Enclosure 2 Source Testing Request for Area Source Electric Arc Furnace Steelmaking Facilities: Procedures, Methods, and Reporting Requirements Contents Schedule................................................................. 1 Introduction............................................................. 2 1.0 Stack Testing Procedures, Methods, and Schedule......................2 1.1 Source Testing, Test Methods and Reporting..........................2 1.2 How to Select Sample Location and Gas Composition Analysis Methods. .2 1.3 Electric Arc Furnace Baghouse Dust Sampling and Mercury Analysis....8 1.4 Ensuring Data Quality of the Source Tests Performed.................8 2.0 How to Report Data................................................... 9 2.1 Reporting Stack Test Data...........................................9 2.2 Required Fields for ERT Reporting..................................10 2.3 Guidance for Calculating and Reporting Measurements Less Than In- Stack Method Detection Levels for Emissions Data Submitted in Response to Information Collection Request (ICR) Programs..........................10 3.0 How to Submit Data.................................................. 12 3.1 Non-confidential Data..............................................12 3.2 Confidential Data..................................................13 3.3 Directions for Uploading Your Data to the EAF Test Request Website. 13 4.0 Contact Information for Questions on Test Plan and Reporting.......15 Appendix A.............................................................. 16 Abbreviations and Acronyms.............................................16 Unit Conversions.......................................................18 Appendix B: List of Hazardous Air Pollutants (HAP)......................19 Appendix C: Frequently Asked Questions (FAQs) and Responses from Electric Arc Furnace Information Collection Request in 2010........................24 Schedule Item to be Submitted Date from Receipt of Letter Test schedule……………………………………………………………………………………………….60 days Enclosure 1 review and update...…………………………………………………………………………...95 days Enclosure 2 test reports……………………………………………………………………………………150 days Area EAF 114 Testing 2016 1 of 48 September 2016
Transcript
Enclosure 2Source Testing Request for Area Source Electric Arc Furnace Steelmaking Facilities:
Procedures, Methods, and Reporting Requirements
ContentsSchedule..................................................................................................................................................................1Introduction............................................................................................................................................................21.0 Stack Testing Procedures, Methods, and Schedule......................................................................................2
1.1 Source Testing, Test Methods and Reporting...............................................................................................21.2 How to Select Sample Location and Gas Composition Analysis Methods...................................................21.3 Electric Arc Furnace Baghouse Dust Sampling and Mercury Analysis........................................................81.4 Ensuring Data Quality of the Source Tests Performed..................................................................................8
2.0 How to Report Data.........................................................................................................................................92.1 Reporting Stack Test Data.............................................................................................................................92.2 Required Fields for ERT Reporting.............................................................................................................102.3 Guidance for Calculating and Reporting Measurements Less Than In-Stack Method Detection Levels for Emissions Data Submitted in Response to Information Collection Request (ICR) Programs..........................10
3.0 How to Submit Data......................................................................................................................................123.1 Non-confidential Data.................................................................................................................................123.2 Confidential Data.........................................................................................................................................133.3 Directions for Uploading Your Data to the EAF Test Request Website.....................................................13
4.0 Contact Information for Questions on Test Plan and Reporting.............................................................15Appendix A...........................................................................................................................................................16
Abbreviations and Acronyms............................................................................................................................16Unit Conversions...............................................................................................................................................18
Appendix B: List of Hazardous Air Pollutants (HAP).....................................................................................19Appendix C: Frequently Asked Questions (FAQs) and Responses from Electric Arc Furnace Information Collection Request in 2010..................................................................................................24
Schedule
Item to be Submitted Date from Receipt of Letter Test schedule……………………………………………………………………………………………….60 daysEnclosure 1 review and update...…………………………………………………………………………...95 days Enclosure 2 test reports……………………………………………………………………………………150 days
Area EAF 114 Testing 2016 1 of 29 September 2016
Introduction
This document provides an overview of approved methods, target pollutant units of measure, and reporting requirements for owners/operators of major source electric arc furnace (EAF) steelmaking facilities who are required to provide emission test data under EPA’s authority under the Clean Air Act (CAA) section 114. (42 U.S.C. 7414). The purpose for this testing is to gather and update data on mercury and other air pollutant emissions from EAF steelmaking area source facilities.
If you operate an EAF steelmaking area source facility, you are required to conduct emissions testing, and in most cases also dust sampling, as described in this document, for the following pollutants
The process units listed below should be tested if you operate an EAF steelmaking area source facility.
Process Unit(s) Test Location Parameters to Test EAF primary control device Outlet Mercury (including vapor phase Hg),
PM filterableEAF control device for fugitive emissions from charging and tapping
Outlet Mercury including vapor phase Hg), PM filterable
EAF Baghouse Dust Dust bin Mercury, zinc
1.0 Stack Testing Procedures, Methods, and Schedule
This information collection request includes stack (performance) test data requests for mercury and particulate matter (PM) emitted from EAF primary and secondary control devices (secondary EAF control devices are used to control fugitive emissions from charging and tapping). All tests must be performed while the emission units, and control device(s) are operating under typical operating conditions. Please perform air emissions testing using the procedures described in this section according to the schedule below. Note: EPA reserves all of its enforcement rights provided by the CAA section 113, including the right to bring a claim in the U.S. District Court to enforce the CAA section 114 obligation to comply with all the requests described in this Enclosure 2.
