Stack Testing 101 Workshop

Transcription

1 Stack Testing 101 Workshop

2 Moderator Randal Tysar

3 Purpose The purpose of the workshop is to present the basics of stack testing from the perspective of the testing company and the regulatory agency.

4 Presenters Matthew Young Mark Dziadosz

5 Workshop Benefits Provide awareness of testing methods and procedures Familiarity with testing equipment You can ask good questions of your testing vendor, agency and process and abatement owners / operators

6 Why is Testing Frequency and Complexity Increasing? Title 5 (ROP) permits shifted responsibility for compliance New NESHAP Standards More Complex NSR permits Increased Inventory Accuracy Ventilation/Engineering Studies

7 Beware Credible Evidence Changes made to Parts 51, 52, 60 and 61 on 2/24/1997 clarify that nonreference method data may be used to establish non-compliance with an emission limitation. Title 5 sources have duty to report all credible evidence of non-compliance as part of their compliance certifications.

8 Why care about air testing? Poorly planned and implemented test programs create: Bad Permits Noncompliance Extra costs Wasted time Worthless reports In the future Testing frequency and complexity will increase!

9 Pre-Test Activities Spending time up front in the design of the testing protocol and program produces: Smooth plan for all testing situations Reduces the risk for error in testing Keeps production and the testing crew on the same page

10 Timing for the Test Back calculate from when the test report is due Include time to: Evaluate bids Critically review the draft test plan Agency review of test plan (regulatory requirements differ) Complete test Review draft test report Give Yourself Plenty of Time

11 Understanding the Process How Does the Process Work? What is the Relationship Between the Process and Emissions? How Does the Air Pollution Control Equipment Work? What is the Maximum Production Rate? What is the Process Operating Schedule?

12 Request for Quotation Name of Facility/Description of Process (Who) Pollutants to Be Tested (What) Required Timing (When) Sampling Location Issues (Where) Include digital pictures Permit, NESHAP, Engineering (Why) Include copy of permit

13 Evaluating the Quotes Technical Capability Relevant Testing Experience Familiarity with Process and/or Facility Pertinent References Cost

14 Designing the Air Testing Protocol Work with your selected contractor They know test methods You know your process and site The best test protocol will come from working together Note that Test Plans must be submitted days prior to the test project depending on regulations.

15 Test Protocol: Typical Contents Timeline and sources to be sampled Pollutants to be sampled EPA or other test methods to be used Sampling train diagram and description Laboratory & field QC/QA methods Description of operations: Minimum Process rate during testing Process monitoring during testing Abatement monitoring during testing Primary testing consultant and any subcontractors such as labs

16 Can we test NOW? Is the Test Plan approved by the Agency? Final Protocol may take some time to negotiate. So be aware of this item in your project time line. Know who gets copies of the Test Protocol. You, your test consultant and your agency contact will need a copy at a minimum You may need to plan for an additional 7-10 days after the Protocol is approved to actually start the testing program. Why is this? And don t forget the Final System Check.

17 Compliance Emission Tests The Agency Perspective Air Testing Workshop Mark Dziadosz February 24, 2017 Novi, Michigan

18 The Air Quality Division Air Monitoring Strategy Development Permits Toxics District Technical Programs

19 What Does MDEQ Want? Continuous Compliance Properly Functioning Equipment Excellent Record Keeping Accurate Emission Reports

20 MDEQ Authority for Emission Tests 40 CFR 60 = NSPS 40 CFR 61 = NESHAP 40 CFR 63 = NESHAP-MACT State Rule Permit to Install Renewable Operating Permit

21 USEPA National Stack Testing Guidance Time Frame for Conducting Stack Tests Stack Test Waivers Stack Test Notifications

22 Requirements Related to Compliance Tests Notification / Plan Submission During the Test: Operation of the Process Monitoring the Process / Control Device Test Report

23 Test Plans The Format for Submittal of Source Emission Test Plans and Reports is available online. Submit 2 copies of the test plan - Lansing - District Part 63 Tests the USEPA Region V must be notified

24 Examples of Emissions Limits Pounds per Thousand Pounds Exhaust Gas Parts Per Million Parts Per 15% Oxygen Pounds per mmbtu Pounds per hour

25 Test Plans Must Contain Contact Information Process Description Pollution Control Device Description Emission Limits for Each Pollutant Test Description

26 Pre-Test Planning Beats Post Test Stress Meet Notification / Test Plan Deadlines Resolve conflicts between process and test activities Coordinate the activity of several different work groups Develop a plan to collect all required data during testing

27 Is The Process Ready for Testing Are Production and Maintenance Ready? Is the expected production available? Will the production be normal? Are the process air supply and exhaust ventilation rates and static pressures within specifications? Are air temperatures normal?

