Document 3JYjM73Zjx3jrZG9ge1MgE5DD

DO A 035477 CONFTDFNTT Al August 20, 1992 Dow U.S.A. The Dow Chemical ComDai~y PO Box '50 Plaojemme -Cu.s ana 70765-0'50 HAND DELIVERED Mr. Allyn M. Davis, Dirsctor Hazardous Wasts Division U.S. Environmsntal Protection Agency 1445 Ross Avenue, Suite 1200 Dallas, Texas 75202-2733 COMPLIANCE TEST NOTIFICATION VINYL II PLANT BOILERS F-410 AND F-420 THE DOW CHEMICAL COMPANY, LOUISIANA DIVISION LAD008187080 Dear Mr. Davis: Dow received a hazardous waste permit on May 19, 1989 for its facility located in Plaquemine, Louisiana. In addition to the previously permitted activities, Dow operates four existing industrial boilers which burn hazardous wastes and which are now operating under the interim status provisions of the new Boiler and Industrial Furnace rules. On August 21, 1991 we submitted a Certification of Pre-compliance for the four boilers in the Louisiana Division in compliance with these regulations. Today, we are submitting Certifications of Compliance as required under 40 CFR 266.103(c) for boilers F-410 and F-420, which are located in our Vinyl II plant. Per approval granted by EPA in a letter dated August 11, 1992, we are submitting data from unit F-410 in lieu of additional testing on identical boiler system F-420. If there should be any questions regarding this matter please call Edward Anthony at (504)382-4044 or me at (504)389-6131. Sincerely, Stanley G. Cole Environmental Manager cc: Glenn Miller, LDEQ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1445 ROSS AVENUE, SUITE 1200 DALLAS. TX 75202-2733 AUG l 1 199? RECEIVED Mr. Stanley G. Cole, Environmental Manager DOW Chemical Company Louisiana Division P.O. Box 150 Plaquemine, Louisiana 70765-0150 AUG 21 1992 environment services Re: Approval of request to use compliance test data from one boiler in lieu of testing an additional similar onsite boiler Dear Mr. Cole: This letter is in response to the request by DOW Chemical Company in Plaquemine, Louisiana, to use compliance test data from one boiler in lieu of conducting compliance tests on an additional similar onsite boiler under 40 CFR 266.103(c)(3) of the Boiler and Industrial Furnace (BIF) Rule. According to 40 CFR 266.103(c)(3), the authorized agency shall provide a written approval to use compliance test data in lieu of testing a similar unit if the hazardous wastes, the devices, and the operating conditions are sufficiently similar, and the data from the compliance test is adequate to meet the conditions specified to certify compliance. We have reviewed the information submitted and have determined the boilers at DOW Chemical to be similar. Based on the following understanding, the request is approved. A compliance test will be done on Boiler F-410 in accordance with all applicable requirements in the BIF Rule. The emission limits and operating parameters established for Boiler F-410 during the compliance test will apply directly to the remaining boiler and a complete and accurate Certification of Compliance mut be submitted to the Environmental Protection Agency no later than August 21, 1992. Please be advised any noncompliance demonstrated from either the testing or the Certification of Compliance for the fully tested boiler may result in a loss of authorization to burn hazardous waste in all boilers. Sincerely yours, Allyn M. Davis, Director Hazardous Waste Management Division (6H) cc: Ross Williams, LDEQ DO A 035479 CONFTDFNTTAl Prmteti Ort Reeve`PC F-410 DO A 035,430 CONFTDFNT 7 Al. COMPLIANCE CERTIFICATION FORM 1 (CC-1) GENERAL FACILITY AND TESTING INFORMATION [X] Initial Certification f 1 Revised Certification \ 1 Recertification 1. EPA Facility I.D. Number: LAD 008187080 2. Facility Name Contact Person: Telephone Number: The Dow Chemical Company Louisiana Division Stanley G. Cole Environmental Manager (504) 389*6131 Facility Address: 3. Type of boiler / industrial furnace: 4. Person responsible for conducting compliance test: (Attach statement of qualifications) Telephone Number: The Dow Chemical Company P.O. Box 150 Plaquemine LA 70765 Fire Tube Boiler F-410 Vinyl II Plant David Martin Air Quality Department Manager (205) 271-1444 Company Name; CH2M Hill Address: 2567 Fairlane Drive Montgomery AL 36116 5. Date(s) of compliance test; July 7 - 9, 1992 6. Person responsible for QA/QC: Clinton Hunt Title: Telephone Number: Senior Environmental Chemist The Dow Chemical Company (504) 389-1676 Attach a statement certifying that procedures prescribed in QA/QC plan submitted with Compliance Test Notification Form 3 (CTN-3) have been followed, or a description of any changes and an explanation of why changes were necessary. I certify under penalty of law that thia information wtt prepared under my direction or eupervieion in accordance with a system designed to eneure that qualified penonnel properly fathered and evaluated the information and supporting documentation. Copie* of all emieaioo* teau, diapcnion modeling reiulta, and other information uaed to determine conformance with the requiremenu of 1266.103(c) arc available at the facility, and can be obuincd from the facility conuct penon lined above. Baeed on my inquiry of the peraon or peraona who manage* the *y*tem, or fhote peraona directly reaponaible for gathering the information, the information aubmitted ia, to the beat of my knowledge and belief, true, accurate, and complete. I am aware that there are *ignificant penaltie* for aubmitting falae information, including the poaaibility of fine and imprisonment for knowing violation*. I *l*o acknowledge that the operating condition* eaubliahed in thi* certification pursuant to 1266.103(c)(4)(iv) are enforceable limiu at which the facility can legally operate during interim autus until (1) a revised certification of compliance is aubmitted or (2) an operating permit ia issued. Signature: xTV Date: August 20. 1992 Title: General Manager. Louisiana Division DD A OA",43] f.ONFTDFNTTAl COMPLIANCE CERTIFICATION FORM 2 (CC-2) DEVIATIONS FROM SUBMITTED NOTIFICATION OF COMPLIANCE TEST 1. Were there any changes in the unit configuration prior to or during testing that would alter any of the information submitted on Form CTN-2 of die unit's Notification of Compliance Test? ______Yes X No If yes, describe these changes and why they were necessary and attach an amended Form CTN-2 describing the unit as actually tested. (Attach additional sheets if necessary). 2. Were there any changes in the planned test conditions prior to or during testing that alter any of the information submitted on Form CTN-3 of the unit's Notification of Compliance Test? X Yes ____ No If yes, describe these changes and why they were necessary and attach an amended Form CTN-3 describing test conditions. (Attach additional sheets if necessary). The original submittal specified three test conditionsfor this unit. Thefirst two test conditions were designed to show compliance with all applicable pre-compliance limits while resolving conflicting parameters ofmaximum thermal input and maximum chlorine load. The plan was to augment the composition ofthe process ventfeed to provide a high BTU load in Test Condition 1 and a high chlorine load in Test Condition 2. However, this wasfound to be an impractical operation. Instead, a way was devised to produce a ventfeed with a composition intermediate between high BTU content and high chlorine contentfor use in Test Condition 1. Test Condition 2 was, therefore, set aside. Test Condition 3 to demonstrate compliance with 266.103(g) is retained. Please see comments on thefollowing page regarding the amount ofashfed during the compliance test. Finally, some minor changes in the original submittal were discussed in a letter to E.P.A. on June 5,1992. A copy ofthe letter is attached. no A 005.4 00 CONFTDFNTTAL COMMENTS REGARDING THE AMOUNT OF ASH FED Introduction: In the Certification of Pre-compliance, the allowable limit for ash in the hazardous waste feeds to units F-410 and F-420 was set at 1.99 pounds per hour. Based on the waste characterization for the T-400 hazardous waste feed stream established for Pre compliance, this limit should not have been exceeded during the Compliance Tests. However, data gathered during the Compliance Test show that the rate of ash fed with this stream was much higher than set in the Certification of Pre-compliance. In