1.1 Source Testing, Test Methods and Reporting
Table 1 presents a summary of the required test methods, minimum number of tests runs required, minimum test run duration, and units of measure for test required to be performed on EAF primary and secondary control devices. For copies of the recommended U.S. EPA methods and additional information, please refer to EPA’s Emission Measurement Center (EMC) website: https://www3.epa.gov/ttn/emc/. For Performance Specification (PS) 12A and 12B, see the EMC website at: https://www3.epa.gov/ttn/emc/prompspec12A.html and https://www3.epa.gov/ttn/emc/prompspec12B.html, respectively, as well as on our EAF Area ICR website at https://icr2010.rti.org/ under “OtherLinksAndInformation.”
1.2 How to Select Sample Location and Gas Composition Analysis Methods
Use EPA Method 1 in Appendix A of Part 60 to determine the sampling location. For sources which may not be amenable to emission testing according to the requirement of Method 1, i.e., positive pressure baghouses, select
Table 1. Summary of Required Source Test Methods and Alternative Methods for EAF Primary and Secondary Control Devices a
Pollutant or Parameter Required Methods Minimum No. of Test Runs and
Duration Units of Measureb
Mercury EPA Method 30B, PS 12A, or PS 12B --For Method 30B, replace the sorbent traps daily and sample for 30 consecutive operating daysc (report daily averages). --For PS 12A, sample for 30 consecutive operating daysc (report daily averages). --For PS 12B, replace sorbent traps weekly and sample for four (4) consecutive operating weeksc (report weekly averages).
ORProvide test reports of continuous Method 30B testing for three (3) consecutive operating days for every year for at least five years since 2010, e.g., (2011-2015)
g/m3
lb/hrlb/ton of raw steeld
Filterable PM & Mercury (as particulate and vapor phase)
--EPA Method 5 (negative pressure baghouses) or EPA Method 5D (positive pressure baghouses)--EPA Method 29-For total filterable PM emissions according to §8.3.1.1 with a filter temperature of 248°F +/- 25°F. --Use inductively coupled (argon) plasma with mass spectrometry (IC (A) P/MS) for mercury. Analyze front and back half samples separately. For mercury, report results for front half, back half, and each individual fraction separately.
--Perform at least three (3) test runs.
--Collect a minimum sample volume of 105 dscf (3 dscm) of gas for each test run.
Perform with each test run as required in methods.h
acfm and dscfm, oracmm and dscmm
Flow rate-- Mercury testing of negative and positive pressure baghouses
Measure fan amperage and a correlation to determine flow rate (see Section 1.2 for details)f,g or Install, calibrate, and operate an instrument to continuously measure flow rate (see Section 1.2 for details)
Each operating day for PS 12A and Method 30B; each operating week for PS 12B.h
acfm and dscfm, or acmm and dscmm
Area EAF 114 Testing 2016 3 of 29 September 2016
Pollutant or Parameter Required Methods Minimum No. of Test Runs and
Duration Units of Measureb
O2 / CO2 EPA Method 3, 3A, or 3B Simultaneous with each PM test run.h Volume %, dryMoisture EPA Method 4 Simultaneous with each PM test run.h
Volume %
a If a single emission control device serves multiple emission units (e.g., any combination of EAF exhaust, EAF fugitive emissions, AOD vessel, and LMF), measure and report the combined emissions and test while each unit is operating under normal and typical operating conditionsb Where g/m3 = grams per dry standard cubic meter, lb/hr = pounds per hour, lb/ton = pound per ton, acfm = actual cubic feet per minute, and dscfm = dry standard cubic feet per minute, acmm = actual cubic meters per minute, dscmm = dry standard cubic meters per minute. Data may be obtained and/or recorded in alternative units of measure, but they must be converted to the above units before reporting for this test request. c See the text above for minimum sampling requirements for EAFs that do not operate all day or do not operate every day in the “Procedures for EAFs Operating on Reduced Schedules” section. See also text under “Sampling at Control Devices with Low Expected Emissions of Mercury and PM” for reduced test times for sampling EAF control devices that control secondary emissions.d The requirement to report the amount of “raw steel” produced during the test period can be replaced with tons of "liquid steel" or "cast steel" as appropriate for the facility. The facility must describe clearly in their response how and where the reported quantity of steel production was determined.e You may measure CO2 concentrations at both the inlet and outlet of the positive pressure fabric filter in conjunction with the pollutant sampling to correct pollutant concentrations for dilution and to determine isokinetic sampling rates. You may use either Method 3A or 3B (with integrated bag sampling). Alternatively, all sources of dilution air between the flow measurement location and the pollutant measurement location can be blocked or sealed on a temporary basis during the testing.f Establish a fan amperage range or correlation with flow during PM testing. Determine flow rate using the correlation with fan amperage, or if the fan amperage is maintained during the mercury testing within ± 15% of the average established during the PM testing, use the average flow rate from the PM testing. Record fan amperage in accordance with the procedures in the NSPS (Subpart AAa).g Facilities must use a continuous flow meter if already installed, or may elect to install and use a flow meter if they choose (See Section 1.2 for details) h For ERT supported methods, Methods 1-4 should be added to the ERT file. Note that for moisture (Method 4), this parameter is already required as part of Methods 5 and 29.
