Southern/USEPA-GHG-QAP-32
                                     June 2004
Test and Quality Assurance
Plan
Paques THIOPAQ and Shell-Paques Gas
Purification Technology
x>EPA
                  Prepared by:
         Greenhouse Gas Technology Center
            Southern Research Institute
   Under a Cooperative Agreement With
U.S. Environmental Protection Agency

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                                      EPA REVIEW NOTICE

This report has been peer and administratively reviewed by the  U.S. Environmental Protection Agency, and
approved for publication.  Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.

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                                             Southern/USEPA-GHG-QAP-32
                                                             June 2004
 Greenhouse Gas Technology Center
A U.S. EPA Sponsored Environmental Technology Verification ( ETr ) Organization
            Test and Quality Assurance Plan

    Paques THIOPAQ and Shell-Paques Gas Purification
                           Technology
                          Prepared by:
                  Greenhouse Gas Technology Center
                     Southern Research Institute
                         PO Box 13825
               Research Triangle Park, NC 27709  USA
                     Telephone: 919/806-3456
                          Reviewed by:
                      Natco Group, Inc.  ^
                     Shell Global Solutions. |E1
        U.S. EPA Office of Research and Development QA Team
                indicates comments are integrated into Test Plan

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         Greenhouse Gas Technology Center
        A U.S. EPA Sponsored Environmental Technology Verification (ET» ) Organization
                     Test and Quality Assurance Plan
  Paques THIOPAQ and Shell-Paques Gas Purification Technology
This  Test and Quality Assurance Plan has been reviewed and approved by the Greenhouse Gas
Technology Center Project Manager and Director, the U.S. EPA APPCD Project Officer, and the U.S.
EPA APPCD Quality Assurance Manager.
Timothy Hansen
Deputy Director
Greenhouse Gas Technology Center
Southern Research Institute
Date
David Kirchgessner
APPCD Project Officer
U.S. EPA
Date
William Chatterton
Project Manager
Greenhouse Gas Technology Center
Southern Research Institute
Date
Robert S. Wright
APPCD Quality Assurance Manager
U.S. EPA
Date
Ashley Williamson
Quality Assurance Manager
Greenhouse Gas Technology Center
Southern Research Institute
Date
Test Plan Final: June 2004

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                              TABLE OF CONTENTS
                                                                                 Page
Appendices    	iii
List of Figures  	iii
List of Tables   	iii
Acronyms/Abbreviations	iv
Distribution List	vi
1.0   INTRODUCTION.
     1.1   BACKGROUND	
     1.2   THIOPAQ AND SHELL-PAQUES SYSTEMS TECHNOLOGY DESCRIPTION	
          1.2.1  Paques THIOPAQ Process	
          1.2.2  Shell-Paques Process...
     1.3   PLANT DESCRIPTIONS AND SYSTEM INTEGRATION
          1.3.1  Host WPCF - (Paques THIOPAQ™)	
                                                                                   -1
                                                                                   -1
                                                                                   -2
                                                                                   -3
                                                                                   -4
                                                                                   -6
                                                                                   -6
          1.3.2  EncanaBantry - (Shell-Paques)	1-8
     1.4   PERFORMANCE VERIFICATION PARAMETERS	1-9
          1.4.1  Environmental Performance Parameters	1-10
          1.4.2  Operational Performance Parameters	1-10
          1.4.3  Shell-Paques Performance	1-11
     1.5.  ORGANIZATION	1-12
     1.6.  SCHEDULE	1-13

2.0   VERIFICATION APPROACH	2-1
     2.1   OVERVIEW	2-1
     2.2   ENVIRONMENTAL PERFORMANCE	2-3
          2.2.1  Air Emissions of Sulfur Compounds	2-3
          2.2.3  Sulfur in Liquid Effluent	2-6
     2.3   OPERATIONAL PERFORMANCE	2-7
          2.3.1  H2S Removal Efficiency and Gas Quality	2-7
          2.3.2  NaOH Consumption	2-9
          2.3.3  Solids and Elemental Sulfur Production	2-9
     2.4   PROCESS OPERATIONS MONITORING	2-10

3.0   DATA QUALITY	3-1
     3.1   BACKGROUND	3-1
     3.2   ENVIRONMENTAL PERFORMANCE PARAMETERS	3-1
     3.3   OPERATIONAL PERFORMANCE PARAMETERS	3-4
          3.3.1  H2S Removal Efficiency	3-4
     3.7   INSTRUMENT TESTING, INSPECTION, AND MAINTENANCE	3-6

4.0    DATA ACQUISITION, VALIDATION, AND REPORTING	1
     4.1   DATA ACQUISITION AND STORAGE	1
          4.1.2  Laboratory Analyses	1
     4.2   DATA REVIEW, VALIDATION, AND VERIFICATION	2
     4.3   RECONCILIATION OF DATA QUALITY OBJECTIVES	2
     4.4   ASSESSMENTS AND RESPONSE ACTIONS	3
          4.4.1  Project Reviews	3
          4.4.2  Technical Systems Audit	3
          4.4.3  Audit of Data Quality	4

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     4.5   DOCUMENTATION AND REPORTS	4
          4.5.1  Field Test Documentation	4
          4.5.2  QC Documentation	5
          4.5.3  Corrective Action and Assessment Reports	5
          4.5.4  Verification Report and Verification Statement	5
     4.6   TRAINING AND QUALIFICATIONS	6
     4.7   HEALTH AND SAFETY REQUIREMENTS	6

5.0   REFERENCES	1

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APPENDIX A
                    APPENDICES

Test Procedures and Field Log Forms ....
 Page
...A-l
Figure 1-1
Figure 1-2
Figure 1-3
Figure 2-1
                  LIST OF FIGURES
                                                               Page
THIOPAQ and Shell-Paques System Schematic	1-4
Typical THIOPAQ System	1-7
Project Organization	1-12
Schematic of Verification Boundary and Measurement Locations	2-3
                                    LIST OF TABLES
Table 1-1
Table 1-2
Table 2-1
Table 3-1
Table 3-2
Table 3-3
Table 3-4
Table 3-5
                                                                                 Pas
Host Site THIOPAQ™ Monitoring Instrumentation	1-8
Bantry Shell-Paques Sytem Design Cases	1-9
THIOPAQ and Shell-Paques Verification Test Matrix	2-2
Verification Reference Methods	3-1
Summary of Vent Air H2S Analyses QA/QC Checks	3-2
Summary of Effluent Sulfate Analyses QA/QC Checks	3-3
Summary of Effluent Sulfide Analyses QA/QC Checks	3-4
Summary of Biogas H2S Analyses QA/QC Checks	3-5
                                            in

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                              ACRONYMS/ABBREVIATIONS
Abs. Diff.
ADQ
ANSI
APPCD
ASME
ASTM
Btu
Btu/scf
Ci
CG+
CAR
CH4
°C
op
°R
DP
DQI
DQO
dscf/MMBtu
EPA
ETV
fps
ft3
gal
GC
GHG Center
gal/min
gal/day
hr
Ib
Ib/dscf
Ib/hr
Ib/yr
LHV
liters per minute
MMBtu/hr
MMcf
mol
NIST
02
ORD
PEA
ppbv
ppmv
ppmvd
absolute difference
Audit of Data Quality
American National Standards Institute
Air Pollution Prevention and Control Division
American Society of Mechanical Engineers
American Society for Testing and Materials
British thermal units
British thermal units per standard cubic foot
quantification of methane
hexanes plus
Corrective Action Report
methane
degrees Celsius
degrees Fahrenheit
degrees Rankine
differential pressure
data quality indicator
data quality objective
dry standard cubic feet per million British thermal units
Environmental Protection Agency
Environmental Technology Verification
feet per second
cubic feet
U.S. gallons
gas chromatograph
Greenhouse Gas Technology Center
gallons per minute
gallons per day
hour
pound
pounds per dry standard cubic foot
pounds per hour
pounds per year
lower heating value
1pm
million British thermal units per hour
million cubic feet
molecular
National Institute of Standards and Technology
oxygen
Office of Research and Development
Performance Evaluation Audit
parts per billion volume
parts per million volume
parts per million volume dry
                                             IV

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                               ACRONYMS/ABBREVIATIONS
                                         (continued)

psia                 pounds per square inch absolute
psig                 pounds per square inch gauge
QA/QC              Quality Assurance/Quality Control
QMP                Quality Management Plan
Rel. Diff.             relative difference
Report               Environmental Technology Verification Report
rms                  root mean square
scfh                 standard cubic feet per hour
scfm                 standard cubic feet per minute
scmd                standard cubic meter per day
Test Plan             Test and Quality Assurance Plan
TSA                 technical systems audit
U.S.                 United States
WPCF               Water Pollution Control Facilities

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                                  DISTRIBUTION LIST
Natco Group, Inc.
       Robert Curcio
       David Mirdadian
       Al Lanning
Shell Global Solutions
       Michael Golda
Paques
       Alex Benschop
U.S. EPA - Office of Research and Development
       David Kirchgessner
       Robert S. Wright
Southern Research Institute (GHG Center)
       Stephen Piccot
       Robert Richards
       William Chatterton
       Ashley Williamson
                                            VI

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                                  1.0      INTRODUCTION
1.1 BACKGROUND

The U.S. Environmental Protection Agency's Office of Research and Development (EPA-ORD) operates
the Environmental Technology Verification (ETV) program to facilitate the deployment of innovative
technologies through performance verification and information dissemination.   The goal of the ETV
program is to further environmental protection by substantially accelerating the acceptance and  use of
improved and innovative environmental technologies.  Congress funds ETV in response to the belief that
there are many viable environmental technologies that are not being used for the lack of credible third-
party  performance data.  With performance  data developed  under this program, technology buyers,
financiers,  and permitters  in the United States and abroad will be better equipped to make informed
decisions regarding environmental technology purchase and use.

The Greenhouse  Gas Technology Center (GHG Center) is one of six verification organizations operating
under the ETV  program.  The GHG Center is managed  by  EPA's partner verification organization,
Southern Research Institute (Southern), which conducts verification testing of promising GHG mitigation
and monitoring technologies.  The GHG Center's verification process consists of developing verification
protocols, conducting field tests, collecting and interpreting field and other data, obtaining independent
peer-review input, and reporting findings. Performance evaluations  are conducted according to externally
reviewed verification Test  and Quality Assurance Plans (Test Plans) and established protocols for quality
assurance (QA).

The GHG  Center is guided by volunteer groups of stakeholders.  These stakeholders  offer advice  on
specific technologies most appropriate for testing, help  disseminate results, and review  Test Plans and
Technology Verification Reports.  The GHG Center's Executive Stakeholder Group consists of national
and international experts  in the areas  of climate science and environmental policy, technology, and
regulation.  It also includes  industry trade organizations, environmental technology finance groups,
governmental organizations, and other interested groups.   The GHG Center's activities are also guided by
industry-specific stakeholders who provide guidance on the verification testing  strategy  related to their
area of expertise  and who peer-review key documents prepared by the GHG Center.

A technology area of interest to some GHG Center stakeholders is reliable renewable  energy sources.
The generation of heat and power at industrial, petrochemical,  agricultural, and waste-handling facilities
with renewable  energy  sources such as anaerobic digester gas (biogas) or landfill gas is a  particular
interest.   These  gases, when released to atmosphere, contribute millions of tons of methane emissions
annually in the U.S.  Cost-effective technologies  are available that  can curb this emission growth  by
processing  the gases to remove harmful  constituents, recovering the methane, and using  it as an energy
source.  Removal of the  harmful components of biogases  (primarily hydrogen sulfide and other sulfurous
compounds) while minimizing the creation of secondary waste  streams and effluents is essential to
development of these renewable energy sources.

NATCO Group,  Inc. (NATCO), located  in Houston, Texas, has requested that the GHG Center perform
an independent performance verification of the Paques THIOPAQ technology - a gas purification system.
This technology, developed in The  Netherlands  by Paques  BioSystems, is designed to safely and
efficiently  remove hydrogen  sulfide  (H2S) from  biogas and other  sour gases while  minimizing the
generation  of harmful emissions or effluents.  The process is suitable to applications where the practices
of venting, incineration, or re-injection of the collected H2S are not desirable options. The system also
                                              1-1

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allows the production of elemental sulfur for subsequent sale or use.  A variation of this technology is the
Shell-Paques  system,  which  operates  on  the  same  principles  as THIOPAQ,  but  includes  system
components that can process low-, medium-, and high-pressure natural gas.  The Shell-Paques version is
of particular interest to the natural gas, petrochemical, and refining industries.  Since the two versions of
the  technology are  very  similar in  principle and operation, the verification will apply to both.  A
THIOPAQ system installed and operating at a midwestern water pollution control facility (WPCF) and a
Shell-Paques system at the Bantry Gas Plant LSD 8-20-13W4M in  Brooks, Alberta, Canada have been
selected for this verification.

Field tests will be performed on Paques THIOPAQ and Shell-Paques systems to independently verify the
performance of this technology.  The verification will include evaluations of both environmental and
operational performance of the systems.  This document is the Test and Quality Assurance Plan (TQAP)
for performance verification of the THIOPAQ and Shell-Paques systems. It contains the rationale for the
selection of verification parameters,  the verification  approach,  data quality  objectives (DQOs), and
Quality  Assurance/Quality Control (QA/QC) procedures.  The TQAP will guide implementation of the
test program, development of the subsequent Verification Report (VR) and Verification  Statement (VS),
and data analysis.

