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Source Emission Testing Comprehensive Performance

Testing Fundamentals

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Agenda

Source emission testing overview Commonly used source test methods Types of hazardous waste incineration units CPT program and regulatory applicability CPT QAPP and test plans CPT Pre-planning Key CPT field testing components POHC selection Data in lieu of testing options Common CPT failures and lessons learned Appendix Material

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Source Emission Testing Overview

Source Emission Testing can be best defined as:

“Quantifying pollutant emissions from a stationary air emission point source”

Point sources can range from a 2-inch ID process vent to a 20 foot or larger diameter utility boiler stack.

Some of the pollutants tested include:• particulates (filterable, condensible, PM-10, PM-2.5)• VOCs• SOx, NOx, CO, THC, NH3• semivolatile compounds• acid gases (HCl, HF, H2SO4)• aldehydes and ketones• toxic metals

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Source Emission Testing Overview

Why Test?

1. To evaluate or demonstrate compliance with a State or Federal emission standard

2. To evaluate the emission impacts of a process modification

3. To audit a continuous emission monitoring device

4. To generate data in support an emissions inventory or permitting activity, or

5. To evaluate the performance of a pollution control device

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Source Emission Testing Overview, con’t

Source emission testing can:• Accurately quantify target pollutant emissions to support a number of

objectives (compliance, diagnostic work, optimization, etc) Source emission testing can’t necessarily:

• Identify all unknown pollutants in a gas stream. Need to have some information on process parameters, raw materials, exhaust gas constituents, etc. to select appropriate test methods.

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Source Emission Test Method Categories

Regulatory agencies (e.g. USEPA and CARB) along with industry trade groups (e.g. NCASI) have established detailed, validated source test methods for specific pollutant types.

These test methods can be divided up into three general categories –• Isokinetic, multi-point sample collection• Single-point, nonisokinetic (constant sample rate)• Instrumental – realtime, on-site analysis

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Volumetric Flow Rate Test Methods Measuring the volumetric flow rate of a gas stream is included in most

source testing programs. It is used to relate pollutant concentrations to mass emissions rates (lb/hr) The following test equipment are used to evaluate flow rate

• S-type or Standard pitot tubes (USEPA Methods 1 and 2)• Hot wire anemometers• Vane anemometers• Ultrasonic flow meters• Orifice meters• Measurement head is traversed across duct to account for particle

stratification

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S-Type Pitot Tube Schematic

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Isokinetic Test Methods Isokinetic methods are used to sample for pollutants in a solid or aerosol

state at stack temperature. These methods maintain a sample rate that is equal to the velocity of the sample stream. • Particulate or particle-bound pollutant captured on filter media• The “same velocity” sample rate is important so that the collected

sample is not biased due to varying particle sizes.• Sample nozzle diameter and sample rate are selected to achieve an

isokinetic sampling condition given specific stack gas conditions• This sample velocity/rate is maintained through-out the test run

regardless of charges to stack flow rate• Sample velocity/rate criteria for the majority of isokinetic methods is 90-

110% stack flow rate

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Isokinetic Test Methods , con’t

Sample nozzle is traversed across duct to account for particle stratification

Commonly used Isokinetic test methods:• USEPA Reference Method 5 (particulates)• USEPA Reference Method 23 (PCDD/DF)• USEPA Reference Method 29 (metals)• USEPA Reference Method 201A (PM-2.5 and PM-10)• CARB Method 429 (PAH) • SW846 Method 0050 (HCl/Cl 2)

USEPA Methods 1-4 which measure stack gas flow rate are conducted in conjunction with above methods

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Isokinetic Sample Train Schematic

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Single Sample Point, Nonisokinetic Test Methods

Single point nonisokinetic test methods are used to sample pollutants in the gaseous or vapor state where isokinetic particle effects can be discounted. • Samples are adsorbed onto a solid sorbent media or absorbed/reacted in

a solution• Sampling is usually conducted at a single point in the duct or stack as

pollutants are assumed to be in gaseous state and not stratified• Sample rate varies with pollutant, concentration, collection media type• Samples are typically analyzed off -site, however on-site analysis can be

conducted depending on complexity of the analysis and need for realtime data.