Area EAF 114 Testing 2016 4 of 29 September 2016
the appropriate measurement strategy found in Section 8.1 of EPA Method 5D, also found in Appendix A of Part 60. Please note that for sources equipped with emission controls you are required to sample only at the outlet of the control device, except for certain situations as described below. For a complete copy of the methods and guidance information, see https://www3.epa.gov/ttn/emc/method1.html and https://www3.epa.gov/ttn/emc/method5d.html. Analysis of flue gas composition, including oxygen concentration, also must be performed simultaneous with Method 29 testing by use of U.S. EPA Methods 3, 3A, or 3B of Appendix A of Part 60. See https://www3.epa.gov/ttn/emc/method3.html for Method 3; https://www3.epa.gov/ttn/emc/method3a.html for Method 3A; and https://www3.epa.gov/ttn/emc/method3b.html for Method 3B.
The intention of this test request is to collect mercury emissions data over 28 or 30 days of furnace operation as described below using one (or more) of three options.
One option is to use a mercury CEMS operated in accordance with PS 12A. With a PS 12A CEMS, you should collect data for 30 consecutive days and report daily average values. If you are required to use a mercury CEMS meeting PS 12A (e.g., by state regulation or permit), you must use this CEMS to satisfy this ICR.
The second option is to use an integrated sorbent trap monitoring system operated in accordance with PS 12B. With PS 12B monitoring, you should collect multiple integrated samples for up to 7 days each but no shorter than 24 hour sampling periods spanning a 4 week period overall (i.e., 28 days total).
The third option is to apply Method 30B. With Method 30B, you may conduct each paired train test run for up to 24 hours for a total of 30 or more runs over the 30-day monitoring period.
In addition to the emission test data, you also must report the process information required to be recorded during the emissions tests listed in Table 2 and described below:
• Production rate of raw steel during each of the emission tests• Percentage of the type of steel produced during testing• Average percent auto scrap during tests• Type and quantity of scrap charged to EAF during tests• Quantity of other materials charged to EAF during tests• Control devices and measures used to control Hg emissions.
Please use the appropriately labeled worksheet in the “EAF Area Emission Test Template” file provided on the CD included in this package and on the ICR website https://icr2010.rti.org/ to report this information.
Concentration and Flow Measurements—Positive Pressure Fabric Filters (baghouses)
In the case of sampling at positive pressure baghouses for PM and mercury concentrations, conduct sampling of the exhaust of one compartment of the baghouse using the procedure for setting isokinetic sampling rates as described in Method 5D. In addition, the compartment selected should be the one most representative of normal operation. Only one baghouse compartment needs to be traversed for PM and mercury; and for mercury, only a single representative point in one compartment needs to be sampled. Follow Section 8.3 in Method 5D for determining the outlet stack flow rate (i.e., measure the flow rate at the inlet using Method 2 and correct for dilution air by measuring either temperature or CO2 concentration at both the inlet and the sampling point, or alternatively, block or seal all sources of dilution air between the flow measurement location and the pollutant measurement location on a temporary basis during the testing).
Table 2: Summary of EAF Operation Information Required for Each Test Report Submitted, by Run, Week, or Daya
Facility nameEmission unit(s) ID - use same ID as in schematicLatitude of stack (decimal degrees, 5 decimal places)Longitude of stack (decimal degrees, 5 decimal places)Date of testSteel production (EAF, AOD vessel, LMF)Percentage of the type of steel produced during mercury testing:- Carbon steel- Stainless steel- High alloy steel
Average percent auto scrap during tests, if knownNumber of switches collected during Hg testingAmount of scrap charged into EAF, by type:- No. 2 heavy melting steel (ISRI Codes 204-206)- Shredded scrap (ISRI Code 210)- (All) Other type(s) of scrap (describe separately)
Direct reduced iron chargedOther ferrous materials charged (describe):Metallurgical coke chargedPetroleum coke chargedCoal chargedLime chargedAlloys chargedTires chargedOther materials charged (list):A description any control devices or control measures used to control PM, mercury or other HAP emissions for this emission unita Answers should be entered into appropriately labeled worksheet on the “EAF Area Emission Test Template” file provided on the CD included in this package and also on the ICR website https://icr2010.rti.org/ .