spite of the high ash feed rate, emissions of particulate were well below the allowable limit set in the regulations. Therefore, we are establishing this new limit for allowable ash feed to the units in lieu of submitting a new Pre-compliance Certification. Background: Preliminary testing for the Certification of Pre-compliance showed that unit F-410 was capable of emissions in excess of the allowable regulatory limit at high hazardous waste feed rates. A large part of these emissions are salt, carried over from the caustic scrubber as an entrained mist. Particulate emissions were measured from the unit in the presence and in the absence of hazardous waste feed in order to determine the significance of salt emissions to the total emissions. A total allowable emissions rate was calculated from the stack velocity (based on an allowable limit of 0.08 gr./dscf, corrected to 7% oxygen), and the salt emissions were subtracted from this value to determine the allowable non-salt emissions rate. In order to assure compliance, the very conservative assumption was made that all ash in the feed would be emitted unattenuated as particulate matter. The flow rate limit for hazardous waste to the unit was set based on these ash feed limits. Basis for New Ash Feed Limits Emissions data gathered during the Compliance Test show that the assumption of unattenuated emission of ash as particulate is too conservative. Particulate emissions were more than twenty (20) times lower than the regulatory limit. In fact, total particulate emissions were lower than the originally estimated salt emissions, indicating that particulate removal by the unit is essentially total. Since the preliminary Pre-compliance testing was completed, the control systems for both of these boilers have been converted over to new, state-of-the-art systems. Improved control may be responsible for the improvement in emissions. The air pollution control devices on units F-410 and F-420 were actually designed for DO A 03M33 1DFMTt Al conf replacement boilers twice the size of the existing units. Their ability to capture particulate is more than adequate to assure low emissions of "true particulate." Salt carry-over as entrained mist is the result of a lack of de-mister pads on the scrubbers. DO A 03-r>434 CONFinFNTT Al COMPLIANCE CERTIFICATION FORM 3 (CC-3) SUMMARY OF COMPLIANCE TEST EMISSIONS Complete a separate form for each test condition (if more than 1) under each mode of operation for each unit. 1. Use the same identification codes as on Form CTN-3 for the following: Unit # 1 : Mode (letter) A ; Test Condition (1,2 or N/A)a 1 Brief Description of Mode and Test Condition: 2. Purpose of Test (e.g. Demonstrate compliance with PM, metals, HCl, C>2 emission limits when firing sludges at maximum feed rate and flue gas flow): Demonstrate compliance with PM, HCl/Cl and chromium VI standards at maximum thermal input rate and maximum chlorine load. 3. Attach a complete copy of QA/QC results for each test. 4. Test Results: Run No. Date (month / day / year) Time Run Started (hr: min) Total Run Time (hr: min) Sootblow Time (mins) CO (ppmv 7 % Oo) Run Avg. Highest 60-min rolling avg. HC (ppmv (3)1% O^) Run Avg. Highest 60-min rolling avg. PM emissions (gr / dsef) HCl emissions (g/hr) Clo emissions (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr) Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) 1 7/7/92 16:08 2:01 2 7/8/92 14:00 2j01 3 7/8/92 17:52 2:00 15.2 45.3 18.2 18.2 15.6 17.8 NA NA 0.0028 122 7.8 NA NA 0.0039 196 5.9 am NA NA 0.0036 249 5.2 "XdtditttL NA NA NA NA Tier! '* . v#:!:'.'.:.- ' w-:W iiiilsiii 0.05 0.03 Metals " : - -iIrKe1 - - "'7 0.01 Vi,:.' NA iiriM ' Allowable 0.08 2270 90.8 3.63 0.35 1.82 0.00 1.27 0.26 4.09 9.99 227.00 0.00 Y Y Y Y Y Y Y Y Y Y Y Y Y a. If facility conducted tecta at only one Kt of teat conditions for the stated mode enter N/A. If two seta of test conditions were ran for the mode, fill out a separate form for each set of test conditions, identifying the test conditions (1 or 2) as on Fotm CTN-3. b. If soot blowing or other daily activity that increases the PM emission rate was incorporated into the testing, calculate avenge using equation provided in instructions. c. Allowable levels are the same as indicated on Form PC-4. 'd. Check if each non-sootblowing run and average are lets than or equal to allowable, e. Indicate tootblowing time or other activity that was incorporated into the testing. Do A COMPLIANCE CERTIFICATION FORM 3 (CC-3) SUMMARY OF COMPLIANCE TEST EMISSIONS Complete a separate form for each test condition (if more than 1) under each mode of operation for each unit. 1. Use the same identification codes as on Form CTN-3 for the following: Unit # 1 : Mode (letter) A ; Test Condition (1,2 or N/A)* ___ 1 Brief Description of Mode and Test Condition: 2. Purpose of Test (e.g. Demonstrate compliance with PM, metals, HC1, CI2 emission limits when firing sludges at maximum feed rate and flue gas flow): Determine minimum allowable temperature forfeeding hazardous waste per 266.103 (g). 3. Attach a complete copy of QA/QC results for each test 4. Test Results: Run No. Date (month / day / year) Time Run Started (hr: min) Total Run Time (hr:min) Sootblow Time (mins) CO (ppmv <& 7 % 0->) Run Avg. Highest 60-min rolling avg. HC (ppmv @ 7 % 0-j) 1 7/9/92 10:50 1:00 - <40.6 45.2 2 7/9/92 14:56 1:00 3 7/9/92 15:58 1:00 \ -x-ifr 31.7 46.2 & &*'Vw.,s 26.1 31.9 Avg.1 Allowable Emission Ratec Kiss*. *.* OKd jvvij;sjv*-'; ^ - 'py;$---yyr<Y~ 7c * vv " *** v - -< - ^ -- vs.:<s. ^ guy.; ? ", 'rr*tfffc Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) .v.'rAvyAjtttiWtl ry,MN|Wt? vtowe QK&yrzivfiMc.vjr-r-Wj^y ... . IJ.- -V.-, V'- V VW^^mvyWJW V-V.-.W *-'V ^''''*W1-'",''W'," A* VJfW; ' ,< `y -""^ra ?. j>:-v>;.'.-.--Tv:jfr'WjSjAfr'.b:-: 'ii ,<Sf; wix-Jw-.v,' v.v.-.Cv:* 5.0^0, AXi4<3mf5M<W $d*ojo6.d\^f5iti}-1 ' a. If facility conducted tests at only one act of ten conditions for the Mated mode enter N/A. If two Kit of teM condition* were run for the mode, fill out a separate form for each set of teM conditions, identifying the teM conditiona (1 or 2) a* on Form CTN-3. b. If aoot blowing or other daily activity that increase* the (M emission rate wai incorporated into the testing, calculate average using equation provided in inMructions. c. Allowable levels are the same a* indicated on Form PC-4. d. Check if each non-tootblowing run and average are lets than or equal to allowable. e. Indicate sootblowing time or other activity that was incorporated into the testing. DO A 0304 3: CONF T DFNT I Al COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and ClN-3. 1. Unit#: 1 Mode: A Test Condition (1,2, or N/A): 1 Run No.: 1 Test Date: 7/7/92 2. Run Start Time (hr:min): 16:08 Run End Time (hr:min): 21:18 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: See discussions, next page 3.______ Operating Conditions: Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (F)b Max. Combustion Chamber Temp.(*F)b APCS Operating Parameters (list applicable parameters, see 266.103(c)(l)(ix-xiii) Acid absorber liquid-to-gas ratio Scrubber liquid-to-gas ratio Scrubber fluid pH Scrubber blow-down rate (gallons per minute) Run Avg. 38.6 449 1985 Run Avg. 3.99 0.58 7.92 81.6 60-nun. Avg.R 41.1 451 1993 60-min. Avg.c 3.97 0.55 7.75 79.9 Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)1 Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr) Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) 1 Uqiad wM HW 751,869 11.39MM 11,278 605,162 0 0 0.107 0 0.013 0 0.107 0 0.535 0 2 fuel (M fm1 115,575 5.48MM 0 0 0 0 0 0 0 0 0 0 0 0 3 firxmt 'mtM wed Hum 634,606 ,9-lTMM 0 138,471 0 0 0 0 0 0 0 0 0 0 4 otetaa efaroarfuin VI etb MurtB 4,989 0 10 0 0 0 0 0 0 3.6 0 0 0 0 * Indicate highest or lowest 60-minute rolling average a> appropriate. b Not applicable if complying with Tier I or adjuated Tier I meult feed rate acreening limit*. c Indicate highcM 60-minute rolling avenge* for maximum flue gaa flow rate and, if choten, maximum auapended solid* content of icrubber water where applicable. Indicate lowett 60-minute avenge* for all other APCS panmeter*. ^ Ownera/openton of ftintace* monitoring metal* concentntion* in collected PM an not required to determine metal* feed nte* in non hazardou* waite feed atnam*. * Copy form and add additional