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Instrumental Test Methods On-site instrumentation is used to obtain real-time emissions data Sampling is conducted at a single point or multi-point traverse depending

on stratification levels. Sample is gaseous, so isokinetic particle effects can be discounted. Commonly used on-site analytical procedures include:

• Chemiluminescence (NOx)• Pulse Fluorescence (SO2)• Nondispersive infrared (CO, CO2)• Electrochemical (O2)• Paramagnetic (O2)• Flame ionization (Total organics)• Gas chromatography and FTIR (speciated VOCs)

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Comprehensive Performance Test Overview

A hazardous waste incinerator comprehensive performance test (CPT) or “Trial Burn” is one of the most complex and extensive source test programs a source owner can conduct

A CPT is:• integral component of a facility's waste treatment program • very expensive program with costs typically ranging from $0.5 to

>$1MM• test that requires tremendous amount of upfront planning and process

evaluation prior to testing• a program that requires intensive communication with numerous groups • Typically involves spiking of waster material or surrogates into the APC

inlet stream

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Hazardous Waste Combustion Units

There are 3 kinds of hazardous waste combustion units:

Incinerators Boilers Industrial Furnaces

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Hazardous Waste Combustion Units

Incinerators An incinerator is an enclosed device using controlled flame combustion Includes infrared incinerators and plasma arc incinerators Does not include industrial furnaces, boilers, sludge dryers, and carbon

regeneration units

There are approximately 120 hazardous waste incinerators in the United States

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Hazardous Waste Combustion Units

Boilers A boiler is an enclosed device using controlled flame combustion that has

an energy recovery system The combustion chamber and primary energy recovery system are of

integral design Thermal energy recovery efficiency must be > 60% Energy exportation and utilization must be > 75%

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Hazardous Waste Combustion Units

Industrial Furnaces An industrial furnace is an enclosed device that is an integral component of a

manufacturing process and uses thermal treatment to recover materials or energy Industrial Furnace types Include:

• Cement, lime, phosphate, and aggregate kilns• Blast, methane reforming, and halogen acid furnaces• Titanium dioxide chloride process oxidation reactors• Coke ovens, smelting, melting, refining furnaces• Pulping liquor recovery furnaces• Combustion devices used in the recovery of sulfur values from spent sulfur

acid

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Hazardous Waste Incinerator MACT Regulated Pollutants

The MACT standards limit emissions of:• Dioxins and furans• Mercury• Semi-volatile metals (cadmium and lead)• Low volatile metals (arsenic, beryllium, and chromium)• Particulate matter, as a surrogate for non -mercury metal• hazardous air pollutants (including antimony, manganese, selenium,

nickel, cobalt)• Hydrogen chloride and chlorine gas• Organic hazardous air pollutants

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Hazardous Waste Incinerator Destruction and Removal Efficiency (DRE) Requirements Units must meet specified DRE requirements:

• 99.99% DRE for each principal organic hazardous constituents (POHC)• 99.9999% for each POHC if unit burns specific dioxin wastes• POHCs are established based on the specific waste being combusted

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Hazardous Waste Incinerator Testing Requirements

Two periodic test programs required to demonstrate compliance with emission limits

• Comprehensive Performance Test (CPT)• Confirmatory Performance Test (CFPT)

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Hazardous Waste Incinerator Testing Requirements

Comprehensive Performance Test

The CPT is the more complex program of the two required compliance tests. The Comprehensive Performance Test (CPT) is conducted in order to:

• Demonstrate compliance with emissions standards• Establish (or revise) limits for operating parameters• Demonstrate compliance with the performance specifications for

continuous monitoring systems (CMS)• A CPT plan must be submitted for approval 12 months before the

scheduled test• Initial CPT must be performed no later than six months after the

compliance date

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Hazardous Waste Incinerator Testing Requirements

