Workshop O Clean Air Lessons Learned, Best Practices & - - PDF document

Workshop O

Clean Air … Lessons Learned, Best Practices & Avoiding Pitfalls in Managing a Stack Test Program

Tuesday, March 27, 2018 2 p.m. to 3:15 p.m.

Biographical Information

Margot Fosnaugh - Senior Consultant, Trinity Consultants 1717 Dixie Hwy, Suite 900, Covington, Kentucky 41011 859-341-8100 x107 mfosnaugh@trinityconsultants.com Margot Fosnaugh is a Senior Consultant in Trinity Consultants’ Covington, Kentucky

• ffice, specializing in air permitting and environmental compliance strategies. After

earning her B.S. in Chemical Engineering from the University of Cincinnati, Margot began her career as a consultant in Trinity’s Columbus, Ohio office in 2006, followed by 6 years in Trinity’s Chicago office. Margot has over 11 years of experience developing customized and automated compliance tracking tools, in state construction and Title V

• perating permitting, NSPS and MACT compliance assistance, air emissions reporting,

and toxic release inventory (TRI) reporting. Margot manages projects across multiple industry sectors, with a special emphasis in petroleum refining and chemical manufacturing. Jason Mennino, CHMM, Dow Corning Corporation A wholly owned subsidiary of The Dow Chemical Company 4770 US Highway 42 East, Mail# CAR 029, Carrollton, KY 41008 502.732.2051 jason.mennino@dow.com Jason Mennino is an Environmental Specialist at Dow Performance Silicones (formerly Dow Corning) in Carrollton, KY. He oversees the Title V program for the Dow site of 400 employees and 1500 acres. After earning his B.S. in Environmental Engineering from the University of Dayton, he worked in an environmental lab then moved on to an R&D project management role for an environmental products company in Yellow Springs, OH. Jason cut his teeth in all environmental regulatory media as an environmental engineer at a shipyard in Pascagoula, MS. Once he earned an MBA, Jason moved on to an air specialist consulting role in Nashville, TN. From there, he went back into industry as an environmental manager for an adhesives and coating manufacturer in Franklin, KY. But that wasn’t enough. He wanted to take a walk on the wild side and try his hand at health and safety so he took an HSE Management position for a nonwoven manufacturer in Old Hickory, TN. He did well but was made an offer he couldn’t refuse to go to Hemlock Semiconductor as an Environmental Specialist. This was by far the most interesting position because it was a green field site which ended up closing without making a single kilogram of polysilicon metal. Fortunately, Hemlock was a JV and Dow Corning was one of the owners. He took an environmental team Leader position at the Carrollton site and has been there ever since.

Workshop O: Lessons Learned, Best Practices & Avoiding Pitfalls in Managing a Stack Test Program

March 27, 2018 Margot Fosnaugh –Trinity Consultants Jason Mennino – Dow Corning

consumer.dow.com

Agenda

˃ Reasons to conduct a stack test ˃ Contracting with a stack test firm ˃ Reviewing test protocols ˃ Preparing for the test ˃ Managing operational parameters (e.g.,

combustion temperature, pressure drop, flow rate)

˃ What to do on test day ˃ Reviewing test reports and submitting test

results

˃ What could go wrong – a case study

Reasons for Stack Testing

3/ 15/ 2018

Purpose of Test

˃ Initial Performance Tests:

 New S

• urce or Modifications to an Existing S
• urce

♦ Baseline tests of current operations ♦ Test during trial of post modification operations  New Rule ♦ New S

• urce Performance S

tandards (NS PS )

♦ National Emissions S

tandards for Hazardous Air Pollutants (NES HAP)

♦ S

tate Reasonably Available Control Technology (RACT)

Purpose of Test

˃ Routine Tests:

 Retest based on calendar time/ permit term or on

hours of operation

 Retest when operating conditions change or change to

control device

 Relative Accuracy Test Audits (RATA) for CEMS

˃ Informal Tests:

 Engineering diagnostic testing  Choosing size/ design features of a control device to

be added

 Demonstrate conformance with a manufacturer’s

guarantee

Purpose of Test

˃ Emission factor development ˃ Compliance with an underlying rule ˃ Response to an Agency request ˃ Compliance with permit condition

 Concentration – flow not considered in calculation  Mass – flow is critical to results  %

reduction - test inlet / outlet simultaneously

Purpose of Test

Stack Emission Testing

Key Emission Information Objectives

˃ Mass-emissions (pounds/ hour) are calculated

from emission concentrations and volumetric flow-rate.

˃ Emission Concentrations corrected for air

dilution (ppmv @ X% O2) calculated from emission concentration and diluent concentration

Contracting with a Test Firm

3/ 15/ 2018

Prepare an RFP

˃ S

pecify the purpose of the test – regulatory as well as internal obj ectives

 Compliance – Identify applicable regulations

and emissions limits

 Engineering – Identify terms of the results

and expected emissions (lb/ hr, lb/ ton, etc.)

˃ S

pecify if initial test or if routine test conducted in the past

 Provide prior test protocol

Prepare an RFP

˃ Provide preferred or required test

methods, by pollutant

 Leave this up to tester?

˃ Process information

 Continuous/ Batch/ Other  Pollution Control Equipment  S

tack parameters

 Test port locations

Prepare an RFP - Timing

Engineering Test Compliance Test New Regulation Compliance Test

Plan ahead

3 months 12 months

Considerations When Choosing a Test Firm

˃ Prior experience at your facility ˃ Cost

 Check all proposals are apples to apples

♦ Test Methods ♦ Days onsite and preparation

˃ Expertise in your test methods and

industry

˃ Availability

Reviewing Test Protocols

3/ 15/ 2018

Planning Considerations

˃ Do not leave testing firm to draft

protocol alone

 Team approach required for success  Testers need plant or consultant input on

plant specifics, concerns, coordination

 Testers cannot be the experts on nuances of

your specific regulation

 If tester does not welcome your involvement

in these aspects, find another

3/ 15/ 2018

Planning Considerations

Testing Firm

• Test Methods

Plant Personnel

• Facility /

Operations

• Permit

Consultant

• Regulations
• Agency

Expectations

SUCCESS

3/ 15/ 2018

Test Protocol Elements

˃ Protocol is high level outline of test ˃ Make internal protocol for informal tests ˃ Critical:

 Process description  Operation – Normal/ Worst Case  Test location information  Test methods to be used  S

chedule

 Method exceptions/ changes (if any)

Test Protocol Elements

˃ Desirable/ Internal:

 Key test personal CVs  Photographs/ diagrams of test location(s)

and emissions unit(s)

 Example field data sheets  Example calculations

Test Protocol Review

˃ Agency review practices vary widely

 Written approval of test protocol PRIOR to test  Protocol review AFTER receipt of test report

˃ Review focuses on compliance with methods

and regulations – NOT accuracy of results

˃ Actively seek approval in advance

 Deviations from regulatory or permit

requirements

 Deviations from test methods

Selecting Test Methodology

> Check permit for regulated pollutant(s)

and applicable regulation(s)

> Review Ohio EP

A Administrative Code

> Check U.S

. EP A Regulation – eCFR Online

http:/ / www.ecfr.gov/ cgi-bin/ text- idx? S ID=ac0a7c178d1c53dec8a6abe091a2f120&tpl=/ ecfrbrowse/ Title 40/ 40tab_02.tpl

Sampling/Analytical Method Sources

> 40 CFR Part 60, Appendix A; Part 63 –Applicable

subpart

> EP

A Emission Measurement Center. Includes promulgated, alternate, conditional and preliminary test methods.