page* if more than four meant* wen fed during test. ^ Ownen/openton of cement and light-weight aggngate kiln* an not nquind to determine aah feed nte* of feed stream* 00 A 035437 OONF TDFNT T Al, Sampling Interruptions on Run 1 of Test Condition 1 Stack sampling was interrupted twice during the first run of Test Condition 1. The reasons for the interruptions are detailed below. The first interruption occurred at approximately twenty (20) minutes into the run. Hazardous waste flow was shut off when the hourly rolling average value for hazardous waste feed flow exceeded its trip point value. The flow indicator for the hazardous waste feed had gone almost instantaneously to its full scale value just before the trip, and since the unit was operating at a flow rate close to this hourly rolling average trip point, the high flow signal was sufficient to raise the hourly rolling average value above the trip point. Sampling was immediately suspended when the flow tripped. The high flow signal was traced to a plugging problem on one of the legs of the differential pressure cell on the flow orifice. The problem was remedied and the unit was re-started. After the unit was allowed to reach steady state, stack testing was resumed. Total suspension of stack testing was two hours and thirty-seven minutes. At approximately fifteen minutes after the run was re-started following the traverse change, a power loss in the field interrupted sampling for about twenty-six (26) minutes. Sampling resumed once this problem was addressed, and the run was not interrupted again. The integrity of the stack sampling was not compromised by either of these two interruptions. Prior to the resumption of sampling following the first (most prolonged) interruption, the system was allowed to equilibrate and the hourly rolling averages were allowed to return to their steady-state values before sampling was resumed. no A 03043A CONFTDFNTTAL COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 1 Mode: A Test Condition (1,2, or N/A): 1 Run No.: 2 Test Date: 7/8/92 2. Run Start Time (hr:min): 14:00 Run End Time (hr:min): 16:05 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (F)b Max. Combustion Chamber Temp.(sF)b APCS Operating Parameters (list applicable parameters, see 5266.103(c)(l)(ix*xiii) Acid absorber liquid-to-gas ratio Scrubber liquid-to-gas ratio Scrubber fluid pH Scrubber blow-down rate (gallons per minute) Run Avg. 39.7 453 2006 Run Avg. 3.99 0.57 7.74 80.3 60-min. Avg.* 40.2 455 2012 60-min. Avg.c 3.97 0.55 7.56 79.1 4. Description of All Fuel, Raw Material, and Waste Feed Streams:*^ Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate fg/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)1 Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr) Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) 1 liquid lainwlib HW 745,132 U.22MM 15,126 594,923 0 0 0.106 0 0.013 0 0.106 0 0.532 0 2 fael fpfl hsl 77,307 3.66MM 0 0 0 0 0 0 0 0 0 0 0 0 3 finrwi vm *M**uvdk 680,619 9.89MM 0 156,610 0 0 0 0' 0 0 0 0 0 0 4 draniw VI ohatioa dndhnVI witosora 4,800 0 10 0 0 0 0 0 0 3.4 0 0 0 0 * Indicate highest or loweat 60-minute rolling avenge aa appropriate. ^ Not applicable if complying with Tier I or adjuned Tier I metala feed rate screening limita. c Indicate higheat 60-minute rolling avengea for maximum flue gaa flow ntc and, if choaen, maximum auapended aolida content of acrubber water where applicable. Indicate loweat 60-minute avengea for all other APCS parameters. ** Ownera/openton of fiirnacea monitoring metala concentretiona in collected PM an not required to determine metala feed ntea in non hazardoua waatc feed atnama. * Copy form and add additional pagea if more than four atreama wen fed during teat. ^ Owners/operators of cement and light-weight aggregate kilns an not roquind to determine ash feed ntea of feed atnama DO A 035439 OONFTOFNTTAl. COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 1 Mode: A Test Condition (1,2, or N/A): 1 Run No.: 3 Test Date: 7/8/92 2. Run Start Time (hr:min): 17:52 Run End Time (hr:min): 19:56 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: 3;^_^_Ogerating>Conditions^ Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (F)b Max. Combustion Chamber Temp.(F)b APCS Operating Parameters (list applicable parameters, see 266.103(c)(i)(ix-xiii) Acid absorber liquid-to-gas ratio Scrubber liquid-to-gas ratio Scrubber fluid pH Scrubber blow-down rate (gallons per minute) Run Avg. 39.3 452 1988 Run Avg. 3.99 0.56 7.52 79.2 60-min. Avg.1 39.8 451 2,000 60-min. Avg.c 3.97 0.55 7.51 78.8 4. Description of All Fuel, Raw Material, and Waste Feed Streams:^ Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. 1 liquid awk Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)* Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr) Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) pmpibfe HW 744,578 11.54MM 6,488 587,736 0 0 0.106 0 0.013 0 0.106 0 0.532 0 2 felt** fuel 77,330 3.67MM 0 0 0 0 0 0 0 0 0 0 0 0 3 pnaiH mil f* Miwn 683,084 8.25MM 0 138,939 0 0 0 0 0 0 0 0 0 0 4 tilSJIUlMI VI oKajou draBimVI pike wuroe 4,800 0 10 0 0 0 0 0 0 3.4 0 0 0 0 ** Not applicable if complying with Tier I or adjusted Tier I metala feed rate screening limit*. c Indicate highest 60-minute rolling average! for maximum flue gai flow rate and, if choaen, maximum auapended aolida content of acrubber water where applicable. Indicate loweat 60-minute average! for all other APCS parameter!. a Ownera/opcratora of ftimacea monitoring metala concentration! in collected PM are not required to determine metala feed ratee in non hazardoua waate feed stream!. * Copy form and add additional pages if more than four streams were fed during teat. * Owners/operators of cement and light-weight aggregate kilns are not required to determine ash feed rates of feed streams COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 1 Mode: A Test Condition (1,2, or N/A): 3 Run No.: 1 Test Date: 7/9/92 2. Run Start Time (hr:min): 10:50 Run End Time (hr:min): 11:51 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: 3. Operating Conditions: Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (F)b Minimum Combustion Chamber Temp.(sF)b APCS Operating Parameters (list applicable parameters, see $266.103(c)(l)(ix-xiii) Run Avg. NA NA 1566 Run Avg. 60-min. Avg.* NA NA 1569 60-min. Avg.c B.d Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)* Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) 1 liquid frtlU* funptbk HW 747,211 11.98MM 24,658 577,486 0 '0 0.107 0 2 Asl pi AbI 82,033 3.89MM 0 0 0 0 0 0 3 procsiA vuc** 101,796 1.32MM 0 18,069 0 0 0 0 4 Cadmium (g/hr) Chromium (g/hr)* 0.013 1.5 0 0 0 0 Lead (g/hr) 0.107 0 0 Mercury (g/hr) Silver (g/hr) 0 0.534 0 0 0 0 Thallium (g/hr) 000 * Indicate highest or lowed 60-minute rolling avenge ai appropriate. b Not applicable if complying with Tier I or adjusted Tier I metala feed nte acnetting limits. c Indicate higheat 60-minute rolling averages for maximum flue gas flow nte and, if chosen, maximum suspended solids content of scrubber water when applicable. Indicate lowest 60-minute avenges for all other APCS parameters ^ Owners/openton of fbmaces monitoring metals concentntions in collected PM an not required to determine metals feed rales in non hazardous waste feed streams. * Copy form and add additional pages if more than four streams were fed during test. "Ownem/openton of cement and light-weight aggngate kilns an not nquind to determine ash feed ntes of feed streams * All metals feed rates based on waste characterization: no analyses performed. DO A CnF-44 1 OONFTDFNT T Al COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 1 Mode: A Test Condition (1,2, or N/A): 3 Run No.: 2 Test Date: 7/9/92 2. Run Start Time (hr:min): 14:56 Run End Time (hr:min): 15:57 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (F)b Minimum Combustion Chamber Temp.