Q Sampling train configuration, as outlined in Method 0040
Q Constant sampling rate
Q Minimum sample time of 60 minutes
Q Consistency with observations documented in the trial burn oversight
report
8.4.2 Reviewing Data Tables For Stack Gas Characteristics
Q Summary table for each isokinetic sampling train, including sampling time,
corrected sample volume, stack gas temperature, moisture content, CO2
percent, O2 percent, stack gas velocity, stack gas flow rate, and percent
isokinetic achieved
Q Summary table for VOST including actual volume sampled, through the
sampling train, average meter temperature, and corrected volume
8.4.3 Reviewing Data Tables for Emission Rates of Constituents of Potential Concern
This information may be collected during trial burn or risk burn test conditions. The TBR should
clearly indicate the basis for the emission rates
Q Summary tables calculated for COPC emission rates (average, minimum,
and maximum), standard deviation, and 95th percentile values for:
Q Hexavalent chromium
a vocs
a svocs
a PCDD/PCDF
a Metals
a PAHs
Q Aldehydes and ketones
Q HC1/C12
a PM
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9.0 REVIEWING CHAPTER 6—LABORATORY PROCEDURES
Q Reference to the approved TBP and approved QAPP
Q Laboratory QA/QC performance checks
Q Whether all proposed samples were collected
Q Whether all proposed analytical parameters were conducted
Q Any deviations from the approved TBP or QAPP
Q Any problems with sampling analysis or QA/QC checks
9.1 REVIEWING THE SUMMARY OF ON-SITE ANALYTICAL PROCEDURES
Q Reference to approved TBP and QAPP
Q Reference to on-site analysis conducted by the facility
Q Reference to on-site analysis conducted by the sampling contractor
Q Discussion of QA/QC checks conducted by the on-site laboratory
Q Discussions of any deviations from approved TBP or QAPP
9.2 REVIEWING THE SUMMARY OF OFF-SITE ANALYTICAL PROCEDURES
Q Reference to the approved TBP and QAPP
Q Identification of off-site laboratory and analyses conducted
Q Presentation of completed COC forms
Q Discussion of any deviations from approved TBP or QAPP
Q Discussion of QA/QC checks conducted by off-site laboratory
10.0 REVIEWING CHAPTER 7—QUALITY ASSURANCE/QUALITY CONTROL
RESULTS
Q Reference to the approved QAPP
Q Assessment of data quality
Q Discussion of out-of-specification data and QA/QC procedure deviations
Q Listing of equipment calibration frequency
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Q Identification of QA/QC objectives, procedures, and results
Q Presentation of data analysis and validation procedures
10.1 REVIEWING THE SUMMARY OF ON-SITE QUALITY CONTROL/QUALITY
ASSURANCE RESULTS
Q Reference to approved TBP and QAPP
Q Documentation of QA/QC activity
Q Discussion of any deviations from approved procedures
10.1.1 Stack Gas Samples
Q U.S. EPA Method 1—Sample and Velocity Traverses
Q Stack/duct diameter or dimensions
Q Circular/rectangular
Q Location of sampling ports
Q Upstream/downstream disturbance
Q Number of traverse points
Q Absence of cyclonic flow
Q U.S. EPA Method 2—Stack Gas Velocity and Flow Rate Determination
Q Type of pitot tube
Q Data sheet velocity traverse
Q Pitot tube coefficient
Q Pitot tube inspection - documentation and date
Q Calculation of average stack gas velocity
Q Calculation of stack gas flow rate
Q Thermocouple calibration range and date
Q Barometer calibration date
Q QC procedures
Q U.S. EPA Method 3—Gas Analysis for CO2, O2, Excess Air, and
Molecular Weight
Q Sampling method—single point/multiple point, grab/integrated
sampling
Q Gas analysis method—Orsat or Fyrite analyzer (U.S. EPA
Method 3) or continuous monitors (U.S. EPA Method 3A)
Q Field data sheet
Q Molecular weight calculation
Q Excess air calculation
Q Leak check for sampling/analyzer
Q QC procedures
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U.S. EPA Method 4—Determination of Moisture in Stack Gases
Q Calibration sheets
Q Field data sheets
Q Constant sampling rate
Q Proper sampling rate
Q Stack properly traversed
Q Train temperature maintained below 68 °F
Q Pump/train leak checked
Q Weight of moisture determined
U.S. EPA Method 5/SW-846 U.S. EPA Method 0050 or U.S. EPA
Method 0051—Particulate, HC1/C12
Q Calibration sheets
Q Field data sheets
Q Isokinetic calculations
Q Maintenance of proper temperatures
Q Sampling rate
Q Leak checks
Q Sample recovery documentation
Q Probe rinse procedures
Q Handling/distribution of samples for analysis
U.S. EPA Modified Method 5/SW-846 U.S. EPA Method
0010—Semivolatile Organics
Q Calibration sheets
Q Field data sheets
Q Isokinetic calculations
Q Maintenance of proper temperatures
Q Sampling rate
Q Leak checks
Q Sample recovery documentation for XAD resin
Q Sample recovery documentation
Q Probe rinse procedures
Q Handling/distribution of samples for analysis
Q Sample recovery documentation for blank sample collection
Q GC/flame ionization detector (FID) for unspeciated semivolatile
organics
Q Gravimetric analysis (GRAY) for non-volatile compoundss
U.S. EPA U.S. EPA Method 0012/SW-846 U.S. EPA Method
0060—Multiple Metals
Q Calibration sheets
Q Field data sheets
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Q Isokinetic calculations
Q Maintenance of proper temperatures
Q Sampling rate
Q Leak checks
Q Sample recovery documentation
Q Probe rinse procedures
Q Handling/distribution of samples for analysis
Q Impinger solutions 1, 2, and 3 collected in a prelabeled sample
bottle
Q Impinger 4 liquid collected in an amber glass sample bottle
Q Impinger solutions 5 and 6 collected in an amber glass bottle with
a Teflon-lined lid
Q Visual inspections conducted
U.S. EPA U.S. EPA Method 0013/SW-846 U.S. EPA Method
0061—Hexavalent Chromium
Q Calibration sheets
Q Field data sheets
Q Isokinetic calculations
Q Maintenance of proper temperatures
Q Sampling rate
Q Leak checks
Q Sample recovery documentation
Q Probe rinse procedures
Q Handling/distribution of samples for analysis
Q Absorbing liquid continuously recirculated from first impinger
through the sample line
Q Probe maintained at a temperature below 200°F throughout
sampling
Q Probe ends capped before removing to recovery area
Q pH of impinger 1 above 8.5
Q Nitrogen bubbled through impinger train at 10 liters/minute for 30
minutes
Q Liquid in impingers 1,2,3, and 4 weighed and placed in an amber
glass sample bottle
Q Contents of container 3 filtered
U.S. EPA U.S. EPA Method 0023/SW-846 U.S. EPA Method
0023A—PCDD/PCDF Sampling
Q Calibration sheets
Q Field data sheets
Q Isokinetic calculations
Q Maintenance of proper temperatures
Q Sampling rate
Q Leak checks
Q Sample recovery documentation
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Q Probe rinse procedures
Q Handling/distribution of samples for analysis
Q Nozzle sealed after being removed from the stack
Q U.S. EPA Methods 0030 and 0031—Volatile Organic Sampling Train
(VOST)
Q Calibration sheets
Q Sample volume
Q Sampling duration
Q Number of trap pairs per test run
Q Leak checks for each run or trap pair
Q Blank traps taken
Q Field data log/documentation for each pair
Q Trap storage and shipment
Q U.S. EPA U.S. EPA Method 0040—Total Volatile Organics
Q Field GC for volatiles
Q U.S. EPA Method 7E—Determination of Nitrogen Oxides Emissions
from Stationary Sources
Q Leak check
Q Proper calibration gas with certificate of analysis
Q Record of calibration results
Q Zero span and calibration draft test
Q Data logged every 60 seconds
Q U.S. EPA Method 10—Determination of Carbon Monoxide Emissions
from Stationary Sources
Q Leak check
Q Proper calibration gas with certificate of analysis
Q Record of calibration results
Q Zero span and calibration draft test
Q Data logged every 60 seconds
Q Instrument measurement range
Q Performance specification test results
Q U.S. EPA Method 25 A—Determination of Total Gaseous Nonmethane
Organic Emissions Using a Flame lonization Analyzer
Q Leak check
Q Proper calibration gas with certificate of analysis
Q Record of calibration results
Q Zero span and calibration draft test
Q Data logged every 60 seconds
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Instrument measurement range
Performance specification test results
Q CO and O2 CEMS
Q Verification of absence of leakage at CO and O2 sampling
location
Q Calibration gas concentration (zero and high-level)
Q Calibration gas certificate (confirm that CO protocol calibration
gases have not expired)
Q Calibration checks before each run and daily
Q Zero and span calibration drift test during trial burn
Q Sampling and analysis conducted every 15 seconds during trial
burn
Q Data logged every 60 seconds during trial burn
10.1.2 Process Samples
Q Identification of all process samples collected
Q Identification of all QA/QC samples collected
Q Sample frequency
Q Sample volume
Q Sample container and storage conditions
Q Sample method
Q Sample traceability procedures
Q Any special sample preparation requirements
10.2 REVIEWING THE SUMMARY OF OFF-SITE QUALITY ASSURANCE/QUALITY
CONTROL RESULTS
Q Sample traceability
Q Holding times
Q Feedstocks, fuel, and APCS residual sample analytical results
Q Stack gas sample analytical results
Q QC assessment
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Q QA coordinator report
11.0 REVIEWING CHAPTER 8—TRIAL BURN RESULTS SUMMARY AND PROPOSED
PERMIT LIMITS
This chapter should include subsections on the following topics:
Q Destruction and removal efficiencies (see Section 11.1)
Q CEMS results (see Section 11.2)
Q Stack gas emission rate results (see Section 11.3)
Q Proposed process limits (see Section 11.4)
Q Proposed waste feed limits (see Section 11.5)
Q Proposed automatic waste feed cutoff limits (see Section 11.6)
Q Proposed data for use in the risk assessment (see Section 11.7)
While reviewing these sections of the TBR, the review team should check for the
following:
Q Emission rate results summary for each run
Q DRE for each POHC (DRE test condition)
Q PCDD/PCDF emission rates (risk burn test condition)
Q Metals emissions rates (high temperature and risk burn test
conditions)
Q Hexavalent chromium emission rate (high temperature and risk
burn test conditions)
Q HC1/C12 emission rates (all test conditions)
Q CO concentration levels in flue gas (all test conditions)
Q VOC and SVOC emission rates (DRE and risk burn test
conditions)
Q Particle size distribution (PSD) (risk burn test condition)
Q TO emission rates for volatile, semivolatile, and GRAY fractions
(risk burn test condition)
Q Summary of the key trial burn operating conditions (these data should
include the following values for each run: minimum, maximum, average,
standard deviations, average HRAs, minimum HRAs, and maximum
HRAs)
Q Liquid waste feed rate
Q Combustion chamber temperature
Q Baghouse (or APCS) inlet temperature
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Q Stack gas O2 concentration
Q Ash feed rate
Q Chloride feed rate
Q Metals feed rate
Q Baghouse differential pressure
Q Combustion gas velocity
Q Auxilliary fuel feed rate
Q Other APCS key parameters
Q Proposed permit limits
Q Maximum waste feed rate
Q Minimum and maximum combustion gas temperature
Q Maximum combustion gas flow rate
Q Minimum and maximum production rate
Q Minimum stack gas O2 concentration
Q Maximum baghouse inlet temperature
Q Minimum baghouse differential pressure
Q Maximum ash feed rate
Q Maximum chloride rate
Q Maximum BIF metals rate
Q Auxilliary fuel feed rates
Q Total pumpable waste feed rate
Q APCS parameters
Sections 11.1 through 11.7 of this component provide more detailed information
for the parameters included under this "Check For" section.