This TQAP has been reviewed by NATCO, the EPA QA team, and selected members of the Center's
Advanced Energy Stakeholder group. Final approval of the TQAP  is indicated by the signatures at the
front of the document.  This indicates that the TQAP meets the requirements of the GHG Center's Quality
Management Plan (QMP), thereby  satisfying the ETV QMP requirements.  The final TQAP will be
posted on  the web  sites maintained by the GHG Center (www.sri-rtp.com)  and the ETV program
(www. epa. gov/etv).

The GHG Center will prepare a VR and VS upon field-test completion. The VR and VS will be reviewed
by the same organizations listed above, followed by EPA-ORD technical, QA, and editorial reviews. The
GHG Center Director and EPA-ORD Laboratory Director will  sign the VS when this review is complete,
and the final documents will be posted on the GHG Center and ETV program web sites.

The following  section provides a detailed description of the Paques THIOPAQ and Shell-Paques systems
and  a brief description of the verification test locations.   This  is  followed  by a list of performance
verification parameters that will be  quantified  through independent testing at the sites.  The  section
concludes with a discussion of key organizations participating in this verification, their roles, and the
verification test schedule.   Section 2.0  describes the technical approach for verifying  each parameter,
including sampling and analytical procedures. Section 3.0 identifies the data quality assessment  criteria
for  critical measurements  and  states  the accuracy,  precision,  and  completeness  goals  for  each
measurement.  Section 4.0 discusses data acquisition, validation, reporting, and auditing procedures.

1.2  THIOPAQ AND SHELL-PAQUES SYSTEMS TECHNOLOGY DESCRIPTION

Renewable biogas produced from the management of municipal and farm waste is a potentially viable
energy source.  Operational performance data is needed to verify the  ability of technologies to remove
contaminants   in  biologically generated  gas  streams.    Biogas  can  be  made  more  usable and
environmentally benign if contaminants (primarily H2S)  are  removed prior to their use as an  energy
source.  Conventional H2S removal technologies  such as caustic scrubbers are available, but these systems
may be costly to operate and produce  hazardous effluents. Redox processes are also available, but these
require use of chelating agents and generate potentially hazardous effluents.
                                              1-2

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1.2.1   Paques THIOPAQ Process

THIOPAQ™ is a biotechnological process for removing H2S from gaseous streams by absorption into a
mild alkaline solution followed by the oxidation of the absorbed sulfide to elemental sulfur by naturally
occurring microorganisms. THIOPAQ™ is licensed by Paques for biogas application and Shell, Paques,
and UOP for refinery gas and other applications. The THIOPAQ™ trademark name is owned by Paques
BV.  The THIOPAQ™ process is used at the host WPCF.

The Paques desulfurization technology, offered by NATCO, is a caustic scrubber-based system designed
to maintain  a  high  level of H2S  removal while addressing several shortcomings of conventional
technologies.  This technology  is designed to:  (1) reduce hazardous effluents from the scrubber by
aerobically digesting the waste  into a more benign sulfurous product, and  (2) regenerate and  recycle
sodium hydroxide (NaOH) needed in the scrubber. The THIOPAQ™ system is specifically designed for
low-pressure biogas streams.  The Shell-Paques process (described in more detail in Section 1.2.2.1) used
in Bantry is basically a high-pressure version  of the THIOPAQ™ process.   H2S to sulfur conversion
efficiency for both systems is expected to be between 95 and 97 percent.

The THIOPAQ™ process begins with the input of biogas or sour natural gas into an absorber unit (or
scrubber) at ambient pressure.   The counter-current  scrubber  design  washes the sour  natural  gas (or
biogas) in three packed beds containing 2-inch Pall rings.  A total draw-off tray combined with a liquid
redistribution tray in-between the packed beds  ensures proper liquid redistribution.  Treated natural gas
(sweet gas) exits the scrubber top, enters a knockout drum, and is routed to the sales gas stream.

The liquid stream is then sent to the bioreactor (ambient pressure). A blower supplies air to a distribution
header in the bottom section of the reactor, enhancing mixing.  Some of the oxygen is consumed in
reactions with sulfide to  produce sulfur by the actions of the Thiobacillus Bacteria.  The bacteria are
maintained using a continuous feed of proprietary nutrients supplied  by Paques.  These nutrients are
pumped into the bioreactor with a small metering pump.

Regenerated solvent  from the bioreactor is pumped back to the  scrubber for reuse.  A portion of the
solvent from the bioreactor is  also pumped to a settling tank where solids are  separated from the solution
and collected gravimetrically.  The solution is then recycled back to the bioreactor for reuse.

A general process flow diagram of the THIOPAQ™ and the Shell-Paques processes is shown in Figure 1-
1. The major difference seen on the diagram  is the use of the flash vessel  in the high-pressure Shell-
Paques system.

Low-pressure biogas (THIOPAQ™) is  processed for removal of H2S using a conventional counter-
current caustic scrubber (pH ranging from 8.2 to 9). Natco claims that H2S removal efficiency is typically
about 99 percent for properly operated systems.  Scrubber design is site-specific in regards to vessel size,
construction specifications, and gas and solution flow capacities.  The Paques system application range is
generally for the capture of approximately 200 pounds to 40 tons of sulfur per day. Spent caustic exiting
the scrubber  is gravity-fed (through stainless-steel piping) to an aerobic bioreactor - the heart of the
Paques technology.
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          Processed
           Gas Out
  Flash Gas
   to flare
(Shell-Paques
    only)
                                           Air
                                                      Circulation
                                                         Pump
                        Flash Vessel
                     (Shell-Paques only)
                                                          Effluent
                                                           Bleed:
                                                         Water and
                                                         sodium salts
                                                          Sulfur
                                                          Product
                                      NaOH    Nutrients
             Figure 1-1.  Simplified THIOPAQ™ and Shell-Paques System Schematic
1.2.2   Shell-Paques Process

The Shell-Paques process is the name of the technology licensed by Shell and Paques for applications in
(1) natural gas, (2) synthesis gas,  and (3) Claus tail-gas treatment. Shell-Paques is a variation of the
THIOPAQ™ system that is designed for use with high-pressure sour gas streams typically associated
with oil/gas and petrochemical industries (it can accommodate inlet gas pressures ranging from 2 to 1,300
psig).  The two systems are virtually identical (other than vessel and pipe pressure ratings) except for a
flash vessel that is required for the Shell-Paques system. The flash vessel is needed for the high-pressure
system to remove dissolved hydrocarbon gases that become entrained in the spent scrubber  solution.
Figure 1-1 provides a schematic of the Paques technology.

At Bantry, the Shell -Paques process begins with the flow of sour natural gas through a feed gas knockout
vessel, a heater, and then the scrubber. The heater was required on the Bantry unit to account for the low
feed gas  temperature expected.  It had the  added benefit of allowing for easy control of the  feed  gas
temperature relative to the solvent temperature to prevent hydrocarbon condensation.

The counter-current scrubber design washes the sour gas in multiple beds filled with random packing. A
liquid  redistribution  tray is used  in-between the packed  beds to ensure proper  liquid  distribution
throughout the scrubber. Treated natural gas (sweet gas) exits the top of the scrubber, enters a knockout
drum, and is routed to the sales gas stream.

The loaded THIOPAQ™ solvent leaves the scrubber and goes to the flash vessel.  The operating pressure
is  3.45 barg (50 psig).  The flash gas (MW-19.75), which  contains some H2S,  is washed in the small
                                              1-4

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column on top of the flash vessel. The vent gas flow rate from the flash vessel is 2.8 kg/hr (76 std. m3/d).
The flash gas is routed to flare at the Bantry unit.

Flashed, loaded THIOPAQ solvent is then sent to the bioreactor where the pressure is reduced to ambient.
A blower supplies air to a distribution header in the bottom section of the bioreactor, enhancing mixing.
Some of the oxygen is  consumed in reactions with sulfide  to  produce sulfur by  the  actions of the
Thiobacillus  Bacteria.  The  bacteria are maintained  using  a continuous feed of proprietary nutrients
supplied by Paques. These nutrients are pumped into the bioreactor with a small metering pump.

Regenerated  solvent from  the bioreactor is pumped back to the  scrubbers (main  and flash vessel) for
reuse.  A portion of the  solvent from the bioreactor is also  pumped to a settling tank where solids are
separated from the solution  and  collected  gravimetrically.  The  solution is  then  recycled back to the
bioreactor for reuse.

The  bacteria catalyze the sulfur and sulfate regeneration  reactions  in the  bioreactor  to  give either
elemental sulfur or sulfate.  The reaction producing elemental sulfur is desired because:

    •   It produces a hydroxyl molecule, which can capture a molecule of H2S in the scrubber and
    •   It produces elemental sulfur, which  can be separated fairly easily from the solvent.

A continuous bleed stream is taken from  a  calm section of the bioreactor to minimize the sulfur content.
The bleed stream goes to a bleed aeration tank to ensure that all sulfur and sulfide is completely oxidized
to sulfate (because BOD demand is zero).   An ultraviolet "stabilizer" has been installed after the aeration
tank because local legislation required sterilization of the bleed stream.  This effluent is collected in a
bleed water tank where it is collected and subsequently transported by truck to a nearby water treatment
facility.

The  vent air leaving the bioreactor can contain trace  amounts  of H2S (typically less than 1  ppmv).
Therefore, it  is initially routed to  a bio-polisher which is a tank with a layer of compost.  The vent air is
discharged directly into the atmosphere from the bio-polisher.

The  regenerated solvent  leaving  the bioreactor typically contains 10 kg S/m3 (1% by weight).  Sulfur
content increases to approximately 10%  wt. sulfur content in the solids  separator.  The  clarified water
from the separator is returned to the bioreactor. The sulfur slurry from the separator is concentrated into a
sulfur paste (~ 65% wt. sulfur content) in a decanter-centrifuge.  Until  a buyer of the potentially salable
paste is found, the sulfur paste is sent to landfill near Bantry.

1.2.3   Process Chemistry

The reactions that drive these processes occur primarily in the scrubber and the bioreactor.  The first main
reaction in the scrubber  (at feed gas pressure) is H2S absorption.  The  H2S is absorbed by the dilute
caustic scrubber solution  (sodium hydroxide (NaOH)) in the scrubber according to the  following chemical
reaction:

                      H2S + NaOH -» NaHS + H2O                         (a)
Reaction (a)  shows that solution alkalinity is consumed during this process.  The solution leaving the
scrubber (NaHS + H2O) is directed to the bioreactor.

Hydroxide ions are also consumed in the scrubber during a CO2 absorption step:
                                               1-5

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                                                                         (b)

and a carbonate formation step:

                      HCO3  + OH -» CO32 + H2O                        (c)

Note: The actual amount of CO2 removed from  the sour gas is very small.  The carbonate / bicarbonate
buffer moderates the solution pH to the appropriate range, providing hydroxide ions for H2S removal and
allowing for the selective removal of H2S and the slip of CO2.

The liquid stream loses the OH- ion in the scrubber and gains the OH- ion back in the bioreactor.  The
bioreactor operates near atmospheric pressure  and is aerated (constant mix) with a controlled inflow of
ambient air. The bacteria react with the spent scrubber solution and convert the dissolved sulfide to solid
elemental  sulfur as follows:

                      NaHS + V2O2 -»•  S° + NaOH                         (d)
This step relies on the biological oxidation of the dissolved sulfide into elemental sulfur using aerobic
bacteria (Thiobacillus). A small portion  of the dissolved sulfide (less than 5 percent)  is completely
oxidized to sulfate as follows:

                     2NaHS +4O2  -» NaHSO4 <-» Na2SO4 + H2SO4         (e)

Solution alkalinity is partially regenerated in equation (d).  The caustic absorbs the H2S gas and is
regenerated during the production of elemental sulfur. Caustic solution regeneration eliminates the need
for a large supply of NaOH to maintain pH above 8.2. Solution regeneration is not 100 percent as shown
in equation (e), so additional NaOH is required.  A  controlled amount of dilute NaOH is added to the
system continuously using a small metering pump.  An automated level sensor detects when bioreactor
solution level is high, and a controlled amount of system effluent is bled to the wastewater treatment plant
influent stream, restoring proper solution level.  This bleed  stream also prevents the accumulation of
sulfate ions. Air leaving the bioreactor is vented to atmosphere.

The sulfur produced has a hydrophilic nature, which significantly reduces the chance of equipment
fouling or blocking. This  characteristic also makes the product suitable for agricultural  use as
fertilizer. Alternatively, the sulfur can be melted to yield a high-purity product which meets  international
Claus sulfur specifications.
1.3 PLANT DESCRIPTIONS AND SYSTEM INTEGRATION

1.3.1   Host WPCF - (Paques THIOPAQ™)

The WPCF hosting the Thiopaq verification is a 40-million gallons per day (MGD) wastewater treatment
facility.  The facility  is  specifically designed to process industrial wastewater streams from numerous
local  industries including grain- and food-processing plants and  a paper mill  (corrugated cardboard
recycler).
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A portion of the plant's influent is characterized as low-flow, high biological oxygen demand (BOD)-type
waste.   This waste stream is approximately 2.5 to 3 MGD and encounters anaerobic pretreatment in
Biothane upflow anaerobic sludge blankets (UASBs).  The facility uses three UASBs to  pre-treat this
wastewater stream, each of which generates around 100 to 200 cubic feet per minute (cfm)  of biogas (or
around 144 to 288 thousand cubic feet per day (cfd)). Biogas composition can vary but is generally 60
percent CH4, 38 percent CO2, and 1 to 1.5 percent H2S. The gas generated in each UASB is collected,
combined, compressed, and used to fuel a sludge incinerator within the plant. The sludge incinerator will
consume all of the biogas generated on-site under normal plant operations.  The biogas is  flared during
rare occurrences when the incinerator is not operating or is being fueled with natural gas.