(F)b APCS Operating Parameters (list applicable parameters, see 266,l03(c)(l)(ix-xiii) Run Avg. NA NA 1574 Run Avg. 60-min. Avg.1 NA NA 1574 60-min. Avg.c ^JDescrigtionofAllFuelj^mv^faterialLandWasteFiMdStreams^ Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)* Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr)* Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) 1 liquid w--* pumpMt HW 746,321 11.85 MM 20,151 592,870 0 0 0.107 0 0.013 1.5 0.107 0 0433 0 2 IWlpa flitl 140,704 6.67MM 0 0 0 0 0 0 0 0 0 0 0 0 3 pnotN tMli 101,928 1.43MM 0 22,006 0 0 0 0 0 0 0 0 0 0 4 1 Indicate higheat or ioweat 60-minute rolling avenge aa appropriate. ** Not applicable if complying with Tier I or adjuated Tier I metala feed nlc acreening limit*. c Indicate highett 60-minute rolling avenge* for maximum flue ga* flow rate and, if choien, maximum impended *olid* content of icrubber water where applicable. Indicate lowe*t 60-minute avenge* for all other AFCS panmeten. Owner*/operaton of furnace* monitoring metal* concentration* in collected PM ere not requited to determine metal* feed rate* in non hazardou* wutc feed meam*. * Copy form and add additional pagea if more than four Meam* were fed during led. * Ownen/opcnton ofcement and light-weight aggregete kiln* ire not required to determine **h feed nte* of feed Meam* * All metal* feed nte* baaed on waite chancterizttion; no analyte* performed. DO A 03*a4? OONF COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 1 Mode: A Test Condition (1,2, or N/A): 3 Run No.: 3 Test Date: 7/9/92 2. Run Start Time (hr:min): 15:59 Run End Time (hr:min): 16:59 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: 3^^_^_OgeratmConditions^ Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (F)b Minimum Combustion Chamber Temp.(F)D APCS Operating Parameters (list applicable parameters, see 266.103(c)(l)(ix-xiii) Run Avg. NA NA 1581 Run Avg. 60-min. Avg.* NA NA 1581 60-min. Avg.c 4. Description of All Fuel, Raw Material, and Waste Feed Streams:** Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)* Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr)* Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) 1 liquid wwu HW 746,589 11.96MM 15,678 578,628 0 0 0.107 0 0.013 1.5 0.107 0 0.533 0 2 folfss A*1 77,262 3.66MM 0 0 0 0 0 0 0 0 0 0 0 0 3 proms root* roro suosb 101,319 1.37MM 0 21,095 0 0 0 0 0 0 0 0 0 0 4 * Indicate higheat or loweat 60-minute rolling average aa appropriate. ** Not applicable if complying with Tier I or adjuated Tier I metale feed rate acreening limit*. c Indicate higheat 60-minute rolling averagea for maximum flue gat flow rite and, if choaen, maximum auapended aolida content of *crubber water where applicable. Indicate loweat 60-minute averagea for all other AFCS parameter*. Ownera/operatora of fumacea monitoring metal* concentration* in collected PM are not required to determine metal* feed rate* in non hazardout watte feed atreamt. * Copy form and add additional page* if more than four atreamt were fed during teat. f Ownera/operatora of cement and light-weight aggregate kiln* are not required to determine aah feed rate* of feed atreama * AH'metal* feed ratea baaed on waate characterization; no analyaea performed. DO A 035443 CONFTDFNTTAL COMPLIANCE CERTIFICATION FORM 5 (CC-5) SUMMARY OF OPERATING AND FEED RATE LIMITS FOR A SPECIFIC MODE 1. Unit#: 1 Mode: A Run No.: 1-3 Test Date: 7/7/92-7/8/92 2. Operating Conditions: Max. PM Control Device Inlet Temp (F)b,e Max. Combustion Chamber Temp.(*F)b Minimum Combustion Chamber Temp.(*F) 452 2002 1575 APCS Operating Parameters (list applicable parameters, see 9266.103(c)(l)(ix-xiii) Acid absorber liquid-to-gas ratio 3.97 Scrubber liquid-to-gas ratio 0.55 Scrubber fluid pH Scrubber blow-down rate (gallons per minute) 7.61 79.3 Max. Production Rate (gallons condenstate per minute) 40.4 Max. Total HW Feed Rate (g/hr) Max. Total Pumpable HW Feed Rate (g/hr)b Max. Total Chlorine and Chloride Feed Rate (g/hr) 747,193 747,193 740,614 Max. Total Ash Feed Rate (g/hr)d 10,974 3. Maximum Metals Feed Rates Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr) Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) Total Feed Streams' 3.63 0.35 1.82 0 1.27 3.5 4.09 9.99 227 0 4. CO, HC, and PM Limits Total HW Feed Streams NA NA NA NA NA NA NA NA NA NA Total Pumpable HW Feed Streams 3.63 0.35 1.82 0 1.27 3.5 4.09 9.99 227 0 CO (ppmv @ 7 % 0?)**b HC (ppmv as propane ffl 796 Oo)c,*,b PM (gr/dscf 7% Oo)1 100 NA 0.08 * Asterisk any panmeter not determined under the primary ten condilioni. b Not applicable if complying with Tier I or adjusted Tier I metale feed rate acreening limita.. c If applicable, attach documentation that the increased cancer riak to the MEI from eminions of dioxins and fursns is not greater than 1 in 100,000. ** Not required for cement and light-weight aggregate kilns. * Not required for furnaces monitoring metals concentrations in collected PM.. If under Tier I, CO limit is 100 ppmv. If under Tier II, limit is the average over all runs of the HHA CO level for each run. " If under Tier 1, HC limit is not applicable. If under Tier II20 ppmv HC limit because of organic matter in raw material feedstocks, the interim HC an CO limits are the baseline limits proposed in the Part B permit application or the limits established by the Director as a condition of a time extension for certification of compliance. 10.08 gr/dscf or existing permit, whichever is more stringent. DO A 035444 CONFT DFNIT T Al &0 * 3$44 Do Nr In^NTT A[ COMPLIANCE CERTIFICATION FORM 1 (CC-1) GENERAL FACILITY AND TESTING INFORMATION [X] Initial Certification [ ] Revised Certification [ ] Recertification 1. EPA Facility I.D. Number: LAD 008187080 2. Facility Name Contact Person: Telephone Number: The Dow Chemical Company Louisiana Division Stanley G. Cole Environmental Manager (504) 389-6131 Facility Address: 3. Type of boiler / industrial furnace: 4. Person responsible for conducting compliance test: (Attach statement of qualifications) Telephone Number: The Dow Chemical Company P.O. Box 150 PlaquemineLA 70765 Fire Tube Boiler F-420 Vinyl 11 Plant David Martin Air Quality Department Manager (205) 271-1444 Company Name: CH2M Hill Address: 2567 Fairlane Drive Montgomery AL 36116 5. Date(s) of compliance test: July 7 - 9, 1992 6. Person responsible for QA/QC: Clinton Hunt Title: Telephone Number: Senior Environmental Chemist The Dow Chemical Company (504) 389-1676 Attach a statement certifying that procedures prescribed in QA/QC plan submitted with Compliance Test Notification Form 3 (CTN-3) have been followed, or a description of any changes and an explanation of why changes were necessary. I certify under penalty of lew that thia information wai prepared under my direction or auperviaion in accordance with a lyetem derigncd to ensure that qualified personnel properly gathered and evaluated the information and supporting documentation. Copies of all emiaaiona tests, dispersion modeling results, and other information used to determine conformance with the requiremenu of (266.103(c) are available at the facility, and can be obtained from the facility conUct person listed above. Baaed on my inquiry of the person or persons who manages the system, or those persona directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete, f am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. I also acknowledge that the operating conditions esublished in this certification pursuant to (266.103(c)(4)(iv) are enforceable litniu at which the facility can legally operate during interim sUtus until (1) a revised certification of compliance is submitted or (2) an operating permit is issued. Signature: Date: August 20. 1992 Title: General Manager. Louisiana Division 1 c COMPLIANCE CERTIFICATION FORM 2 (CC-2) DEVIATIONS FROM SUBMITTED NOTIFICATION OF COMPLIANCE TEST 1. Were there any changes in the unit configuration prior to or during testing that would alter any of the information submitted on Form CTN-2 of the unit's Notification of Compliance Test? _____ Yes X No If yes, describe these changes and why they were necessary and attach an amended Form CTN-2 describing the unit as actually tested. (Attach additional sheets if necessary). 