Comprehensive Performance Test, con’t

• CPTs must be conducted every five years with a one month• extension (i.e., 61 months) following the anniversary date of the

previous CPT• Designed to be performed under worst-case operations similar to RCRA

trial burns• Testing must be completed within 60 days of initiating testing• Results must be submitted to the permitting agency 90 days following

completion of the test

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Hazardous Waste Incinerator Testing Requirements

Confirmatory Performance Test (CFPT)

Significantly less intensive and complex than a CPT Demonstrate compliance with dioxin/furan emission standards only Performance evaluation of dioxin/furan CMS Completed midway between CPTs (every 31 months after commencing CPT)

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CPT Timeline

Sources are required to submit plans one year prior to actually conducting CPT

Regulatory agencies are to notify facility of intent to approve or disapprove test plan within 9 months of submittal

Source owners must notify the lead agency of their intent to test and issue a public notice no sooner than 60 days prior to testing

Once started, testing must be completed within 60 days of initiating the test

Facilities must submit their CPT results and Notification of Compliance within 90 days of completing the CPT

Extension of time provisions exist to both extend the review period, plus also extend the test timing

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CPT Pre-Planning - CPT Plans and Quality Assurance Project Plans (QAPP)CPT Plan Overview

Similar to a traditional stack testing protocol that contains information outlined in 40 CFR 63.1207 which includes:• Details of the unit(s) to be tested• Details on the waste(s) treated• Test location schematics• Process operating information to demonstrate that the unit(s) will

operate under one or more “worst case” conditions• Waste feed procedures, spiking, injection rates, and/or surrogate fuels• Relevant QA/QC processes and activities to validate the data

Key to a successful CPT: Plan, Plan, and then Plan some more!

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CPT Plan Content

CPT Component Regulatory Citation• Program Summary 40 CFR § 63.1207(f) and § 63.7(c)(2)(i)

• Test schedule 40 CFR § 63.1207(f), (f)(1)(v) and § 63.7(c)(2)(i)

• Data Quality Objectives (DQOs) 40 CFR § 63.1207(f) and § 63.7(c)(2)(i)

• Internal and External Quality Assurance Plan 40 CFR § 63.1207(f) and § 63.7(c)(2)(i)

• Analysis of feedstreams (as fired) 40 CFR § 63.1207(f)(1)(i)

• Detailed engineering description of combustor 40 CFR § 63.1207(f)(1)(iii)

• Description of Waste handling and blending operations 40 CFR § 63.1207(f)(1)(ii)(C)

• Planned Feed and Operating conditions during the CPT 40 CFR § 63.1207(f)(1)(iv) and 40 CFR §63.1207(f)(1)(vi) & (vii)

• Procedures for stopping waste feed and controlling emissions during malfunction 40 CFR § 63.1207(f)(1)(viii)

• malfunction determination of hazardous waste residence time 40 CFR § 63.1207(f)(1)(ix)

• Metal feed rate limit extrapolation (if used) 40 CFR § 63.1207(f)(1)(x)

• CMS and CEMS performance evaluation plans 40 CFR § 63.8(e)(4) and 1207(b)(1)

• Levels of regulated constituents feedstreams that are not analyzed 40 CFR § 63.1207(f)(1)(xi)

• Conditioning time needed to reach steady state prior to testing 40 CFR § 63.1207(f)(1)(xii)

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CPT Pre-Planning – Mini-burns

Conducting a mini-burn is highly recommended - great dry run prior to the CPT

Mini-burn can be used to:• Evaluate selected waste and POHC feed spiking rates• Assess compliance with emission limits• Evaluate process and control operations• Test process set-points and cut-offs• Review source test locations and access issues• Identify and resolve program logistical problems upfront

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Key CPT Field Testing Components