http:/ / www.epa.gov/ ttn/ emc

> EP

A Office of S

• lid Waste, S

W-846 Methods

http:/ / www.epa.gov/ epaoswer/ hazwaste/ test/ under.htm

> California Air Resources Bureau

http:/ / www.arb.ca.gov/ testmeth/ testmeth.htm

> National Council for Air and S

tream Improvement (NCAS I) Methods.

http:/ / www.ncasi.org/ Publications/ Detail.aspx? id=172400

Preparing for the Test

3/ 15/ 2018

Select Test Date(s)

˃ S

chedule the test date with Tester

 Plan for intent to test notification (30-60 days prior

to test)

 Provide buffer before regulatory deadline in case

something goes wrong

 Be aware of process shutdowns, turnarounds, or

• ther situations

˃ S

chedule the necessary production.

 The maj ority of compliance tests in Ohio and

Kentucky must be performed at a “ Maximum Achievable Rate” or a Worst Case scenario

 Plan for two hours of production for every 1 hr of

scheduled sampling.

Planning Considerations

˃ Test Ports Accessibility/ Clearance

 Has source been tested before?  Are ports adequate/ correct/ usable?  Any obstructions ?

˃ S

afety

 Plant S

afety Training Required?

 Contractor S

afety Plan

3/ 15/ 2018

Good Test Platform

Test Ports Heat Shield Hand, Knee and Toe Rails

Clearance Problem

Safety/Environmental Problem

Ladder Types

Safety Cage Tracked, with Safety Harness Free Climb Temporary Always Tie Off!

Other Access

Stack Elevators Articulated Lifts

ASK ABOUT WEIGHT LIMITS

Planning Considerations

˃ Crazy hours are a given

 Pack/ reserve for an extra day  After-hours plant contact?

˃ S

ampling ports open day prior (rust)

 Also clean out if PM testing

˃ Communications challenges

 S

pecify if testers need radios. Does consultant need a tester radio, plant radio? Extras hard to get without planning.

3/ 15/ 2018

Planning Considerations

˃ Power!

 Identify power needs, source locations,

who will connect/ disconnect hardwiring when

 Power needs increase for more

methods/ analytes

 CEMS

trailer power significantly more

˃ Extension cords

 Limitation for distance due to voltage drop  S

afety

˃ Generators

 Ensure adequate fuel

3/ 15/ 2018

What to Do on Test Day

3/ 15/ 2018

Test Day

˃ Three test-runs per test parameter ˃ Most test runs are one hour. S

• me tests are 2,

3, 4 or more hours

˃ Measure all parameters simultaneously, if

• possible. Depends on sample location

˃ Time between runs to turnaround. Fifteen

minutes to one hour depending on methods used.

˃ Don’t start-up process right before first test.

Make sure everything is well-stabilized before testing.

Managing Operational Parameters

˃ Verify operating rates consistent with protocol

 Verify rates throughout test runs

˃ Ensure process/ production rates are

monitored for each test run

˃ Keep records of relevant monitoring data –

take manual readings even if continuous recorder

 Incinerator temperature  S

crubbing liquid flow rate, pH, outlet gas temp

 Pressure drop

Thermal Oxidizer

˃ Optimize Temperature S

etpoint

Wet Scrubber

˃ Optimize flow rate

Reviewing Test Reports and Submitting Test Results

3/ 15/ 2018

Test Report Review

 Verify Test Results S

ummary (TRS ) provided

 Test consistent with the protocol?  Description of any issues from test day  Results presented in terms of standard  Agency communications in appendix  Relevant plant operational data in appendix  Resulting emission factors, operating limits,

monitoring parameter ranges clearly identified with all supporting data

 Prepare transmittal letter with additional

information

Agency Submittals - Report

˃ S

tate S ubmittal - typically 30 days as specified in plan approval, operating permit

˃ NS

PS – Refer to specific subpart, generally 60 days after the test has been completed

˃ NES

HAP - Before the close of business on the 60th day following the completion of the performance test, unless specified otherwise [40 CFR 63.7(g)]