The facility installed a THIOPAQ™ system in 2001 to efficiently scrub H2S from the biogas prior to its
use as fuel or incineration in the flares.  This THIOPAQ™ system was selected for this verification test
(Figure 1-2).
                            Figure 1-2. Typical THIOPAQ™ System

The  THIOPAQ™ system has  a biogas treatment  capacity of  1000 cubic feet per minute.   The
THIOPAQ™ system to be tested is largely automated and PLC-controlled and includes numerous
monitoring devices to record the system parameters shown in Figure 1-1. Table 1-1 summarizes some of
the monitoring instrumentation used at the plant.
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                    Table 1-1. Host Site THIOPAQ™ Monitoring Instrumentation
Parameter
Biogas flow
(generation) rate
Scrubber solution
flow rate
NaOH consumption
rate
Typical Range
100-200acfmper
each UASB
800 to l,000gpm
Approximately
1,500 Ib/day
Instrumentation
Fluid Components International,
Model ST98 thermal mass flow
meters (3 total)
Promag 50/53W electromagnetic
flow monitor
Milltronics level sensor
Location
One on the outlet of
each UASB
Scrubber pump
discharge
NaOH holding tank
The system at this facility decants a liquid effluent batch only about once per week.  Solids collected in
the settling tank are removed by a vacuum filter press (made by Straight-Line Filter Press) approximately
once per day. The facility has not yet found a buyer or user of the sulfur, so the solids are collected in a
large bin and disposed of in a landfill.  The bioreactor vent is  a two-foot diameter rain-capped vent
emitting directly to atmosphere.
1.3.2   Encana Bantry - (Shell-Paques)


The Bantry  Shell-Paques unit is located near the town of Brooks, east of Calgary, in Canada, and is
owned and operated by EnCana Resources, a major Canadian and global gas producer. The natural gas is
extracted  from well sites that are on, or adjacent to, the properties of over forty Canadian landowners
around the Bantry North facility.

New Paradigm Gas Processing Ltd. (New Paradigm), a subsidiary of the Canadian technology company
(CCR) Technologies Ltd. and the authorized licensor of the Shell-Paques process in Canada, constructed
the unit under license.

The Bantry  Shell-Paques unit is designed to remove H2S  from the sour gas extracted from nine natural
gas fields.   Basic design specifications  for  this  system  including  gas flow  rates, pressures,  and
composition are summarized in Table 1-2.  The sulfur recovered from the  system is currently sent to a
landfill.
                                              1-8

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                       Table 1-2.  Bantry Shell-Paques System Design Cases
Parameter
Gas Flow

Pressure

Temperature

Gas Composition
H2
He
N2
CO2
H2S
Cl
C2
C3
i-C4
n-C4
i-C5
n-C5
C6
C7-plus
Units
IGsNmVday
mmscfd
Barg
Psig
°C
°F

%vol.
% vol.
%vol.
%vol.
%vol.
%vol.
%vol.
%vol.
% vol.
%vol.
% vol.
%vol.
%vol.
% vol.
Low Pressure,
Winter case
321.5
12.0
5.9
85
4
39

0.005
0.061
4.112
2.506
0.202
84.429
4.348
2.041
0.496
0.862
0.330
0.281
0.211
0.117
High Pressure,
Summer case
321.5
12.0
13.8
200
10
50

0.005
0.061
4.112
2.506
0.202
84.429
4.348
2.041
0.496
0.862
0.330
0.281
0.211
0.117
1.4 PERFORMANCE VERIFICATION PARAMETERS

Regulatory and industry stakeholders in the oil and gas, waste-handling, and power production industries
have a need and use for independently verified field data on the technical, emissions, and operational
performance of gas-processing technologies.  The verification approach in this TQAP  is intended to
provide credible performance data to potential industry users and environmental regulators.

The Paques THIOPAQ™ and Shell-Paques versions of this technology differ only by the need for a flash
vessel on the Shell-Paques unit.  Since the flash vessel does not change the environmental or operational
performance of the system, a detailed verification of each type of Paques system would be redundant and
unnecessarily costly.  Therefore, a detailed  verification will be  conducted only  on the  THIOPAQ™
system at the host WPCF.  A significantly abbreviated evaluation will be conducted on the Shell-Paques
system in Alberta simply to show comparability with  results from the THIOPAQ™ verification. The test
will also independently verify that the flash vessel  does not introduce an additional system emission
point. The THIOPAQ™ testing will include verification of the performance parameters described below.
Section 2.0 presents detailed descriptions of measurement and analysis methods and Section 3.0 discusses
data quality assessment procedures for each verification parameter.
                                              1-9

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1.4.1   Environmental Performance Parameters

Air Emissions.  Process information provided by NATCO and THIOPAQ™ indicate that there are no air
emissions from the system other than the aerobic bioreactor vent. Fugitive emissions are not expected for
the THIOPAQ™ because the system operates near ambient pressure.  The bioreactor vent continuously
releases vent gases to the atmosphere since this is an aerobic process.  The GHG Center will conduct
measurements on this vent to independently verify emission rates of H2S or other sulfur compounds, if
any, that are liberated from the vent.  The GHG Center personnel will collect  at least three vent air
samples on each of three consecutive days for analysis. Concentrations of H2S or other sulfur compounds
will be determined at a laboratory and reported  in units of parts per billion by volume (ppbv). Vent gas
flow rate will be measured in conjunction with  sample collection using  a pitot tube and  differential
pressure gage. Emission rates of H2S from  the vent will be calculated in units of pounds per hour (Ib/hr)
using the reported concentrations and measured vent air flow rates.  Vent gas temperature and pressure
will be measured to support the conversion of emission rates to standard conditions.

Liquid Effluent. The THIOPAQ™ and Shell-Paques systems include only one liquid effluent point - the
effluent bleed stream used to regulate solution  conductivity.  The THIOPAQ™ reduces  the volume  of
hazardous liquid effluent associated with conventional wet scrubbers but  small amounts of effluent must
be bled from the system intermittently to maintain proper system pH and conductivity.  This effluent,
consisting of water and small amounts of sulfate and sulfides, is directed back to the wastewater treatment
facility.  Under normal  plant operations, only  one batch of effluent is expected to be  bled from the
THIOPAQ™ system every week or so.  This  verification will include  only one event during the test
period.  The Center will quantify the effluent volume and sulfur content in the bleed stream from this
event by conducting the following measurements:

(1) Collect a sample to determine the concentrations of sulfates and sulfides (Ib/gal).
(2) Measure the volume of effluent dispensed during the bleed event (gallons).

The Center will then request the site operator to repeat these measurements during the next two effluent
bleed events to establish three replicates of each  measurement.

1.4.2   Operational Performance Parameters

H?S Removal Efficiency.  The Center will conduct three tests per day  to determine the system's H2S
removal efficiency.  This will be done in  conjunction with the  environmental testing outlined above.
Time-integrated biogas samples will be collected simultaneously at the inlet and outlet of the scrubber
during  each test. Collected samples will be express-shipped to a laboratory for determination of H2S and
17  other sulfur-based compounds.  Results of each species  in each sample  will be standardized and
reported in units of parts per million by volume (ppmv).  Removal efficiency will be  calculated and
reported.

Gas Composition  and Quality.    Gas  processing by  the THIOPAQ™ system is not expected  to
significantly impact gas quality other than removal of H2S.  The Center will examine gas quality before
and after treatment in the THIOPAQ™ to verify this.  A second set of integrated biogas samples will be
collected simultaneously  at  the inlet and  outlet of the  scrubber  and submitted to the  laboratory  to
determine gas composition (Cl through C6+) and lower heating value (LHV). Results of the analysis will
be examined to determine if the LHV of the  gas is significantly changed by THIOPAQ™ processing.

NaOH  Consumption Rate.  The THIOPAQ™ system reduces NaOH consumption by the process because
of NaOH regeneration in the bioreactor.  The  host facility uses metering pumps to add NaOH to the
                                             1-10

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process.  The Center will measure and report the NaOH consumption rate at this facility so that potential
THIOPAQ™ system users can estimate NaOH savings at their own facilities.

Sulfur Production and Purity.   The solids  cake generated by the THIOPAQ™ system  represents a
potentially salable product.  THIOPAQ™ estimates a potential elemental sulfur purity of 95 percent in the
sludge cake from the vacuum filter press.   The Center will estimate the average solids and elemental
sulfur production rate in units of Ib/day using the following procedures.

    (1)  Each batch of solids collected during the verification period will be weighed and an average daily
        solids production rate will be calculated.
    (2)  A sample of each batch will be  collected and shipped to a laboratory to determine  the moisture
        content  and estimate the purity of the  sulfur.   An extraction  procedure used  for  sulfur
        determination, described in Appendix A-7, will be used to remove "foreign matter" (insoluble
        residue).  The sulfur will be defined as the difference between 100 and the percentage of foreign
        matter to the nearest 0.1  percent.    Moisture will be determined simply by desiccation and
        subsequent calculations for moisture percent.
    (3)  The percentage of sulfur and the solids production rates will be used to calculate an average daily
        solids and elemental sulfur production rate.

Process Operations.  Operational parameters will be monitored during  the testing to document system
operations and to aid  in post-testing data analysis.  These will include biogas  flow rate through the
system, scrubber water flow rate, and NaOH, nutrient, and air flow rate to the bioreactor.  These data, all
collected by site metering equipment (Table 1-1), are not used as primary verification parameters but will
be included in the report to document system operations during testing.  They will also allow the Center
to evaluate operational stability or variation during the verification test periods.

1.4.3    Shell-Paques Performance

Completion of the field testing and data analysis on the host THIOPAQ™ system will be followed by the
GHG Center conducting  the abbreviated verification test on the Shell-Paques system in Alberta.   The
following samples will be collected in Bantry:

    •   Two bioreactor vent gas samples to determine H2S concentrations.
    •   Two effluent samples from the bioreactor bleed stream to determine total sulfates and dissolved
        sulfides.
    •   One sample from the sludge cake to estimate sulfur purity.

One day's NaOH consumption and solids production will also be documented. Note that this level may
be increased or decreased depending on the variability of the THIOPAQ™ testing results.
                                              1-11

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1.5.     ORGANIZATION

Figure  1-3  presents  the project organization  chart.   The following  section  discusses functions,
responsibilities, and lines of communications for the verification test participants.
EPA
ETV GHG Pilot Manager
EPA - APPCD
David Kirchgessner


EPA
Quality Assurance Manager
EPA - APPCD
Robert Wright

Southern Research Institute
Quality Assurance Manager
Ashley Williamson


f
I
Southern Research Institute
ETV GHG Center Director
Stephen Piccot

Southern Rese
ETV GHC
Project \
William C


arch Institute
j Center
[anager
latterton

Southern Research Institute
ETV GHG Center
Field Team Leader
Robert Richards

Air Analyses
Air Toxics, Ltd.
Gas Analyses
Empact Analytical
Systems, Inc.



\
Liquid Analyses
CT Laboratories
Solids Analyses
Commercial Testing &
Engineering Co.
\
GHG Center Stakeholders

NATCO Group, Inc.
Process Engineer
Al Lanning

Host Facility
Process Engineer

                                Figure 1-3. Project Organization
Southern's  GHG  Center  has  overall  responsibility  for  planning  and  ensuring the  successful
implementation of this verification test.  The GHG Center will ensure that effective coordination occurs,
schedules are developed and adhered to, effective planning occurs, and high-quality independent testing
and reporting occurs.

Mr. Stephen Piccot is the GHG Center Director.  He will ensure that the staff and resources are available
to complete this verification as defined in this TQAP.  He will ensure effective review of the TQAP and
reports occur to ensure they are  of high quality and consistent with ETV operating principles.   He will
oversee the activities of the GHG Center staff and provide  management support where needed.  Mr.
Piccot will  sign the VS along with the EPA-NRML Laboratory Director.

Mr. William  Chatterton will serve as the project manager.  He will be responsible for developing  the
TQAP and overseeing field data collection activities of the GHG Center's field team leader, including
assessment of the team leader's  accomplishment of DQOs.  Mr. Chatterton will ensure the procedures
outlined  in Sections 2.0  and  3.0 are adhered to during  testing unless modification  is required.
                                              1-12

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Modifications will be completed, explained, and justified in the VR. He is also ultimately responsible for
conformation that quality control procedures specified in this TQAP are conducted and criteria met by
field testing personnel as well as subcontractors and laboratories.  Mr. Chatterton will have authority to
suspend testing  should  a situation  arise during testing that could affect  the health or safety of any
personnel.  He will also have the authority to  suspend testing if quality problems occur or host site or
vendor problems arise.   He  will also be responsible  for maintaining  effective communications  with
NATCO, host facility personnel, Southern QA team members, and ETV document reviewers.

Mr. Robert Richards will serve as the field team leader.  Mr. Richards will be responsible for the effective
planning,  mobilization,  and  execution of all field-testing activities.   He will install and operate
measurement instruments,  supervise  and  document activities  conducted by  the  emissions testing
contractors, collect gas samples and coordinate sample analysis with the laboratory,  and ensure that all
QA/QC procedures outlined in Section 2.0 are adhered to.  He will also support Mr. Chatterton's data
quality  determination and report  preparation activities and  will submit all  results to Mr.  Piccot
documenting the final reconciliation of DQOs.  He will be responsible for ensuring that performance data
collected  by continuously monitored instruments  and  manual sampling techniques are  based on
procedures described in Section 4.0.

Southern's QA Manager, Dr. Ashley Williamson, has reviewed, approved, and  signed this TQAP.  He
will  also review  the results from the verification test and conduct an  Audit of Data Quality (ADQ),
described  in Section 4.4.   The ADQ will include his independent review of QC documentation and
confirmation of DQO attainment. He will also conduct an internal Technical Systems Audit (TSA) of this
test.  Dr. Williamson will prepare a written report of his findings from internal audits and document
reviews. These findings will be used to prepare the VR.