For the continuous mercury testing, facilities with positive pressure baghouses may sample for mercury concentration at a single representative point in a single compartment. Determine the volumetric flow rate during the continuous mercury emission testing using fan performance curves for either static pressure or amperage unless the facility already has certified and calibrated flow meters installed to determine the volumetric flow rate at the inlet to the baghouse, in which case the facility must use certified and calibrated flowmeters to determine the volumetric flow rate. When using fan performance curves, the facility should measure and record the static pressure (or pressure differential across the fan) or the amperage, collect at least three data points to confirm or adjust the manufacturer's fan curve to the site-specific application, and monitor that parameter to determine the volumetric flow rate during the mercury emission test. Alternatively, if the fan amperage is maintained during the mercury testing within ± 15% of the average established during the PM testing, use the average flow rate from the PM testing. Record fan amperage in accordance with the procedures in the New Source Performance Standards (NSPS) (Subpart AAa). Facilities may also choose to install, calibrate, and maintain a certified flow meter for continuously measuring and recording the baghouse inlet volumetric flow rate during mercury testing. The volumetric flow rate must be reported for each sampling period (e.g., daily to weekly when using the sorbent trap).
For the continuous mercury testing, facilities with negative pressure baghouses should determine the volumetric flow rate using fan performance curves as described above for positive pressure baghouses unless the facility already has calibrated flow meters installed for volumetric flow rate, in which case the facility must use the calibrated flow meters to determine the volumetric flow rate. A facility may choose to install, calibrate, and maintain an instrument for continuously measuring and recording the exhaust flow rate to the atmosphere rather than using fan performance curves. If this option is chosen, install each sensor of the flow rate monitoring system in a location that provides representative measurement of the exhaust gas flow rate at the sampling location for mercury concentration taking into account the manufacturer’s recommendations. The flow rate monitoring system must be:
1. Designed to measure the exhaust flow rate over a range that extends from a value of at least 20 percent less than the lowest expected exhaust flow rate to a value of at least 20 percent greater than the highest expected exhaust flow rate.
2. Accurate within 5 percent of the exhaust flow rate.3. Equipped with a data acquisition and recording system that is capable of recording values over the entire
range specified above.
The signal conditioner, wiring, power supply, and data acquisition and recording system for the flow rate monitoring system must be compatible with the output signal of the flow rate sensors used in the monitoring system. The flow rate monitoring system must be designed to complete a minimum of one cycle of operation for each successive 15-minute period. To have a valid hour of data, the flow rate monitoring system must measure and record at least three of four equally spaced data values (or at least 75 percent of the total number of values) for each hour (not including startup, shutdown, malfunction, or out-of-control periods). Perform an initial calibration of the flow rate monitoring system according to manufacturer’s recommendations.
Procedures for EAFs Operating on Reduced Schedules
We understand that some EAFs may not operate during each shift every day or may not operate every day. For EAFs that do not operate for full days or every day during the week, sampling for mercury emissions from the primary control device must be performed for each day the EAF operates, even if it operates for only part of the day, for 30 consecutive operating days when using PS 12A or Method 30B, or for four (4) consecutive operating weeks when using PS 12B. If the sampling term described above does not provide at least 8 daily average measurements, the EAF facility must continue sampling and obtain a minimum of 8 daily average mercury measurements for the primary control device.
For the purposes of calculating mass emissions in units of pound per ton (lb/ton) of raw steel produced, it is necessary to collect mercury samples only when the EAF is operating. At your discretion, you may coordinate operation of the sampling system (i.e., starting and stopping sample collection) with the EAF operation such that you collect mercury samples only when the EAF is operating (i.e., continuing heat cycle after heat cycle on your normal operating schedule without a system shutdown) provided that you document the sampling periods, coordinate mercury sampling with the corresponding stack gas flow rates, and describe the EAF operating periods clearly. In the end, you should have mercury emissions values spanning 30 days of documented continuous or intermittent EAF operation. You must also submit data for concentration measurements (e.g., grams per dry standard cubic meter (g/dscm)) and mass rate (e.g., lb/hr) in order to provide data quality information (e.g., for calculations). We expect that the vast majority of EAFs generally operate continuously over at least a 24-hour period with periodic shutdowns that may last for several hours or a few days.
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Sampling for mercury emissions for the control device for fugitive emissions from melting and tapping (if different from the primary control device) for an EAF not on a full operating schedule must be performed for seven (7) consecutive operating days when using PS12A or Method 30B, or for one (1) operating week when using PS 12B. If the sampling term described above does not provide at least three (3) daily measurements for the fugitive emission control device, the EAF facility must continue sampling and obtain a minimum of three (3) daily average mercury measurements for the fugitive emission control device.
If your EAF does not operate every day and you qualify for the minimum sampling requirements above, please submit documentation (such as copies of heat sheets showing operating days and hours) that shows this reduced operating schedule has been in place for at least three (3) months from the date of receipt of this letter.
Sampling at Control Devices with Low Expected Emissions of Mercury and PM
For some control devices that control fugitive EAF cast house emissions and/or emissions from charging or tapping the EAF, the emissions of mercury and PM are very low and are a small percentage (less than 1 percent) of the total EAF emissions combined. In these cases, reduced sampling times may be used, as follows:
For PS 12A, sample for seven (7) consecutive calendar days (report daily averages); For PS 12B, sample for one (1) calendar week; and For Method 30B, replace the sorbent traps daily and sample for seven (7) consecutive calendar days
(report daily averages).