Agency Submittals - Report

˃ S

ubmittal of final report



S ubmit to S tate / District Office



One copy to EP A Regional office for NS PS / NES HAP

˃ EP

A ’s Electronic Reporting Tool (ERT), Version 5.0



Create and submit test plans as well as calculate and submit the test results (CDX registration)



Now required by many NS PS and MACT regulations



Up to date list: https://www3.epa.gov/ttn/chief/ert/ert_rules.pdf

What Could Go Wrong – Case Study

3/ 15/ 2018

Test Day Readiness Roadmap

 Has the official test date(s) been scheduled with the

regulatory agency?

 Do the plant personnel know what to expect and what’s

expected of them?

 Is the process ready to go?  Is there enough production?

3 one-hour runs = 8 hours

 Has the pollution control device been checked-out?  Are the test ports accessible, open and clean?  Is an electrician ready to hook-up the test lab’s power?  Do you know what/ how often

production/ process/ pollution control info has to be documented?

 Is the plant neat/ tidy?  Has this checklist been visited far enough ahead of the

test to take corrective action?

Test Case #1

˃ Purpose of testing

 MON performance testing

˃ What are the compliance limits?

 20 ppm, 1 lb/ hr, etc.

˃ What are we testing?

 Working losses & breathing losses from HCl

tank – HCl emissions

˃ Control device

 Packed bed scrubber

Test Case #1

˃ Testing scenarios

 Emissions while loading the tank  Emissions on a hot day

˃ People

 Test firm

♦ EP

A Methods 1-4 & 26

 Operations

♦ Expectations of both sides ♦ S

chedule/ Reminders

 Agency

Test Case #1

˃ Paperwork

 Protocol submitted  Test firm PO &/ or contract

˃ Process

 Control device maintenance/ operational

readiness

 Process data availability  Test ports & access  Power  Housekeeping

Test Case #1

˃ Testers onsite ˃ Agency onsite ˃ Work permits acquired ˃ Operations begins unloading HCl into tank ˃ Test begins ˃ What could go wrong? ˃ Water to packed bed scrubber valved out

Test Case #1A

˃ MON performance testing ˃ Working & breathing losses from HCl tank ˃ Packed bed scrubber ˃ People notified

 Tester, Operations & Agency

˃ Paperwork submitted – protocol, etc. ˃ Process is online ˃ S

crubber is operational

Test Case #1A –Test Day

˃ Testers onsite ˃ Agency onsite ˃ Work permits acquired ˃ Operations unloading HCl into tank ˃ Nice hot day! ˃ Testing goes well

Test Case #1A

˃ Process data collected & verified ˃ Onsite testing data collected & verified ˃ Test report finalized ˃ What could go wrong? ˃ EP

A Method 26 audit sample was not acquired and transported to the site prior to the test

Test Case #2… if we have time

3/ 15/ 2018

Test Case #2

˃ Purpose of test

 HON, MON & NS

PS performance testing

 Establish operational compliance

parameters to meet:

♦ HON = >98%

DRE OHAP

♦ MON

– >98%

DRE OHAP

– >99%

DRE Hydrogen halide halogen HAP

♦ NS

PS NNN & RRR = 98% DRE VOC

 Establish PM emission factors

Test Case #2

˃ Purpose of test continued

 Performance testing – establish operational

compliance limits

♦ Minimum combustor temperature ♦ Liquid-to-vent (LTV) ratio

˃ Liquid to vent ratio

 Liquid = All HAP scrubbing liquid

♦ Water, caustic, etc.)

 Vent = All gases passing through the scrubber

♦ S

team, combustion gases, natural gas, etc.

Test Case #2

˃ What are we testing?