Mr. Al Lanning,  Senior Process Engineer, will serve as the primary contact person for NATCO.  Mr.
Lanning will provide technical assistance and help coordinate this test with the host site as necessary.  A
process engineer  at the host WPCF will  be the main contact for the host site and will oversee system
operations during the verification testing.

EPA-ORD will provide oversight and QA support for this verification.  The APPCD Project Officer, Dr.
David Kirchgessner, is responsible for obtaining final approval of the TQAP, VR, and VS.  The APPCD
QA Manager, Robert Wright, will ensure review of the TQAP and reports occur and that approval is
granted once any issues have been resolved satisfactorily.

1.6.    SCHEDULE

The THIOPAQ and Shell-Paques systems selected for this verification are installed and operational.  The
tentative schedule of activities for this verification are listed below.
                                              1-13

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Verification Milestone	Scheduled Completion

Verification Test Plan Development
       GHG Center Internal Draft Completed                       March 12, 2004
       NATCO Review/Revision                                  March 31, 2004
       Peer Review/Revision                                     May 7, 2004
       EPA Review/Revision                                     May 28, 2004
       Final Test Plan Posted                                     June 11, 2004

Verification Testing and Analysis
       Field Testing                                             June 28 - July 2 2004
       Data Validation and Analysis                               June 28 - July 16, 2004

Verification Report Development
       GHG Center Internal Draft Development                     June 28 - July 30, 2004
       Vendor and Host Site Review/Revision                       August 13, 2004
       EPA and Industry Peer-Review/Revision                     August 27, 2004
       Final Report Posted                                       August 31, 2004
                                            1-14

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                           2.0      VERIFICATION APPROACH
       2.1.           OVERVIEW

The Paques technology is designed to provide efficient sour gas purification for removal of H2S.  The
technology is unique in that the bioreactor regenerates the gas scrubbing liquid, eliminating the large
quantities of waste  effluent generated by conventional  gas scrubbing systems.   This benefit  is
accompanied by a significant reduction in treatment chemical consumption.   Section 1.4 introduced the
verification parameters and basic approach. This section provides the detailed sampling and analytical
procedures that will  be used to verify performance parameters.   The GHG Center will conduct
performance testing at normal site conditions to address the following verification parameters:

Environmental Performance (Section 2.2)
       Air emissions of H2S and other sulfur species, Ib/hr
       Liquid effluent sulfate and sulfide emissions, mg/day

Operational Performance (Section 2.3)
       H2S removal efficiency, %
       Gas quality (composition and LHV)
       NaOH consumption, Ib/day
       Nutrient consumption, gal/day
       Sulfur production, Ib/day

Table 2-1 summarizes the testing matrix.   The  matrix includes the detailed verification testing to be
conducted on the THIOPAQ system and the comparability  checks that will be  conducted on the Shell-
Paques system at Bantry. Sections 2.2 and  2.3 detail the sampling and analytical procedures that will be
used to verify each performance parameter on the THIOPAQ™ system.  Quality assurance and control
procedures for each of the determinations are detailed in Section 3.0.

The GHG Center will conduct a one-day test survey for the Shell-Paques system intended to  (1) compare
this system to the THIOPAQ™ system and  (2) confirm  that the flash vessel is not an additional emission
point. Two samples of vent air from the bioreactor and two samples of liquid effluent from the centrifuge
bleed stream will be  collected and analyzed.  One  elemental sulfur sample will be collected  from the
sludge cake and evaluated.  The site monitors raw (sour gas) and processed gas composition and quality
(including H2S  content and gas composition).  This  data will be reviewed and reported in the VR but
independent verification of these parameters will not be repeated by the Center. Process variables such as
gas flow  rates and scrubber water flow rate, also monitored  by the site, will be reviewed to  confirm that
typical and steady system operations occur during the  short 1-day test period.
                                              2-1

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                 Table 2-1. THIOPAQ™ and Shell-Paques Verification Test Matrix
Verification Parameters
Environmental
Parameters
Operational
Parameters
Air emissions of
sulfur compounds
(Ib/hr)
Sulfur compounds
in liquid effluent
(Ib/hr)
H2S removal
efficiency (%)
Gas quality
NaOH
consumption
(Ib/day)
Sulfur production
(Ib/day)
Required
Measurements
Sulfur compounds from
bioreactor vent (ppm)
Bioreactor vent flow rate
(scfm)
Sulfur compounds in
effluent (mg/1)
Effluent disposal rate
(gal/day)
H2S concentration in raw
biogas or sour gas (ppm)
H2S concentration in
processed gas (ppm)
Composition (%), LHV
(Btu/scf) in raw biogas or
sour gas
Composition (%), LHV
(Btu/scf) in processed gas
NaOH feed rate to system
(Ib/day)
Production rate (Ib/day)
Sulfur purity (%)
Measurement Frequency
THIOPAQ
3 samples on each of
3 consecutive days
3 samples on each of
3 consecutive bleed
events
3 samples on each of
3 consecutive days
3 samples on each of
3 consecutive days
3 -day monitoring
period
3 -day monitoring
period
3 samples on each of
3 consecutive days
Shell-Paques
2 samples on one day
(reported as ppm
only)
2 samples (reported
as mg/1 only)
Not independently
verified
Review site records
1 -day monitoring
period
1 sample on one day
Figure 2-1 is a schematic showing the verification system testing boundary and the location of each of the
required measurements listed in Table 2-1.
                                             2-2

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             Processed       Flash Gas
              Gas Out     (Shell-Paques only)     Air Vent
                                                               System Boundary
 Sour
Gas In
	©*
                    Flash Vessel
                 (Shell-Paques only)
                                                                                   Effluent Bleed:
                                                                                   Sulfur Product
                                        NaOH     Air
   Measurements Required
      for Environmental
   Performance Parameters

© Sulfur compounds in air vent
(B) Air vent flow rate
(c) Sulfates and sulfides in effluent
(D) Effluent flow rate
                                    Measurements Required
                                        for Operational
                                    Performance Parameters

                                    (E) Inlet gas H2S and composition
                                    (F) Outlet gas H2S and composition
                                    (G) NaOH consumption
                                    @ Sulfur production
                                    © Sulfur purity
   Monitoring of
Process Operations

\T\ Gas flow rate
0 Scrubber flow rate
rri Airflow
                Figure 2-1.  Schematic of Verification Boundary and Measurement Locations
  2.2    ENVIRONMENTAL PERFORMANCE

  The GHG Center will verify the environmental performance of the THIOPAQ™ over a three-day testing
  period at the host WPCF. Environmental performance of the Shell-Paques system in Bantry, Alberta, will
  be conducted during a subsequent one-day testing period.  The verification parameters listed in Section
  2.1 will be  evaluated through direct on-site measurements.  All testing will be conducted during stable
  plant operations with stable THIOPAQ™ system operations confirmed by site operators.  Results of the
  testing will be  used to report air emissions of H2S and other sulfur compounds as well  as sulfate and
  sulfide effluents. The following sections detail the measurements and test methods that will be used.

  2.2.1   Air Emissions of Sulfur Compounds

  The bioreactor vent is the only source of air emissions on the THIOPAQ™ system. Therefore, testing
  will be conducted on the bioreactor vent to determine emissions of H2S and other sulfur compounds.  A
  total of nine vent gas samples will be collected from the  THIOPAQ™ system - three on each of three
                                               2-3

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consecutive days. Two samples will be collected from the Shell-Paques vent in Bantry.  The samples will
be collected several hours apart to allow ample process time between samples.

Time-integrated vent gas samples will be collected in tedlar bags over a period of approximately one hour
per sample.  A lung-type sampling system will be used to collect the bag samples.  A teflon  probe is
inserted into the  vent and attached to a tedlar bag mounted inside a leak-free vessel.  A vacuum pump is
used to slowly evacuate the vessel, thereby filling the tedlar bag with  vent gas.  Evacuation rate will be
controlled with a needle valve so that the bag will fill over a period of approximately one hour. Appendix
A-2 provides a log form for bag sample collection.

Collected samples will be express-shipped daily to a laboratory that specializes  in air  analyses (Air
Toxics, Ltd.), for analysis of sulfur compounds. Appendix A-5 provides an example  of the chain-of-
custody form that will accompany all samples and document the  date and time of collection, release,
receipt, and analysis  of  samples.   A  coordinated effort between field sampling personnel  and the
laboratory analyst will be made to complete sample analyses within 24 to 30 hours  of collection to
minimize bias caused by the instability of H2S.  The samples will also be protected  from prolonged
exposure to  light.  These procedures are expected to minimize H2S losses and bias. Analyses will be
conducted in accordance with ASTM Method 5504 (7) to quantify concentrations of the following sulfur
species:

           •  hydrogen sulfide               2,5-dimethylthiophene
           •  carbon disulfide               2-ethylthiophene
           •  carbonyl sulfide               3-methylthiophene
           •  diethyl disulfide               ethyl methyl sulfide
           •  diethyl sulfide                ethyl mercaptan
           •  isobutyl mercaptan            isopropyl mercaptan
           •  methyl mercaptan             n-butyl mercaptan
           •  n-propyl mercaptan            tert-butyl mercaptan
           •  tetrahydrothiophene           thiophene

A known volume of sample is injected into a gas chromatograph (GC) equipped with a molecular sieve
column.  The sulfur components elute from the GC and they are directed to a sulfur chemiluminescence
detector (SCD) for quantitation.  Resultant peaks in the chart trace are determined for each compound.
These  areas are  compared to the areas of the  same compounds  contained in a calibration reference
standard  that is analyzed under identical conditions.  A total of 20 sulfur compounds are included in the
analysis  with individual  compound reporting limits  of approximately 4 parts per billion by volume
(ppbv). QA/QC procedures for this analysis include instrument calibrations, laboratory  control samples,
internal standards, laboratory blanks, and duplicate analyses.  Details  regarding the QA/QC procedures
are presented in Section 3.2.1.

Vent gas flow-rate determinations are required to convert any detectable sulfur compound concentrations
to mass emissions in terms of pounds per hour (Ib/hr). A temporary duct will be fitted over the two-foot
diameter THIOPAQ™ system vent to allow air flow-rate measurements.  Air flow rates are expected to
be very low, so  the duct will neck down to no more than one foot in diameter.  The duct will be of
sufficient length to provide  laminar flow (at least  6  feet in length) and will be fitted with flow-
straightening vanes.

Test personnel will conduct vent gas velocity and temperature measurements on the THIOPAQ™ system
vent during each bag sampling event with a standard-type pitot tube and manometer following the general
                                              2-4

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procedures of EPA Reference Method 2 (2). The manometer (Dwyer Model 115-AV) is an incline oil
manometer with a sensitivity of approximately 0.005 inches of water (in. w.c.) and a range of 0.25 in. w.c.

Vent gas velocity depends on the average pitot differential pressures, gas molecular weight, temperature,
and pressure as follows:
               Vv = 85.49(Cp)(Avg[jApyi—Z-                               (Eqn. 1)


where:
       Vv =   vent gas velocity, ft/sec
       Cp =   pitot coefficient, dimensionless
       Ap =   change in velocity head, inches H2O
       Tv =   average gas temperature, °R
       Pv =   absolute pressure in vent duct, in. Hg
       Mv =   molecular weight of vent gas, Ib/lb-mole
       85.49= constant

Volumetric flow rate for the vent gas will be calculated as follows:


               Qstd=VvA^^                                           (Eqn. 2)
                         "std L std

where:
        Qstd =  volumetric flow rate, dscf/min
        Vv =   vent gas velocity, ft/min
        A =    duct cross-sectional area, ft2
        Pv =    absolute pressure in duct, in. Hg
        Pstd =   standard pressure, 29.92 in. Hg
        TV =    average gas absolute temperature, °R
        Tstd =   standard temperature, 532 °R
Analysts will convert measured pollutant concentrations as ppbv to pounds per dry standard cubic foot
(Ib/dscf), and calculate emission rates for each as follows:

               Epou=CpoUQstd60                                           (Eqn. 3)

where:
        Epoii =  pollutant emission rate, Ib/hr
        Cpoii =  average pollutant concentration, Ib/dscf
        Qstd =  standard dry volumetric flow rate, dscf/min, (Eqn. 2)
        60 =   minutes per hour

Section 3.2.1 contains the procedures and associated DQOs.
                                               2-5

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2.2.2    Sulfur in Liquid Effluent

The verification will include determination of the amount of sulfur emitted from the system in the liquid
bleed effluent.  The THIOPAQ™ effluent at this  site  is routed back into the sewage treatment plant
influent line and  subsequently treated, so it is not a true  source of emissions.  This  information can,
however, be important to sites where this effluent is a waste stream (unable to be recycled back into the
influent).  Any sulfur present in the effluent will be in  the form of sulfates or dissolved sulfides.  This
analysis will include measurement of the sulfates  and sulfides present in the effluent in units of mg/1 and
the effluent rate in units of liters per day (1/d).