11.1 REVIEWING DESTRUCTION AND REMOVAL EFFICIENCIES
Q DRE of at least 99.99 percent for each POHC (during each run of the
DRE test condition) identified in the trial burn
Q DRE calculations, including POHC feed rate and POHC stack gas
emissions rate
11.2 REVIEWING CONTINUOUS EMISSION MONITORING SYSTEM RESULTS
Q Whether CO concentration, during testing (for each run, all test
conditions), corrected to 7 percent O2, is below 100 ppmv
11.3 REVIEWING STACK GAS EMISSION RATE RESULTS
This chapter of the TBR should include subsections regarding the following topics:
Q PM and PSD results for each run (see Section 11.3.1)
Q HC1 and C12 emission rate results for each run (see Section 11.3.2)
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Q Metals emission rate results for each run (see Section 11.3.3)
Q POHC emission rate results for each run (see Section 11.3.4)
Q PIC emission rate results for each run (see Section 11.3.5)
Q TO emission rate results for each run (see Section 11.3.6)
Q PCDD/PCDF emission rate results for each run (see Section 11.3.7)
This section discusses how to review the emission rate results for each of these
compounds. Sections 11.3.1 through 11.3.7 of this component include example
sections for each of the emission parameters
11.3.1 Reviewing Particulate Matter Emission Rate Results
Q Whether emission rate is less than 180 //g/dscm (0.08 gr/dscf)
Q PM emission calculations
Q Whether isokinetic sampling results are acceptable (within 90 to 110
percent)
Q Appropriate correction for soot blowing
11.3.2 Reviewing Hydrogen Chloride and Chlorine Gas Emission Rate Results
Q Trial burn HC1 and C12 emission rates (use field data and laboratory
results to see whether TBP objectives were met)
Q HC1 and C12 emission rate calculations
11.3.3 Reviewing Metal Emission Rate Results
Q Trial burn results for metal emissions to see whether TBP objectives
were met
Q Metal emissions calculations
11.3.4 Reviewing POHC Emission Rate Results
Q Trial burn results of POHC emissions to see whether TBP objectives are
met
Q POHC stack gas emission calculations (check field data logsheets and
analytical report)
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Section 11.1 of this component presents POHC (benzene) emission rate sample
calculations. To calculate POHC in ash and residue, multiply the POHC
concentration in the ash and residue by the ash and residue generation rate,
respectively.
11.3.5 Reviewing PIC Emission Rate Results
Q VOC PICs emission rate based on VOST results
(U.S. EPA Methods 0030 and 0031)
Q SVOC PICs emission rate based on SVOST results
(sampling U.S. EPA Method 0010, analytical U.S. EPA Method 8270)
11.3.6 Reviewing Total Organic Emission Rate Results
Q Volatile organics emission rate of compounds determined using
U.S. EPA Method 0040 (SW-846)
Q Semiovolatile organics emission rate of compounds determined using
U.S. EPA Method 0010 (SW-846)
Q Nonvolatile organics emission rate of compounds determined using U.S.
EPA Method 0010 (SW-846)
11.3.7 Reviewing Polychlorinated Dibenzopdioxin/Polychlorinated Dibenzofuran Emission Rate
Results
Q Trial burn results of PCDD/PCDF emissions
Q PCDD/PCDF emission calculations
Q ORE of 99.9999 percent for PCDD/PCDFs
11.4 REVIEWING PROPOSED PROCESS LIMITS
Q Maximum (average during test run) emission rate of each metal
Q Feed rate of metals in each hazardous waste stream
Q Total feed rate of C12 and HC1 in total feed streams
Q Fuel feed rates
Q Maximum combustion gas temperature
Q Minimum combustion gas temperature
Q Maximum flue gas temperature at the inlet to the PM control device
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Q Combustion gas velocity
Q Maximum device production rate
Q Minimum device production rate
Q APCS parameters
Subsections that follow contain procedures for reviewing proposed waste feed
limits, AWFCO limits, combustion unit parameters, and APCS parameters.
Sections 11.5, 11.6, 11.6.1, 11.6.2, and 11.6.2.1 through 11.6.2.6 of this
component include the example comments for review of key process limits.
11.5 REVIEWING PROPOSED WASTE FEED LIMITS
Q Whether waste feed rate is the proposed permit limit set at maximum
feed rate (review feed rate data of trial burn)
Q Whether the proposed permit limit is established as a single, 1-hour rolling
average
11.6 REVIEWING PROPOSED AUTOMATIC WASTE FEED CUTOFF LIMITS
This chapter of the TBR should include subsections that address:
Q Combustion unit parameters (see Section 11.6.1)
Q APCS parameters (see Section 11.6.2)
Q Parameters for other associated equipment (see Section 11.6.3)
During review of these subsections, the TBR review team should check for the
following:
Q AWFCO limits
Q Whether AWFCO limits are established for the parameters listed above
11.6.1 Reviewing Parameters for Combustion Units
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Q Whether the proposed permit limit for combustion gas velocity is set at
the maximum combustion gas velocity (review gas velocity data during
the appropriate test conditions of the trial burn)
Q Whether proposed permit limits for combustion chamber temperature are
set at minimum and maximum combustion unit temperatures measured
during the appropriate test conditions of the trial burn
Q Whether the proposed permit limits are established as both instantaneous
andHRA
11.6.2 Parameters for Reviewing Air Pollution Control Systems
The following subsections should be included (if applicable to the APCS employed):
Q Dry scrubber parameters (see Section 11.6.2.1)
Q Wet ionizing scrubber parameters (see Section 11.6.2.2)
Q Venturi scrubber parameters (see Section 11.6.2.3)
Q Wet scrubber parameters (see Section 11.6.2.4)
Q Electrostatic precipitator parameters (see Section 11.6.2.5)
Q Baghouse (fabric filter) parameters (see Section 11.6.2.6)
Q Other associated equipment parameters (see Section 11.6.3)
The following items should be evaluated by the TBR review team:
Q Proposed permit limits for APCS parameters
Q Trial burn monitoring data for APCS parameters to confirm that
proposed permit limits reflect actual APCS monitoring parameters
Q Whether proposed permit limits for APCS parameters are established as
HRAs
11.6.2.1 Reviewing Dry Scrubber Parameters
Q Minimum average caustic feed rate
Q Maximum average flue gas flow rate
11.6.2.2 Reviewing Parameters For Wet Ionizing Scrubber
Q Minimum average liquid to gas ratio
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Minimum average scrubber blowdown from the system or maximum
suspended solids content of scrubber water
Minimum average pH level of the scrubber
Minimum average electric power, in kilovolt amperes (kVA) or applied
voltage, to precipitator plates
Q Maximum average flue gas flow rate
11.6.2.3 Reviewing Venturi Scrubber Parameters
Q Minimum average differential gas pressure limit across the venturi
scrubber (the differential pressure is measured by applying pressure taps
on each side of the venturi, connected to a differential pressure [A?]
transducer)
Q Minimum average liquid-to-gas ratio limit
Q pH level limit
Q Maximum total suspended solids
Q Minimum APCS inlet temperature (dry units)
11.6.2.4 Reviewing Wet Scrubber Parameters
Q Minimum average liquid-to-gas ratio limit
Q Maximum average flue gas flow rate limit
Q pH level limits for scrubber effluent
Q Maximum average inlet temperature
Q Maximum total suspended solids
11.6.2.5 Reviewing Parameters For Electrostatic Precipitators
Q Minimum electric power, in kVA or applied voltage, to precipitator plates
Q Maximum average flue gas flow rate
Q Maximum average inlet temperature
11.6.2.6 Reviewing Baghouse (Fabric Filter) Parameters
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Q Minimum average pressure drop, as set by the TBP
Q Maximum average inlet temperature
Q Air-to-cloth ratio
Q Cleaning cycle
11.6.3 Reviewing Parameters For Other Associated Equipment
Q Parameters from trial burn data (Group A and B parameters)
Q Cyclones
Q Inlet gas temperature
Q Gas velocity
Q Pressure drop
Q Absorber
Q Inlet gas temperature
Q Scrubber liquid flow rate
Q Scrubber liquid inlet and outlet pH
Q Nozzle pressure
Q Recirculation and blow down rate
Q Induced- or forced-draft fan
Q Volumetric flow rate
Q Temperature
Q Pressure
Q Horsepower
Q Packed-bed scrubber
Q Liquid-to-gas ratio
Q Scrubber liquid pH
Q Scrubber liquor blowdown rate
Q Parameters independent of trial burn (Group C parameters)
Q APCS inlet gas temperature
Q Maximum total heat input for each chamber
Q Liquid injection burner settings
Q Maximum viscosity of pumped waste
Q Maximum burner turndown
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Q Minimum atomization fluid pressure
Q Minimum waste heating value
Q Minimum and maximum nozzle pressure to scrubber
11.7 REVIEWING PROPOSED DATA FOR USE IN THE RISK ASSESSMENT
Q VOC emission rates including PICs, during each run
Q SVOC emission rates including PICs, during each run
Q PAH emission rates during each run
Q Emission rates for other organic compounds that may be of concern,
such as aldehydes, during each run
Q Metal emission rate during each run
Q HC1 and C12 emission rates during each run
Q PCDD and PCDF emission rates during each run
Q Particle size distribution
Q TO emission rates
12.0 REVIEWING THE Appendices
Q The TBP and QAPP would have been submitted and approved prior to
conducting the trial burn. They may or may not be resubmitted as
appendices; however, if they are not included as appendices to the TBR,
they should be obtained for use in the TBR review (see Sections 12.1
and 12.2).
Q Stack sampling report (see Section 12.3)
Q Process sampling report (see Section 12.4)
Q QA/QC report (see Section 12.5)
Q Instrument calibration records (see Section 12.6)
Q Performance calculations (see Section 12.7)
Q Field logs (see Section 12.8)
Q Analytical data packages (see Section 12.9)
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12.1 REVIEWING APPENDIX A— TRIAL BURN PLAN
The TBP must have been submitted and approved prior to the trial burn;
it may or may not be resubmitted as an appendix to the TBR; however,
at a minimum, it should be obtained for use in the TBR review
Letters of correspondence between the BIF facility and the regulatory
agency
Notices of deficiency and responses
Letter from U.S. EPA stating that the TBP is acceptable for
implementation
12.2 REVIEWING APPENDIX B— QUALITY ASSURANCE PROJECT PLAN
Q The trial burn QAPP should have been submitted and approved prior to
the trial burn, it may or may not be resubmitted as an appendix to the
TBR; however, as a minimum, it should be obtained to assist in the TBR
review.