2. Were there any changes in the planned test conditions prior to or during testing that alter any of the information submitted on Form CTN-3 of the unit's Notification of Compliance Test? X Yes ____ No If yes, describe these changes and why they were necessary and attach an amended Form CTN-3 describing test conditions. (Attach additional sheets if necessary). The original submittal specified three test conditionsfor this unit. Thefirst two test conditions were designed to show compliance with all applicable pre-compliance limits while resolving conflicting parameters ofmaximum thermal input and maximum chlorine load. The plan was to augment the composition ofthe process ventfeed to provide a high BTU load in Test Condition 1 and a high chlorine load in Test Condition 2. However, this wasfound to bean impractical operation. Instead, a way was devised to produce a ventfeed with a composition intermediate between high BTU content and high chlorine contentfor use in Test Condition 1. Test Condition 2 was, therefore, set aside. Test Condition 3 to demonstrate compliance with $266.103(g) is retained. Please see comments on thefollowing page regarding the amount of ashfed during the compliance test. Finally, some minor changes in the original submittal were discussed in a letter to E.P.A. on June 5, 1992. A copy ofthe letter is attached. no A 00544 CONFTOFNTIA COMMENTS REGARDING THE AMOUNT OF ASH FED Introduction: In the Certification of Pre-compliance, the allowable limit for ash in the hazardous waste feeds to units F-410 and F-420 was set at 1.99 pounds per hour. Based on the waste characterization for the T-400 hazardous waste feed stream established for Pre compliance, this limit should not have been exceeded during the Compliance Tests. However, data gathered during the Compliance Test show that the rate of ash fed with this stream was much higher than set in the Certification of Pre-compliance. In spite of the high ash feed rate, emissions of particulate were well below the allowable limit set in the regulations. Therefore, we are establishing this new limit for allowable ash feed to the units in lieu of submitting a new Pre-compliance Certification. Background: Preliminary testing for the Certification of Pre-compliance showed that unit F-410 was capable of emissions in excess of the allowable regulatory limit at high hazardous waste feed rates. A large part of these emissions are salt, carried over from the caustic scrubber as an entrained mist. Particulate emissions were measured from the unit in the presence and in the absence of hazardous waste feed in order to determine the significance of salt emissions to the total emissions. A total allowable emissions rate was calculated from the stack velocity (based on an allowable limit of 0.08 gr./dscf, corrected to 1% oxygen), and the salt emissions were subtracted from this value to determine the allowable non-salt emissions rate. In order to assure compliance, the very conservative assumption was made that all ash in the feed would be emitted unattenuated as particulate matter. The flow rate limit for hazardous waste to the unit was set based on these ash feed limits. Basis for New Ash Feed Limits Emissions data gathered during the Compliance Test show that the assumption of unattenuated emission of ash as particulate is too conservative. Particulate emissions were more than twenty (20) times lower than the regulatory limit. In fact, total particulate emissions were lower than the originally estimated salt emissions, indicating that particulate removal by the unit is essentially total. Since the preliminary Pre-compliance testing was completed, the control systems for both of these boilers have been converted over to new, state-of-the-art systems. Improved control may be responsible for the improvement in emissions. The air pollution control devices on units F-410 and F-420 were actually designed for D0 A 03544ft CONFTDFNTTAi,. replacement boilers twice the size of the existing units. Their ability to capture particulate is more than adequate to assure low emissions of "true particulate." Salt carry-over as entrained mist is the result of a lack of de-mister pads on the scrubbers. DO A 030449 CONFTDFNTTAl. COMPLIANCE CERTIFICATION FORM 3 (CC-3) SUMMARY OF COMPLIANCE TEST EMISSIONS Complete a separate form for each test condition (if more than 1) under each mode of operation for each unit. 1. Use the same identification codes as on Form CTN-3 for the following: Unit # 2 Mode (letter) A ; Test Condition (1,2 or N/A)a 1 Brief Description of Mode and Test Condition: 2. Purpose of Test (e.g. Demonstrate compliance with PM, metals, HC1, CI2 emission limits when Bring sludges at maximum feed rate and flue gas flow): Demonstrate compliance with PM, HCl/Cl and chromium VI standards at maximum thermal input rate and maximum chlorine load, 3. Attach a complete copy of QA/QC results for each test. 4. Test Results: Run No. Date (month / day / year) Time Run Started (hr:min) Total Run Time (hr: min) Sootblow Time (mins)* CO (ppmv @ 7% 0->) Run Avg. Highest 60-min rolling avg. HC (ppmv 7 % Oj) Run Avg. Highest 60-min rolling avg. PM emissions (gr / dsef) HC1 emissions (g/hr) Cb emissions (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr) Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) 1 7/7/92 16:08 2:01 2 7/8/92 14:00 2:01 mmm 3 7/8/92 17:52 2:00 NA 15.2 45j3 18.2 18.2 -- 15.6 17.8 NA NA 0.0028 122 7.8 NA NA 0.0039 196 5.9 an NA NA 0.0036 249 5.2 Adjusted j NA NA NA NA v.v.v....... f. . lllllllllll; 0.05 .Wj.'S&.SSiK ] 0.03 ire 0.01 1 NA IH Tiefl j v^V; A * Allowable 2270 90.8 3.63 0.35 1.82 0.00 1.27 0.26 4.09 9.99 227.00 0.00 Y Y Y Y Y Y Y Y Y Y Y Y a. If facility conducted teita at only one aet of tea conditions for the stated mode enter N/A. If two seta of tea conditions were run for the mode, fill out a separate form for each set of tea conditions, identifying the tea conditions (1 or 2) as on Form CTN-3. b. If soot blowing or other daily activity that increases the PM emission rate was incorporated into the testing, calculate average using equation provided in instructions. c. Allowable levels are the same as indicated on Form PC-4, d. Check if each non-sootblowing run and average are leu than or equal to allowable. e. Indicate sootblowing time or other activity that was incoiponted into the testing. DO A 03F.4 50 CONFTDFNTTAL COMPLIANCE CERTIFICATION FORM 3 (CC-3) SUMMARY OF COMPLIANCE TEST EMISSIONS Complete a separate form for each test condition (if more than 1) under each mode of operation for each unit. 1. Use the same identification codes as on Form CTN-3 for the following: Unit # 2 : Mode (letter) A ; Test Condition (1,2 or N/A)* 3 Brief Description of Mode and Test Condition: 2. Purpose of Test (e.g. Demonstrate compliance with PM, metals, HC1, Clj emission limits when firing sludges at maximum feed rate and flue gas flow): Determine minimum allowable temperature forfeeding hazardous waste per 266.103 (g). 3. Attach a complete copy of QA/QC results for each test 4. Test Results: Run No. Date (month / day / year) Time Run Started (hr: min) Total Run Time (hr:min) Sootblow Time (mins)e CO (ppmv Q->) Run Avg._________________ Highest 60-min rolling avg. HC (ppmv 7 % O-y) Run Avg._________________ Highest 60-min rolling avg. PM emissions (gr / dscf) HC1 emissions (g/hr)______ Cb emissions (g/hr)_______ Antimony (g/hr)__________ Arsenic (g/hr)_____________ Barium (g/hr)_____________ Beryllium (g/hr)___________ Cadmium (g/hr)___________ Chromium (g/hr)__________ Lead (g/hr)_______________ Mercury (g/hr)____________ Silver (g/hr)______________ Thallium (g/hr) * 5 iWr'i'iViV.Vr'IVrt^'iVL.V.-.VjV.-.'.Vl'.'.^rtw: fci&ifowSiwWfcirt.1. ft.iWyiw'i.jjiissxS &ti. -,,X"M -sy.-xfokjoi.sfe&3 1y g:gvyyyzzyvyrzf?* y.y;*--y ^igra-g %;;r &WiWvXw.Avrf^ii^\iwrtCvWwi vx-^ x-x-x ^>>MMUgoo<XAS} ^ev^vS^^1TM4 /MwitoSomAMisix fc^jww^wK^ww, >A*siiivWic<MM (^AwifaviiJvAV j:J--;:v133 &30CMOyMx&z&;M:y&- .v'-v2vtui wAj&AvJJc^'!8 K&3$boebobob&. a. If facility conducted teata at only one act of teat conditions for the stated mode enter N/A. If two seta of teat conditions were run for the mode, fill out a separate form for each set of test conditions, identifying the teat conditions (I or 2) at on Form CTN-3. b. If aoot blowing or other daily activity that increases the PM emission rate was incorporated into the testing, calculate avetage using equation provided in instructions. c. Allowable levels are the same as indicated on Form PC-4. d. Check if each non-sootblowing run and average are less than or equal to allowable. e. Indicate sootblowing time or other activity that was incorporated into the testing. 00 A 005451 C0NFTDFNTTA1 COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 2 Mode: A Test Condition (1,2, or N/A): 1 Run No.: 1 Test Date: 7/7/92 2. Run Start Time (hr:min): 16:08 Run End Time (hr:min): 21:18 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: See discussions, next page 3.