Schedule – CPTs have a long lead time – establish project timeline early and be sure to include all subcontractors (spiking firm, on-site FTIR/GC, etc)

Identify and confirm program personnel and lines of communication Prepare thorough CPT plan and QAP and ensure they are thoroughly

reviewed with all program participants Meet with CPT program personnel well ahead of field test date to review:

• Test locations• Facility safety procedures, PPE requirements• Electrical power needs• Spiking equipment set-up locations• Process operations• Field test schedule

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Key CPT Field Testing Components, con’t

Ensure that field test team calibrates all test equipment and calibration data is brought on-site

Prepare waste and source test sample labels prior to testing Schedule sample media delivery from laboratories well in advance of field

testing Establish all sample shipping and/or transport logistics prior to field

mobilization - often overlooked! Procure field sample audits from designated laboratories – watch required

lead time

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Key CPT Field Testing Components – POHC Selection

POHC selection is one of the most important aspects of any CPT program Be sure and select a POHC that:

• Is more difficult to combust than organic HAPs• Base on historical data and test results, if possible• Is not a product of incomplete combustion• Is readily available and cost effective• Not necessarily native to the waste stream• Requires routine test methods to evaluate DRE

Select a POHC injection rate that will show acceptable DRE, but be careful not to overload sample media

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Key CPT Field Testing Components – POHC Selection

POHC Feed rate is critical POHC feedrate too low

• Need 104 X difference between lb/hr fed vs emitted to achieve a 99.99% DRE

• Need 106 X difference to achieve a 99.9999% DRE POHC feed rate too high

• Overwhelm sampling train Confirm that selected POHC cannot be introduced from unexpected

source(s) in waste or process vent systems

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Key CPT Field Testing Components – Inorganic Spiking Only conduct inorganic spiking if necessary Select an inorganic spike material that:

• Has a physical state compatible with native waste stream• Commercially available and cost effective• Can be spiked accurately using well established feed systems• NIST traceable, if possible

Select an injection rate that is close to established or permitted emission limits

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Data-in-Lieu of Testing (DILO)

Allowed under 40 CFR 63.1207(c)(2) DILO testing results can be used in place of actual testing on the same unit

(data from previous RCRA trial burns, compliance programs) Can also be used in place of testing on a “identical” or “similar” unit Identical units are physical clones with the same manufacturer, with major

aspects of the unit being identical: • Process and mechanical design• Feed systems and waste feeds/rates• Air and auxiliary fuel systems and fuels• Combustion chamber(s) • Air pollution control (APC) system

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Data-in-Lieu of Testing (DILO), con’t

Similar units - Units are not total clones, but many features are virtually the same

Same process design – feed systems, combustion chambers, APC, etc. Same feeds, possibly at different feed rates Some differences in equipment sizes, but same equipment manufacturers Two examples –

1. Two kilns, same style, purpose, similar diameter, different length, or 2. Same combustion chamber geometry and burner configuration, but

slightly different firing capacities, everything else is identical

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Data-in-Lieu of Testing (DILO), con’tImportant Considerations for DILO Requests Incorporate DILO request in CPT Plan Incorporate with regulatory notification of intent to test Important to allow for public comment regarding the use of DILO List major unit features (Feed rate, combustion chamber/burners, APC

design, etc) in CPT Plan When using data from earlier test programs:

• Verify feed rate and operating conditions is same as current program• Verify sample test methods are the same• Verify QA/QC procedures were consistent with current testing

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Primary Causes of CPT Failures

CPT test conditions not representative of actual or planned operations

Process equipment operational issues• Pollution control equipment malfunctions• Incinerator operating problems

Incorrect spiked POHC or waste feed rates (under or overfeeding)

Difficulty maintaining desired test conditions (lack of experience/run time)

Incorrect incinerator DRE performance assumptions or erroneous pretest data

Errors in CPT field sample collection or analysis

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Implications of a Failed CPT

Following completion of a CPT a facility has 90 days to submit a notification of compliance

If a facility determines within the 90 day period that it exceeded an emissions standard, does not meet the DRE threshold, or does not meet a CMS performance standard, they must:• suspend hazardous waste burning during the tested process operating

condition(s)• facility can burn waste for up to 720 hours for the purpose of pre-testing

or confirmatory testing • facility can petition regulatory agencies for a waiver to burn waste for

other purposes • facility must conduct another CPT under revised process conditions

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Questions?