 Closed vent system emissions (entire site)

˃ Control device

 Thermal incinerator  Packed bed absorber  Ionizing Wet S

crubber

Test Case #2

˃ Testing scenarios

 The Matrix Temp Process Cond 1 Process Cond 2 Water flow IWS 950 Yes Yes High Both on 975 No No Low A off, B on 1000 A on, B off Both off

Test Case #2

˃ People – communication plan

 Test firm communication

♦ Multiple Detailed test protocol discussions

 Operations communication

♦ Multiple planning sessions across internal orgs ♦ Expectations of both sides ♦ S

chedule & continuous reminders

 Agency communication

♦ Multiple calls explaining and revising the test plan

Test Case #2

˃ Paperwork

 Test protocol revised many times

♦ Incorporate new scenarios ♦ Explain testing & data collection rationale

 Protocol submitted (more than once)  Test firm PO &/ or contract - $$$$$

Test Case #2

˃ Process

 Control device maintenance/ operational

readiness

 Process data availability

♦ Flow meters, thermocouples, etc.

 Test ports & access  Power  Housekeeping

Test Case #2 - Test Day

˃ Testers & Agency onsite ˃ Work permits acquired ˃ Testing went well

 3 days  14 test runs

˃ Test report finalized, submitted and

accepted

Test Case #2

˃ What could go wrong? ˃ Voided one run ˃ S

• lely focused on combustor temperature

 Compliance temp was close to incinerator

shutdown temp

˃ Did not optimize control device operation

to reduce LTV ratio

 Minimum LTV ratio increased  Couldn’ t meet new LTV ratio

Share Your Story…

Test Methodologies

3/ 15/ 2018

Method: 1 Port Location

SAMPLING PORTS

˃

90° Apart (Round Duct)

˃

Nipple Protrusion

˃

PM Build-up (Horizontal Stacks) TRAVERSE POINTS

˃

PM vs. Velocity

˃

Nipple Lengths

˃

Elliptical Stacks

˃

Two Sets of Points

EPA Method 1 Criteria Data

Measurement Site Disturbance Disturbance

A B

2 3 4 5 6 7 8 9 10 10 20 30 40 0.5 1.0 1.5 2.0 2.5 Used For Particulate Sampling Used For Velocity Sampling * Higher Number is For Rectangular Stacks or Ducts Duct Diameters Downstream from Flow Disturbance (Distance A)

a a From point of any type of disturbance (bend, expansion contraction, etc.)

Duct Diameters Upstream from Flow Disturbance (Distance B)

a

Minimum Number of Traverse Points Stack Diameter = 0.30 to 0.01 m (12-24 inches) Stack Diameter > 0.01 m (24 inches) 24 or 25* 8 or 9* 20 16 12

EPA Method 1 Criteria Data

Method: 2 Flow Rate

EQUIPMENT

˃

Calibration Documentation

˃

Sensitivity SAMPLING AND ANALYSIS CONCERNS

˃

Level

˃

Pitot Tube Alignment

˃

DP Profile and Temp Profile

˃

Cyclonic Symptoms

˃

Leak Checks

˃

Steady vs/ Unsteady Operation

˃

Ducts >12”

Level and Perpendicular? Obstructions? Damaged? 1 (-10° < 1 < +10°) 2 (-10° < 2 < +10°) 1 (-10° < 1 < +10°) 2 (-10° < 2 < +10°)   A z= A tan  ( < 0.125") w = A tan  ( < 0.03125") Dt (3/16 < Dt < 3/8") 1.05Dt < PA < 1.5Dt 1.05Dt < PB < 1.5Dt PA = PB ± 0.063"

EPA Method 2 Pitot Tube Inspection

3/ 15/ 2018

Method: 3 Molecular Weight

EQUIPMENT

˃

Tedlar, Mylar, etc.