28 Pretest Meeting A must meeting to become familiar with process, abatement, test site and people or TEAM associated with testing program. Determine production schedules and run-times. What if the process only runs 3 rd shift? Figure out who to call in case of production or abatement problems Discuss Testing Timeline Satisfy plant health & safety requirements (e.g., roof pass) Determine EPA or agency interaction with the testing Set up contingencies and what ifs especially if production is lost or slows (shut down testing? )

29 During the Test Monitor the process and control equipment Have a plan if production slips or control system has a problem Document Keep a daily log. Take Pictures. Keep an eye out for safety issues Keep in touch with the testing team. Observe leak checks, sample recoveries, etc. Know where everyone is.

30 What about Agency Personnel Plan on Agency Personnel being present Cover safety issues, escort them to test site. Inform them of communication chain Be able to answer questions about testing protocol, taking pictures, site safety.

31 Practical Considerations in Sampling Confirm that: You have test site access You have power to run equipment An Electrician is available to hookup large voltage connections The situation is Safe The stack is ready to Test

32 Site Access Considerations Confirm that: Site-specific safety training is arranged, if necessary Sampling ports are in appropriate locations. Sample locations must meet test method requirements they must accommodate sampling equipment and they must be placed to permit extraction of a representative sample.

33 Easy Site Access?

34 Site Access Considerations Confirm that: Stairs, ladders, and platforms are structurally sound. Test platforms are adequately sized to meet testing requirements. Space is available in a clean location for a small laboratory if test method(s) require equipment preparation and/or sample handling on-site. Your Team can get out in an emergency!

35 Safe Access Scaffolding

36 Safe Access Scaffolding

37 Site Access How do we get up there? Bucket Lift Scissor Lift

38 Electrical Power is Needed Adequate power is a MUST Inadequate power supply is one of the most common reasons for delays in test programs. Typically, you need: one to two 120-volt 20-amp circuits per sampling method being employed. Don t forget about running heaters in the winter! Put those on a separate circuit. Ask consultant what power input they can receive. Some sampling trailers can utilize 480 volt and employ a Power Transformer. Or you can make a portable Power Transformer.

39 Use a Portable Power Transformer Unit Portable Power Supply Independent Circuit Breakers Outlets Hookup

40 Site Safety Considerations Your Team may need training which needs to be scheduled and planned Facility Safety Orientation Roof Training Fall Protection Electrical Safety Site-Specific Health Concerns

41 Stack Ready to Test? Eye Bolts L Flange Port

42 Stack Testing Monorail Support Can I reach this w/o a tie off? Are ports exactly 90 apart Will bottom of box clear roof surface? Ensure Box & Monorail can hang unobstructed

43 Is this stack ready to Test? Sampling Ports were buried in debris

44 Final System Check Meeting Access to sampling locations and test ports unobstructed? All ladders, stairs, and platforms structurally sound? Adequate power available at each sampling location? Agency notified of pending activities? Cell phones or radios functional in the plant & test site? Test team and chain of command in place? Emergency names and phone numbers readily available? Production systems including ventilation ready? Abatement system ready?

45 Is The Process Ready for Testing? Production and Maintenance ready? What production rate is expected? Will production be normal? Are the process air supply and exhaust ventilation rates and static pressures within specifications? Are air temperatures normal? Do we know what to monitor & record?

46 Is the Air Pollution Control Equipment Ready? Check scrubbers, dust collectors, oxidizers, etc. for proper operation: Static pressure drops Scrubber liquid flow rates ph for acid or caustic scrubbers Temperatures, cycles times & valve clearances for RTO & RCO units Check log of preventative maintenance activities

47 Are Abatement Systems Ready for Testing? Check scrubbers, dust collectors, oxidizers and other equipment for proper operation: Static Air Pressure drops Water flow rates ph for acid or caustic scrubbers Operating temperatures, cycle times & valve clearances for RTO & RCO units Check & review log of last preventative maintenance activities What shall we monitor & record?

48 Testing Responsibilities Monitoring the Process and Abatement Systems and know what to do if production slips or the abatement system has problems Keep a Daily Test Activity Log and take pictures Beware of safety issues Know the whereabouts of all personnel during testing Ensure that you and the consultant know how to coordinate with the Agency

49 Testing Activities Monitoring the Process and Abatement System The process and the abatement systems must be monitored during emissions testing. Electronic and manual monitoring methods available. Systems and parameters to be monitored should be discussed in Pre-Test Meeting. Personnel responsible for monitoring need to be identified and should provide real-time information. Emissions Testing coordinator or another assigned person should audit this information periodically using a log sheet.