Sixteen essential elements of a trial burn QAPP include:
Q Title page with provisions for approval signatures
Q Table of contents
Q Project description
Q Project organization and responsibility
Q QA objectives for later measurement, in terms of precision,
accuracy, completeness, representativeness, and comparability
Q Sampling procedures
Q Sample custody
Q Calibration procedure and frequency
Q Analytical procedures
Q Data reduction, validation, and reporting
Q Internal QC checks and frequency
Q Performance and system audits and frequency
Q Preventive maintenance procedures and schedules
Q Specific routine procedures to be used to assess data precision,
accuracy, and completeness of specific measurement
parameters involved
Q Corrective action
Q QA reports to management
Document control indicator in the top right corner of each page
How the trial burn QAPP is contained in the overall plan (incorporated
into the TBP or separate from it)
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12.3 REVIEWING APPENDIX C— STACK SAMPLING REPORT
The TBR should include the following subsections:
Q U.S. EPA Method 0010 field data sheets and emission rate calculations
(See Section 12.3.1)
Q U.S. EPA Method 23 or 0023A field data sheets and emission rate
calculations (See Section 12.3.2)
Q U.S. EPA Method 0012 or 0060 field data sheets and emission rate
calculations (See Section 12.3.3)
Q U.S. EPA Method 0013 or 0061 field data sheets and emission rate
calculations (See Section 12.3.4)
Q U.S. EPA Method 0030 or 0031 field data sheets and emission rate
calculations (See Section 12.3.5)
Q Total organics field data sheets and emission rate calculations (See
Section 12.3.6)
Q U.S. EPA Method 0050 or 0051 field data sheets and emission rate
calculations (See Section 12.3.7)
During review of these subsections, the TBR review team should evaluate the
following:
Q Field data sheets for each sampling method used during the trial burn
Q Emission rate calculations, in consistent units for each method used
during the trial burn
Q Calibration records for pretest and post-test calibration of all methods
and sampling equipment
Q All calibration records for calibration equipment
12.3.1 Reviewing U.S. EPA Method 0010 Field Data Sheets and Emission Rate Calculations
Q Field data sheets indicating traverse points sampling time; vacuum; stack
temperature; velocity head; pressure differential across orifice meter;
gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser
Q Filter temperature of 248 ± 25 °F
Q Gas temperature entering the sorbent-trap of less than 68 °F
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Q Isokinetic sampling rate of 90 to 110 percent
Q Stack flow rate calculations
Q Minimum sample column calculations
Q SVOC emission rate calculations
12.3.2 Reviewing Method 23 Field Data Sheets and Emission Rate Calculations
Q Field data sheets indicating traverse points; sampling time; vacuum; stack
temperature; velocity head; pressure differential across orifice meter;
gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser
Q Minimum sample volume required for DRE measurement is 106 dscf;
this volume can be used as the absolute minimum for PCDD/PCDF
sampling
Q Filter temperature of 248 ± 25 °F
Q Gas temperature entering the sorbent-trap of less than 68 °F
Q Isokinetic sampling rate of 90 to 110 percent
Q Stack flow rate calculations
Q Minimum sample column calculations
Q PCDD/PCDF emission rate calculations
Q Demonstrated experience of the analyst in the use of air sampling
methods for PCDDs, PCDFs
12.3.3 Reviewing U.S. EPA Method 0012 Field Data Sheets and Emission Rate Calculations
Q Field data sheets (for each traverse point record: sampling time; vacuum;
stack temperature; velocity head; pressure differential across orifice
meter; gas sample volume; gas sample dry-gas meter inlet and outlet
temperature; and temperature of gas leaving condenser [last impinger])
Q Maintenance of proper temperature (probe and filter at 248 ± 25 °F, train
exit gas below 68°F)
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
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Q Metals emission rate calculations
12.3.4 Reviewing U.S. EPA Method 0013 Field Data Sheets and Emission Rate Calculations
Q Field data sheets (for each traverse point records: sampling time;
vacuum; stack temperature; velocity head; pressure differential across
orifice meter; gas sample volume; gas sample dry-gas meter inlet and
outlet temperature; and temperature of gas leaving condenser [last
impinger])
Q Maintenance of proper temperature (probe and filter at 248 ± 25 °F, train
exit gas below 68°F)
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
Q Hexavalent chromium emission rate calculations
Q First impinger pH
12.3.5 Reviewing U.S. EPA Method 0030 Field Data Sheets and Emission Rate Calculations
Q Sample collection rate
Q Temperature of gas stream entering first trap
Q Leak checks
Q Identification of O-rings
Q Identification of sample cartridge storage conditions
Q Qualifications of sampling personnel
Q Holding time for VOST tubes from time and day of collection to time and
day of analysis
12.3.6 Reviewing Total Organics Field Data Sheets and Emission Rate Calculations
Q U. S. EPA Method 0040 field data sheets
Q Field GC results
a U.S. EPA Method 0010 field data sheets
Q TCO results
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a GRAY results
Q Unidentified organics emission rate calculations
Q Experience in sampling and analysis techniques
12.3.7 Reviewing U.S. EPA Method 0050 Field Data Sheets and Emission Rate Calculations
Q Field data sheets for each traverse point recording the following:
Q Sampling time
Q Vacuum
Q Stack temperature
Q Velocity head
Q Pressure differential across orifice meter
Q Gas sample volume
Q Gas sample dry-gas meter inlet and outlet temperature
Q Temperature of gas leaving condenser (last impinger)
Q Maintenance of proper temperature (probe and filter 248 ± 25 °F, train
exit gas below 68°F)
Q Whether isokinetic calculations are within 90 to 110 percent
Q Stack flow rate calculations
12.4 REVIEWING APPENDIX D—PROCESS SAMPLING REPORT
The TBR should include subsections on the following:
Q Raw data (see Section 12.4.1)
Q Data summary calculations (see Section 12.4.2)
The TBR review team should evaluate these section for the following
information:
Q Sampling equipment, as proposed in the TBP
Q Sampling data forms to see whether location, method, frequency, and
presentation agree with TBP
Q Responsibility assignments
Finally, raw data should be spot-checked against data included in the trial burn
oversight report.
12.4.1 Reviewing Raw Data
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Q Sampling location
Q Sampling method
Q Sampling frequency
Q Sample preservation
Q Run number, data, and sampler identity
Q Sample identification
Raw data should also be spot-checked against data collected during the trial burn
oversight
12.4.2 Reviewing Data Summary Calculations
Q Presentation of summary calculations
Q Whether summary calculations are complete
Q Whether summary calculations are accurate
12.5 REVIEWING APPENDIX E—THE QA/QC REPORT
This section of the TBR contain subsections that include the following:
Q Field sampling QA/QC report (see Section 12.5.1)
Q Laboratory QA/QC report (see Section 12.5.2)
Q Chain-of-custody forms (see Section 12.5.3)
The TBR review team should evaluate the following aspects of this information:
Q Formal presentation of the 16 trial burn QAPP elements
Q QA/QC information on items listed in the explanation
Q Consistency between TBP, trial burn QAPP, and TBR presentation
12.5.1 Reviewing Field Sampling Quality Assurance/Quality Control Report
Using the checklists, the reviewer should evaluate the following:
Q U.S. EPA Method 1
6-B-42
-------
Q Absence of cyclonic flow
U.S. EPA Method 2
Q Thermocouple calibration range and date
Q Barometer calibration range
U.S. EPA Method 3
Q Leak check for sampling
Q Leak check for analyzers
U.S. EPA Method 4
Q Calibration sheets for vacuum gauge
Q Calibration sheets for thermocouples
Q Calibration sheets for dry-gas meter
Q Proper sampling rate
Q Pump leak checked
Q Leak check on train
Q Train temperature less than 68 °F
U.S. EPA Method 5
Q Calibration sheets for sampling nozzle, pitot tube, dry-gas meter
and thermometers/thermocouples
Q Leak checks for sample line and pitot lines
Q Proper sampling rate
Q Adequate total sampling time (2-hour minimum) and sampling
time at each point
Q Proper temperature maintained (probe and filter 240 ± 25 °F,
train exit gas less than 68°F)
Q Sampling rate within 90 to 110 percent of isokinetic
U.S. EPA Modified Method 5 (U.S. EPA Method 0010) for semivolatile
organics
Q Sample recovery documentation for XAD tubes
Q Sample recovery documentation for blank sample collection
Q Calibration sheets for sampling nozzle, pitot tube, dry-gas meter
and thermometers/thermocouples
Q Leak checks for sample line and pitot lines
Q Proper sampling rate
Q Adequate total sampling time (2-hour minimum) and sampling
time at each point
Q Proper temperature maintained (probe and filter 240 ± 25 °F,
train exit gas less than 68°F)
6-B-43
-------
Q Sampling rate within 90 to 110 percent of isokinetic
Q U.S. EPA Methods 0012 and 0060 - Determination of Metals Emissions
from Stationary Sources. Review method for QA/QC procedures and
proper sample collection, transfer, and train component cleanup
Q U.S. EPA Methods 0030 and 0031 for volatile organics
Q Leak checks for the train
Q Calibration sheets for dry gas meter and thermocouples
Q Sampling volume, duration, and leak checks for each trap pair
recorded
Q Trip blanks collected
Q Field data logsheets for each trap pair available
Q U.S. EPA Method 0040 - Total Organics Measurement. Review method
for QA/QC procedures and field analytical requirements
Q U.S. EPA Methods 0050 and 0051 - Sampling Method for PM, HC1 and
C12. Check method for QA/QC, sampling requirements, transfer and
train cleanup
Q COandO2CEMS
Q Leak checks for CO and O2 sampling locations
Q Calibration gas concentration (zero and high level)
Q Calibration gas certificate (whether CO protocol calibration
gases have expired)
Q Whether calibration checks are performed before each run and
daily
Q Whether zero and span calibration drift test is performed during
trial burn
Q Whether sampling and analysis are conducted every 15 seconds
during trial burn
Q Whether data are logged every 60 seconds during trial burn
12.5.2 Reviewing Laboratory Data Summary Report
Q Identification of all reportable data
Q Presentation of field records
Q Calibration data
Q Precision and accuracy results
Q Internal audit results
6-B-44
-------
Q Data quality assessment report
Q SQL determination summary
Q Flagged data with discussion
12.5.3 Reviewing Chain-of-Custody Forms
Q Completed forms
Q Signatures
Q Sample identification
Q Other information, as required
12.6 REVIEWING APPENDIX F—INSTRUMENT CALIBRATION RECORDS
Q Process monitoring equipment calibration records (see Section 12.6.1)
Q Process control equipment calibration records (see Section 12.6.2)
Q Emission monitoring equipment calibration records (see Section 12.6.3)
Q Stack gas sampling equipment calibration records (see Section 12.6.4)
Q Field analytical equipment calibration records (see Section 12.6.5)
The TBR review team should closely check this information for consistency with
the trial burn oversight report.
12.6.1 Reviewing Calibration Records For Process Monitoring Equipment
Q List of process monitoring equipment and measurement devicesoutlined
in the TBP
Q Identification and response criteria of each process monitoring device
outlined in the trial burn QAPP
The TBR review team should closely check this information for consistency with
the information presented in the trial burn oversight report.
12.6.2 Reviewing Calibration Records For Process Control Equipment
Q List of the process control equipment measuring devices outlined in the
TBP
Q Calibration records
6-B-45
-------
Q Identification and response criteria of each process control equipment
device outlined in the trial burn QAPP
The TBR review team should closely check this information for consistency with
the trial burn oversight report.
12.6.3 Reviewing Calibration Records For Continuous Emission Monitoring Equipment
Q Monitor calibration error for all gases
Q Zero drift of the monitor
Q Calibration drift of the monitor
Q Sample system bias of the monitor
The TBR review team should closely check this information for consistency with
the trial burn oversight report.
12.6.4 Reviewing Calibration Records for Stack Gas Sampling Equipment
Q Pitot tube calibration form
Q Thermocouple calibration form
Q Dry-gas meter calibration form (pretest and post-test)
Q Barometer calibration form
Q Sample train nozzle calibration form
12.6.5 Reviewing Calibration Records For Field Analytical Equipment
Q Pre- and post-test calibrations
Q Sampling system bias evaluations
Q Equipment performance and percent recovery
Q Spike and matrix spike evaluations
12.7 REVIEWING APPENDIX G—PERFORMANCE CALCULATIONS
Q DRE calculations
Q DRE of at least 99.99 percent for each POHC (during each run)
identified during the trial burn
6-B-46
-------
a DRE of at least 99.9999 percent for PCDD/PCDFs, if applicable
12.8 REVIEWING APPENDIX H—FIELD LOGS
Q Notes or logs by program coordinator, unit operation, process, or control
room operators of the facility
Q Notes or logs recorded by source testing company coordinator, field
crew leader, and equipment operators
Q Notes, logs, or checklists taken by U.S. EPA, state regulatory, and
contracted oversight observers
Q Field notes, logs, or checklists prepared by an independent third-party
auditor
12.9 REVIEWING APPENDIX I—ANALYTICAL DATA PACKAGES
Q Analytical data package for waste feed parameters
Q Analytical data package for process samples
Q Analytical data package for stack gas samples
Q Information presented in the data packages for:
Q Sample identification name and number
Q Analytical method followed
Q Matrix type
Q Date, time, and location of sample collection
Q Person responsible for sample collection and recovery
Q Temperature of sample when received
Q Result of the sample analysis and units associated with the
number valve
Q Method detection limit and sample quantitation limit
Q Spike results
Q Spike recovery
Q Matrix spike results
Q Duplicate matrix spike results
Q Whether the QA/QC objectives of the TBP were met and satisfied
Q Whether the QA/QC objectives of the trial burn QAPP were met and
satisfied
6-B-47
-------
ATTACHMENT C
STACK GAS EMISSION CALCULATIONS
-------
How to Use the Method 0010 Raw Data Calculation Workbook
The Method 0010 calculation worksheet was written in Excel. The workbook is comprised of two separate
worksheets as follows:
1) Determination of stack gas flow rate parameters and percent isokinetic (Flows)
2) Determination of semivolatile organic compound mass emission rates (SVOC)
The workbook has been protected so that calculations and measurement units associated with each parameter
cannot be mistakenly changed by the user. Significient figures for input information and calculation results
have been considered and the cells have been formatted to satisfy this requirement. Calculation results that
are used in subsequent pages and/or worksheets automatically carry forward in the workbook. Thus, it is
imperative that all red colored input information is inserted in the specified order.
The font style and size have been configured for Times New Roman 10-point. The workbook will print
from most popular HP laser jet printers.
Steps to Use the Method 0010 Workbook
The two worksheets of this workbook must be used in the following order.
Flows Worksheet (Flows)
1) Obtain raw stack test field data and verify/compute average values.
2) Enter plant, location, unit, test condition, and run number. The fields for this information are red
colored.
3) Input raw field data on page 1. Some of this information will be averaged raw test data, equipment
calibration coefficients, and/or single point measurement values. The fields for this information
arered colored.
4) Review and/or print worksheet.
5) A summary of the key input and results data is contained on page 5.
Semivolatile Organic Compound Worksheet (SVOC)
1) Obtain raw laboratory data.
2) Input semivolatile organic contstiuents mass in micrograms on page 1 (total concentration of each
constituent in all sample train subsamples). A cell is available for the "<" symbol when the
minimum
detection limit is used for the value. The fields for this information are red colored.
3) Review and/or print worksheet.