On the  THIOPAQ™  system, a batch of effluent is bled  from the system weekly as dictated by the
solution conductivity.  At Bantry, effluent is bled continuously from a calm section of the bioreactor to
minimize sulfur content in the bleed stream. The estimated bleed stream rate from the Bantry design is
4.5 m3/d.  On the THIOPAQ™ system, GHG Center personnel will obtain three  replicate samples by
requesting site operators to collect three effluent  samples on each of three consecutive  bleed-off events.
Two samples will be collected from the Bantry effluent  stream. Samples will be collected from the hose
leading  from  the bioreactor to the  drain  in 250-ml  pre-cleaned (EPA Level-1  cleaning  and QC
procedures)  polyethylene bottles.   The samples  will  be shipped to CT Laboratories of Baraboo,
Wisconsin, along  with proper chain-of-custody forms. The  following analyses will be conducted on each
sample:

                                   Effluent Sample Analyses

        Analyte              Reference Methods"           Principle of Detection
        Total sulfates         EPA Method 9056              Ion chromatography
        Dissolved sulfides     EPA Method 9030B and 9034   Distillation and titration
        a Source: SW-846 - Test Methods for Evaluating Solid Waste, Physical / Chemical Methods
        (3,4,5)

Total Sulfates

Method 9056 procedures specify that a small aliquot of sample (typically 2 to 3 ml) is injected into an ion
chromatograph where inorganic ions are separated and measured using an electrical conductivity cell.
Individual  anions are  identified  based  on their retention  times  compared to  known   standards.
Quantitation is accomplished by measuring the peak area for the sulfate anion and comparing it to a
calibration curve generated from known standards.  The method detection limit (MDL) is approximately
O.lmg/L.

Dissolved Sulfides

The  Method 9030B distillation procedure is  designed for the determination of sulfides in aqueous
solutions and effluents. An aliquot of sample is distilled under acidic conditions at 100°C under a stream
of nitrogen.   Hydrogen  sulfide  gas is released from the sample and collected in gas scrubbing bottles
containing zinc and a strong acetate buffer.  Zinc sulfide precipitates and is then oxidized to sulfur by
adding a known  amount of excess iodine.  The solution is then titrated with a  standard  of sodium
thiosulfate to quantify the sulfur content. The MDL is approximately 0.2 mg/L.
                                              2-6

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Determination of Effluent Bleed Rate

The amount of effluent bled from the THIOPAQ™ system will be measured during each of the three
events tested.  The average bleed rate will be used in conjunction with the measured sulfate and sulfide
concentrations to estimate the daily sulfate and sulfide emission rate in units of mg/day.

Effluent bleed rate will be determined by collecting the liquid from each of the three  events in a tared
container. The container and collected liquid will then be weighed on-site using a digital scale.  The total
mass  (Ibs) of liquid collected during the three  events will be divided by the total number of days that
passed between the last bleed event prior to the verification period and the third batch tested. This value
will represent the average daily amount of liquid bled from this THIOPAQ™ system.  The liquid mass
values will be converted to volume (gallons) using specific gravity data  determined by CT Laboratories
on each of the samples (Standard Methods 2710F (6)).  The average sulfate and sulfide liquid emission
rate will then be calculated and reported in units of Ib/day.

The digital scale that will be used for field determinations is a Digi Matex Model DI 28 S-SL. The scale
has a range of 100  Ibs and a factory calibration of ± 0.02 percent.  The scale will be field-calibrated
following procedures detailed in Section 3.2.2.  Appendices A-4 and A-5 provide log forms for effluent
bleed rate determinations and field calibration of the  scale.
2.3   OPERATIONAL PERFORMANCE

The GHG Center will also verify the operational performance of the THIOPAQ™ system during the
three-day testing period at the  host WPCF.  Operational performance  of the Shell-Paques system in
Bantry, Alberta, will be conducted during a one-day test period.  The verification parameters listed in
Section 2.1 will be evaluated through direct on-site measurements and analysis of collected samples. All
testing will  be conducted during stable plant operations with proper THIOPAQ™ system operations
confirmed by site operators.  Results of the testing will be used to report air and liquid emissions of H2S
and other sulfur compounds listed in Section 2.2.1.  The following  sections detail the measurements and
test methods that will be used.

2.3.1    H2S Removal Efficiency and Gas Quality

Testing will be  conducted to  evaluate  the  THIOPAQ™ system  performance by  comparing the
composition, heating value, and contaminant concentrations of raw gas to that of processed gas. The
following gas compositional and quality criteria will be evaluated on raw and processed gas samples:

    •    Gas properties (gross and net heating value, density, and compressibility)
    •    Gas composition (N2, O2, CO2, and Ci through C6)
    •    Sulfur compounds (primarily H2S)

A minimum of nine gas samples will  be collected for  the THIOPAQ testing on both the upstream and
downstream sides of the scrubber, including three on each of three consecutive days.  The time interval
between gas sampling events will be at least one hour. Results of the analyses will be used to evaluate
removal efficiency for H2S and  other sulfur compounds and to examine the gas quality before and after
treatment. The results will also allow  the Center to evaluate the effects, if any, on gas composition and
heating value.  Gas samples will not be collected at the  Bantry site. Gas composition and quality reports
generated by the facility will be obtained and reported, but not independently verified.
                                              2-7

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Determination of H?S Removal Efficiency

THIOPAQ™ system H2S removal efficiency will be calculated according to the following equation:


       RE = l-(Cout/Cin)*100                                           (Eqn.4)

where:
       RE =  removal efficiency, %
       Cm  =  H2S concentration in raw gas, ppmv
       Cout =  H2S concentration in processed gas, ppmv

Gas  samples for analysis of H2S and other sulfur compounds (listed earlier in Section 2.2.1) will be
collected in Tedlar bags.  Raw biogas samples will be collected from sampling ports in the scrubber inlet
and outlet gas lines at the site with the THIOPAQ™ system. Gas pressures at both locations are expected
to be less than 1 psig, so the bags will be filled using line pressure. Gas pressure in the scrubber inlet line
at the Bantry plant will be around 1000 psig, so a regulator will be installed at the sampling port to allow
safe  collection of gas  in the bags.  Appendix A-l provides more detail regarding the gas sampling
procedures.  All samples will be properly labeled and documented using the log form shown in Appendix
A-2.

Collected  gas samples will be handled using the same procedures for the  air sampling and handling
described in section 2.2.1. Samples will be protected from light and analyzed withing 24 to 30 hours after
collection.  Analysis will be conducted by a laboratory that specializes in  fuel gas analyses (Empact
Analytical Systems, Inc., of Brighton, Colorado), following ASTM Method 5504  (7).  A known volume
of sample is injected into a gas chromatograph (GC) equipped  with a molecular-sieve column for analysis
of sulfur  species.   The  sulfur components  elute from the  GC and they are  transferred  to a  sulfur
chemiluminescence detector (SCD)  for quantitation. Resultant peaks in the chart trace are determined for
each compound. These areas are compared to the areas of the  same compounds contained in a calibration
reference  standard that is analyzed under identical conditions.  A total of 20  sulfur compounds  are
included in the analysis with individual compound reporting limits of 4.0 ppbv.

QA/QC procedures for this analysis include instrument calibrations, laboratory control samples, internal
standards, laboratory  blanks, and  duplicate  analyses.  Details regarding the QA/QC procedures  are
presented in Section 3.3.1.

Determination of Gas Composition and Quality

The  field team leader will collect a  corresponding set of gas samples in 600-ml stainless-steel gas
sampling canisters concurrent with the gas sampling described above.  These samples will be shipped to
Empact for compositional analyses  and determination of gas LHV. The samples  will be collected at the
same locations as the bag sampling described above.

The  laboratory evacuates the canisters to prepare them for  sampling.  Test personnel will check  the
canisters with a vacuum gauge to ensure that they remain under vacuum and are leak-free prior to sample
collection.   Canisters  that are  not  fully evacuated will not be used or will be  evacuated  on  site and
checked again before use. Appendices A-l, A-2, and A-6 contain detailed sampling procedures, log, and
chain-of-custody forms.
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Compositional  analysis will  be conducted  in  accordance with ASTM  Specification  D1945 (7) for
quantification of speciated hydrocarbons, including methane through pentane (Ci through pentane C5),
heavier hydrocarbons (grouped as hexanes  plus  C6+), N2, O2, and CO2 at the laboratory.  The lab
procedure specifies sample gas is injected into a Hewlett-Packard 589011 GC equipped with a molecular-
sieve column  and  a thermal conductivity  detector (TCD).   The  column  physically separates  gas
components, the FID detects them, and the instrument plots the chart traces and calculates the resultant
areas for each compound. The instrument then compares these areas to the areas of the same compounds
contained in a calibration reference standard analyzed under identical conditions.  The reference standard
areas are used to determine instrument response  factors for each compound and these factors are used to
calculate the component concentrations in the sample.

The  laboratory calibrates the instruments weekly with the reference standards. The instrument operator
programs the analytical response factors  generated for each compound  analyzed  into the instrument
during calibrations.  Allowable method error during calibration is ±  1 percent of the reference value of
each gas component. The laboratory re-calibrates the instrument whenever its performance is outside the
acceptable calibration limit of ± 1 percent for each component.  The GHG Center will obtain and review
the calibration  records.  Each sample  will also be analyzed  in duplicate to  reconcile data quality
objectives (Section 3.3.2).

The laboratory will use the compositional data to calculate the gross (HHV) and net (LHV) heating values
(dry,  standard  conditions), compressibility  factor,  and the  specific gravity of the  gas  per ASTM
Specification D3588  (8).  The data quality of the heating  value determinations  is  related  to the
repeatability of the ASTM D1945 analysis.
2.3.2    NaOH Consumption

The design NaOH concentration in the make-up tank is 50 wt%.  However, it is diluted with make-up
water to about 4 wt% before entering the system.  The NaOH usage estimated in the design was 9.25
kg/day. The host facility continuously monitors the amount of NaOH added to the system using a tank
level sensor in the NaOH holding tank.    The data is transmitted to the plant data acquisition system.
The data will be provided to the Center and used to document NaOH addition rates and trends during the
test period. Review of historical tank level data indicate that during each day of normal system operation,
the tank level drops around 3 to 4 inches.

NaOH consumption will be reported  for each of the three days of verification testing in units of gallons
per day. A field reasonableness check will  be conducted on the level  sensor readings as described in
Section 3.3.3.

2.3.3    Solids and Elemental Sulfur Production

A batch of solids slurry is drawn from the settling tank at the plant and directed to the vacuum filter where
water is extracted from the slurry stream and returned to the bioreactor.  The resultant solids cake is then
collected in a container for disposal.  The Center will determine the  average solids and elemental sulfur
production rate in units of Ib/day using the following procedures.

   (1)  Determine the mass of solids  collected during each of the three days of testing.
   (2)  Collect a sample of each of the three batches for sulfur and moisture analyses.
                                              2-9

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Determination of Solids and Sulfur Production Rate

The amount of solids produced by the process will be verified daily during the three-day test period.
Current operations at this facility allow the solids  cake to fall off of the vacuum filter press into a large
collection bin for subsequent disposal. The bin will be emptied and lined with a clean, pre-weighed sheet
of polyethylene at the beginning of the verification period.  Solids from the THIOPAQ™ system will be
deposited into the bin following standard system operations on the first day of testing.  The material will
be gathered in the polyethylene sheet and a final weight obtained. The difference between the initial and
final weights will be the mass of material collected that day. The  process will be repeated on the two
remaining days of testing and the three results will be averaged.

All weights will be determined using the same  scale and  procedures  specified in  Section  2.2.2  for
determination of effluent bleed rates.  The QA/QC procedures outlined in Section 3.3.4 will also apply for
these determinations.

Elemental Sulfur and Moisture Content

Solids  cake  samples will be collected   and shipped to Commercial  Testing  and  Engineering  for
determination  of sulfur and moisture content.  Sulfur purity in the filter cake  is estimated  using an
extraction and drying process. The large  amount of liquid in the filter cake will require that moisture
analyses be  conducted prior to the sulfur  analyses.  The  sulfur and moisture analytical procedures  are
shown in Appendix A-6.

The amount of moisture in the sample is  determined by  weighing 50 grams of undried sample into  a
previously dried, cooled, and weighed 100- by 15-mm Petri dish.  The sample is then dried at 105°C for
one hour. The sample is weighed after cooling in a desiccator.   This dried sample can be  used for the
sulfur determination.

The sulfur analysis begins by weighing a 1-gram specimen  in a fritted-glass  extraction thimble.   The
sample is extracted in the extraction apparatus for at least 15 minutes with carbon disulfide  (CS2).  The
container is  removed, dried, and weighed.   The percentage of insoluble residue is reported as foreign
matter (including the ash).  The percentage of sulfur, defined as the CS2 soluble fraction, is the difference
between 100 and the percentage of foreign matter (to the nearest 0.1%).

2.4     PROCESS OPERATIONS MONITORING

All of the process operational parameter monitored by the site are recorded, logged, and stored by plant
operational systems.  Table 1-1 summarized the key system operational measurements that will be used to
document THIOPAQ™ operations throughout the verification period.  The facility will provide  biogas
flow rate, scrubber fluid flow rate, and NaOH level data to the  GHG Center, and the report will include
15-minute averages for each of these  parameters  during the test  periods.   Other parameters such as
conductivity and air flow to the bioreactor are considered proprietary to the Paques systems  and will not
be included.
                                              2-10

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                                  3.0
                                   DATA QUALITY
       3.1.
               BACKGROUND
The GHG Center selects methodologies and instruments for all verifications to ensure that the desired
level  of data quality in the  final results is  obtained.  The  GHG  Center specifies  DQOs  for each
verification parameter before testing starts and uses these goals as a statement of data quality.  Ideally,
quantitative DQOs are established based on  the level of confidence in results needed by stakeholders or
potential users of a technology.  In some cases, such as this verification, quantitative DQOs are not well
defined and therefore, qualitative DQOs are established.