˃

Leak Check Documentation

˃

Fyrite vs. Orsat (M3B)

˃

CO2 (SO2, HCl); O2 (N2O, NH4, Acetylene) SAMPLING AND ANALYSIS CONCERNS

˃

Fo Fuel Factor

˃

Constant Rate

˃

Analysis < 8 Hours or On Site

˃

Chain of Custody

Method: 4 Moisture

EQUIPMENT

˃

Calibrate Meter, Temperature Sensors, Barometer etc., like M5

˃

Filter Required SAMPLING AND ANALYSIS CONCERNS

˃

Constant Rate ± 10%

˃

< 0.75 cfm

˃

21 dscf

˃

Traversed

˃

Chain of Custody

˃

Obtain Copies of Data Sheet

EPA Method 4 Sample Train Schematic

IMPINGER TRAIN OPTIONAL. MAY BE REPLACED BY AN EQUIVALENT CONDENSER REVERSE TYPE PITOT TUBE ORIFICE DRY GAS METER AIR TIGHT PUMP BY-PASS VALVE MAIN VALVE VACUUM GAUGE THERMOMETER 100 ml D.I. H2O

(modified / no tip)

100 ml D.I. H2O (standard tip) empty

(modified / no tip)

silica gel 200-300 g.

(modified / no tip)

THERMOMETERS CHECK VALVE PITOT MANOMETER HEATED PROBE STACK WALL TEMPERATURE SENSOR HEATED AREA THERMOMETER FILTER HOLDER VACUUM LINE PROBE ICE BATH TEMPERATURE SENSOR PITOT TUBE MANOMETER

3/ 15/ 2018

Method: 5 Particulate Matter

EQUIPMENT

˃

Pretest Calibrations, Meter Box, Probe, Assembly, Nozzles,Temp. Sensors, etc.

˃

Glass Liners

˃

Meter Orifice Check SAMPLING AND ANALYSIS CONCERNS

˃

MDL

˃

M3 & M4 Simultaneous

˃

Temperatures

˃

Isokinetics (+/- 10%)

˃

Probe Handling (Vertical)

˃

High Vacuum

˃

Probe Rinses 3 / 6

˃

Acetone Blank < 0.001%

˃

Post Leak Checks, Train & Pitot

˃

Chain of Custody

˃

Field Data Sheets Copies

Air Compliance Testing, Inc.

EPA Method 5 Sample Train Schematic

EPA Method 5 Sample Train Schematic

3/ 15/ 2018

Method: 201A/202 PM10

EQUIPMENT

• Pretest Calibrations, Meter Box,

Probe, Assembly, In-stack Sizing Device, Nozzles,Temperature Sensors, Additional Impingers, PM2.5 Separator, etc.

• Glass Liners
• Meter Orifice Check

SAMPLING AND ANALYSIS CONCERNS

˃

MDL

˃

M-3 and M-4 Simultaneous

˃

Elevated Temperatures

˃

Entrained Water Droplets

˃

Isokinetics (+/- 20%)

˃

Probe Handling (Vertical)

˃

High Vacuum

˃

Acetone Blank < 0.001%

˃

Field Blanks and Corrections

˃

Post Leak Checks, Train & Pitot

˃

Chain of Custody

˃

Field Data Sheets Copies

EPA Method 201A/202 Sample Train Schematic

Method: 6C, 7E, 10 SO2, NOX & CO

EQUIPMENT

• CO/ SO2 / NOx CAL Gases (0-20%,

40-60%, Span)

• CO Span 1.5x SPS
• SO2 / NOx Span > 30% Emissions

Standard

• EPA Protocol Gases
• MDL < 2% Span

SAMPLING & ANALYSIS CONCERNS

• NO + Air Converter Check
• SO2 Interference Checks/ M6
• Invalid Test Runs (when?)
• Span Exceedences
• SO2 Solubility
• Sample System Flow Rate

EPA Method 6C Sample Train Schematic

STACK WALL MOISTURE REMOVAL SYSTEM PUMP SAMPLE GAS MANIFOLD SO2 ANALYZER CALIBRATION VALVE HEATED SAMPLE LINE SAMPLE BY-PASS VENT BY-PASS FLOW CONTROL VALVE SAMPLE TRANSPORT LINE SAMPLE FLOW CONTROL VALVE ANALYZER FLOW CONTROL VALVE HEATED PROBE CALIBRATION GAS IN-STACK FILTER