4) The results begin on page 3.
6-C-l
-------
RAW DATA INPUT
FOR
EPA METHOD 0010 FLOW
Plant Name:
Location:
Unit:
Condition:
Run No.
Variable Definition
Po - Average Meter Differential Pressure
Pb - Barometric Pressure
Tm - Average Dry Gas Meter Temperature
DGMC - Dry Gas Meter Correction Factor
Vlcg - Total Condensate Collected
Vm - Dry Gas Meter Sample Volume
T - Sampling Time Duration
%CO2 - Carbon Dioxide Concentration, Dry Basis
%O2 - Oxygen Concentration, Dry Basis
%CO - Carbon Monoxide Concentration, Dry Basis
Dn - Nozzle Diameter
Cp - Pilot Tube Coefficient
Dp - Avg. Sq. Root of Velocity Head
Ts - Average Stack Gas Temperature
Sp - Static Pressure of Gas Stream
D - Stack Diameter
RATE CALCULATIONS
XYZ COMPANY
ANYWHERE, USA
BIF UNIT
NORMAL
ONE
Data Units
1.56 in. H2O
30.11 in. Hg
94.790 °F
0.987 Dimensionless
410.5 grams
81.140 dcf
120.0 min
6.80 % Volume
10.00 % Volume
0.00 % Volume
0.3120 in.
0. 84 Dimensionless
0.4593 in. H2O05
141.1 °F
0.18 in. H20
42.00 in.
Flows
6-C-2
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Pm
Po
Pstd
Pb
Kl
K2
Tm
Tstd
DGMC
Vlcg
Vm
Vmstd
Vwstd
Bws
Bwd
Pm
Vwstd =
Bwd
MOISTURE CONTENT AND SAMPLE VOLUME CORRECTION CALCULATIONS
XYZ COMPANY CONDITION: NORMAL
ANYWHERE, USA TEST RUN: ONE
BIF UNIT
VARIABLE LIST
Definition Units
Absolute Dry Gas Meter Pressure in. Hg
Average Meter Differential Pressure in. H2O
Absolute Standard Pressure (29.92) in. Hg
Barometric Pressure in. Hg
Conversion Factor (13. 6) in. H2O/in. Hg
Standard Volume H2O Vapor/Unit Weight Liquid (0.04715) ft3/g
Average Dry Gas Meter Temperature °R
Absolute Standard Temperature (528) °R
Dry Gas Meter Correction Factor Dimensionless
Total Condensate Collected grams
Dry Gas Meter Sample Volume dcf
Dry Gas Meter Sample Volume, at Standard Conditions dscf
Volume of Water Vapor Collected, at Standard Conditions scf
Moisture Content mole fraction
Moisture Content % Volume
TEST DATA
Variable Data Variable Data
Pb= 30.11 Tm= 554.8
Vm= 81.140 Po= 1.56
Vlcg= 410.5 DGMC= 0.987
CALCULATIONS
Pb + (Po/Kl) = 30.11 +(1.56/13.6) = 30.22 in. Hg
(Vm)(DGMC)(Pm)(Tstd) (81.140)(0.987)(30.22)(528)
7/: gel H«rf
(Pstd)(Tm) (29.92)(554.8)
(K2)(Vlcg) = (0.04715)(410.5) = 19.355 scf
(Vwstd) 19.355
0 2009
(Vwstd) + (Vmstd) (19.355)+(76.981)
(Bws)(100%) = (0.2009)(100%) = 20.09 % Volume
Flows
6-C-3
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Md
Ms
Bws
%CO2
%CO
%02
%N2
0.32
0.28
0.28
0.44
18.0
MOLECULAR WEIGHT DETERMINATION
XYZ COMPANY CONDITION:
ANYWHERE, USA TEST RUN:
BIF UNIT
VARIABLE LIST
Definition
Sample Gas Molecular Weight, Dry Basis
Sample Gas Molecular Weight, Wet Basis
Moisture Content
Carbon Dioxide Concentration, Dry Basis
Carbon Monoxide Concentration, Dry Basis
Oxygen Concentration, Dry Basis
Nitrogen Concentration, Dry Basis (gas balance)
Molecular Weight of Oxygen, divided by 100%
Molecular Weight of Carbon Monoxide, divided by 100%
Molecular Weight of Nitrogen, divided by 100%
Molecular Weight of Carbon Dioxide, divided by 100%
Molecular Weight of Water
NORMAL
ONE
Units
Ib/lb-mole
Ib/lb-mole
mole fraction
% Volume
% Volume
% Volume
% Volume
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
TEST DATA
Variable Data Variable Data
Bws= 0.2009 %CO= 0.00
%N2= 83.20 %C02= 6.80
%O2 = 10.00
CALCULATIONS
Md
Md
Md
Ms
Ms
Ms
(0.44)(%CO2) + (0.32)(%O2) + (0.28)(%N2 + %CO)
(0.44)(6.80) + (0.32)(10.00) + (0.28)(83.20 + 0.00)
29.488 Ib/lb-mol
(Md)(l - Bws) + (18.0)(Bws)
(29.488)(1 - 0.2009) + (18.0)(0.2009)
27.180 Ib/lb-mol
Flows
6-C-4
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Cp
Vs
Qsd
Qact
Bws
Dp
Pb
Kp
Ts
Ms
Sp
Tstd
Pstd
CSA
Ps
Kl
K2
Pi
D
Ps
Vs
Vs
CSA
Qact
Qsd ~
Qsd
VELOCITY AND VOLUMETRIC FLOW RATE DETERMINATION
XYZ COMPANY CONDITION:
ANYWHERE, USA TEST RUN:
BIF UNIT
VARIABLE LIST
Definition
Pilot Tube Coefficient
Stack Gas Velocity
Volumetric Flow Rate at Standard Conditions, Dry Basis
Volumetric Flow Rate, Wet Basis
Moisture Content
Avg. Sq. Root of Velocity Head
Barometric Pressure
Constant = 85.49 (ft)(lb/lb-mol)(in.HgA0.5)/(s)(°R)(in.H2O)
Average Stack Gas Temperature
Sample Gas Molecular Weight, Wet Basis
Static Pressure of Gas Stream
Absolute Standard Temperature (528)
Absolute Standard Pressure (29.92)
Stack Cross-Sectional Area
Absolute Stack Gas Pressure
Conversion Factor (13.6)
Conversion Factor (60)
Constant (3. 1416)
Stack Diameter
TEST DATA
Variable Data Variable Data
Ms = 27.180 Dp = 0.4593
Bws= 0.2009 Pb = 30.11
Sp = 0.18 Ts = 601.1
CALCULATIONS
Pb + (Sp/Kl) = 30.11 +(0.18/13.6) =
(Kp)(Cp)(Dp)[(Ts)/(Ms)(Ps)r0.5
(85.49)(0.84)(0.4593)[601.1/(27.180)(30.12)]A0.5 = 28.26
(Pi)(D2)/[(4)(144)] = (3.1416)(42.00r2/[(4)(144)] =
(Vs)(CSA)(K2) = (28.26)(9.62)(60) = 16311.7
(Qact)(l-Bws)(Tstd)(Ps) (1631 1.7)(1 - 0.2009)(528)(30. 12)
(Ts)(Pstd) (601.1)(29.92)
11526.1 dscfm
NORMAL
ONE
Units
Dimensionless
ft/sec
dscfm
cfm
mole fraction
in. H2005
in. Hg
°R
Ib/lb-mole
in. H20
°R
in. Hg
ft2
in. Hg
in. H2O/in. Hg
sec/min
Dimensionless
in.
Variable Data
Cp = 0.84
D = 42.00
30.12 in. Hg
ft/sec
9.62 ft2
cfm
Flows
6-C-5
-------
COMPANY:
LOCATION:
SOURCE:
Variable
%C02
%co
%O2
%N2
Pb
Sp
Po
Ts
Tm
Vlcg
Vm
DGMC
Dp
Cp
D
Md
Ms
Ps
Pm
Vmstd
Vwstd
Bws
Bwd
CSA
Vs
Qact
Qsd
I
FLOW RATE DATA SUMMARY
XYZ COMPANY
ANYWHERE, USA
BIF UNIT
VARIABLE LIST
Definition
INPUT DATA SUMMARY
Carbon Dioxide Concentration, Dry Basis
Carbon Monoxide Concentration, Dry Basis
Oxygen Concentration, Dry Basis
Nitrogen Concentration, Dry Basis (gas balance)
Barometric Pressure
Static Pressure of Gas Stream
Average Meter Differential Pressure
Average Stack Gas Temperature
Average Dry Gas Meter Temperature
Total Condensate Collected
Dry Gas Meter Sample Volume
Dry Gas Meter Correction Factor
Avg. Sq. Root of Velocity Head
Pilot Tube Coefficient
Stack Diameter
RESULTS SUMMARY
Sample Gas Molecular Weight, Dry Basis
Sample Gas Molecular Weight, Wet Basis
Absolute Stack Gas Pressure
Absolute Dry Gas Meter Pressure
Dry Gas Meter Sample Volume, at Standard Conditions
Volume of Water Vapor Collected, at Standard Conditions
Moisture Content
Moisture Content
Stack Cross-Sectional Area
Stack Gas Velocity
Volumetric Flow Rate, Wet Basis
Volumetric Flow Rate, at Standard Conditions, Dry Basis
Isokinetic Sampling Rate
CONDITION:
TEST RUN:
Value
6.80
0.00
10.00
83.20
30.11
0.18
1.56
601.1
554.8
410.5
81.140
0.987
0.4593
0.84
42.00
29.488
27.180
30.12
30.22
76.981
19.355
0.2009
20.09
9.62
28.26
16311.7
11526.1
100.86
NORMAL
ONE
Units
% Volume
% Volume
% Volume
% Volume
in. Hg
in. H2O
in. H2O
°R
°R
grams
dcf
Dimensionless
in. H2005
Dimensionless
in.
Ib/lb-mole
Ib/lb-mole
in. Hg
in. Hg
dscf
scf
mole fraction
% Volume
ft2
ft/sec
cfm
dscfm
%
Flows
6-C-6
-------
COMPANY:
LOCATION:
SOURCE:
Variable
I
Ts
Vmstd
Vs
T
An
Ps
Dn
Vlcg
Pi
Kl
K2
K3
K4
K5
Variable
Vmstd =
Vs =
Vlcg =
Ts =
An
An
T
ISOKINETIC SAMPLING DETERMINATION
XYZ COMPANY CONDITION: NORMAL
ANYWHERE, USA TEST RUN: ONE
BIF UNIT
VARIABLE LIST
Units
Isokinetic Sampling Rate %
Average Stack Gas Temperature °R
Dry Gas Meter Sample Volume, at Standard Conditions dscf
Stack Gas Velocity ft/sec
Sampling Time Duration minutes
Cross-Sectional Area of Nozzle ft
Absolute Stack Gas Pressure in. Hg
Nozzle Diameter in.
Total Condensate Collected grams
Constant (3.1416) dimensionless
Conversion Factor (144) in /ft
Conversion Factor (100) Percent
Conversion Factor (17.64) °R/in. Hg
Conversion Factor (0.002669) Hg-ft3/ml-°R
Conversion Factor (60) sec/min
TEST DATA
Data Variable Data Variable Data
76.981 Ps= 30.12 K2 = 100
28.26 T= 120.0 K3 = 17.64
410.5 Dn= 0.312 K4= 0.002669
601.1 Kl = 144 K5= 60
CALCULATIONS
(Pi)(Dn)-2/[(4)(Kl)]
(3.1416)(0.312)A2/[(4)(144)] = 0.000531 ft2
(K2)(Ts)[(Vmstd/K3) + (K4)(Vlcg)]
(K5)(Vs)(An)(Ps)(T)
(100)(601.1)[(76.98 1/17.64) + (0.002669)(410.50)]
1 on s^ %
(60)(28.26)(0.000531)(30.12)(120.0)
Flows
6-C-7
-------
How to Use the Method 0050 Raw Data Calculation Workbook
The Method 0050 calculation worksheet was written in Excel. The workbook is comprised of three separate
worksheets as follows:
1) Determination of stack gas flow rate parameters and percent isokinetic (Flows)
2) Determination of hydrogen chloride and chlorine mass emission rates (HC1-C12)
3) Determination of participate matter mass emission rate (PM)
The workbook has been protected so that calculations and measurement units associated with each parameter
cannot be mistakenly changed by the user. Significient figures for input information and calculation results
have been considered and the cells have been formatted to satisfy this requirement. Calculation results that
are used in subsequent pages and/or worksheets automatically carry forward in the workbook. Thus, it is
imperative that all red colored input information is inserted in the specified order.