______ Operating Conditions: Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (F)b Max. Combustion Chamber Temp.(F)b APCS Operating Parameters (list applicable parameters, see 266.103(cXl)(ix-xiii) Acid absorber liquid-to-gas ratio Scrubber liquid-to-gas ratio Scrubber fluid pH Scrubber blow-down rate (gallons per minute) Run Avg. 38.6 449 1985 Run Avg. 3.99 0.58 7.92 81.6 60-min. Avg.* 41.1 451 1993 60-min. Avg.c 3.97 0.55 7.75 79.9 Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)* Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr) Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) E-d 1 2 pminMi HW 751,869 11.39MM 11,278 605,162 0 0 0.107 0 0.013 0 0.107 0 0.535 0 Pml 115,575 5.48MM 0 0 0 0 0 0 0 0 0 0 0 0 3 prooaM Mil 634,606 9.17MM 0 138,471 0 0 0 0 0 0 0 0 0 0 4 OhMiOB Dlls *oura 4,989 0 10 0 0 0 0 0 0 3.6 0 0 0 0 " Not applicable if complying with Tier I or adjunct! Tier I metali feed rate screening limits. c Indicate highest 60-minute rolling average! for maximum flue gas flow rate and, if chosen, maximum suspended solids content of scrubber water where applicable. Indicate lowest 60-minute averages for all other APCS parameters. " Owners/operators of furnaces monitoring metals concentrations in collected PM are not required to determine metals feed rales in non hazardous waste feed streams. * Copy form and add additional pages if more than four streams were fed during test. * Owners/operators of cement and light-weight aggregate kilns are not required to determine ash feed rates of feed streams A 035 CONFIDENT Sampling Interruptions on Run 1 of Test Condition 1 Stack sampling was interrupted twice during the first run of Test Condition 1. The reasons for the interruptions are detailed below. The first interruption occurred at approximately twenty (20) minutes into the run. Hazardous waste flow was shut off when the hourly rolling average value for hazardous waste feed flow exceeded its trip point value. The flow indicator for the hazardous waste feed had gone almost instantaneously to its full scale value just before the trip, and since the unit was operating at a flow rate close to this hourly rolling average trip point, the high flow signal was sufficient to raise the hourly rolling average value above the trip point. Sampling was immediately suspended when the flow tripped. The high flow signal was traced to a plugging problem on one of the legs of the differential pressure cell on the flow orifice. The problem was remedied and the unit was re-started. After the unit was allowed to reach steady state, stack testing was resumed. Total suspension of stack testing was two hours and thirty-seven minutes. At approximately fifteen minutes after the run was re-started following the traverse change, a power loss in the field interrupted sampling for about twenty-six (26) minutes. Sampling resumed once this problem was addressed, and the run was not interrupted again. The integrity of the stack sampling was not compromised by either of these two interruptions. Prior to the resumption of sampling following the first (most prolonged) interruption, the system was allowed to equilibrate and the hourly rolling averages were allowed to return to their steady-state values before sampling was resumed. 00 A 03F.453 CONFTDFNTTAi COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 2 Mode: A Test Condition (1,2, or N/A): 1 Run No.: 3 Test Date: 7/8/92 2. Run Start Time (hr:min): 17:52 Run End Time (hr:min): 19:56 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: 3;_^>^^Ogerating^Conditions^ Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (F)b Max. Combustion Chamber Temp.(F)b APCS Operating Parameters (list applicable parameters, see $266.103(c)(l)(ix-xiii) Acid absorber liquid-to-gas ratio Scrubber liquid-to-gas ratio Scrubber fluid pH Scrubber blow-down rate (gallons per minute) Run Avg. 39.3 452 1988 Run Avg. 3.99 0.56 7.52 79.2 60-min. Avg.a 39.8 451 2,000 60-min. Avg.c 3.97 0.55 7.51 78.8 4. Description of All Fuel, Raw Material, and Waste Feed Streams:** Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)* Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr) Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) 1 pw^ible HW 744,578 U.54MM 6,488 587,736 0 0 0.106 0 0.013 0 0.106 0 0.532 0 2 fuel (U fml 77,330 3.67MM 0 0 0 0 0 0 0 0 0 0 0 0 3 WC* MfWD 683,084 8.25MM 0 138,939 0 0 0 0 0 0 0 0 0 0 4 T*irumhn VI otaka ctranhsn VI oU* Mura* 4,800 0 10 0 0 0 0 0 0 3.4 0 0 0 0 * Indicate highest or lowest 60-minute rolling average aa appropriate. Not applicable if complying with Tier I or adjuated Tier I metela feed rate acreening limite. c Indicate higheat 60-minute rolling averager for maximum flue gaa flow rate and, if choaen, maximum auapended aolide content of crubber water where applicable. Indicate loweat 60-minute averagea for all other APCS parameten. ^ Ownera/operatora of fiirnacea monitoring metala concentration! in collected PM are not required to determine metela feed rater in non hazardous waste feed streams. * Copy form and add additional pages if more than four streams were fed during teat. ' Ownera/operatora of cement and light-weight aggregate kilns are not required to determine ash feed rates of feed streams A 0D54S4 CONFIDENTIAL COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 2 Mode: A Test Condition (1,2, or N/A): 1 Run No.: 2 Test Date: 7/8/92 2. Run Start Time (hr:min): 14:00 Run End Time (hr:min): 16:05 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: 3. Operating Conditions: Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (*F)b Max. Combustion Chamber Temp.(F)b APCS Operating Parameters (list applicable parameters, see 5266.103(c)(l)(ix-xiii) Acid absorber liquid-to-gas ratio Scrubber liquid-to-gas ratio Scrubber fluid pH Scrubber blow-down rate (gallons per minute) Run Avg. 39.7 453 2006 Run Avg. 3.99 0.57 7.74 80.3 60-min. Avg.* 40.2 455 2012 60-min. Avg.c 3.97 0.55 7.56 79.1 4. Description of All Fuel, Raw Material, and Waste Feed Streams:** Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)* Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr) Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) 1 liqud warts pwnpaMi HW 745,132 11.22MM 15,126 594,923 0 0 0.106 0 0.013 0 0.106 0 0.532 0 2 tm\ 77.307 3.66MM 0 0 0 0 0 0 0 0 0 0 0 0 3 pnxass vaau vsi stnam 680,619 9.89MM 0 156,610 0 0 0 0 0 0 0 0 0 0 4 VI otttkjQ dmaniwn VI srtiw tautm 4,800 0 10 0 0 0 0 0 0 3.4 0 0 0 0 * Indicate highest or lowet 60-minute rolling average aa appropriate. ^ Not applicable if complying with Tier I or adjusted Tier I metals feed rate screening limits. c Indicate higheat 60-minute rolling avenges for maximum flue gas flow rate and, if choien, maximum suspended solids content of scrubber water where applicable. Indicate lowest 60-minute avenges for all other APCS parameters. Owners/operators of fiimaces monitoring metals concentrations in collected PM are not required to determine metals feed rates in non hazardous waste feed streams. e Copy form and add additional pages if more than four streams were fed during test. ^Ownen/operatora of cement and light-weight aggregate kilns are not required to determine ash feed rates of feed streams X> 'S' DO A 0354 0 ONFIDFNTT COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 2 Mode: A Test Condition (1,2, or N/A): 3 Run No.: 1 Test Date: 7/9/92 2. Run Start Time (hr:min): 10:50 Run End Time (hr:min): 11:51 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: 3. Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (SF)^ Minimum Combustion Chamber Temp.