During this verification, determination of  each of the primary verification parameters will be conducted
based on published reference methods.  The qualitative DQOs for this verification, then, are to meet all of
the QA/QC requirements of each method. Each of the methods were introduced in Section 2.0 of this
TQAP and are listed below. Additional details regarding the QA/QC requirements of each method are
provided in the following sections.
                           Table 3-1. Verification Reference Methods
Verification Parameter
H2S air emissions (vent)
Sulfate emissions
Sulfide emissions
H2S removal efficiency
Gas Quality
NaOH consumption rate
Sulfur production
Required Measurements
H2S Concentrations
Air Flow Rate
Sulfates in water
Sulfides in water
Raw gas H2S content
Processed gas H2S content
Gas composition
Gas heating value
NaOH consumption rate
Solids production
Solids moisture content
Solids sulfur content
Applicable Reference
Methods
Modified ASTM D5504
EPA Reference Method 2
EPA Method 9056
EPA Methods 903 OB and
9034
ASTM D5504
ASTM D 1945
ASTMD3588
None, see Section 3.3.3
None, see Section 3.3.4
3.2
ENVIRONMENTAL PERFORMANCE PARAMETERS
The primary verification parameters for environmental performance are air emissions of H2S and sulfate
and sulfide effluent emissions. The DQOs for these parameters identified in Table 3-1 are detailed below
along with explanations of the DQIs for each supporting measurement.
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3.2.1   H2S Air Emissions

Two measurements are  required to determine emissions of H2S from the bioreactor.  These are H2S
concentrations in the vent gas and vent gas flow rate. The combined error in these two measurements are
the basis for the 30-percent relative error DQO stated in Table 3-1 for this parameter.  Air Toxics, Ltd.,
will be analyzing collected samples in accordance with a modified version of ASTM Method 5504. The
QA/QC procedures specified in  the method will be followed, but acceptance criteria are  modified to
account for the fact that the sample matrix is air (the method  is designed for gas samples),  and
concentrations of H2S and other sulfur compounds are expected to be very low.  Table 3-2  summarizes
the QC checks and the corresponding performance criteria.

                  Table 3-2. Summary of Vent Gas H2S Analyses QA/QC Checks
QC Check
Three -point instrument
calibration
Analysis of laboratory
spiked sample
Daily single-point
calibration reanalysis
(continuing calibration)
Minimum Frequency
Monthly
Daily, in conjunction with
sample analyses
Daily, after sample analyses
Acceptance Criteria
Three consecutive analyses of standards
with a relative standard deviation less
than 30%
Recovery within 30% of expected values
Within 30% of calibration standard
Documentation from Air Toxics, Ltd., that each of these QC checks was conducted and achieved will
indicate that the qualitative DQO was met.

As an additional QC check, the  GHG Center will supply one blind/audit air sample to the laboratory for
analysis. The audit gas will be  an independent Reference Standard of H2S in air manufactured by Scott
Specialty Gases with a certified analytical accuracy of ± 5 percent.  The audit sample will be collected,
handled, and analyzed using the same procedures and equipment as the air samples. It will be submitted
to the laboratory along with the vent samples collected during one of the test days. This QC check will
serve as a performance evaluation audit (PEA) for this verification, and will be reported to the Southern
QA Manager for inclusion in the audit report. The audit will also allow the GHG Center to evaluate H2S
losses in the air samples.

Determination of air vent flow  rate  includes measurement of exhaust gas concentrations of velocity as
differential pressure across a pitot tube and temperature. Method 2 specifies that a standard pitot be
assigned an accuracy coefficient of 0.99.  Method 2  calibration criteria also require that  testers perform
pre-  and post-test thermocouple calibrations by subjecting the thermocouples used during testing to the
average temperature found during testing.  These readings will be compared to the readings of a NIST-
traceable reference thermometer. The thermocouple  reading must be within 1.5 percent of the reference
thermometer to  be considered acceptable.   Details on thermocouple  calibration are  referenced in
40CFR60 Method 2, Section 10.3.1.  The Dwyer manometer is  a primary standard and does not require
calibration.

These calibrations will provide documentation that the accuracy of each of the individual measurements
conformed to reference  method specifications.   An overall uncertainty of ± 2 percent of reading is
                                              3-2

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therefore assigned for air flow rate, based on propagation of the sum of the squares of the individual
measurement errors (9).

Determination of mass emission rates for each pollutant in the vent gas is a multiplicative function of the
concentration measurement and the exhaust stack flow rate. An estimate of the compounded error, using
two multiplied values, is shown in Equation 5 (10):
                       err.
           err,
              c,rel
                    JI  valuel
     value-.
                                                         (Eqn.5)
       Where:   errC]rel   =
                 err2
                 value i
                 value2
Compounded error, relative
Error in first multiplied value, absolute value
Error in second multiplied value, absolute value
First multiplied value
Second multiplied value
The target error for concentration measurement error for H2S is expected to be ±30 percent and air flow
rate error is ±2 percent.  The compounded error is ±30 percent, as shown in the following example
calculation, and this is the DQO for vent emissions.
               Error in H2Svented = 
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                Table 3-4. Summary of Effluent Sulfide Analyses QA/QC Checks
QC Check
Analysis of a check standard
(a known quantity of sodium
sulfide)6
Analysis of a matrix-spiked
samplec
Minimum Frequency
Once per twenty samples
Once per twenty samples
Acceptance Criteria"
Not specified
Not specified
 a Method uncertainty can be estimated after the QC checks are completed.
 b The check standard provides an evaluation of the accuracy of the titration procedures.
 c The matrix spike provides an evaluation of the entire sample preparation, handling, and titration
 procedures.  Recoveries are estimated to be in the range of 8 to 23 percent.	

Documentation from CT Laboratories that each of these QC checks were conducted will indicate that the
qualitative DQO was met.

Effluent bleed rate is calculated using the mass of liquid collected over a known time period.  The DQI
for this measurement will be the accuracy of the scale used for weighing the collected liquid.  The Center
maintains a factory calibration  for the  Digi Matex scale, but field calibrations will be  used to assess
accuracy during the verification.  Calibrations will be performed before and after testing using a series of
standard  weights (Appendix A-3).  These calibrations will verify the accuracy of the scale to within ±1
percent of reading. The scale will be replaced or repaired if this accuracy is not demonstrated in the field
prior to testing.

The DQOs for sulfate and sulfide emissions then are the combined errors of 10 percent (sulfate) or  15
percent (sulfide) and ±1 percent for mass.  The errors are propagated as demonstrated  earlier and the
DQOs for sulfate and sulfide emissions are ±10 and 15 percent, respectively.
3.3    OPERATIONAL PERFORMANCE PARAMETERS

The  primary verification parameters for operational performance are  H2S removal efficiency, NaOH
consumption, and sulfur production rates. DQOs for each of these parameters were identified in Table 3-
1 and are detailed below along with explanations of the DQIs for each supporting measurement.  DQIs are
also presented below for gas quality parameters (composition and LHV).

3.3.1    H2S Removal Efficiency

The QA/QC requirements of Method 5504 are summarized in Table 3-5. The method does not specify
acceptance criteria for the QA/QC requirements, so the GHG Center has established data quality goals for
each check.   Actual results of these checks will be reported after testing, but recent similar analyses
conducted by Empact indicate that these goals will likely be met.

Documentation from Empact Analytical that each of these QC checks were conducted and goals achieved
will indicate that a DQI of ±10 percent has been achieved.
                                              3-4

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                   Table 3-5. Summary of Biogas H2S Analyses QA/QC Checks
QC Check
Three -point instrument
calibration
Daily single-point
calibration
Analysis of spiked sample
Daily single-point
calibration reanalysis
Minimum Frequency
Monthly
Daily, prior to sample analyses
Once during sample analyses
Daily, after sample analyses
Data Quality Goals
None - establishes instrument calibration
curve
Three consecutive analyses of standard
within a range of 5% of expected values
Recovery within 10% of expected values
Within 10% of calibration standard
The WPCF hosting the test provided the Center with preliminary biogas data. The data show the scrubber
inlet and outlet H2S concentrations for samples collected on 14 days in October 2003. The data indicate
average H2S concentrations of 12,276 ppmv and  13.9 ppmv at the scrubber inlet and outlet, respectively.
Equation 4 from Section 2.3.1 showed that corresponding removal efficiency averaged 99.89 percent as
shown below.

        99.89 =(1 - (13.9/12,276)) * 100 , or
        99.89 =(1 - (0.001132)) * 100

The value "0.001132" represents the fraction of H2S not removed by the scrubber. The relative error in
the two measurements  contributing to that value is ±10  percent each.  The  total  error is,  therefore,
determined by calculating the sum of the squares of the two measurement errors as follows:

        Relative error = 0.001132 ± (O.I2 + O.I2)172, or 0.001132 ±14.1 percent

If the ±10  percent  analytical error  DQIs are  met for  the two  analyses, then  the uncertainty  in
determination of the fraction of H2S not removed is then ±14 percent.

3.3.2    Gas Composition, HHV and LHV

Field  personnel will collect raw and processed biogas samples as described in Section  2.3.1 and submit
them for laboratory analysis to determine gas composition and FIFfV/LHV. Compositional analyses will
be conducted according to ASTM D1945 and LHV will be calculated based on the composition according
toASTMD3588.

ASTM D1945 repeatability directly affects the ASTM D3588 HHV and LHV data  quality.  The LHV
repeatability is approximately 0.84 Btu/ ft3, or about 0.1 percent, provided the D1945 repeatability criteria
are met.  Duplicate analyses will be conducted on each sample submitted.  The ASTM allowable method
error during calibration is ± 1.0 percent of the reference value for each component.

The compounded accuracy of the two  methods,  including  repeatability, allowable calibration  error, and
uncertainty in the calibration reference standard  (±2 percent) therefore, is 2.2 percent.  Achievement of
proper calibrations and repeatability imply that use of these two ASTM methods will ensure that HHV
and LHV data are accurate to ± 2.2 percent or better.  Empact Analytical will provide the complete
calibration and repeatability data to the  Center when results  are submitted.
                                              3-5

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As an additional QC check, the GHG Center will supply one blind/audit gas sample to the laboratory for
analysis. The audit gas will be an independent Natural Gas GPA Reference Standard manufactured by
Scott Specialty Gases with a certified analytical accuracy of ± 2 percent. The audit gas will be shipped to
the test location and the Field Team Leader will collect a canister sample of it immediately after one of
the gas samples is collected. He will ship the audit sample to the laboratory with the other fuel samples.
The  laboratory will analyze the audit sample in duplicate.  The GHG Center will compute the average
result from  the  two analyses and will  compare the results to the certified concentration  of each
constituent.  This QC check will serve as a second PEA for this verification.

3.3.3   NaOH Consumption

The NaOH consumption is currently measured at the WPCF with a Milltronics (Process Instruments Inc.)
level transmitter that relays the liquid levels (height) in the tank to the WPCF's data acquisition system.
NaOH consumption is monitored continuously by tracking the liquid levels in the tank.

The  Center will evaluate the accuracy of the level sensor data using a direct measurement field check.
Specifically, NaOH consumption will be measured during the test period by measuring the flow rate of
NaOH from  a hose attached to the metering pump (after the NaOH tank) into a five-gallon bucket placed
next to the pump. The mass of solution collected over a known time period will be recorded.  The NaOH
consumption measured by the field team  leader with the pump flow test will be compared to the level
sensor reading recorded on the DAS.  The pump flow test will be  considered acceptable for deviations of
less than 10 percent between the two NaOH consumption methods.

3.3.4   Sulfur Purity and Production

Determination of sulfur purity and production was described in Section 2.3.3. Three measurements are
required including determination of solids production  rate, moisture content, and estimation of sulfur
purity.  A field calibration of the scale used to determine solids production rate will  be conducted. The
scale and calibration procedures were described in Section 2.2.3.

The  methods that will be used to determine moisture and sulfur content are procedures developed and
used internally by  Commercial Testing (not published  reference  methods).  Therefore, QA/QC checks
will be limited to Commercial Testing's internal QA policies. The Center will procure and maintain the
lab's Statement of quality and standard operating procedures. The Center will also obtain and review the
calibration data for the analytical balance used for the analyses.  Analytical uncertainty is expected to be ±
10 percent or better for both determinations.
3.7   INSTRUMENT TESTING, INSPECTION, AND MAINTENANCE

GHG Center personnel, the field team  leader, laboratories, and/or contracted test organizations will
subject all test equipment to the pre- and post-test QC checks discussed earlier.  Operators will assemble
and test it as anticipated to be used in the field before the equipment leaves the GHG Center or analytical
laboratories.  They will operate and calibrate all controllers, flow meters, computers, instruments, and
other sub-components of the measurements system as required by the manufacturer and/or this TQAP.
Any faulty sub-components will be repaired or replaced before being transported to the test site.  Test
personnel will maintain  a small amount of consumables and frequently needed spare parts will  be
maintained at the  test site.   The  Field Team Leader and Project Manager  will handle major sub-
component failures  on  a  case-by-case basis  (e.g., by  renting replacement equipment or buying
replacement parts).
                                              3-6

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                      4.0  DATA ACQUISITION, VALIDATION, AND REPORTING


4.1   DATA ACQUISITION AND STORAGE

Test personnel will acquire the following types of data during the verification:

    •    Continuous measurements (i.e., process operational parameters collected by the sites'
        operating systems)
    •    Vent air pollutant concentrations
    •    Effluent sulfur concentrations
    •    Vent air flow and effluent flow rate measurements
    •    Gas composition, heating value, and H2S content from biogas sample analyses
    •    NaOH consumption rates
    •    Sulfur product purity analyses  and production rates

The field team leader will also take site photographs and maintain a Daily Test Log which includes the
dates and times of setup, testing, teardown, and other activities.