3/ 15/ 2018

Method: 8 H2SO4 & SO2

EQUIPMENT

˃

Glass No Steel Liners

˃

M5 Filter Specs

˃

35dscf = 0.04 ppm (In Stack)

˃

Flourides, Ammonia SAMPLING & ANALYSIS CONCERNS

˃

Temperatures > Condensation

˃

< 1.0 cfm or 0.75 cfm (M4)

˃

15 Minute Purge

˃

Barium Normality (0.0100N)

˃

EPA Audit Samples

˃

Gravimetric M4 ( Isopropanol)

˃

Audit Sample Reanalysis (option)

EPA Method 8 Sample Train Schematic

IMPINGER TRAIN OPTIONAL. MAY BE REPLACED BY AN EQUIVALENT CONDENSER REVERSE TYPE PITOT TUBE ORIFICE DRY GAS METER AIR TIGHT PUMP BY-PASS VALVE MAIN VALVE VACUUM GAUGE THERMOMETER 100 ml IPA

(std. tip)

100 ml H2O2 (mod. tip) silica gel 200-300 g.

(mod. tip)

THERMOMETERS CHECK VALVE PITOT MANOMETER HEATED PROBE STACK WALL TEMPERATURE SENSOR HEATED AREA THERMOMETER FILTER HOLDER VACUUM LINE PROBE ICE BATH TEMPERATURE SENSOR PITOT TUBE MANOMETER 100 ml H2O2 (std. tip)

3/ 15/ 2018

Method: 18

Gaseous Organics

EQUIPMENT

˃

D.I., Tubes, Bags

˃

Spike (40-60%) and Recovery (70- 130%) Study

˃

Sample Probe

˃

H2O >3% Knock-out SAMPLING & ANALYSIS CONCERNS

˃

Constant Sample Rate

˃

Sample Loss During Recovery

˃

Data Reported with R-Value

˃

Condensation GRAY AREAS

˃

Pre-survey (Optional)

˃

Hot and Wet

EPA Method 18 Sample Train Schematic - Direct Interface

Hewlett Packard GC

Duct Wall 3/8" Female Fitting 3/8" Heated Teflon Line

Dilution System (If Required)

Insulation Temperature Controller

T.C. Readout T.C. Readout or Controller

Heated Gas Sampling Valve in GC Carrier In Needle Valve Pump Charcoal Absorber Flowmeter Vent

3/ 15/ 2018

EPA Method 18 Sample Train Schematic - Tube

Probe Charcoal Sorbent Tube Critical Orifice Vacuum Guage Silica Gel Drying Tube Needle Valve Pump Flowmeter Vent Flexible Sample Line inHg inHg 15 ml D.I. H2O Knockout Impinger

THERMOMETER

3/ 15/ 2018

EPA Method 18 Sample Train Schematic - Bag

Tedlar Bag Rigid Leakproof Container Check Valve Stack Wall Probe Needle Valve Vacuum Line Flowmeter Vent Quick Connects Teflon Sample Line Charcoal Tube Pump 3/ 15/ 2018

Method: 25

Total Gaseous Non-Methane Organics

EQUIPMENT

˃

Concentrations >50 ppm(c)

˃

Pre-test Leak Check

˃

Traps in Dry Ice SAMPLING & ANALYSIS CONCERNS

˃

Pretest Flow Needed

˃

Collect  3 Liters

˃

Constant Rate Sampling GRAY AREAS

˃

MDL 50 ppm (c)

˃

Default to MDL

EPA Method 25 Sample Train Schematic

• .

. .

