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2008, 2009, 2010 & 2011 By J. Sutton Stack Testing: Best Practices for Environmental Managers.

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Presentation on theme: "2008, 2009, 2010 & 2011 By J. Sutton Stack Testing: Best Practices for Environmental Managers."— Presentation transcript:

1 2008, 2009, 2010 & 2011 By J. Sutton Stack Testing: Best Practices for Environmental Managers

2 A GENDA Why do we Test Regulatory Requirement Internal Preparation Biggest Bang for the Buck Presentation Objective: How to reduce costs for testing (compliance testing) How to save money through process improvement (engineering testing)

3 W HY DO WE T EST Required by Regulators Compliance Permit requirements Information Collection Request (ICR) Internal Improvement and Future Requirements Engineering testing Equipment Process

4 R EQUIRED BY R EGULATORS Compliance Typically reported to state Gases S0 2, NO X, CO, VOC, O 2, and others PM Filterable Condensable HAPS ICR / MACT Testing Mandated by EPA Industry specific Best performing units set MACT limits ERT

5 I NTERNAL I MPROVEMENT AND F UTURE R EQUIREMENTS Engineering/Performance Testing Equipment Fan performance Air leakage Destruction efficiency ESP performance Vendor guarantee Ensure proper equipment design Process Back pressure regulator Venting Air leakage Operations Flow profiles

6 B Y -P ASS L EAKAGE RTO TP1 – Inlet Port TP 4 - Stack TP 3 – RTO Outlet RTO Combustion Air Process Gases TP 2 – Bypass Treated Gases Three-Way Valve Blank If data is unexpected Immediately, go through process to validate Simultaneously, assume it is correct and go through process to determine problem

7 B ACKPRESSURE V ENT Tramp Air BPR Air, N2, Gases Natural Gas Problem: Improperly functioning back pressure regulator (BPR) Drives up cost of fuel to support flare combustion Drives up cost of raw material/product and/or nitrogen (it’s being vented) How Identified: Check flows throughout system Solution: Replace BPR

8 P REPARATION FOR TESTING General Power Supply Specified by testing company 110 to 480 volt (higher for gases) Proposal should specify amperage Proper operation and/or process lined out Test Equipment area clear of obstacles Proper port placement (new plant) Proper platforms for testing team Monorail supports Proper sample port sizing


10 201A Head – PM 2.5/10 Method 5 set-up requires a minimum 3 inch port Method 201A (PM2.5/10) requires a minimum 6 inch port Method 5 EPA M ETHOD 5 VS. 201A HEAD

11 P REPARATION FOR TESTING General (continued) Identify entry requirements up front Drug testing Site specific safety Special requirements (TWIC, MSHA) Communication Security, electricians, production Safety requirements “What we have here is a failure to communicate”

12 P REPARATION FOR TESTING Compliance EPA test methods Built in bias (inaccuracies) – will tend to be high ICR ERT Data accuracy and detection limits Pre-site survey and pre-test scope meeting critical

13 P REPARATION FOR TESTING Engineering/performance testing Vendor equipment guarantee Data accuracy QA/QC Define / determine expected concentrations so that proper MDL (minimum Detection Limit) can be set – longer test runs may be necessary Equipment and process improvements Additional ports may be needed

14 M OST E FFICIENT USE OF TEST DOLLARS Site Prep Eliminates retest Out of scope work Contractor cost Equipment cost Gas Testing Add other components If you’re doing gases, add: CO 2 (most times no additional costs) NO 2, CH 4, etc. (minimal additional costs) If you’re doing Method 5, add: Condensables, Acids, Metals, Semi-Vols

15 M OST E FFICIENT USE OF TEST DOLLARS Coordinate testing Eliminate additional mob/de-mob cost Qualified Testing Company (ASTM D7036-4) Required for Part 75 work (will eventually roll-out to others - ex: Part 60) Requires qualified individuals on all tests (QSTI) Process to correct non-compliance Robust QA/QC system Mandates training Defines requirements for Test Plans / Protocols Reporting Data handling

16 S PECIAL T OOLS FOR ANALYSIS Particle Sizing Cascade impactor EPA Method 201A (PM 2.5/10) FTIR Ammonia slip Real time acid gases (HCl, HF) Speciated volatile gases Real time data for many compounds High Temperature HVT probes Air-cooled or water-cooled Mercury 30b (sorbent traps) High Pressure Specially designed packing glands, etc.


18 F LOW S TRATIFICATION Problem: Improperly functioning SCR Shortened life of resin Compliance Issues How Identified: Detailed flow profile determined stratified flow Solution: Straightening vanes at inlet

19 P ARTICLE S IZING Plant underwent major boiler upgrades Upgraded pulverizers, burners, boiler, control devices Benchmark / engineering testing conducted prior to outage for use in engineering upgrades Post outage Plant conducted guarantee testing Equipment did not meet guarantees Large amount of PM testing conducted with no definitive results (the data was consistent at various fuels, conditions, etc.) The solution wasn’t apparent until particle size analysis was conducted Problem was tied back to new pulverizers – particle size going to the control devices had changed dramatically Once data is verified, act on the data Look at plant upgrades holistically

20 2008, 2009, 2010 & 2011 Questions and Answers Thank You for Your Time J. Sutton 205-358-1011

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