The font style and size have been configured for Times New Roman 10-point. The workbook will print
from most popular HP laser jet printers.
Steps to Use the Method 0050 Workbook
The three worksheets of this workbook must be used in the following order.
Flows Worksheet (Flows)
1) Obtain raw stack test field data and verify/compute average values.
2) Enter plant, location, unit, test condition, and run number. The fields for this information are red
colored.
3) Input raw field data on page 1. Some of this information will be averaged raw test data, equipment
calibration coefficients, and/or single point measurement values. The fields for this information are
red colored.
4) Review and/or print worksheet.
5) A summary of the key input and results data is contained on page 5.
HC1-C12 Worksheet (HC1-C12)
1) Obtain raw laboratory data.
2) Input HC1 and C12 mass in milligrams on page 1. The fields for this information are red colored.
3) Review and/or print worksheet.
4) The results are contained on page 2
PM Worksheet (PM)
1) Obtain raw laboratory data.
2) Input probe wash, filter, and acetone rinse raw data. The fields for this information are red colored.
3) Review and/or print worksheet.
4) The results are contained on page 2.
6-C-8
-------
RAW DATA INPUT
FOR
HYDROGEN CHLORIDE AND CHLORINE EMISSION CALCULATIONS
Plant Name: XYZ COMPANY
Location: ANYWHERE, USA
Unit: BIF UNIT
Condition: NORMAL
Run No. ONE
Variable
Definition
Data
Units
Cm
Cn
Hydrogen Chloride Concentration
Chlorine Concentration
45.40 mg
62.00 mg
HCL-CL2
6-C-9
-------
HYDROGEN CHLORIDE AND CHLORINE EMISSION RATE CALCULATIONS
COMPANY:
LOCATION:
SOURCE:
Variable
Em
En
Vmstd
Cm
Cn
Qsd
Kl
K2
K3
XYZ COMPANY CONDITION:
ANYWHERE, USA TEST RUN:
BIF UNIT
VARIABLE LIST
Definition
Hydrogen Chloride Mass Emission Rate
Chlorine Mass Emission Rate
Dry Gas Meter Sample Volume, at Standard Conditions
Hydrogen Chloride Concentration
Chlorine Concentration
Volumetric Flow Rate, at Standard Conditions, Dry Basis
Conversion Factor (60)
Conversion Factor (0.002205)
Conversion Factor (1000)
NORMAL
ONE
Units
Ib/hr
Ib/hr
dscf
mg
mg
dscfin
min/hour
Ib/g
mg/g
TEST DATA
Variable Data Variable Data
Vmstd= 76.981 Qsd = 11,526.1
Cm= 45.40 Cn= 62.00
CALCULATIONS
Em
En
(Cm)(Qsd)(Kl)(K2) (45.40)(11526.1)(60)(0.002205)
(Vmstd)(K3) (76.981)(1000)
0.90 Ib/hr
(Cn)(Qsd)(Kl)(K2) (62.00)(11526.1)(60)(0.002205)
(Vmstd)(K3) (76.981)(1000)
1.23 Ib/hr
HCL-CL2
6-C-10
-------
How to Use the Methods 0012 and 0060 Raw Data Calculation Workbook
The Methods 0012 and 0060 calculation worksheet was written in Excel. The workbook is comprised of
three separate worksheets as follows:
1) Determination of stack gas flow rate parameters and percent isokinetic (Flows)
2) Determination of metal constituents mass emission rates (Metal)
3) Determination of particulate matter mass emission rate (PM)
The workbook has been protected so that calculations and measurement units associated with each parameter
cannot be mistakenly changed by the user. Significient figures for input information and calculation results
have been considered and the cells have been formatted to satisfy this requirement. Calculation results that
are used in subsequent pages and/or worksheets automatically carry forward in the workbook. Thus, it is
imperative that all red colored input information is inserted in the specified order.
The font style and size have been configured for Times New Roman 10-point. The workbook will print
from most popular HP laser jet printers.
Steps to Use the Methods 0012 and 0060 Workbook
The three worksheets of this workbook must be used in the following order.
Flows Worksheet (Flows)
1) Obtain raw stack test field data and verify/compute average values.
2) Enter plant, location, unit, test condition, and run number. The fields for this information are red
colored.
3) Input raw field data on page 1. Some of this information will be averaged raw test data, equipment
calibration coefficients, and/or single point measurement values. The fields for this information are
red colored.
4) Review and/or print worksheet.
5) A summary of the key input and results data is contained on page 5.
Metals Worksheet (Metal)
1) Obtain raw laboratory data.
2) Input metals mass in micrograms on page 1 (total concentration from all sample train subsamples).
A cell
is available for the "<" symbol when the minimum detection limit is used for the value. The fields
for this information are red colored.
3) Review and/or print worksheet.
4) The results begin on page 2.
PM Worksheet (PM)
1) Obtain raw laboratory data.
2) Input probe wash, filter, and acetone rinse raw data. The fields for this information are red colored.
3) Review and/or print worksheet.
4) The results are contained on page 2.
6-C-ll
-------
RAW DATA INPUT
FOR
EPA METHODS 0012 AND 0060 FLOW RATE CALCULATIONS
Plant Name:
Location:
Unit:
Condition:
Run No.
Variable Definition
Po - Average Meter Differential Pressure
Pb - Barometric Pressure
Tm - Average Dry Gas Meter Temperature
DGMC - Dry Gas Meter Correction Factor
Vlcg - Total Condensate Collected
Vm - Dry Gas Meter Sample Volume
T - Sampling Time Duration
%CO2 - Carbon Dioxide Concentration, Dry Basis
%O2 - Oxygen Concentration, Dry Basis
%CO - Carbon Monoxide Concentration, Dry Basis
Dn - Nozzle Diameter
Cp - Pilot Tube Coefficient
Dp - Avg. Sq. Root of Velocity Head
Ts - Average Stack Gas Temperature
Sp - Static Pressure of Gas Stream
D - Stack Diameter
XYZ COMPANY
ANYWHERE, USA
BIF UNIT
NORMAL
ONE
Data Units
1.56 in. H2O
30.11 in. Hg
94.790 °F
0.987 Dimensionless
410.5 grams
81.140 dcf
120.0 min
6.80 % Volume
10.00 % Volume
0.00 % Volume
0.3120 in.
0. 84 Dimensionless
0.4593 in. H2O05
141.1 °F
0.18 in. H20
42.00 in.
Flows
6-C-12
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Pm
Po
Pstd
Pb
Kl
K2
Tm
Tstd
DGMC
Vlcg
Vm
Vmstd
Vwstd
Bws
Bwd
Pm
Vwstd =
Bwd
MOISTURE CONTENT AND SAMPLE VOLUME CORRECTION CALCULATIONS
XYZ COMPANY CONDITION: NORMAL
ANYWHERE, USA TEST RUN: ONE
BIF UNIT
VARIABLE LIST
Definition Units
Absolute Dry Gas Meter Pressure in. Hg
Average Meter Differential Pressure in. H2O
Absolute Standard Pressure (29.92) in. Hg
Barometric Pressure in. Hg
Conversion Factor (13. 6) in. H2O/in. Hg
Standard Volume H2O Vapor/Unit Weight Liquid (0.04715) ft3/g
Average Dry Gas Meter Temperature °R
Absolute Standard Temperature (528) °R
Dry Gas Meter Correction Factor Dimensionless
Total Condensate Collected grams
Dry Gas Meter Sample Volume dcf
Dry Gas Meter Sample Volume, at Standard Conditions dscf
Volume of Water Vapor Collected, at Standard Conditions scf
Moisture Content mole fraction
Moisture Content % Volume
TEST DATA
Variable Data Variable Data
Pb= 30.11 Tm= 554.8
Vm= 81.140 Po= 1.56
Vlcg= 410.5 DGMC= 0.987
CALCULATIONS
Pb + (Po/Kl) = 30.11 +(1.56/13.6) = 30.22 in. Hg
(Vm)(DGMC)(Pm)(Tstd) (81.140)(0.987)(30.22)(528)
7/: gel H«rf
(Pstd)(Tm) (29.92)(554.8)
(K2)(Vlcg) = (0.04715)(410.5) = 19.355 scf
(Vwstd) 19.355
0 2009
(Vwstd) + (Vmstd) (19.355)+(76.981)
(Bws)(100%) = (0.2009)(100%) = 20.09 % Volume
Flows
6-C-13
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Md
Ms
Bws
%CO2
%CO
%02
%N2
0.32
0.28
0.28
0.44
18.0
MOLECULAR WEIGHT DETERMINATION
XYZ COMPANY CONDITION:
ANYWHERE, USA TEST RUN:
BIF UNIT
VARIABLE LIST
Definition
Sample Gas Molecular Weight, Dry Basis
Sample Gas Molecular Weight, Wet Basis
Moisture Content
Carbon Dioxide Concentration, Dry Basis
Carbon Monoxide Concentration, Dry Basis
Oxygen Concentration, Dry Basis
Nitrogen Concentration, Dry Basis (gas balance)
Molecular Weight of Oxygen, divided by 100%
Molecular Weight of Carbon Monoxide, divided by 100%
Molecular Weight of Nitrogen, divided by 100%
Molecular Weight of Carbon Dioxide, divided by 100%
Molecular Weight of Water
NORMAL
ONE
Units
Ib/lb-mole
Ib/lb-mole
mole fraction
% Volume
% Volume
% Volume
% Volume
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
TEST DATA
Variable Data Variable Data
Bws= 0.2009 %CO= 0.00
%N2= 83.20 %C02= 6.80
%O2 = 10.00
CALCULATIONS
Md
Md
Md
Ms
Ms
Ms
(0.44)(%CO2) + (0.32)(%O2) + (0.28)(%N2 + %CO)
(0.44)(6.80) + (0.32)(10.00) + (0.28)(83.20 + 0.00)
29.488 Ib/lb-mol
(Md)(l - Bws) + (18.0)(Bws)
(29.488)(1 - 0.2009) + (18.0)(0.2009)
27.180 Ib/lb-mol
Flows
6-C-14
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Cp
Vs
Qsd
Qact
Bws
Dp
Pb
Kp
Ts
Ms
Sp
Tstd
Pstd
CSA
Ps
Kl
K2
Pi
D
Ps
Vs
Vs
CSA
Qact
Qsd ~
Qsd
VELOCITY AND VOLUMETRIC FLOW RATE DETERMINATION
XYZ COMPANY CONDITION:
ANYWHERE, USA TEST RUN:
BIF UNIT
VARIABLE LIST
Definition
Pilot Tube Coefficient
Stack Gas Velocity
Volumetric Flow Rate at Standard Conditions, Dry Basis
Volumetric Flow Rate, Wet Basis
Moisture Content
Avg. Sq. Root of Velocity Head
Barometric Pressure
Constant = 85.49 (ft)(lb/lb-mol)(in.HgA0.5)/(s)(°R)(in.H2O)
Average Stack Gas Temperature
Sample Gas Molecular Weight, Wet Basis
Static Pressure of Gas Stream
Absolute Standard Temperature (528)
Absolute Standard Pressure (29.92)
Stack Cross-Sectional Area
Absolute Stack Gas Pressure
Conversion Factor (13.6)
Conversion Factor (60)
Constant (3. 1416)
Stack Diameter
TEST DATA
Variable Data Variable Data
Ms = 27.180 Dp = 0.4593
Bws= 0.2009 Pb = 30.11
Sp = 0.18 Ts = 601.1
CALCULATIONS
Pb + (Sp/Kl) = 30.11 +(0.18/13.6) =
(Kp)(Cp)(Dp)[(Ts)/(Ms)(Ps)r0.5
(85.49)(0.84)(0.4593)[601.1/(27.180)(30.12)]A0.5 = 28.26
(Pi)(D-2)/[(4)(144)] = (3.1416)(42.00r2/[(4)(144)] =
(Vs)(CSA)(K2) = (28.26)(9.62)(60) = 16311.7
(Qact)(l-Bws)(Tstd)(Ps) (1631 1.7)(1 - 0.2009)(528)(30. 12)
(Ts)(Pstd) (601.1)(29.92)
11526.1 dscfm
NORMAL
ONE
Units
Dimensionless
ft/sec
dscfm
cfm
mole fraction
in. H2005
in. Hg
°R
Ib/lb-mole
in. H20
°R
in. Hg
ft2
in. Hg
in. H2O/in. Hg
sec/min
Dimensionless
in.