50 Basic Testing Methods for Air Flow

51 Basic Test Methods for Air Flow Why measure air flow? To determine: Mass of air emissions Whether process ventilation is within specifications

52 Test Methods EPA Method 1 Sampling Locations & number of sampling points EPA Method 2 Air or Gas Velocity EPA Method 3 Air Molecular Weight & Flue gas analysis EPA Method 4 Air Moisture Content

53 EPA Method 2 Determination of Stack Gas Velocity This method employs a pitot tube to measure the gas velocity pressure and temperature at discrete points within the stack or duct. From this data, gas velocity is calculated. A standard or S-type pitot tube and manometer is normally used for the differential pressure measurement.

54 Type S Pitot Tube & Manometer

55 EPA Method 3 Determination of MW and Gas Analysis Flue gas molecular weight (MW) is needed to determine flue gas velocity. A dry volume of exhaust air is obtained and tested for CO 2, O 2 and CO using an Orsat or Fyrite analyzer. Method 3 is normally used for non-combustion processes. Other versions of Method 3 include 3A, 3B and 3C. Method 3 also allows measuring CO 2 and O 2 and doing calculations for MW, or using 30 as a default value

56 Equipment Used to Obtain A Dry Air Gas Sample Dry air gas sample (bag) is tested using ORSAT, Fyrite or other equipment

57 Versions of EPA Method 3 Method EPA Method 3 EPA Method 3A EPA Method 3B Technique & Gas Measured Orsat or Fyrite for O 2, CO 2 & CO Real-time analyzer for O 2 & CO 2 Orsat analyzer for O 2, CO 2 & CO (fossil-fuel combustion sources) EPA Method 3C GC analyzer for CO 2, CH 4, N 2 & O 2

58 EPA Method 3 Typical Fyrite and Orsat equipment to determine CO 2, O 2 and CO using wet chemical absorbtion solutions.

59 EPA Method 4 Determination of the Moisture Content of a Flue Gas Stream Water is collected in impingers to determine the flue gas moisture content. As an option, Method 4 also allows use of a psychometric chart and a wet bulb/dry bulb thermometer for some situations. Data from this method can be used to calculate MW for subsequent velocity calculations. Method 4 is used with caution if water droplets are present.

60 EPA Method 4 Equipment Main Valve

61 EPA Methods 2, 3, and 4 Summary EPA Methods 2, 3 and 4 are used to calculate stack and duct air flows. Three different values of air flow are normally reported: Actual cubic feet per minute (ACFM) Standard cubic feet per minute (SCFM) Dry standard cubic feet per minute (DSCFM)

62 Basic PM Test Methods

63 Particulate Matter Today s Standards PM 10 Less than 10 microns in approximate aerodynamic diameter 25 times smaller than diameter of human hair PM 2.5 Less than 2.5 microns in approximate aerodynamic diameter 100 times smaller than diameter of human hair SOURCE: US EPA and Pima County AZ Department of Environmental Quality

64 Particulate Matter (PM) Test Methods EPA Method 5 EPA Method 17

65 Particulate Matter (PM) Test Methods EPA Method 5 Particulate Matter (PM) is withdraw isokinetically from source through heated probe and filter Valid test must be 90% to 110% isokinetic The filter and acetone wash are desiccated and weighed to calculate the particulate mass gain The particulate mass gain is combined with the flow data to calculate mass emission rates

66 Isokinetic Sample Velocity

67 Non-Isokinetic Sample Velocity

68 EPA Method 5 Sampling Train Heated Probe 250 F Impingers in Ice Bath Total Equipment Weight = 70 lbs. approximately

69 Particulate Matter (PM) Test Methods EPA Method 17 Determination of total particulate emissions (In-stack filtration) Particulate Matter (PM) is withdraw isokinetically from source through an in-situ holder assembly Cannot be used in stacks containing water droplets or saturated with water vapor Gravimetric determination performed to calculate particulate mass gain. Particulate mass gain is combined with flow data to calculate mass emission rates.

70 Method 17 Filters and Housings Balston Gelman 47 mm Probe tip

71 Other PM 10 Test Methods EPA Method 201 EPA Method 202 Cascade impactors for particulate size distribution (PSD) Microscopic examination of particulate sizes, scanning electron microscope (SEM)

72 EPA Method 201A Determination of Filterable Particulate Matter less than 10 microns in diameter (PM 10 ) Method uses equipment similar to EPA Method 17, except a cyclone separates particulates by size. Stack or duct gas sample is extracted at a constant flow rate that equates to an isokinetic sampling rate. Gravimetric determination is performed on the filterable material to calculate the particulate mass. Downstream of the filter are a series of impingers, an air pump, and a gas meter.