In addition, see the text above for minimum sampling requirements for EAFs that do not operate all day or do not operate every day under the “Procedures for EAFs Operating on Reduced Schedules” heading.
1.3 Electric Arc Furnace Baghouse Dust Sampling and Mercury Analysis
If you operate an electric arc furnace steelmaking facility, you must sample and analyze the EAF baghouse dust during the mercury emission test to determine the concentration of mercury. EAF baghouse dust samples must be collected once per day during each week of the test for mercury emissions and composite into a weekly sample. Each weekly sample must be analyzed using the procedures in Table 3, below. For copies of the recommended U.S. EPA SW-846 methods, please refer to EPA’s SW-846 Online website: https://www.epa.gov/hw-sw846
1.4 Ensuring Data Quality of the Source Tests Performed
While we are not specifying numerical minimum detection levels for the tests to be performed, we have specified the testing conditions and methods required, including test run times when appropriate, which we believe will provide data of a quality sufficient for decision making.
We remind source owners and testers of the CAA section 114(a)(1) requirement to provide the information requested for the potential development of emissions standards using methods that provide sufficient data for regulatory decisions. For the most part, we can identify test methods and procedures that will satisfy those decision making needs (e.g., minimum sampling times). In other cases, we recognize that the source owner's or tester's selection of test procedures or equipment could bear significantly on the quality of the data.
We believe that the CAA is clear in that it is the responsibility of the source and the tester to apply methods and procedures that result in optimized data quality, including providing for the lowest possible detection limits considering practical and reasonable limitations. For example, source owners and testers should not automatically choose to use low or medium quality equipment for testing (e.g., for cost reasons) if high quality
Table 3. Dust Sampling and Analysis Methods for Mercury and Zinc
Parameter Pollutant Recommended Method
Alternative Method
Units of Measure
EAF Dust Digestion Hg, Zn EPA SW-846 Method 3050
EPA SW-846 Method 3051
Not applicable
Mercury Analysis Hg EPA SW-846 Method 7471B
None mg/kg (dry basis)
Zinc Analysis Zn EPA SW-846 Method 6020B
None mg/kg (dry basis)
equipment is reasonably available. We will review test reports in light of this expectation and will be particularly mindful of whether the testing procedures applied are representative of the highest reasonably expected capabilities (e.g., comparing reported minimum measurement detection levels between tests and testers).
If we believe that a source owner or tester has failed to meet the requirement of the CAA to provide data sufficient for our decisions, we can and will request additional measurements that require the use of improved testing procedures.
On completion of your required tests, please provide the full test reports, including summary pages, that contain the information listed below. Please ensure that the following information is included (at a minimum):
Run-by-run pollutants and emission rates measured (e.g., lb/hr, g/dscm, lb/ton) for the pollutants of interest for this survey, including mercury and PM filterable;
Stack parameters (volumetric flow rates, temperature, % oxygen, % moisture, etc.); Names of the test methods or procedures used; Information on actual production or processing rates during the test; Identify any runs where the process or control device was not operating normally and any runs that were
invalidated (including the reason); and Quality assurance and quality control activities performed.
2.0 How to Report Data
The method for reporting the results of any testing and monitoring requests depends on the type of tests and the type of methods used to complete the test requirements. This section discusses the requirements for reporting the data.
2.1 Reporting Stack Test Data
If you conducted additional stack tests in response to this test request using one of the methods listed in Table 4 shown below, you must report your data using the EPA Electronic Reporting Tool (ERT) Version 5.0. The ERT is a Microsoft® Access database application available at https://www3.epa.gov/ttnchie1/ert/. If you are not a registered owner of Microsoft® Access, you can install the 2010 runtime version of the ERT Application. An Excel spreadsheet can be used to assist with the upload of the field sampling data. This spreadsheet file, Method_29-30B_Example_Data_2014 (ZIP 19M), is available at https://www3.epa.gov/ttnchie1/ert/. After completing the data entry into the ERT, you will also need to attach supporting documentation to the Attachments module of the ERT. The supporting documentation should include: complete lab reports, chain of custodies, field data and sample/moisture recovery sheets, CEMS raw data, calibrations of equipment, gases and
Table 4: List of Applicable Test Methods Supported by EPA’s Electronic Reporting Tool (ERT)a
Test Methods Supported by the ERTMethods 1 through 4Method 3AMethod 5Method 29Method 30Bb
a Data collected with other EPA methods or alternative methods have an alternate reporting tool discussed in Section 2.1.b This method has been added to the ERT since the previous EAF testing in 2010.
instruments, QA/QA data, audit sample results (if applicable), and field notes. The ERT database file should be transmitted to EPA using one of the options described below in Section 3.