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Thank You

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Appendix

Commonly Used Field Emission Testing Equations

Acronyms

Sample Train Schematics and Photographs

Reference Citations

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Commonly used CPT Testing Equations

Stack Gas Velocity (ft/sec) = K x pitot tube coefficient x ( ΔP)½ x (Ts/Ps x Ms)½

Stack gas Molecular Weight = 0.44 x (%CO 2) + 0.32 x (%O2) + 0.28 x (%N2 + % CO)

Stack Gas Flow Rate (dscf/min) = 3600 x (1-Bws) x Vs x Stack Area x (TSTD x Ps/Ts x PSTD)

Where:ΔP = pitot tube differential pressure (in H2O)K= Conversion constantTs = Stack Temperature (Deg. R)Ps = Stack Pressure = (In Hg)Ms = Stack gas molecular weightBws = Stack gas moisture content (percent by vol.)T STD = Standard temperature (460 Deg. R)PSTD = Standard pressure (29.92 in Hg)

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Commonly used CPT Testing Equations, con’t

% Isokinetic Sample Rate = 100 x Ts x [(Vm x Volc)/Tm x (Pbar + ΔH/13.6)]60 x Ps x An x Vs

Sample Volume (dscm) = Vm x Meter Gamma (Y) x Ts x (Pbar+ ΔH/13.6)Tm x Ps

Pollutant Concentration (mg/dscm) = Pollutant Mass (mg)Vm(STD) (m3)

Pollutant Emission Rate (lb/hr) = Pollutant Conc. (mg/dscm) x volumetric flow rate (dscm/min) x 60 x K

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Exhaust Stream Flow Profile Evaluation

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Single Point, Nonisokinetic Test Methods

Example of single point test methods include:• USEPA Reference Method 6 (SO2)• USEPA Reference Method 7E (NOx)• USEPA Reference Method 18 (VOCs)• USEPA Reference Method 26 (HCl/Cl2)• USEPA Reference Method 308 (Methanol)• SW846 Method 0051 (HCl/Cl 2)

USEPA Methods 1-4 which measure stack gas flow rate are conducted separately from the above methods

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Single Point, Nonisokinetic Sample Train Schematic

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Isokinetic Sample Train Schematic

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Single Point, Nonisokinetic Sample Train Schematic

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Single Point, Nonisokinetic Sample Train Schematic – VOST

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Instrumental Continuous Emissions Analyzers

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CPT Reference Material• Guidance on Setting Permit Conditions and Reporting Trial Burn Data – USEPA Document

EPA/625/6-89/019

• Guidance for Quality Assurance Project Plans – USEPA Document EPA/240/R-02/009• USEPA Reference Test Methods – 40 CFR Part 60, Appendix A

• USEPA CEMS Performance Test Methods – 40 CFR Part 60, Appendix B• CPT Hazardous Waste Test Methods – USEPA SW846

• Memorandum on Trial Burns (Guidance on Trial Burn Failures) – USEPA Document EPA/530/F-94/023

• CPT Notification Requirements – 40 CFR Part 63.1210

• CPT Performance Test Requirements – 40 CFR Part 63.1207 • CPT Test Methods – 40 CFR Part 63.1208

• CPT Monitoring Requirements – 40 CFR Part 63.1209• QA/QC Procedures for Emission Monitors Serving Hazardous Waste Incinerators and

Performance Testing Requirements for CEMS Certifications – Appendix to Subpart EEE