73 EPA Method 201A Sample Probe 4 Filter Cyclone

74 EPA Method 202 Determination of Condensable PM 10 Method consists of analyzing impinger water for material considered condensable particulate matter. Some agencies require that Method 202 results be added to Method 201A and Method 5 results to determine total PM 10 and total PM. There are many issues related to this method. VOC and other chemicals may condense or convert to material collected in the impingers and be counted as PM 10. Also, there is no way to prove the collected material is indeed PM 10.

75 Particulate Matter QA On Site: Nozzle does not touch the stack Nozzle is pointed into gas flow Sampling Train/Pitot Leak Checks Sample Cleanup Report Review: Sampling velocity matches exhaust velocity Calculations are correct

76 Basic SO 2, NO X & CO Test Methods

77 SO 2, NO X & Carbon Monoxide (CO) Test Methods EPA Method 6C EPA Method 7E EPA Method 10 EPA Method 19

78 EPA Method 6C Determination of Sulfur Dioxide Concentrations EPA Method 6C provides continuous real-time sulfur dioxide (SO 2 ) concentrations from stationary sources. A gas sample is extracted from the source and conditioned to remove moisture prior to entering the SO 2 analyzer. Requires compressed gas cylinders for equipment calibration. The sample is then conveyed to an instrument analyzer for determination of SO2 gas concentration using an ultraviolet (UV) analyzer, nondispersive infrared (NDIR) analyzer, or fluorescence analyzer.

79 EPA Method 7E Determination of NO X Concentrations Provides continuous real-time NO X concentrations from stationary sources. A gas sample is continuously extracted from the effluent stream and conditioned to remove moisture prior to entering NO X analyzer. Requires compressed gas cylinders for equipment calibration. The sample stream is conveyed to a chemiluminescent analyzer to determine NO X concentrations.

80 EPA Method 6C & 7E Analyzers Temperature Controller Calibration Gases Heated Sample Line

81 EPA Method 10 Determination of Carbon Monoxide Emissions This method requires the use of a Non-Dispersive Infrared (NDIR) analyzer to determine real-time carbon monoxide (CO) concentrations. Requires compressed gas cylinders for equipment calibration. Requires sample conditioning to remove moisture from the sample stream.

82 EPA Methods 6C, 7E, and 10 Sampling Train SO 2 Analyzer CO Analyzer NO x Analyzer

83 Basic VOC & Organic Test Methods

84 VOCs & Organic Testing Methods EPA Method 25 & 25A EPA Method 18

85 EPA Method 25A Determination of Total Hydrocarbon Concentrations Provides continuous real-time total hydrocarbon (THC) concentrations making this method more frequently used than Method 25. Often used to determine capture and/or destruction efficiency as well as to fine tune control equipment. A gas sample is extracted from the source through a heated sample line to a flame ionization detector (FID). The FID is calibrated with gas such as propane and zero air. Results are reported as VOC as propane, if propane is the calibration gas.

86 EPA Method 25A Equipment

87 Instrumental Method QA On Site: Protocol 1 calibration gases are used Gas certifications are current Analyzer is calibrated Sampling system is accurate Calibration range of the analyzer is correct

88 EPA Method 18 Determination of Gaseous Organic Compound Emissions by Gas Chromatography Method 18 allows three sampling and analytical techniques: Stack gases are sent directly to a field GC, which requires calibration gases. Stack gases are collected in an integrated bag sample or canisters (summa) and submitted for laboratory GC analysis. Stack gases are directed into adsorbent tubes, which are submitted for laboratory GC analysis. Bag and adsorbent tube collection methods require a QA.QC plan, which involves the collection of spiked and unspiked sorbent tubes and bag spiked samples.

89 EPA Method 18 Sorbent Tube Sampling Train

90 MQEQ Activities During Testing Observe Process and Data Collection Observe Sample Collection Attempt to resolve problems that may arise during the test

91 USEPA National Stack Testing Guidance Observation of Stack Tests Representative Testing Conditions Stoppages Postponements

92 Post Testing Issues We are done with the testing! What do we do now?

93 Post Test Activities Clean up the Test Site Follow up with Testing Consultant Follow up with Plant and Corporate Develop a Draft Test Report Finalize the Test Report Submit Report to Agency (compliance testing only)

94 Post-Test Activities Report Format and Contents To have a successful test, you must have an excellent supporting document or test report. Report format should follow acceptable technical report writing guidelines: Executive summary Discussion Data, Tables & Figures Appendix

95 Submittal of Report to Agency Notify the agency that a Final Test Report will be sent to their attention. IMPORTANT! Develop a report cover letter to explain the testing program, and provide any interpolation of results. If the test failed, provide reasons for failure and describe your future course of action.

96 Test Report Send 1 copy of each test plan and each test report to: The Technical Programs Unit (TPU, Lansing) The appropriate District Office