Alternatively, if you perform tests with methods PS12A or PS12B for mercury, you must report the results of these tests in an individual Microsoft® Excel “EAF Area Emission Test Template.” The individual Excel EAF templates are specific to each pollutant and type of unit, and they can be downloaded from the Electric Arc Furnace Area EPA Test Request website http://icr2010.rti.org. Note that Method 30B has been added to the test methods supported by the ERT since the EAF testing that was performed in 2010. You must report the results of each test that is not in the ERT using an appropriately labeled worksheet that you develop using the EAF Area Emission Test Template provided on the CD included in this package and the ICR website https://icr2010.rti.org/, and which corresponds to the specific tests requested at your facility. If more than one source at your facility was tested using methods not currently supported by the ERT, you must make an electronic copy of the EAF worksheet to report these data within the file, making sure to update the source ID in order to distinguish between each separate source/test. After completing all the required EAF Worksheets on the CD, you must also submit an electronic copy of the emission test report (PDF format preferred). Both the EAF Worksheet CD and the emission test report should be transmitted to EPA using one of the options described below in Section 3.
2.2 Required Fields for ERT Reporting
Enclosure 8 provides an EPA ERT Version 5.0 example test plan and lists each field within the ERT. Note that the required reporting includes the latitude and longitude of each stack tested (in decimal degrees to 5 decimal places).
2.3 Guidance for Calculating and Reporting Measurements Less Than In-Stack Method Detection Levels for Emissions Data Submitted in Response to Information Collection Request (ICR) Programs
Please identify the status of the measured values relative to the detection levels on the individual Excel spreadsheet or in the ERT Access database using the following descriptions:
BDL (below detection level) – all analytical values used to calculate and report an in-stack emissions value are less than the laboratory’s reported detection level(s);
DLL (detection level limited) – at least one but not all values used to calculate and report an in-stack emissions value are less than the laboratory’s reported detection level(s); or
ADL (above detection level) – all analytical values used to calculate and report an in-stack emissions value are greater than the laboratory’s reported detection level(s).
For each reported emissions value, insert the appropriate flag (BDL, DLL, or ADL) in the Note line of Excel emission test spreadsheet template or in the Flag column of the Electronic Reporting Tool (ERT).
When reporting and calculating individual test run data:
For analytical data reported from the lab as “nondetect” or “below detection level;” Include a brief description of the procedures used to determine the analytical detection and in-
stack detection levels:o In the Note line of Excel emission test spreadsheet template; oro In the Comments line of Lab Data tab in the Run Data Details in the ERT.
Describe these procedures completely in a separate attachment including the measurements made, the standards used, and the statistical procedures applied.
Calculate in-stack emissions rate for any analytical measurement below detection level using the relevant method detection level, sample volumes, and other relevant run specific parameters (such as oxygen and flowrate). The reported value must assume that the analyte is present at the full MDL value.
Report the calculated emissions concentration or rate result:o As a bracketed “less than” detection level value (e.g., [<0.0105]) in the Excel emission
test spreadsheet template and include the appropriate flag in the Note line; oro As a numerical value in the ERT with the appropriate general flag in the Flag column
Report as numerical values (i.e., no brackets or < symbol) any analytical data measured above the detection level including any data between the analytical detection level and a laboratory-specific reporting or quantification level (i.e., flag as ADL).
If applicable, data flags for each fraction which have been labeled by the analytical lab (i.e., B, J, E, etc…) must be identified in the comments section, as well as designation for the data flag (e.g., J – estimated value, below the lowest calibration point)
For pollutant measurements composed of multiple components or fractions (e.g., Hg sampling trains) when the result for the value for any component is measured below the analytical detection level;
Calculate in-stack emissions rate or concentrations as outlined above for each component or fraction;
Sum the measured and/or calculated values (using the detection level values as outlined above) using the in-stack emissions rate or concentrations for all of the components or fractions; and
Report the sum of all components or fractions:o As a bracketed “less than” detection level value (e.g., [<0.0105]) in the Excel emission
test spreadsheet template and include the appropriate flag in the Note line; oro As a numerical value in the ERT with the appropriate flag in the Comments line.o If all components or fractions are BDL, the appropriate flag is BDL. If the components or
fractions are a mix of BDL, DLL, and ADL, then the appropriate flag is DLL. [Note: If all components or fractions are above the MDL, the appropriate flag is ADL.]
Report also the individual component or fraction values for each run if the Excel emission test spreadsheet template or ERT format allows (i.e., front half metals and back half metals); if not (i.e., the format allows reporting only a single sum value):
o For the Excel emission test spreadsheet template, next to the sum reported as above report in the Notes line the appropriate flag along with the values for the measured or
Area EAF 114 Testing 2016 11 of 29 September 2016
detection level value for each component or fraction as used in the calculations (e.g., 0.036, [<0.069], 1.239, [<0.945] for a four fraction sample)
o For the ERT, next to the sum reported as above, report in the Flag column the appropriate general flag in the Comments column and the measured or detection level value for each component or fraction as used in the calculations followed by a space and any specific flag identifier provided by the laboratory (e.g., 0.036, [<0.069] J, 1.239, [<0.945] B for a four fraction sample)
For measurements conducted using the instrumental test method (Method 3A) Record gaseous concentration values as measured including negative values.