Variable Data
Cp = 0.84
D = 42.00
30.12 in. Hg
ft/sec
9.62 ft2
cfm
Flows
6-C-15
-------
COMPANY:
LOCATION:
SOURCE:
Variable
%C02
%co
%O2
%N2
Pb
Sp
Po
Ts
Tm
Vlcg
Vm
DGMC
Dp
Cp
D
Md
Ms
Ps
Pm
Vmstd
Vwstd
Bws
Bwd
CSA
Vs
Qact
Qsd
I
FLOW RATE DATA SUMMARY
XYZ COMPANY
ANYWHERE, USA
BIF UNIT
VARIABLE LIST
Definition
INPUT DATA SUMMARY
Carbon Dioxide Concentration, Dry Basis
Carbon Monoxide Concentration, Dry Basis
Oxygen Concentration, Dry Basis
Nitrogen Concentration, Dry Basis (gas balance)
Barometric Pressure
Static Pressure of Gas Stream
Average Meter Differential Pressure
Average Stack Gas Temperature
Average Dry Gas Meter Temperature
Total Condensate Collected
Dry Gas Meter Sample Volume
Dry Gas Meter Correction Factor
Avg. Sq. Root of Velocity Head
Pilot Tube Coefficient
Stack Diameter
RESULTS SUMMARY
Sample Gas Molecular Weight, Dry Basis
Sample Gas Molecular Weight, Wet Basis
Absolute Stack Gas Pressure
Absolute Dry Gas Meter Pressure
Dry Gas Meter Sample Volume, at Standard Conditions
Volume of Water Vapor Collected, at Standard Conditions
Moisture Content
Moisture Content
Stack Cross-Sectional Area
Stack Gas Velocity
Volumetric Flow Rate, Wet Basis
Volumetric Flow Rate, at Standard Conditions, Dry Basis
Isokinetic Sampling Rate
CONDITION:
TEST RUN:
Value
6.80
0.00
10.00
83.20
30.11
0.18
1.56
601.1
554.8
410.5
81.140
0.987
0.4593
0.84
42.00
29.488
27.180
30.12
30.22
76.981
19.355
0.2009
20.09
9.62
28.26
16311.7
11526.1
100.86
NORMAL
ONE
Units
% Volume
% Volume
% Volume
% Volume
in. Hg
in. H2O
in. H2O
°R
°R
grams
dcf
Dimensionless
in. H2005
Dimensionless
in.
Ib/lb-mole
Ib/lb-mole
in. Hg
in. Hg
dscf
scf
mole fraction
% Volume
ft2
ft/sec
cfm
dscfm
%
Flows
6-C-16
-------
COMPANY:
LOCATION:
SOURCE:
Variable
I
Ts
Vmstd
Vs
T
An
Ps
Dn
Vlcg
Pi
Kl
K2
K3
K4
K5
Variable
Vmstd =
Vs =
Vlcg =
Ts =
An
An
T
ISOKINETIC SAMPLING DETERMINATION
XYZ COMPANY CONDITION: NORMAL
ANYWHERE, USA TEST RUN: ONE
BIF UNIT
VARIABLE LIST
Units
Isokinetic Sampling Rate %
Average Stack Gas Temperature °R
Dry Gas Meter Sample Volume, at Standard Conditions dscf
Stack Gas Velocity ft/sec
Sampling Time Duration minutes
Cross-Sectional Area of Nozzle ft
Absolute Stack Gas Pressure in. Hg
Nozzle Diameter in.
Total Condensate Collected grams
Constant (3.1416) dimensionless
Conversion Factor (144) in /ft
Conversion Factor (100) Percent
Conversion Factor (17.64) °R/in. Hg
Conversion Factor (0.002669) Hg-ft3/ml-°R
Conversion Factor (60) sec/min
TEST DATA
Data Variable Data Variable Data
76.981 Ps= 30.12 K2 = 100
28.26 T= 120.0 K3 = 17.64
410.5 Dn= 0.312 K4= 0.002669
601.1 Kl = 144 K5= 60
CALCULATIONS
(Pi)(Dn)-2/[(4)(Kl)]
(3.1416)(0.312)A2/[(4)(144)] = 0.000531 ft2
(K2)(Ts)[(Vmstd/K3) + (K4)(Vlcg)]
(K5)(Vs)(An)(Ps)(T)
(100)(601.1)[(76.98 1/17.64) + (0.002669)(410.50)]
1 on s^ %
(60)(28.26)(0.000531)(30.12)(120.0)
Flows
6-C-17
-------
How to Use the Methods 0013 and 0061 (Chrome+6) Raw Data Calculation Workbook
The Methods 0013 and 0061calculation worksheet was written in Excel. The workbook is comprised of two
separate worksheets as follows:
1) Determination of stack gas flow rate parameters and percent isokinetic (Flows)
2) Determination of Chrome+6 mass emission rates (Chrome+6)
The workbook has been protected so that calculations and measurement units associated with each parameter
cannot be mistakenly changed by the user. Significient figures for input information and calculation results
have been considered and the cells have been formatted to satisfy this requirement. Calculation results that
are used in subsequent pages and/or worksheets automatically carry forward in the workbook. Thus, it is
imperative that all red colored input information is inserted in the specified order.
The font style and size have been configured for Times New Roman 10-point. The workbook will print
from most popular HP laser jet printers.
Steps to Use the Method Chrome+6 Workbook
The two worksheets of this workbook must be used in the following order.
Flows Worksheet (Flows)
1) Obtain raw stack test field data and verify/compute average values.
2) Enter plant, location, unit, test condition, and run number. The fields for this information are red
colored.
3) Input raw field data on page 1. Some of this information will be averaged raw test data, equipment
calibration coefficients, and/or single point measurement values. The fields for this information are
red colored.
4) Review and/or print worksheet.
5) A summary of the key input and results data is contained on page 5.
Chrome+6 Worksheet (Chrome+6)
1) Obtain raw laboratory data.
2) Input Chrome+6 mass in micrograms on page 1 (total concentration of all sample train subsamples).
A cell is available for the "<" symbol when the minimum detection limit is used for the value.
The fields for this information are red colored.
3) Review and/or print worksheet.
4) The results are presented at the bottom of page 1.
6-C-18
-------
RAW DATA INPUT
FOR
EPA METHODS 0013 AND 0061
Plant Name:
Location:
Unit:
Condition:
Run No.
Variable Definition
Po - Average Meter Differential Pressure
Pb - Barometric Pressure
Tm - Average Dry Gas Meter Temperature
DGMC - Dry Gas Meter Correction Factor
Vlcg - Total Condensate Collected
Vm - Dry Gas Meter Sample Volume
T - Sampling Time Duration
%CO2 - Carbon Dioxide Concentration, Dry Basis
%O2 - Oxygen Concentration, Dry Basis
%CO - Carbon Monoxide Concentration, Dry Basis
Dn - Nozzle Diameter
Cp - Pilot Tube Coefficient
Dp - Avg. Sq. Root of Velocity Head
Ts - Average Stack Gas Temperature
Sp - Static Pressure of Gas Stream
D - Stack Diameter
FLOW RATE CALCULATIONS
XYZ COMPANY
ANYWHERE, USA
BIF UNIT
NORMAL
ONE
Data Units
1.56 in. H2O
30.11 in. Hg
94.790 °F
0.987 Dimensionless
410.5 grams
81.140 dcf
120.0 min
6.80 % Volume
10.00 % Volume
0.00 % Volume
0.3120 in.
0. 84 Dimensionless
0.4593 in. H2O05
141.1 °F
0.18 in. H20
42.00 in.
Flows
6-C-19
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Pm
Po
Pstd
Pb
Kl
K2
Tm
Tstd
DGMC
Vlcg
Vm
Vmstd
Vwstd
Bws
Bwd
Pm
Vwstd =
Bwd
MOISTURE CONTENT AND SAMPLE VOLUME CORRECTION CALCULATIONS
XYZ COMPANY CONDITION: NORMAL
ANYWHERE, USA TEST RUN: ONE
BIF UNIT
VARIABLE LIST
Definition Units
Absolute Dry Gas Meter Pressure in. Hg
Average Meter Differential Pressure in. H2O
Absolute Standard Pressure (29.92) in. Hg
Barometric Pressure in. Hg
Conversion Factor (13. 6) in. H2O/in. Hg
Standard Volume H2O Vapor/Unit Weight Liquid (0.04715) ft3/g
Average Dry Gas Meter Temperature °R
Absolute Standard Temperature (528) °R
Dry Gas Meter Correction Factor Dimensionless
Total Condensate Collected grams
Dry Gas Meter Sample Volume dcf
Dry Gas Meter Sample Volume, at Standard Conditions dscf
Volume of Water Vapor Collected, at Standard Conditions scf
Moisture Content mole fraction
Moisture Content % Volume
TEST DATA
Variable Data Variable Data
Pb= 30.11 Tm= 554.8
Vm= 81.140 Po= 1.56
Vlcg= 410.5 DGMC= 0.987
CALCULATIONS
Pb + (Po/Kl) = 30.11 +(1.56/13.6) = 30.22 in. Hg
(Vm)(DGMC)(Pm)(Tstd) (81.140)(0.987)(30.22)(528)
7/: gel H«rf
(Pstd)(Tm) (29.92)(554.8)
(K2)(Vlcg) = (0.04715)(410.5) = 19.355 scf
(Vwstd) 19.355
0 2009
(Vwstd) + (Vmstd) (19.355)+(76.981)
(Bws)(100%) = (0.2009)(100%) = 20.09 % Volume
Flows
6-C-20
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Md
Ms
Bws
%CO2
%CO
%02
%N2
0.32
0.28
0.28
0.44
18.0
MOLECULAR WEIGHT DETERMINATION
XYZ COMPANY CONDITION:
ANYWHERE, USA TEST RUN:
BIF UNIT
VARIABLE LIST
Definition
Sample Gas Molecular Weight, Dry Basis
Sample Gas Molecular Weight, Wet Basis
Moisture Content
Carbon Dioxide Concentration, Dry Basis
Carbon Monoxide Concentration, Dry Basis
Oxygen Concentration, Dry Basis
Nitrogen Concentration, Dry Basis (gas balance)
Molecular Weight of Oxygen, divided by 100%
Molecular Weight of Carbon Monoxide, divided by 100%
Molecular Weight of Nitrogen, divided by 100%
Molecular Weight of Carbon Dioxide, divided by 100%
Molecular Weight of Water
NORMAL
ONE
Units
Ib/lb-mole
Ib/lb-mole
mole fraction
% Volume
% Volume
% Volume
% Volume
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
TEST DATA
Variable Data Variable Data
Bws= 0.2009 %CO= 0.00
%N2= 83.20 %C02= 6.80
%O2 = 10.00
CALCULATIONS
Md
Md
Md
Ms
Ms
Ms
(0.44)(%CO2) + (0.32)(%O2) + (0.28)(%N2 + %CO)
(0.44)(6.80) + (0.32)(10.00) + (0.28)(83.20 + 0.00)
29.488 Ib/lb-mol
(Md)(l - Bws) + (18.0)(Bws)
(29.488)(1 - 0.2009) + (18.0)(0.2009)
27.180 Ib/lb-mol
Flows
6-C-21
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Cp
Vs
Qsd
Qact
Bws
Dp
Pb
Kp
Ts
Ms
Sp
Tstd
Pstd
CSA
Ps
Kl
K2
Pi
D
Ps
Vs
Vs
CSA
Qact
Qsd ~
Qsd
VELOCITY AND VOLUMETRIC FLOW RATE DETERMINATION
XYZ COMPANY CONDITION:
ANYWHERE, USA TEST RUN:
BIF UNIT
VARIABLE LIST
Definition
Pilot Tube Coefficient
Stack Gas Velocity
Volumetric Flow Rate at Standard Conditions, Dry Basis
Volumetric Flow Rate, Wet Basis
Moisture Content
Avg. Sq. Root of Velocity Head
Barometric Pressure
Constant = 85.49 (ft)(lb/lb-mol)(in.HgA0.5)/(s)(°R)(in.H2O)
Average Stack Gas Temperature
Sample Gas Molecular Weight, Wet Basis
Static Pressure of Gas Stream
Absolute Standard Temperature (528)
Absolute Standard Pressure (29.92)
Stack Cross-Sectional Area
Absolute Stack Gas Pressure
Conversion Factor (13.6)
Conversion Factor (60)
Constant (3. 1416)
Stack Diameter
TEST DATA
Variable Data Variable Data
Ms = 27.180 Dp = 0.4593
Bws= 0.2009 Pb = 30.11
Sp = 0.18 Ts = 601.1
CALCULATIONS
Pb + (Sp/Kl) = 30.11 +(0.18/13.6) =
(Kp)(Cp)(Dp)[(Ts)/(Ms)(Ps)r0.5
(85.49)(0.84)(0.4593)[601.1/(27.180)(30.12)]A0.5 = 28.26
(Pi)(D2)/[(4)(144)] = (3.1416)(42.00r2/[(4)(144)] =
(Vs)(CSA)(K2) = (28.26)(9.62)(60) = 16311.7
(Qact)(l-Bws)(Tstd)(Ps) (1631 1.7)(1 - 0.2009)(528)(30. 12)
(Ts)(Pstd) (601.1)(29.92)
11526.1 dscfm
NORMAL
ONE
Units
Dimensionless
ft/sec
dscfm
cfm
mole fraction
in. H2005
in. Hg
°R
Ib/lb-mole
in. H20
°R
in. Hg
ft2
in. Hg
in. H2O/in. Hg
sec/min
Dimensionless
in.