(0F) APCS Operating Parameters (list applicable parameters, see {$266.103(c)(l)(ix-xiii) Run Avg. NA NA 1566 Run Avg. 60-min. Avg.a NA NA 1569 60-min. Avg,c Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)* Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr)* Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) 1 liquid puuptNt HW 747,211 11.98MM 24,658 577,486 0 0 0.107 0 0.013 1.5 0.107 0 0.534 0 2 ft*! gm Aal 82,033 3.89MM 0 0 0 0 0 0 0 0 0 0 0 0 3 proCM VBtl Md MlMB 101,796 1.32MM 0 18,069 0 0 0 0 0 0 0 0 0 0 4 b Not applicable if complying with Tier I or adjusted Tier I metali feed rate screening limit*. c Indicate higheit 60*minute rolling avengea for maximum flue gat flow rate and, if choaen, maximum auapended tolidi content of scrubber water where applicable. Indicate lowest 60-minute avenges for all other APCS parameter*. " Ownen/openfora of furnaces monitoring metals concentrations in collected PM an not required to determine metals feed rates in non hazardous waste feed streams. * Copy form and add additional pages if more than four streams were fed during test. ' Ownere/operatora of cement and light-weight aggregate kilns are not required to determine ash feed rates of feed streams * All metals feed rates baaed on waste characterization; no analyses performed. DO A 03S45A OONFTDFNTTAl COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 2 Mode; A Test Condition (1,2, or N/A): 3 Run No.: 2 Test Date: 7/9/92 2. Run Start Time (hr:min): 14:56 Run End Time (hr:min): 15:57 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: 3.______ Operating Conditions: Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (F)b Minimum Combustion Chamber Temp.(*F)b APCS Operating Parameters (list applicable parameters, see 5266.103(c)(l)(x-xiii) Run Avg. NA NA 1574 Run Avg. 60-min. Avg.a NA NA 1574 60-min. Avg.c ^^escrijrtionofAllJruel^awMateriaLandWast^eedStreanre^ Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)* Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr)* Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) 1 Uqtad v*61* |MHnlih HW 746,321 11.85MM 20.151 592,870 0 0 0.107 0 0.013 1.5 0.107 0 0.533 0 2 tm\ tM Ul 140,704 6.67MM 0 0 0 0 0 0 0 0 0 0 0 0 3 pnaHvmtf 101,928 1.43MM 0 22,006 0 0 0 00 0 0 0 0 0 4 * Indicate highett or lowett 60-minute rolling average ai appropriate. ** Not applicable if complying with Tier I or adjueted Tier I metal* feed rate acnetting limit*. c Indicate higheat 60-minute rolling average* for maximum flue gat flow rate and, if choaen, maximum auapended aolida content of acrubber water where applicable. Indicate lowett 60-minute average* for all other APCS parameter*. ** Ownera/operator* of furnace* monitoring metal* concentration* in collected PM are not required to determine metal* feed rate* in non hazardou* wane feed itreama. * Copy form and add additional page* if more than four nrearnt were fed during teit. 'Ownera/operator* of cement and light-weight aggregate kiln* are not required to determine aih feed ratea of feed ttrearm * All metal* feed ntea baaed on watte characterization; no analytea performed. 00 A 035457 CONFTDFNTTAi COMPLIANCE CERTIFICATION FORM 4 (CC-4) SUMMARY OF COMPLIANCE TEST OPERATING CONDITIONS Complete a separate form for each run of a specified test condition, use same identification codes as on Forms CC-3 and CTN-3. 1. Unit#: 2 Mode: A Test Condition (1,2, or N/A): 3 Run No.: 3 Test Date: 7/9/92 2. Run Start Time (hr:min): 15:59 Run End Time (hr:min): 16:59 If there were any interruptions in sampling, discuss cause, duration, and impact on sampling: 3.______ Operating Conditions: Max. Production Rate (gallons condensate per minute) Max. PM Control Device Inlet Temp (F)b Minimum Combustion Chamber Temp.(*F)b APCS Operating Parameters (list applicable parameters, see 5266.103(c)(l)(ix-xiii) Run Avg. NA NA 1581 Run Avg. 60-min. Avg.a NA NA 1581 60-min. Avg.c 4. Description of All Fuel, Raw Material, and Waste Feed Streams:** Stream No. Stream Type (e.g. coal, shale, sludge, liquid solvents, etc. 1 liquid MtH 2 Att! (M 3 4 Category (e.g. Fuel, Raw Material, Pumpable HW) Mass Feed Rate (g/hr) Thermal Feed Rate (Btu/hr) Ash Feed Rate (g/hr)* Chlorine and Chloride (g/hr) Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr)* Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) HW 746,589 11.96MM 15,678 578,628 0 0 0.107 0 0.013 1.5 0.107 0 0.533 0 fuel 77,262 3.66MM 0 0 0 0 0 0 0 0 0 0 0 0 101,319 1.37MM 0 21,095 0 0 0 0 0 0 0 0 0 0 1 Indicate highert or loweat 60-minute rolling average at appropriate. b Not applicable if complying with Tier I or adjutted Tier I metali feed rate ecreening limita. c Indicate higheat 60-minute rolling averagea for maximum flue gaa flow rate and, if choaen, maximum auapended aolida content of crubber water where applicable. Indicate loweat 60-minute averagea for all other APCS parameter*. d Ownera/operatora of fiimacea monitoring metala concentration* in collected PM are not required to determine metal* feed rate* in non hazardou* waate feed ttream*. e Copy form and add additional pagea if more than four atream* were fed during teat. * Owner*/operator* of cement ami light-weight aggregate kiln* are not required to determine aih feed rate* of feed atream* * All metala feed rate* baaed on waate characterization; no analyaea performed. DO A 0frNTT Al C.ONFT COMPLIANCE CERTIFICATION FORM 5 (CC-5) SUMMARY OF OPERATING AND FEED RATE LIMITS FOR A SPECIFIC MODE 1. Unit#: 2 Mode: A Run No.: 1-3 Test Date: 7/7/92-7/8/92 2. Operating Conditions: Max. PM Control Device Inlet Temp (F)b*e Max. Combustion Chamber Temp.(F)b Minimum Combustion Chamber Temp.CF) 452 2002 1575 APCS Operating Parameters (list applicable parameters, see 5266.103(c)(l)(ix*xiii) Acid absorber liquid-to-gas ratio 3.97 Scrubber liquid-to-sas ratio 0.55 Scrubber fluid pH 7.61 Scrubber blow-down rate (gallons per minute) 79.3 Max. Production Rate (gallons condenstate per minute) 40.4 Max. Total HW Feed Rate (g/hr) 747,193 Max. Total Pumpable HW Feed Rate (g/hr)b Max. Total Chlorine and Chloride Feed Rate (g/hr) Max. Total Ash Feed Rate (g/hr)d 747.193 740,614 10,974 3. Maximum Metals Feed Rates Antimony (g/hr) Arsenic (g/hr) Barium (g/hr) Beryllium (g/hr) Cadmium (g/hr) Chromium (g/hr) Lead (g/hr) Mercury (g/hr) Silver (g/hr) Thallium (g/hr) Total Feed Streamse 3.63 0.35 1.82 0 1.27 3.5 4.09 9.99 227 0 4. CO, HC, and PM Limits Total HW Feed Streams NA NA NA NA NA NA NA NA NA NA Total Pumpable HW Feed Streams 3.63 0.35 1.82 0 1.27 3.5 4.09 9.99 227 0 CO (ppmv 1% CM1'11 HC (ppmv as propane 7 % Oy)c,S*b PM (gr/dsef ffl 7% Cb)1 100 NA 0.08 * Asterisk any parameter not determined under the primary test condition*. b Not applicable if complying with Tier I or adjusted Tier I metala feed rate screening limit*.. * If applicable, attach documetuition that the increased cancer risk to the MEI from emitsions of dioxin* and fiiran* ia not greater than 1 in 100,000. d Not required for cement and light-weight aggregate kiln*. * Not required for furnaces monitoring metala concentration* in collected PM. * If under Tier I, CO limit i* 100 ppmv. If under Tier , limit i* the average over all run* of the HHA CO level for each run. b If under Tier I, HC limit i* not applicable. If under Tier II20 ppmv HC limit because' of organic matter in raw material feedstock*, the interim HC an CO limit* am the baseline limit* proposed in the Pan B permit application or the limit* established by the Director *s a condition of a time extension for certification of compliance. 1 0.08 gr/dicf or existing permit, whichever is more stringent. Do Correspondence oo A 035,460 C-ONF rofrNTTAI. Dow U.S.A. June 5, 1992 -i Mr. Ruben Casso Hazardous Waste Division U.S. Environmental Protection Agency 1445 Ross Avenue, Suite 1200 Dallas, Texas 75202-2733 COMPLIANCE TEST NOTIFICATIONS REVISION OF QUALITY ASSURANCE PROJECT PLANS THE DOW CHEMICAL COMPANY, LOUISIANA DIVISION LAD008187080 Dear Mr. Casso: The Dow chemical Company received a hazardous waste permit on May 19, 1989 for its facility located in Plaquemine, Louisiana. In addition to the previously permitted activities, Dow operates four existing industrial boilers which burn hazardous wastes and which are now operating under the interim status provisions of the new Boiler and Industrial Furnace (BIF) rules. As part of those interim status provisions, Dow has submitted three Compliance Test Notifications to the agency, as follows: Glycol I Plant Vinyl II Plant Chlorinated Methanes Plant March 17, 1992 April 22, 1992 April 29, 1992. Each of these Compliance Test Notifications included a Quality Assurance Project Plan (QAPjP), detailing among other things 1) the interval for sampling the hazardous waste liquid feed stream into a composite sample during the Compliance Tests, and 2) the methodology for analysis of the vent feed stream to be fed to the unit at the Chlorinated Methanes Plant. The purpose of this letter is to document two modifications to our QAPjP'st First, in preparation for the Compliance Test at our Glycol I