When reporting and calculating average emissions rate or concentration for a test when some results are reported as BDL in the spreadsheet
Sum all of the test run values including those indicated as BDL or DLL as numerical values Calculate the average emissions rate or concentration (e.g., divide the sum by 3 for a three-run
test) Report the average emissions rate or concentration average:
o As a bracketed “less than” detection level value (e.g., [<20.06]) in the Excel emission test spreadsheet template and include the appropriate flag in the Note line
3.0 How to Submit Data
3.1 Non-confidential Data
You should submit your non-confidential data (including revised responses to the survey questions, new test reports, ERT database, Excel spreadsheets, and associated information, etc.,) in one of the ways listed below. Please refer to Enclosure 4 to aid you in determining what information can be claimed confidential. In order to avoid duplicate data and keep all data for a particular facility together, we request that you submit all of the data requested from your facility in the same way, if possible. To submit your data, you may choose any ONE of the procedures below, although uploading files is preferred:
(1) Preferred - Upload an electronic copy of all requested files to a website that has been created specifically for this EAF area source test request: http://icr2010.rti.org. See below in Section 3.3 for the procedures to access this site and for setting up a password unique to your company; or
(2) Alternative - Mail a CD, or DVD containing an electronic copy of all requested files to either of the two EPA addresses below (hard copies are permitted if that’s the only possibility; otherwise, electronic is preferred):
Please use the address below for NONCONFIDENTIAL U.S. mail:
Dr. Donna Lee Jones Metals and Inorganic Chemicals Group (Mail Code D243-02)Office of Air Quality Planning and StandardsU.S. Environmental Protection AgencyResearch Triangle Park, NC 27711
For NONCONFIDENTIAL commercial package carriers, such as FedEx and UPS, please use:
Dr. Donna Lee Jones Metals and Inorganic Chemicals Group (Mail Code D243-02)Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency4930 Old Page RdDurham, NC 27709
3.2 Confidential Data
If the process data or other information you are providing is considered confidential, please create a separate CD or DVD containing only the confidential portion of your data or prepare a copy of the hard copy materials containing only the pages that include the information you consider confidential. Clearly mark the disk and/or materials with the words “Confidential Business Information.” Please refer to Enclosure 4 to aid you in determining what information can be claimed confidential. Send the confidential files under separate cover to the attention of Dr. Donna Lee Jones at either of the two addresses below.
Please use the following address for sending CONFIDENTIAL information via U.S. mail:
Ms. Tiffany Purifoy, Government Information Specialist (C404-02) ATTN: Electric Arc Furnace Steelmaking (Project #415)Office of Air Quality Planning and StandardsU.S. Environmental Protection AgencyResearch Triangle Park, NC 27711
For sending CONFIDENTIAL information via commercial package carriers, e.g., FedEx and UPS, please use:
Ms. Tiffany Purifoy, Government Information Specialist (C404-02) ATTN: Electric Arc Furnace Steelmaking (Project #415)Office of Air Quality Planning and Standards U.S. Environmental Protection Agency4930 Old Page RdDurham, NC 27709
For the security of your data, EPA recommends sending your CONFIDENTIAL files to Ms. Purifoy via registered U.S. mail using return receipt requested, Federal Express, or other method for which someone must provide a signature upon receipt. Do not electronically transmit confidential business information (CBI) to EPA. E-mail or facsimile are not considered secure forms of communication and should never be used to transmit CBI. Do not upload confidential information to the EAF website because this website is not an official mode of transferring confidential information to the EPA.
3.3 Directions for Uploading Your Data to the EAF Test Request Website
1. To Open the Web siteOpen the Electric Arc Furnace Area EPA Test Request Web site, located at the following address: http://icr2010.rti.org.
2. To Find the EAF Area Source SiteClick on the “Industries” menu item within the menu bar at the left of the screen, and then click on the “Electric Arc Furnace (EAF) Area” menu item.
3. To Register a New User Name or Recover a Previous User Name
a. If you have a previously registered User Name from the 2010 EAF Area ICR effort, you may use it for this 2016 EAF Area ICR effort. If you have forgotten your User Name and want to use the same one as in 2010, please email Gabrielle Raymond, RTI, [email protected].
b. Alternatively, if you want to register a New User Name (and password), click on the “Register” menu item at the top of the screen to register a new User Name. Please fill in all the required fields. You will be prompted to set new password in this step. To submit your account information, click on “Register” at the bottom of the screen.
c. You will immediately receive an email notification confirming you have registered. You will receive a second email confirming that you have been added as a Registered User to the website within 24 hours.
d. You will not be able to submit, i.e., upload, any facility information until you have received the second email. However, you have full access to the information on the site immediately.
e. You may now proceed to Log In.
3. To Log In or Recover a Forgotten Password
a. Click on the “Login” menu item at the top of the screen to get to the Login page.
b. Type in your User Name and Password.
c. If you have forgotten your password from the 2010 EAF Area ICR effort, you can create a new one by clicking on the “Forgot Password?” hyperlink on the Login page. Type in your User Name, and click on “Send Password”. The password will be sent to the email address you provided during registration.
d. When ready, click on the gray “Login” button to Log In.