Variable Data
Cp = 0.84
D = 42.00
30.12 in. Hg
ft/sec
9.62 ft2
cfm
Flows
6-C-22
-------
COMPANY:
LOCATION:
SOURCE:
Variable
%C02
%co
%O2
%N2
Pb
Sp
Po
Ts
Tm
Vlcg
Vm
DGMC
Dp
Cp
D
Md
Ms
Ps
Pm
Vmstd
Vwstd
Bws
Bwd
CSA
Vs
Qact
Qsd
I
FLOW RATE DATA SUMMARY
XYZ COMPANY
ANYWHERE, USA
BIF UNIT
VARIABLE LIST
Definition
INPUT DATA SUMMARY
Carbon Dioxide Concentration, Dry Basis
Carbon Monoxide Concentration, Dry Basis
Oxygen Concentration, Dry Basis
Nitrogen Concentration, Dry Basis (gas balance)
Barometric Pressure
Static Pressure of Gas Stream
Average Meter Differential Pressure
Average Stack Gas Temperature
Average Dry Gas Meter Temperature
Total Condensate Collected
Dry Gas Meter Sample Volume
Dry Gas Meter Correction Factor
Avg. Sq. Root of Velocity Head
Pilot Tube Coefficient
Stack Diameter
RESULTS SUMMARY
Sample Gas Molecular Weight, Dry Basis
Sample Gas Molecular Weight, Wet Basis
Absolute Stack Gas Pressure
Absolute Dry Gas Meter Pressure
Dry Gas Meter Sample Volume, at Standard Conditions
Volume of Water Vapor Collected, at Standard Conditions
Moisture Content
Moisture Content
Stack Cross-Sectional Area
Stack Gas Velocity
Volumetric Flow Rate, Wet Basis
Volumetric Flow Rate, at Standard Conditions, Dry Basis
Isokinetic Sampling Rate
CONDITION:
TEST RUN:
Value
6.80
0.00
10.00
83.20
30.11
0.18
1.56
601.1
554.8
410.5
81.140
0.987
0.4593
0.84
42.00
29.488
27.180
30.12
30.22
76.981
19.355
0.2009
20.09
9.62
28.26
16311.7
11526.1
100.86
NORMAL
ONE
Units
% Volume
% Volume
% Volume
% Volume
in. Hg
in. H2O
in. H2O
°R
°R
grams
dcf
Dimensionless
in. H2005
Dimensionless
in.
Ib/lb-mole
Ib/lb-mole
in. Hg
in. Hg
dscf
scf
mole fraction
% Volume
ft2
ft/sec
cfm
dscfm
%
Flows
6-C-23
-------
COMPANY:
LOCATION:
SOURCE:
Variable
I
Ts
Vmstd
Vs
T
An
Ps
Dn
Vlcg
Pi
Kl
K2
K3
K4
K5
Variable
Vmstd =
Vs =
Vlcg =
Ts =
An
An
T
ISOKINETIC SAMPLING DETERMINATION
XYZ COMPANY CONDITION: NORMAL
ANYWHERE, USA TEST RUN: ONE
BIF UNIT
VARIABLE LIST
Units
Isokinetic Sampling Rate %
Average Stack Gas Temperature °R
Dry Gas Meter Sample Volume, at Standard Conditions dscf
Stack Gas Velocity ft/sec
Sampling Time Duration minutes
Cross-Sectional Area of Nozzle ft
Absolute Stack Gas Pressure in. Hg
Nozzle Diameter in.
Total Condensate Collected grams
Constant (3.1416) dimensionless
Conversion Factor (144) in /ft
Conversion Factor (100) Percent
Conversion Factor (17.64) °R/in. Hg
Conversion Factor (0.002669) Hg-ft3/ml-°R
Conversion Factor (60) sec/min
TEST DATA
Data Variable Data Variable Data
76.981 Ps= 30.12 K2 = 100
28.26 T= 120.0 K3 = 17.64
410.5 Dn= 0.312 K4= 0.002669
601.1 Kl = 144 K5= 60
CALCULATIONS
(Pi)(Dn)-2/[(4)(Kl)]
(3.1416)(0.312)A2/[(4)(144)] = 0.000531 ft2
(K2)(Ts)[(Vmstd/K3) + (K4)(Vlcg)]
(K5)(Vs)(An)(Ps)(T)
(100)(601.1)[(76.98 1/17.64) + (0.002669)(410.50)]
1 on s^ %
(60)(28.26)(0.000531)(30.12)(120.0)
Flows
6-C-24
-------
How to Use the Methods 0023 and 0023A Raw Data Calculation Workbook
The Methods 0023 and 0023A calculation worksheet was written in Excel. The workbook is comprised of
two separate worksheets as follows:
1) Determination of stack gas flow rate parameters and percent isokinetic (Flows)
2) Determination of Dioxin/Furan mass emission rates (SVOC)
The workbook has been protected so that calculations and measurement units associated with each parameter
cannot be mistakenly changed by the user. Significient figures for input information and calculation results
have been considered and the cells have been formatted to satisfy this requirement. Calculation results that
are used in subsequent pages and/or worksheets automatically carry forward in the workbook. Thus, it is
imperative that all red colored input information is inserted in the specified order.
The font style and size have been configured for Times New Roman 10-point. The workbook will print
from most popular HP laser jet printers.
Steps to Use the Methods 0023 and 0023A Workbook
The two worksheets of this workbook must be used in the following order.
Flows Worksheet (Flows)
1) Obtain raw stack test field data and verify/compute average values.
2) Enter plant, location, unit, test condition, and run number. The fields for this information are red
colored.
3) Input raw field data on page 1. Some of this information will be averaged raw test data, equipment
calibration coefficients, and/or single point measurement values. The fields for this information are
red colored.
4) Review and/or print worksheet.
5) A summary of the key input and results data is contained on page 5.
Dioxin/Furan Worksheet (SVOC)
1) Obtain raw laboratory data.
2) Input Dioxin/Furan contstiuents mass in micrograms on page 1 (total concentration of each
constituent in all sample train subsamples). A cell is available for the "<" symbol when the
minimum detection limitis used for the value. The fields for this information are red colored.
3) Review and/or print worksheet.
4) The results begin on page 2.
6-C-25
-------
RAW DATA INPUT
FOR
EPA METHODS 0023 AND 0023A FLOW RATE CALCULATIONS
Plant Name:
Location:
Unit:
Condition:
Run No.
Variable Definition
Po - Average Meter Differential Pressure
Pb - Barometric Pressure
Tm - Average Dry Gas Meter Temperature
DGMC - Dry Gas Meter Correction Factor
Vlcg - Total Condensate Collected
Vm - Dry Gas Meter Sample Volume
T - Sampling Time Duration
%CO2 - Carbon Dioxide Concentration, Dry Basis
%O2 - Oxygen Concentration, Dry Basis
%CO - Carbon Monoxide Concentration, Dry Basis
Dn - Nozzle Diameter
Cp - Pilot Tube Coefficient
Dp - Avg. Sq. Root of Velocity Head
Ts - Average Stack Gas Temperature
Sp - Static Pressure of Gas Stream
D - Stack Diameter
XYZ COMPANY
ANYWHERE, USA
BIF UNIT
NORMAL
ONE
Data Units
1.56 in. H2O
30.11 in. Hg
94.790 °F
0.987 Dimensionless
410.5 grams
81.140 dcf
120.0 min
6.80 % Volume
10.00 % Volume
0.00 % Volume
0.3120 in.
0. 84 Dimensionless
0.4593 in. H2O05
141.1 °F
0.18 in. H20
42.00 in.
Flows
6-C-26
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Pm
Po
Pstd
Pb
Kl
K2
Tm
Tstd
DGMC
Vlcg
Vm
Vmstd
Vwstd
Bws
Bwd
Pm
Vwstd =
Bwd
MOISTURE CONTENT AND SAMPLE VOLUME CORRECTION CALCULATIONS
XYZ COMPANY CONDITION: NORMAL
ANYWHERE, USA TEST RUN: ONE
BIF UNIT
VARIABLE LIST
Definition Units
Absolute Dry Gas Meter Pressure in. Hg
Average Meter Differential Pressure in. H2O
Absolute Standard Pressure (29.92) in. Hg
Barometric Pressure in. Hg
Conversion Factor (13. 6) in. H2O/in. Hg
Standard Volume H2O Vapor/Unit Weight Liquid (0.04715) ft3/g
Average Dry Gas Meter Temperature °R
Absolute Standard Temperature (528) °R
Dry Gas Meter Correction Factor Dimensionless
Total Condensate Collected grams
Dry Gas Meter Sample Volume dcf
Dry Gas Meter Sample Volume, at Standard Conditions dscf
Volume of Water Vapor Collected, at Standard Conditions scf
Moisture Content mole fraction
Moisture Content % Volume
TEST DATA
Variable Data Variable Data
Pb= 30.11 Tm= 554.8
Vm= 81.140 Po= 1.56
Vlcg= 410.5 DGMC= 0.987
CALCULATIONS
Pb + (Po/Kl) = 30.11 +(1.56/13.6) = 30.22 in. Hg
(Vm)(DGMC)(Pm)(Tstd) (81.140)(0.987)(30.22)(528)
7/: gel H«rf
(Pstd)(Tm) (29.92)(554.8)
(K2)(Vlcg) = (0.04715)(410.5) = 19.355 scf
(Vwstd) 19.355
0 2009
(Vwstd) + (Vmstd) (19.355)+(76.981)
(Bws)(100%) = (0.2009)(100%) = 20.09 % Volume
Flows
6-C-27
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Md
Ms
Bws
%CO2
%CO
%02
%N2
0.32
0.28
0.28
0.44
18.0
MOLECULAR WEIGHT DETERMINATION
XYZ COMPANY CONDITION:
ANYWHERE, USA TEST RUN:
BIF UNIT
VARIABLE LIST
Definition
Sample Gas Molecular Weight, Dry Basis
Sample Gas Molecular Weight, Wet Basis
Moisture Content
Carbon Dioxide Concentration, Dry Basis
Carbon Monoxide Concentration, Dry Basis
Oxygen Concentration, Dry Basis
Nitrogen Concentration, Dry Basis (gas balance)
Molecular Weight of Oxygen, divided by 100%
Molecular Weight of Carbon Monoxide, divided by 100%
Molecular Weight of Nitrogen, divided by 100%
Molecular Weight of Carbon Dioxide, divided by 100%
Molecular Weight of Water
NORMAL
ONE
Units
Ib/lb-mole
Ib/lb-mole
mole fraction
% Volume
% Volume
% Volume
% Volume
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
Ib/lb-mole
TEST DATA
Variable Data Variable Data
Bws= 0.2009 %CO= 0.00
%N2= 83.20 %C02= 6.80
%O2 = 10.00
CALCULATIONS
Md
Md
Md
Ms
Ms
Ms
(0.44)(%CO2) + (0.32)(%O2) + (0.28)(%N2 + %CO)
(0.44)(6.80) + (0.32)(10.00) + (0.28)(83.20 + 0.00)
29.488 Ib/lb-mol
(Md)(l - Bws) + (18.0)(Bws)
(29.488)(1 - 0.2009) + (18.0)(0.2009)
27.180 Ib/lb-mol
Flows
6-C-28
-------
COMPANY:
LOCATION:
SOURCE:
Variable
Cp
Vs
Qsd
Qact
Bws
Dp
Pb
Kp
Ts
Ms
Sp
Tstd
Pstd
CSA
Ps
Kl
K2
Pi
D
Ps
Vs
Vs
CSA
Qact
Qsd ~
Qsd
VELOCITY AND VOLUMETRIC FLOW RATE DETERMINATION
XYZ COMPANY CONDITION:
ANYWHERE, USA TEST RUN:
BIF UNIT
VARIABLE LIST
Definition
Pilot Tube Coefficient
Stack Gas Velocity
Volumetric Flow Rate at Standard Conditions, Dry Basis
Volumetric Flow Rate, Wet Basis
Moisture Content
Avg. Sq. Root of Velocity Head
Barometric Pressure
Constant = 85.49 (ft)(lb/lb-mol)(in.HgA0.5)/(s)(°R)(in.H2O)
Average Stack Gas Temperature
Sample Gas Molecular Weight, Wet Basis
Static Pressure of Gas Stream
Absolute Standard Temperature (528)
Absolute Standard Pressure (29.92)
Stack Cross-Sectional Area
Absolute Stack Gas Pressure
Conversion Factor (13.6)
Conversion Factor (60)
Constant (3. 1416)
Stack Diameter
TEST DATA
Variable Data Variable Data
Ms = 27.180 Dp = 0.4593
Bws= 0.2009 Pb = 30.11
Sp = 0.18 Ts = 601.1
CALCULATIONS
Pb + (Sp/Kl) = 30.11 +(0.18/13.6) =
(Kp)(Cp)(Dp)[(Ts)/(Ms)(Ps)r0.5
(85.49)(0.84)(0.4593)[601.1/(27.180)(30.12)]A0.5 = 28.26
(Pi)(D-2)/[(4)(144)] = (3.1416)(42.00r2/[(4)(144)] =
(Vs)(CSA)(K2) = (28.26)(9.62)(60) = 16311.7
(Qact)(l-Bws)(Tstd)(Ps) (1631 1.7)(1 - 0.2009)(528)(30. 12)
(Ts)(Pstd) (601.1)(29.92)
11526.1 dscfm
NORMAL
ONE
Units
Dimensionless
ft/sec
dscfm
cfm
mole fraction
in. H2005
in. Hg
°R
Ib/lb-mole
in. H20
°R
in. Hg
ft2
in. Hg
in. H2O/in. Hg
sec/min
Dimensionless
in.