The field team leader will submit digital data files, gas analyses, chain-of-custody forms, and the Daily
Test Log to the Project Manager.   The Project Manager will initiate the data review, validation, and
calculation process. These submittals will form the basis of the VR which will present data analyses and
results in table, chart, or text format as suited to the data type. The VR's conclusions will be based on the
data and the resulting calculations.  The GHG  Center will archive and store all data in accordance with
the GHG Center QMP.

The field team leader will retrieve, review, and validate the  collected data  at the end of each day of
testing.  The  field team  leader will record manually acquired data (i.e., test  run  information and
observations) in the Daily Test Log and on the log forms in Appendix  A.  Disk copies of the Excel
spreadsheet results will be made at the  end of each  day.

Section 3.0 discussed the data quality assurance checks for the instruments illustrated in Figure 2-1. The
field team leader will maintain manual and electronic records (as required) resulting from these checks.

The GHG Center will store original field data forms, the Daily Test Log, and electronic copies of data
output and statistical  analyses at the  GHG Center's RTP office per guidelines described in the GHG
Center's QMP after the completion of all test runs.

4.1.2    Laboratory Analyses

Sections 2.0 and 3.0 discussed biogas, effluent, and solids sampling and QA/QC.  The field team leader
will maintain sampling logs and chain-of-custody records. The laboratory will submit results  for each
sample, calibration records, and repeatability test results to the field team leader after the  field test. The
GHG Center will store original lab reports,  electronic data copies, and statistical analyses at the GHG
Center's RTP  office  per guidelines described in the GHG Center's QMP.  The  field team leader will
compute the actual electrical efficiency at each load tested and report the  results to the project  manager
after receipt of the laboratory analyses.
                                             4-1

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4.2   DATA REVIEW, VALIDATION, AND VERIFICATION

Data review and validation will primarily occur at the following stages:

    •   On-site ~ by the field team leader
    •   Before writing the draft Verification Report ~ by the project manager
    •   During QA review of the draft Verification Report and audit of the data ~ by the GHG
       Center QA Manager

Section 1.5 identifies the individuals who are responsible for data validation and verification.

The field team leader will be able to review,  verify, and validate some data while on-site.  Other data,
such as analytical results from the laboratories must be reviewed, verified, and validated after testing has
ended. The project manager has overall responsibility for these tasks. All collected data will be classed
as valid,  suspect, or invalid after review.  The GHG Center will use the QA/QC criteria discussed  in
Section 3.0 and specified in the associated tables.

Valid results  are  based  on measurements which meet the  specified DQIs and  QC checks. They were
collected when an instrument was verified as being properly  calibrated  and they  are consistent  with
reasonable expectations (e.g., manufacturers' specifications, professional judgment).

The data review process often identifies anomalous data. Test personnel will investigate all outlying  or
unusual values in the field as is possible.  Anomalous data may be considered  suspect if no specific
operational cause  to  invalidate the data is found.

The VR will incorporate all data-valid,  invalid, and suspect. However, report conclusions will be based
on valid data only and the report  will justify the reasons for excluding  any data.  Suspect data may be
included  in the analyses,  but may be  given  special treatment as specifically indicated.  The Project
Manager will decide to continue the test, collect additional  data, or terminate the test and report the data
obtained if the DQI goals cannot be met due to excessive data variability.

The QA Manager will review and validate the data and the draft VR using the TQAP and test method
procedures as source material.  The data review and data audit will be conducted in accordance with the
GHG Center's  QMP.  For example, the QA Manager will  randomly select raw data and independently
calculate the  performance verification  parameters dependent on that data.  The comparison of these
calculations with the results presented in the draft VR will yield an assessment of the QA/QC procedures
used by the GHG  Center.

4.3   RECONCILIATION OF DATA QUALITY OBJECTIVES

A fundamental  component of all verifications is the reconciliation of the data and its quality as collected
from the field with the  DQOs.  The field  team leader and project  manager will typically  review the
collected data to  ensure  that they are valid and are consistent with expectations.  They will  assess the
quality of the data in terms of accuracy  and  completeness as they relate to the  stated DQI goals. Section
3.0 discusses each of the verification parameters and their contributing measurements in detail.  The
procedures that field personnel will use to ensure that DQIs  are achieved are also specified in Section 3.0.
Analysts will conclude that DQOs were achieved if the test data show that DQI goals were met.  DQIs
and DQOs  will therefore be reconciled. The GHG Center will assess achievement of certain DQI goals
during field testing  because QC checks and calibrations will be performed on-site or prior to testing.
                                             4-2

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Other DQIs,  such as gas analysis repeatability, will  be reconciled after field tests  have concluded.
Finally, the quality manager will also conduct an independent reconciliation of DQOs.

4.4   ASSESSMENTS AND RESPONSE ACTIONS

The  Field Team Leader, Project  Manager, QA Manager, GHG Center Director,  and technical peer-
reviewers will assess the quality  of the project and associated data.   The  Project Manager and QA
Manager independently oversee the project and assess its quality through project reviews, inspections  (if
needed),  a technical  systems audit (TSA), the two PEAs described in  Section 3, and an audit of data
quality (ADQ).

4.4.1    Project Reviews

The  project manager is responsible for project data review and writing project reports.  He is also
responsible for conducting the first complete project assessment.  Project personnel are involved with
ongoing data review but it is the project manager's responsibility to ensure that project activities meet the
measurement and DQO requirements.

The GHG Center Director performs the second project review.  The Director is responsible for ensuring
that the project's activities adhere  to the ETV program requirements and stakeholder expectations. The
GHG Center Director's review will also include an overall project assessment to ensure that the field team
leader has the equipment, personnel, and resources to complete the project as required and to deliver data
of known and defensible quality.

The third review is that of the QA  Manager, who is responsible for ensuring that the  project management
systems function as  required by the QMP and corporate policy.  The QA Manager  is the final reviewer
within the Southern organization and is responsible for assuring the achievement of all QA requirements.

The  vendor (NATCO) and selected members of the Center's stakeholder groups will then review the
report. Technically competent persons who are familiar with the technical aspects of the project, but not
involved with the conduct of project activities, will perform the peer-reviews.  The peer-reviewers will
provide written comments to the project manager. Further details on project review  requirements can  be
found in the GHG Center's QMP.

The draft report will then be submitted to EPA QA personnel, and the project manager will address their
comments as needed.  The VR and VS will  undergo EPA management reviews,  including the  GHG
Center Program Manager, EPA ORD Laboratory  Director, and EPA Technical Editor following this
review.

4.4.2   Technical Systems Audit

An internal Technical Systems Audit (TSA) of this test will be conducted by Southern's QA Manager.
EPA QA/G7 states that TSAs are "thorough, systematic, and qualitative audits of the measurement system
used in environmental data operations", which "are  usually performed  on the site  of the project." The
objective of the TSA is to assess  and document acceptability of all facilities, maintenance, calibration
procedures, reporting requirements, sampling and analytical activities, and quality control procedures. As
implemented by the GHG Center, the approved TQAP (this document) provides the basis for the TSA.
Objective evidence  is gathered by interviewing personnel, examining records, and  observing project
activities. Audit findings are brought to the attention of GHG Center management in a written  Audit
Report.
                                            4-3

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The GHG Center also anticipates that independent TSAs will be conducted by the EPA QA Manager of at
least one test per year. The GHG Center technical and QA staff will assist in the audit and respond to its
findings as required if the EPA QA Manager elects to conduct a TSA on this test.
4.4.3    Performance Evaluation Audits

Two performance evaluation audits (PEAs) will be conducted as described in Section 3.0.  These include
submittal of a blind H2S in air reference standard as an analytical audit on vent air samples.  The second
PEA is submittal of a natural gas reference  standard as an analytical audit on biogas  compositional
analyses.  The Field Team Leader will evaluate the performance data for compliance with the project
requirements and report the findings to the QA Manager upon receiving the analytical  data from the
analysts.

4.4.4    Audit of Data Quality

The ADQ is an evaluation of the measurement, processing, and data evaluation steps to determine if
systematic errors have been introduced.  The QA Manager will randomly select approximately 10 percent
of the data to be followed through the analysis and data processing during the ADQ.  The scope of the
ADQ is to verify that the data-handling system functions correctly and to assess the quality of the data
generated. The ADQ also includes review of QC documentation to verify that the planned QC checks and
calibrations  were performed and were within  acceptance  specifications.  This process includes  the
independent review of DQI data and calculation of DQO attainment. The ADQ also includes review of
any problems, changes, or corrective actions documented during the test program to verify that their
impact on data quality has been assessed and documented.

The ADQ, as part of the project QA review, is not an evaluation of the reliability of the data presentation.
The review of the data presentation is the  responsibility of the project manager  and the technical peer-
reviewer.

4.5   DOCUMENTATION AND REPORTS

Documentation and proper information reporting for the different project activities is critical. The project
manager, field personnel, vendor representatives, and QA personnel must be  involved. The GHG Center
will prepare the following field test documentation, QC documentation, corrective  action/assessment
report, and verification report/statements to  insure the complete transfer of information to all parties
involved in this project.

4.5.1    Field Test Documentation

The field team leader will record all important field activities.  The field team leader will review all data
sheets and maintain them in an organized file.  Sections 2.0 and 3.0 describe the required test information.
The field team leader  will  also maintain  a daily test  log that documents  the  field  team's activities,
significant events, and any schedule deviations from the schedule or TQAP.   The field team leader will
immediately report any major problems that require corrective action to the project manager through a
CAR.
                                             4-4

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The  project manager will check the test  results with the field team leader's assistance to determine
whether the QA criteria were satisfied.  The GHG Center Director will be notified following this review
and confirmation that the appropriate data were collected and DQOs were satisfied,

4.5.2   QC Documentation

The  completion of the verification test will be followed by the collection of test data,  sampling logs,
calibration records, certificates of calibration, and other relevant information for storage in the project file
in the GHG Center's RTF office. Calibration records will include information about the instrument being
calibrated, raw calibration  data,  calibration  equations, analyzer  identifications,  calibration  dates,
calibration standards used and their traceabilities,  calibration equipment,  and  staff conducting the
calibration.  These records will be used to prepare the Data Quality  section in the Verification Report, and
made available to the QA Manager for internal audits and final report QA review.

4.5.3   Corrective Action and Assessment Reports

A corrective action must occur when (1) deviations from the TQAP  occur due to unforeseen events or
problems or (2) when the result of an audit or quality control measurement is  shown to be unsatisfactory
(as defined by the DQOs or by the measurement objectives for each task). The corrective action process
involves the field team leader, project manager, and QA Manager.

Immediate corrective action  responds quickly  to improper  procedures, indications  of malfunctioning
equipment,  or  suspicious  data. This TQAP includes validation processes to ensure data quality and
establishes predetermined  limits for data acceptability.  Consequently, data determined to deviate from
these objectives require evaluation through an immediate correction action process. The field team leader,
as a result of calibration checks and internal quality control sample  analyses, will most  frequently identify
the need for such an action.  The field team leader will immediately notify the project manager and will
take  and document appropriate action. The project manager is responsible for and is authorized to halt the
work if it is  determined that  a  serious  problem  exists.   The  field  team  leader  is  responsible for
implementing  corrective actions identified by the project manager and is authorized  to implement any
procedures to prevent the recurrence of problems. A written Corrective Action Report (CAR), included in
Appendix A-6, is required on major corrective  actions that deviate from the  TQAP.  The CAR will be
routed to the QA Manager and retained in the project files.

The QA Manager will route the results of internal assessments (TSA and ADQ) to the project manager for
review, comments, and corrective action.  The  results will be documented in the  project records. The
project manager will take any necessary corrective  action needed and  will address the QA  Manager's
comments in the final Verification Report.

4.5.4   Verification Report and Verification Statement

The project manager will coordinate preparation of a draft VR and VS within 8 weeks of completing the
field test,  if possible. The VR will summarize the  results for each verification parameter discussed in
Section 2.0 and will contain sufficient raw data to support findings  and allow others to  assess data trends,
completeness,  and quality.  Clear statements will be  provided which characterize the performance of the
verification parameters identified in Sections 1.0 and 2.0. The VR will contain a VS, which  is a 3 to 5
page summary of the Paques technology, the test strategy used, and the verification results obtained.

The project manager will submit the draft VR and VS to the QA Manager and Center Director for review.
A preliminary  outline of the report is shown below.
                                             4-5

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Preliminary Outline
                         THIOPAQ and Shell-Paques Verification Report

Verification Statement

Section 1.0:    Verification Test Design and Description
               Description of the ETV program
               Technology and site description
               Overview of the verification parameters and evaluation strategies

Section 2.0:    Results
               Environmental performance
               Operational performance

Section 3.0:    Data Quality

Section 4.0:    Additional Technical and Performance Data (optional) supplied by the vendor

Section 5.0:    References:
Appendices:    Raw Verification and Other Data

4.6   TRAINING AND QUALIFICATIONS

The GHG Center's field team leader has extensive experience (+15 years) in field testing of air emissions
from  many types of sources.   He is also familiar with gas  flow measurements from  production,
processing, and transmission stations. He is familiar with the requirements of all of the test methods and
standards that will be used in the verification test.

The project manager has performed numerous field verifications under the ETV program and is familiar
with requirements mandated by the EPA and GHG Center QMPs.  The QA Manager is an independently
appointed individual whose responsibility  is  to  ensure the  GHG  Center's activities  are  performed
according to the EPA approved QMP.

4.7   HEALTH AND SAFETY REQUIREMENTS

This section applies to GHG Center personnel only.  Other organizations involved  in the project have
their own health and safety plans specific to their roles in the project.