MANOMETER VACUUM PUMP REGULATING VALVE DUAL RANGE ROTAMETER PURGE VALVE THERMOCOUPLE SAMPLE VALVE TEMPERATURE CONTROLLER THERMOCOUPLES STAINLESS STEEL PROBE STACK WALL HEATED BOX DRY ICE CONDENSATE TRAP SAMPLE TANK STAINLESS STEEL FILTER HOLDER ROTAMETER FLOW CONTROL VALVE SAMPLE TANK VALVE 3/ 15/ 2018

Method: 25A Total Gaseous Organics

EQUIPMENT

˃

Concentration < 50 ppm (c)

˃

Hydrocarbons only

˃

Span 1.5 to 2.5 Pre-established

˃

Components 220ºF

˃

• Cal. Check Within 2 Hours

SAMPLING & ANALYSIS CONCERNS

˃

2.5% - 3.0% Max Linear

˃

Analyzer Settings

˃

Sample Pressure GRAY AREAS

˃

Propane x 3 = Carbon

˃

RF

˃

Drift Check Failures (Recalibrate?)

EPA Method 25A Sample Train Schematic

STACK WALL ORGANIC ANALYZER AND RECORDER PROBE HEATED CALIBRATION VALVE HEATED PARTICULATE FILTER SAMPLE PUMP HEATED SAMPLE LINE STACK WALL

3/ 15/ 2018

Method: 26A HCl, HF & Cl2

EQUIPMENT

˃

No Steel Liners

˃

One Piece Liners > 410º

˃

Quartz Filter > 410ºF

˃

Teflon Filter < 410ºF

˃

ClO2 , NH4Cl, High NO2 SAMPLING & ANALYSIS CONCERNS

˃

Temperatures > 248ºF

˃

< 1.0 cfm or 0.75 cfm (M4)

˃

Sodium Thiosulfate/Convert Hypohalous Acid

˃

EPA Audit Samples

˃

Condensed HCl

˃

Stack Temp vs Probe Temp

˃

Detection Limits (multiples)

EPA Method 26A Sample Train Schematic

IMPINGER TRAIN WITH ABSORBING SOLUTIONS REVERSE TYPE PITOT TUBE ORIFICE DRY GAS METER AIR TIGHT VACUUM PUMP BY-PASS VALVE (FINE ADJUST) MAIN VALVE (COARSE ADJUST VACUUM GAUGE THERMOCOUPLE Silica Gel 200-300g

(modified/ no tip)

THERMOCOUPLES CHECK VALVE PITOT MANOMETER HEATEDGLASS LINED PROBE STACK WALL THERMOCOUPLE HEATED AREA THERMOCOUPLE FILTER HOLDER VACUUM LINE PROBE THERMOCOUPLE PITOT TUBE MANOMETER GAS EXIT GLASS PROBE TIP ICE BATH 100ml 0.1N H2SO4

(standard tip)

100ml 0.1N H2SO4

(standard tip)

100ml 0.1N NaOH

(modified / no tip)

100ml 0.1N NaOH

(modified / no tip)

3/ 15/ 2018

Organics Test Method Selection Considerations

DRE (Total Organics)

˃

Relative

˃

< 50 ppm(c) M25A

˃

> 50 ppm(c) M25 Hydrocarbon

˃

M25/M25A - I/O MER (Total Organics)

˃

Gaseous < 50 ppm(c) M25A

˃

> 50 ppm(c) M25

˃

Response Factors (RF)

˃

Semivolatiles

˃

Hot, Wet

˃

MM5 DRE & MER (Specific Organics)

˃

Test Methods (EPA, SW-846)

˃

Gaseous or Semivolatile

˃

NIOSH (M18)

˃

PPM or %

˃

Hot, Wet, Aerosols

˃

Sample Conditioning

˃

Pre-survey Sampling

Other Common EPA Methods

˃

M-6 (SO2)

˃

M-9 (VE)

˃

M-23 (PCDD/DF)

˃

M-29 (Metals)

˃

M-204 (Enclosure Verification)

˃

M-306 (Total Chromium)

˃

M-320 (Vapor Phase Organics)