Variable Data
Cp = 0.84
D = 42.00
30.12 in. Hg
ft/sec
9.62 ft2
cfm
Flows
6-C-29
-------
COMPANY:
LOCATION:
SOURCE:
Variable
%C02
%co
%O2
%N2
Pb
Sp
Po
Ts
Tm
Vlcg
Vm
DGMC
Dp
Cp
D
Md
Ms
Ps
Pm
Vmstd
Vwstd
Bws
Bwd
CSA
Vs
Qact
Qsd
I
FLOW RATE DATA SUMMARY
XYZ COMPANY
ANYWHERE, USA
BIF UNIT
VARIABLE LIST
Definition
INPUT DATA SUMMARY
Carbon Dioxide Concentration, Dry Basis
Carbon Monoxide Concentration, Dry Basis
Oxygen Concentration, Dry Basis
Nitrogen Concentration, Dry Basis (gas balance)
Barometric Pressure
Static Pressure of Gas Stream
Average Meter Differential Pressure
Average Stack Gas Temperature
Average Dry Gas Meter Temperature
Total Condensate Collected
Dry Gas Meter Sample Volume
Dry Gas Meter Correction Factor
Avg. Sq. Root of Velocity Head
Pilot Tube Coefficient
Stack Diameter
RESULTS SUMMARY
Sample Gas Molecular Weight, Dry Basis
Sample Gas Molecular Weight, Wet Basis
Absolute Stack Gas Pressure
Absolute Dry Gas Meter Pressure
Dry Gas Meter Sample Volume, at Standard Conditions
Volume of Water Vapor Collected, at Standard Conditions
Moisture Content
Moisture Content
Stack Cross-Sectional Area
Stack Gas Velocity
Volumetric Flow Rate, Wet Basis
Volumetric Flow Rate, at Standard Conditions, Dry Basis
Isokinetic Sampling Rate
CONDITION:
TEST RUN:
Value
6.80
0.00
10.00
83.20
30.11
0.18
1.56
601.1
554.8
410.5
81.140
0.987
0.4593
0.84
42.00
29.488
27.180
30.12
30.22
76.981
19.355
0.2009
20.09
9.62
28.26
16311.7
11526.1
100.86
NORMAL
ONE
Units
% Volume
% Volume
% Volume
% Volume
in. Hg
in. H2O
in. H2O
°R
°R
grams
dcf
Dimensionless
in. H2005
Dimensionless
in.
Ib/lb-mole
Ib/lb-mole
in. Hg
in. Hg
dscf
scf
mole fraction
% Volume
ft2
ft/sec
cfm
dscfm
%
Flows
6-C-30
-------
COMPANY:
LOCATION:
SOURCE:
Variable
I
Ts
Vmstd
Vs
T
An
Ps
Dn
Vlcg
Pi
Kl
K2
K3
K4
K5
Variable
Vmstd =
Vs =
Vlcg =
Ts =
An
An
T
ISOKINETIC SAMPLING DETERMINATION
XYZ COMPANY CONDITION: NORMAL
ANYWHERE, USA TEST RUN: ONE
BIF UNIT
VARIABLE LIST
Units
Isokinetic Sampling Rate %
Average Stack Gas Temperature °R
Dry Gas Meter Sample Volume, at Standard Conditions dscf
Stack Gas Velocity ft/sec
Sampling Time Duration minutes
Cross-Sectional Area of Nozzle ft
Absolute Stack Gas Pressure in. Hg
Nozzle Diameter in.
Total Condensate Collected grams
Constant (3.1416) dimensionless
Conversion Factor (144) in /ft
Conversion Factor (100) Percent
Conversion Factor (17.64) °R/in. Hg
Conversion Factor (0.002669) Hg-ft3/ml-°R
Conversion Factor (60) sec/min
TEST DATA
Data Variable Data Variable Data
76.981 Ps= 30.12 K2 = 100
28.26 T= 120.0 K3 = 17.64
410.5 Dn= 0.312 K4= 0.002669
601.1 Kl = 144 K5= 60
CALCULATIONS
(Pi)(Dn)-2/[(4)(Kl)]
(3.1416)(0.312)A2/[(4)(144)] = 0.000531 ft2
(K2)(Ts)[(Vmstd/K3) + (K4)(Vlcg)]
(K5)(Vs)(An)(Ps)(T)
(100)(601.1)[(76.98 1/17.64) + (0.002669)(410.50)]
1 on s^ %
(60)(28.26)(0.000531)(30.12)(120.0)
Flows
6-C-31
-------
How to Use the Methods 0030 and 0031 Raw Data Calculation Workbook
The Methods 003 land 0030 calculation worksheet was written in Excel. The workbook is comprised of
two separate worksheets as follows:
1) Determination of sample gas volume, corrected to standard conditions (Flows)
2) Determination of volatile organic compound mass emission rates (VOC)
The workbook has been protected so that calculations and measurement units associated with each parameter
cannot be mistakenly changed by the user. Significient figures for input information and calculation results
have been considered and the cells have been formatted to satisfy this requirement. Calculation results that
are used in subsequent pages and/or worksheets automatically carry forward in the workbook. Thus, it is
imperative that all red colored input information is inserted in the specified order.
The font style and size have been configured for Times New Roman 10-point. The workbook will print
from most popular HP laser jet printers.
Steps to Use the Methods 0030 and 0031 Workbook
The two worksheets of this workbook must be used in the following order.
Sample Volume Worksheet (Flows)
1) Obtain raw stack test field data and verify/compute average values.
2) Enter plant, location, unit, test condition, and run number. The fields for this information are red
colored.
3) Input raw field data on page 1. Some of this information will be averaged raw test data, equipment
calibration coefficients, and/or single point measurement values. The fields for this information are
red colored.
4) Review and/or print worksheet.
5) The corrected sample volume is presented on page 2.
Volatile Organic Compound Worksheet (VOC)
1) Obtain raw laboratory data.
2) Input volatile organic contstiuents mass in micrograms on page 1 (total concentration of each
constituent in all sample train subsamples). A cell is available for the "<" symbol when the
minimum
detection limit is used for the value. The fields for this information are red colored.
3) Review and/or print worksheet.
4) The results begin on page 2.
6-C-32
-------
RAW DATA INPUT
FOR
EPA METHODS 0030 AND 0031 VOLATILE ORGANICS
PARAMETER LIST FROM SW-846 METHOD 8260A
Plant Name: XYZ COMPANY
Location: ANYWHERE, USA
Variable
Qsd
y-i
^Chlorom ethane
Cyinyl Chloride
y-i
^Bromomethane
y-i
^Chloro ethane
y-i
^Trichlorofluorom ethane
Cij-Dichloroethene
Ccarbon Disulfide
^Acetone
C]VIethylene Chloride
y-i
^trans-l^-Dichloroethene
Cij-Dichloroethane
Ccis-l,2-Dichloroethene
C Chloroform
Cl,2-Dichloroethane
Cyinyl Acetate
y-i
v-'2-Butanone
Ci,i,i-Trichloroethane
C-Carbon Tetrachloride
y-i
^Benzene
Clrichloroethene
y-i
^l^-Dichloropropane
y-i
^Bromodichloromethane
y-i
^cis-^S-Dichloropropene
y-i
^trans-^S-Dichloropropene
Ci,i,2-Trichloroethane
y-i
^Dibromochlorom ethane
y-i
^Bromoform
C4-Methyl-2-Pentanone
^Toluene
Cietrachloroethene
y-i
v-'2-Hexanone
y-i
^Chlorobenzene
CEthylbenzene
Cm-/p-Xylene
y-i
^o-Xylene
y-i
^Styrene
Ci,i,2,2-Tetrachloroethane
Unit: BIF UNIT
Condition: NORMAL
Run No. ONE
Definition
Volumetric Flow Rate, Dry Standard Conditions
Concentration of Chlorom ethane <
Concentration of Vinyl Chloride <
Concentration of Bromom ethane <
Concentration of Chloroethane <
Concentration of Trichlorofluorom ethane <
Concentration of 1,1-Dichloroethene <
Concentration of Carbon Disulfide <
Concentration of Acetone <
Concentration of Methylene Chloride <
Concentration of trans-l,2-Dichloroethene <
Concentration of 1,1-Dichloroethane <
Concentration of cis-l,2-Dichloroethene <
Concentration of Chloroform <
Concentration of 1,2-Dichloroethane <
Concentration of Vinyl Acetate <
Concentration of 2-Butanone <
Concentration of 1,1,1-Trichloroethane <
Concentration of Carbon Tetrachloride <
Concentration of Benzene <
Concentration of Trichloroethene <
Concentration of 1,2-Dichloropropane <
Concentration of Bromodichlorom ethane <
Concentration of cis-l,3-Dichloropropene <
Concentration of trans-l,3-Dichloropropene <
Concentration of 1,1,2-Trichloroethane <
Concentration of Dibromochlorom ethane <
Concentration of Bromoform <
Concentration of 4-Methyl-2-Pentanone <
Concentration of Toluene <
Concentration of Tetrachloroethene <
Concentration of 2-Hexanone <
Concentration of Chlorobenzene <
Concentration of Ethylbenzene <
Concentration of m-/p-Xylene <
Concentration of o-Xylene <
Concentration of Styrene <
Concentration of 1,1,2,2-Tetrachloroethane <
Data Units
42566.3 dscmi
2.0 ug
200.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
3.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
2.0 ug
VOC
6-C-33
-------
VARIABLE LIST
Kl
K2
Conversion Factor (1EE+06)
Conversion Factor (60)
ug/g
s/min
CALCULATIONS
Echloromethane
Eyinyl Chloride
ERr,
^•Trichlorofluorom ethane
Eij-Dichloroethene
Ecarbon Disulfidt
^Acetone
-Methylene Chloride
^•trans-l,2-Dichloroethene
Eij-Dichloroethane
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(
-------
Ecis-l,2-Dichloroethene
Echloroform
El,2-Dichloroethane
^•2-Butanone
Ei,i,i-Trichloroethane
^Carbon Tetrachloride
Errichloroethene
1,2-Dichloropropane
^Bromodichloromethane
^cis-l,3-Dichloropropene
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
Etrans-l,3-Dichloropropene
El,l,2-TrichloroeUiane
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
0.000018 g/sec
0.000018 g/sec
voc
6-C-35
-------
^Dibromochlorom ethane
E4-Methyl-2-Pentanone
Eroluene
Eretrachloroethene
^•2-Hexanone
^•Chlorobenzene
EEthylbenzene
^•m-/p-Xylene
^o-Xylene
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
0.000018 g/sec
Estyrene
-1,1,2,2-Tetrachloroethane
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(C)(Qsd)/(Vmstd)(Kl)(K2) =
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
(<2.0)(42566.3)
(76.701)(1EE+06)(60)
0.000018 g/sec
0.000018 g/sec
voc
6-C-36
------- |