GHG Center staff will comply with all known host, state/local, and federal regulations relating to safety at
the test facility.  This includes use of personal protective gear (e.g., safety glasses, hard hats, hearing
protection, safety toe shoes) as required by the host and completion of site safety orientation (i.e., site
hazard awareness, alarms, and signals).
                                             4-6

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                                    5.0    REFERENCES
(7).    American Society  for Testing and Materials, Standard Practice for Determination of Sulfur
       Compounds in Natural Gas by Gas Chromatography and Chemiluminescense. ASTM D5 5 04-01.
       West Conshohocken, PA. 2001.

 (2).    U.S. Environmental Protection Agency.  Code of Federal Regulations, Title 40, Part 60. New
       Source Performance Standards. Appendix A. Washington, DC. 1999.

(3)     U.S. Environmental Protection Agency. Office of Solid Waste. SW-846 - Revision 2, Method
       90 BOB-Acid-Soluble and Acid-Insoluble Sulfides:  Distillation.  Washington, DC. 1994.

(4)     U.S. Environmental Protection Agency. Office of Solid Waste. SW-846 - Revision 2, Method
       9034 - Titrimetric  Procedure for Acid-Soluble and Acid Insoluble Sulfides. Washington, DC.
       1994.

(5)     U.S. Environmental Protection Agency. Office of Solid Waste. SW-846 - Revision 2, Method
       9056 - Determination of Inorganic Anions by Ion Chromatography. Washington, DC. 1994.

(6).    American Public Health Association, American  Water Works  Association,  Water Pollution
       Control Federation, Standard Methods for the Examination of  Water and Wastewater.   20th
       Edition. Washington, DC. 1998.

(7).    American Society for Testing and Materials, Standard Test Method for Analysis of Natural Gas
       by Gas Chromatography. ASTM D1945-9GRI. West Conshohocken, PA. 2001.

(8).    American Society  for Testing and Materials, Standard Practice for Calculating Heat Value,
       Compressibility factor,  and  Relative Density of  Gaseous Fuels. ASTM D3588-98.  West
       Conshohocken, PA. 2001.

(9).    Shigehara, R.T.,  Todd, W.F.,  Smith,  W.S.,  Significance   of Errors  in  Stack  Sampling
       Measurements. Presented at  the annual meeting of the Air Pollution Control Association. St.
       Louis, MO. 1970.

(10).   Skoog, Douglas  A., and Donald M. West. Fundamentals of Analytical Chemistry. 4th Edition.
       CBS College Publishing. Philadelphia, PA. 1982.
                                             5-1

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                                    Appendix A

                      Test Procedures and Field Log Forms
                                                                                Page
Appendix A-l.     Gas Sampling Procedures	A-3
Appendix A-2.     Gas Sampling Log 	A-5
Appendix A-3.     Log Form for Field Calibration of Scale	A-6
Appendix A-4.     Determination of Effluent or Solids Removal Rate	A-7
Appendix A-5.     Sample Chain-of-Custody Record	A-8
Appendix A-6.     Corrective Action Report	A-9
Appendix A-7.     Sulfur and Moisture Analysis Methods	A-10
                                          A-l

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A-2

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                              Appendix A-l.  Gas Sampling Procedures


Important:   Follow these procedures to collect canister samples when the gas pressure is > 5 psi
above atmospheric pressure.

1.  Attach a leak free vacuum gauge to the sample canister inlet. Open the canister inlet valve and verify that the
canister vacuum is at least 15 "Hg. Record the gage pressure on the Gas Sampling Log form.

2.  Close the canister inlet valve, remove the vacuum gauge, and attach the canister to the gas line sample port.

3.  Open the  gas  line sample port valve and check all connections for leaks with bubble solution or a  hand-held
analyzer. Repair any leaks, then open the canister inlet valve.  Wait five (5) seconds to allow the canister to fill with
gas.

4.  Open the canister outlet valve and purge the canister with gas for at least fifteen (15), but not more than thirty
(30) seconds.  Close the canister outlet valve, canister inlet valve, and gas line sampling port valve in that order.

5.  Enter the  required information (date, time, canister ID  number, etc.) on the Gas Sampling  Log and Chain-of-
Custody Record forms. Remove the canister from the sampling port.


Important:   Follow these procedures  to collect  canister samples when  the gas pressure is <  5 psi  above
atmospheric pressure.

1.  Construct a leak free gas extraction and collection system such as shown in the following sketch.
                                               1
                                                               [X]- Flow Control Valves

                                     Gas Purge Vent
                                                                  ) - Pressure/vacuum Gauge
                        Peristaltic Pump
                                                       EX]
                                                           X
                                                                         Sample Canister
                                    Canister Evacuation Loop
2.  Make a leak free connection from the gas source to the inlet of the gas collection system.

3.  Using the control valves and vacuum gauge, check and record the sample canister vacuum.  If necessary, fully
evacuate the canister using the peristaltic pump and control valves. Record the final canister vacuum (should be -25
in. Hg or less).

4.  Isolate the evacuated canister and configure the valves so that gas is slowly vented through the purge vent (ensure
proper ventilation of gas before starting the purge). Purge for 10 seconds.

                                                                                              (continued)
                                                  A-3

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                               Appendix A-l  Gas Sampling Procedures
                                               (continued)


5. Close the purge vent and slowly open the valves upstream of the canister and allow the canister to pressurize to
no less than 2 psig.

6. With the pump still running, open the canister outlet valve and purge the canister for 5 seconds.  Sequentially
close the canister outlet valve, canister inlet valve, and pump inlet valve.  Turn off pump.

7. Record the date, time, gas temperature, canister ID number, and final canister pressure on log form.

8. Return collected sample(s) to laboratory with completed chain-of-custody form.


Important:  Follow these procedures  to collect bag samples when  the gas  pressure is  > 5  psi  above
atmospheric pressure.

1. Use the gas extraction and collection system to completely evacuate the tedlarbag.

2. Attach a leak free, stainless steel gas regulator to the  sampling port and control gas pressure to around 5 psig.
Purge the regulator for at least 15  seconds.

3. Attach the evacuated bag to the regulator using teflon tubing and allow the bag to fill completely.  Close the bag
valve and stop the flow of gas.

4. Record the date, time, gas temperature, canister ID number, and final canister pressure on log form.

5. Return collected sample(s) to laboratory with completed chain-of-custody form.


Important:  Follow these procedures  to collect bag samples when  the gas  pressure is  < 5  psi  above
atmospheric pressure.

1. Use the gas extraction and collection system to completely evacuate the tedlarbag.

2. Attach the evacuated bag to the sampling port using teflon tubing and allow the bag to fill completely.  Close the
bag valve and stop the flow of gas.

3. Record the date, time, gas temperature, bag ID number, and final canister pressure on log form.

4. Return collected sample(s) to laboratory with completed chain-of-custody form.
                                                  A-4

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                                  Appendix A-2. Gas Sampling Log
Project ID:_
Date:	
Location (city, state):_
Signature:	
Unit Description:,
Fuel Source (e.g., pipeline, digester):_
Note:  If desired,  assign random sample ID  numbers to prevent  the lab from attributing  analysis results to a
particular test or audit sample. Transfer sample ID numbers to Chain-of-Custody Record prior to sample shipment.
Date
















Time
















Run ID
















Sample ID
















Canister/Bag ID
















Initial Vacuum
("Hg)
















Notes:
                                                  A-5

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                      Appendix A-3. Log Form for Field Calibration of Scale
Project ID:

Date:
Location (city, state):

Signature:	
Unit Description:
        Sampling Location :
Calibration Procedures:
    1.   Prior to any field weighing, assemble the platform and readout as specified in the user's manual.
    2.   Ensure that the platform is level using the bubble level indicator.
    3.   Zero the scale.
    4.   Place the 5 Ib standard weight onto the scale and record the reading.
    5.   Using the remaining standard weights, repeat step 4 at each of the following values:  10, 25, 50,
        75, and 90 Ibs.
    6.   Repeat the entire process at the end of each day of testing.
Standard
Weight (Ib)
5
10
25
50
75
90
Initial Scale
Response (Ib)






Difference
(Ib)






Acceptable? a






Gas Temp






End of Day
Scale
Response (Ib)






Acceptable
Repeatability? b






a Acceptable difference = (std weight * 0.002) + 0.05 Ibs
b Acceptable difference = Initial response - final response < 0.05 Ibs
Notes:
                                               A-6

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                Appendix A-4. Determination of Effluent and Solids Removal Rates
Project ID:

Date:
Location (city, state):

Signature:	
Unit Description:
       Sampling Location :
Determination of Effluent Bleed Rate:
    7.   Calibrate the scale following procedures in Appendix A-4.
    8.   Place effluent collection receptacle on scale and record tare weight.
    9.   Record the effluent bleed start time and date.
    10.  Collect all effluent bled from system in receptacle and record the bleed end time.
    11.  Record the final receptacle weight and calculate  the weight of effluent collected and the elapsed
        time.

Solids Removal Rate:
    12.  Calibrate the scale following procedures in Appendix A-4.
    13.  Line the  solids collection receptacle with tared sheet of polyethylene.
    14.  Record the solids removal start time and date.
    15.  Collect all solids in receptacle and record the end time.
    16.  Record the final weight of polyethylene sheet and collected solids
    17.  Calculate the weight of solids collected and the elapsed time.
Indicate
liquid or
solids
collection










Date and
Start Time










Receptacle
or poly Tare
weight (Ibs)










End time










Elapsed time
(min)










Final weight
(Ibs)










Material
collected (Ibs)










Notes:
                                              A-7

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                         Appendix A-5. Sample Chain-of-Custody Record


                      Southern Research Institute Chain-of-Custody Record


Important:  Use separate Chain-of-Custody Record for each laboratory and/or sample type.

Project ID:	       Location (city, state):	
Originator's signature:.
                       Unit description:.
Sample description & type (gas, liquid, other.):	

Laboratory:	       Phone:_

Address:	       City:
Relinquished by:_
Received by:	
Relinquished by:_
Received by:	
Relinquished by:_
Received by:	
                              Fax:_

                           State:
              Zip:.
Sample ID
















Bottle/Canister ID
















Sample Matrix
















Analyses Req'd
















Notes/Comments
















Date:.
Date:.

Date:.
Date:.

Date:.
Date:
Time:
Time:

Time:
Time:

Time:.
Time:
Notes: (shipper tracking #, other)_
                                               A-8

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                           Appendix A-6. Corrective Action Report
                                Corrective Action Report
Verification Title:
Verification Description:

Description of Problem:_
              Originator:	              Date:
Investigation and Results:,
Corrective Action Taken:
              Investigator:	              Date:
              Originator:	              Date:
              Approver:	              Date:
                   cc: GHG Center Project Manager, GHG Center Director, Southern QA Manager
                                            A-9

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                      Appendix A-7. Sulfur and Moisture Analysis Methods


                                            SULFER

Hydrochloric Acid, Concentrated
Hydrochloric Acid, 1:1.
Sodium Carbonate.
Sodium Nitrate.
Liquid Bromine.

Procedure  1  is sufficiently  accurate for ordinary  routine work.   Use procedure 2  for very  accurate
determinations.

       Procedure 1.- Weigh a 1-g. specimen in the fritted glass extraction thimble and
extract in the extraction apparatus for at least 15 minutes with carbon disulfide. Remove the container,
dry and weigh.  Report the percentage of insoluble residue as foreign matter.  (This includes the ash.)
Report the percentage of sulfur as the difference between 100 and the percentage of foreign matter to the
nearest 0.1%.

       Note - Organic impurities may dissolve in the CS2, causing a slight inaccuracy.

       Procedure 2.- Weigh a 0.5-g. specimen into a 250-ml. porcelain dish, warm to 30°C  and add
about 6 ml. of bromine. Keep the mixture at this temperature for about 10 minutes and then add 15 ml. of
concentrated HNO3 previously brought to 30°C. After the violent reaction has subsided, heat the  mixture,
cautiously at  first, then boil to drive off the HNO3  Add about 0.5g. of NaCl to avoid loss of H2SO4 and
evaporate the mixture to a small volume.  Repeat the evaporation three or four times, adding after each
evaporation about 5 ml. of concentrated HC1. Evaporate to dryness on the steam bath and heat the residue
gently.  Take up this  residue with 5 ml. of HC1 (1:  1) and about 100 ml. of water, filter out the insoluble
matter and  wash thoroughly on the filter paper with hot water.  (This may be ignited and weighed, if the
amount of insoluble matter is desired.)
       Transfer the filtrate to a 500-ml. volumetric flask, dilute to the mark and thoroughly mix. Pipette
a 100-ml. aliquot into a beaker, heat to boiling, and add 10 ml. of 10% BaCl2 solution drop by drop to the
boiling solution with constant stirring. Stir the solution thoroughly, preferably  letting it stand overnight
and filter through an ignited and weighed Gooch crucible with  asbestos mat. Wash with boiling water,
dry, ignite at  700-750°C and weigh as BaSO4. Calculate to the percentage of sulfur to the nearest 0.01%,
correcting for the aliquoting of the solution.
       Calculation.-

                      Weight of BaSO4 * 0.1374 = Weight of S in sample
                                              A-10

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                                           MOISTURE

       Procedure.- Weigh 50g.  of the  undried prepared laboratory sample  into a  previously  dried,
cooled, and weighed 100- by  15-mm. Petri dish.  Place in an oven at 105°C for 1 hour.  Then remove,
cool in a desiccator, and weigh.
        Calculation.-
                                    sample wt. - dried wt.
                       % moisture =                        x 100
                                         Sample wt.
        Notes.-l.This dried  sample  may be used for the ash, elemental sulfur, combined sulfur, arsenic, and
selenium determinations.  However,  since approximately 100 g. of dried sulfur will be required for all of these
determinations, it is suggested that the moisture determination be made in duplicate.
                                               A-ll

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