Plant, we reviewed the pertinent sections of the laghnifftl Implementation Document EPA'g BOlltg And Industrial Furnace Regulations, which we received on March 31, 1992. At section 5.2.6.1 we noticed that a sampling interval of every fifteen (15) minutes is specified for the liquid hazardous waste feed to the BIF unit. Our QAPjP states an interval of every thirty (30) minutes. Therefore, we are hereby amending the sampling plans for each of the liquid hazardous waste feeds to specify an interval of every fifteen (IS) minutes as specified in the above cited implementation document. All of our liquid hazardous waste feed data to be submitted with each Certification of Compliance will be based on samples composited at this shorter interval. r>o A o COMp- Tr^NT TAI Second, in preparation for the Compliance Teat at our Chlorinated Methanes Plant, we have concluded that the methodology originally specified for analysis of the vent feed stream is inappropriate. The stream contains mostly hydrogen chloride gas and nitrogen, with some small amount of other chlorinated hydrocarbons. Therefore, rather than attempt to perform gas chromatography on the contents of the integrated gas bag (our originally specified plan), a measured aliquot from the bag will be captured on alkaline impingers and analyzed for hydrogen chloride according to EPA method 9057. we will make the conservative assumption when setting the compliance limits per 40 CFR 266.103(c)(1)(iii) that all of the chlorine contribution from the vent feed is from hydrogen chloride. Also, since this stream has essentially no heat value, we will not attempt a measurement of this parameter. Please note that this second modification applies only to the QAPjP for the Chlorinated Methanes Plant. If you have any questions regarding these modifications please feel free to call me at (504) 382-4044. Sincerely, 3 Edward B. Anthony Environmental Project Specialist Quality Assurance / Quality Control DO A 005460 CONFIDENTIAL August 19, 1992 QUALITY ASSURANCE STATEMENT We hereby certify that, to the best of our knowledge and belief, the procedures prescribed in the QA/QC plan submitted with Compliance Test Notification Form 3 (CTN-3) for the boiler F-410 located at the Vinyl II Plant have been followed in the gathering of data presented in this document. Clinton Hunt Quality Assurance Coordinator The Dow Chemical Company Edward B. Anthony Project Manager The Dow Chemical Company MEMORANDUM CKMHil TO: Project File COPIES: Caroline Melton/MGM Susan Douglas/BTR Ed Anthony/Dow FROM: David Martin/MGM DATE: August 18, 1992 SUBJECT: QA/QC for Particulate Analysis Per USEPA Method 5 PROJECT: MGM33563.AO For each particulate sample collected by USEPA Method 5, the following QA/QC procedures apply: Filters, Handling and Acceptance - glass fiber filters having at least 99.95 percent efficiency (<0.05 percent penetration) on 0.3 micron dioctyl phthalate smoke particles were used. The filters were checked against light for flaws and pinholes and labeled on the backside near the edge. They were desiccated for 24 hours at 2 0 + /- 5.6 degrees C weighed to constant weight, and the results recorded to the nearest 0.1 mg in a permanent filter weighing log. Filters, Recovery and Storage - Filters were recovered from the Method 5 sampling train as specified in the Method. Filters were returned to their respective petri dishes, which were sealed, and labeled. Analytical Balance - The balance is serviced and certified annually. It can measure to within 0.1 mg. Probe or Front Wash - Acetone rinses of the probe assembly were collected in glass storage containers as specified in the method. The containers were labeled and the liquid level was marked for shipment. Probe or Front Wash - The wash sample was transferred to a tared 250 mL beaker and allowed to air dry, then desiccated and weighed to a constant weight. The following general.procedures were followed: All Weighings - Selected beakers and filters are routinely reweighed as an accuracy check of the weighing process. DO A 035405 CONFI DENT T Al MEMORANDUM Page 2 August 18, 1992 MGM33563.AO Blank - Filter and acetone blanks are included with each set of analyses. Calculations - Reweigh values and related math are rechecked by individuals other than the original analyst. No unusual circumstances or problems were encountered with the analysis of Dow particulate samples. D0 A CONFTDFNTTM 07/28/92 15:49 CLEAN AIR ENGINEERING IL. 002 CERTIFICATE Of* ANALYSIS CUSTOMER: CH2M HILL SAMPLE TYPE: 0.1 N KOH LIQUIDS PARAMETERS: HEXAVALENT CHROMIUM (Cf+6) MARKS: 26114-01--05 DATE RECEIVED: JOB/P.O. NUMBER; DATE REPORTED: DETECTION UMfT: 7/14/92 7/28/92 0.25 U0/L LAB ID* 28114-01 26114-02 26114-03 26114-04 26114-05 CLIENT SAMPLED T1 * R1 - WB T1 - R1 - RB T1-R1-CR T1 - R2 - CR T1 - R3 - CR SAMPLE pH Of VOL.(ml) SAMPLE 37S 390 400 510 565 6.5 14.0 9.0 9.0 9.0 CONG.* Of +6 (Ufl/L) < 0.25 0.28 30.93 15.32 3.30 TOTAL Or +6 (ug) < 0.09 0.11 ^ ^ 12.4 'T \ 7.81 --, \l.87 DUPLICATE; % DEVIATION: 26114-02 4.9 SPIKE; % RECOVERY: 26114-03 108 26114-03 0-7 26114-03 99.0 26114-04 7.0 Analyst; Nadine L^fauna Analytical Chamict Reviewed by: John Chapman Vice Pres. RSD DO A 035467 conftdfntjai. DOW Chemical, Plaquemine, LA MGM33565.A0 Vinyl II Emissions Testing Report Particulate Run # j Emission Rate gr/dscf lb/hr (7% 02) 1 0.124 0.0028 2 0.182 0.0039 3l 0.168 0.0036 Average 0.158 0.0034 Chloride/Chlorine -- Draft Run # ! Emission Rate ! HC1 Cl | Impingers 1&2 Impingers 3&4 ! Ib/hr lb/hr 1 0.269 0.017 2i 0.432 0.013 3' 0.548 0.012 Average 0.416 0.014 Chromium+6 Run# | Emission Rate lb/hr g/hr 1 1.05E-04 4.78E-02 2 6.30E-05 2.86E-02 3 2.70E-05 1.23E-02 Average 6.51E-05 2.95E-02 DO A O35,4 f-,a conftdfnttai D0 A 0354 CONFTDFNTTAl USEPA M thod 26 Test Results DOW Chemical, Plaqucminc, LA MGM33563.A0.05 HCt/Chlorinc Results Vinyl II Sample No. Lah HCI** CI2** Sample Sample Corrected Corrected Meter Cone. # Volume Cone. Cone. Cone. Volume Blanks Jug)_ _ (yg) (TM0 (ug/ml) (ug/ml) (ug) (ft31 (ug/ft3) TI-R1-WB 333330 1 142 230 0.62 Tl-RI-AB 333330 2 84 205 0.41 TI-R1-BB 333330 3 3150 235 13.40 Run 1 T1-R1-I1 333330 4 28900 260 111.15 110.74 28793 75.393 382 T1-R1-I2 333330 5 872 160 5.45 5.04 806 75.393 11 T1-RI-I34* 333330 6 6037 310 19.47 6.07 1882 75.393 25 Run 2 T1-R2-I1 333330 7 46800 230 203.48 203.07 46706 76.059 614 T1-R2-I2 333330 8 1960 180 10.89 10.48 1886 76.059 25 T1-R2-34 333330 9 5430 295 18.41 5.00 1476 76.059 19 Run 3 T1-R3-I1 333330 10 59700 235 254.04 253.63 59604 75.436 790 T1-R3-I2 333330 11 1480 175 8.46 8.05 1408 75.436 19 T1-R3-34 333330 12 _ 5370 305 17.61 4.20 1282 75.436 17 * Average of three analyses. ** Mass calculated from ug chloride corected for molecular weight of HCI and CI2, respectively. Flow Emission Rates (sctli) (g/ftO /(16/hr) 3105% 118.620/ 310596 3.322/ 310596 7.752/ 0.261 0.007 0.017 307119 188.593/ 307119 7.616/ 307119 5.959/ 0.415 0.017 0.013 307787 243.190/ 307787 5.746/ 307787 5.229/ 0.536 0.013 0.012 CH2M HILL PUG-14-1992 11! 03 FROM CH2M HILL LAB-RDD TO MGM P.03 " ....... Datasheet for HC1/CL2 Eitunission Sampling Train Method: DOW 9057 Analyzed bv: DS SAMPLE VOL MATRIX DATE CHLORIDE HCL CL2 HCL CL2 RPD mL ug/mL Ufl ug TV TV 33333-1 230 W 33333-2 205 r a fek/isasJ 0.6 142 0.4 84 164 33333-3 235 B 6.7 3150 33333-4 260 A 07/31/92 108 33333-4^ 260 A 07/31/92 110 29400 1.7 33333--4M 260 A 07/31/92 212 66700 "26700 33333-5 160 A 07/29/92 5.3 872 33333-5P !60 A 07/29/92 5.0 1)23 5.8 33333--5M 160 A 07/29/92 23.4 3850 3290 33333-6 310 B 07/29/92 8.3 5150 33333--6M 310 B 07/29/92 25.8 16000 12400 33333-8D 310 B 07/29/92 25.5 15800 12400 1.2 33333-6 310 B 07/31/92 10.3 6390 33333-6M 310 B 07/31/92 45.9 28500 24800 33333--6D 310 B 07/31/92 45.8 24800 0.4 33333-6 310 B 07/29/92 10T 6570 33333--6M 310 B 07/29/92 86.3 53500 62000 33333--6D 310 B 07/29/92 86.8 62000 0.6 33333-7 230 A 07/29/92 198 46800 33333-8 180 A 07/29/92 10.6 1960 33333-9 295 B 07/29/92 9.2 5430 33333-10 235 A 07/31/92 247 69700 33333-11 175 A 07/29/92 8.2 1480 33333-12 305 6 07/29/92 ST 5375" 33333-13 33333-14 0 w 07/29/92 13.7 0 w 07/29/92 _1ZL j CLA1R333 i vBJuJSS %R 104 90.6 87.5 85.9 89.2 88.8 75.7 76.2 CH2M HILL Qualify Analytical Laberatary i 5090 Caterpllar Read. Redding, CaHtomla 96005-1412 00 a 03S47o r-0NF7nFNTTA( 916.244.5227 FAX 916244.4109 TOTAL P.03 I ; `ji