4. To Upload Files (completed ERT Database, Excel Spreadsheets, electronic survey responses, electronic test reports, and any other correspondence related to this information request.)
a. Click on the "Upload Files" menu item.
b. Enter a description for the upload (please include facility name(s) and type of document i.e., ERT Database, Excel Spreadsheet, Survey Response, Test Report).
c. Browse to the file that you wish to upload.
d. After selecting the file, click on the “Upload” link. Uploading may take a few seconds or minutes depending on the size of the file you are attempting to upload, and your internet connection speed.
b. Next to each file will be links to “Download” and “Delete” the file.
i. If you would like to check the file that is currently uploaded, click on the “Download” link to download a copy of it.
ii. You can click on the “Delete” link if you wish to remove the file in order to upload a new version.
c. You have complete ownership of the files you upload; only you have the access to view and delete the files. You will not be able to view or delete files uploaded by another company.
4.0 Contact Information for Questions on Test Plan and Reporting
For questions on how to report data using the ERT Access database, contact:Theresa Lowe (U.S. EPA) at (919) 541-4786 or [email protected]
For all other questions related to this test request, contact:Donna Lee Jones (U.S. EPA) at [email protected]
acf actual cubic feetacfm actual cubic feet per minuteacm actual cubic metersacmm actual cubic meters per minuteCAA Clean Air ActCBI confidential business informationday/yr days per year°C degrees Celsius °F degrees Fahrenheitdscf dry standard cubic feetdscfm dry standard cubic feet per minutedscm dry standard cubic metersdscmm dry standard cubic meters per minuteEAF electric arc furnaceEPA U.S. Environmental Protection Agency
ft foot or feetft2 square feetft3 cubic feetfpm feet per minute (acfm divided by ft2 of filter area)fps feet per secondgal gallongpm U.S. gallons per minutegr graingr/dscf grains per dry standard cubic footg gramg/dscm grams per dry standard cubic meterHAP hazardous air pollutantshr hour or hourshr/day hours per dayin inch or inchesin H2O inches of water (pressure drop)kg kilogramkPa kilopascalskv kilovoltkw-hr kilowatt hourlb poundlb/day pounds per daylb/gas pounds per U.S. gallonlb/hr pounds per hourlb/ton pounds per tonm meterMACT maximum achievable control technologym3 cubic meters
Area EAF 114 Testing 2016 16 of 29 September 2016
Appendix A
min minute or minutesMg megagrammg milligrammg/dscm milligrams per dry standard cubic metermg/l milligrams per literMM scf millions of standard cubic feetMMlb/yr million pounds per yearNAICS North American Industry Classification SystemNESHAP National Emission Standards for Hazardous Air PollutantsOAQPS Office of Air Quality Planning and StandardsOTM Other Test MethodPM particulate matterppmv parts per million by volumeppmw parts per million by weight% percents second or secondsSPPD Sector Policies and Programs Divisionscf standard cubic feetscfm standard cubic feet per minutescm standard cubic metersscmm standard cubic meters per minutetpd tons (short) per daytpy tons (short) per year µg/dscm micrograms per dry standard cubic metervol% volume percent, or percent by volumewt% weight percent, or percent by weightyr year
Area EAF 114 Testing 2016 17 of 29 September 2016
Appendix A
Unit Conversions
To Convert From To Multiply by°C °F multiply by 1.8, then add 32°F °C subtract 32, then multiply by 0.556ft m 0.0348ft/min m/min 0.0348ft2 m2 0.0929ft3 m3 0.028g lb 0.0022g/m3 lb/ft3 0.0000624 gr lb 0.000143gr/dscf mg/dscm 2,290in water mm water 25.4kg/hr lb/hr 2.205 lb g 454lb gr 7000lb/ft3 g/m3 16,000lb/hr kg/hr 0.454 m ft 3.28m/min ft/min 3.28mm water in water 0.0394m2 ft2 10.76mg/dscm gr/dscf 0.00044m3 ft3 35.31 Mg ton 1.1 ton (short) Mg 0.907
Area EAF 114 Testing 2016 18 of 29 September 2016
Appendix B
Appendix B: List of Hazardous Air Pollutants (HAP)
CAS Number Chemical NameAntimony Compounds Arsenic Compounds (inorganic including arsine) Beryllium Compounds Cadmium Compounds Chromium Compounds Cobalt Compounds Coke Oven Emissions Cyanide Compounds1 Glycol ethers2
Lead CompoundsManganese Compounds Mercury Compounds Fine mineral fibers3 Nickel Compounds Polycylic Organic Matter4
CAS Number Chemical Name63252 Carbaryl75150 Carbon disulfide56235 Carbon tetrachloride463581 Carbonyl sulfide120809 Catechol133904 Chloramben57749 Chlordane
CAS Number Chemical Name95954 2,4,5-Trichlorophenol 88062 2,4,6-Trichlorophenol 121448 Triethylamine 1582098 Trifluralin 540841 2,2,4-Trimethylpentane 108054 Vinyl acetate 593602 Vinyl bromide 75014 Vinyl chloride 75354 Vinylidene chloride (1,1-Dichloroethylene)
1330207 Xylenes (isomers and mixture) 95476 o-Xylenes108383 m-Xylenes106423 p-Xylenes
NOTE: For all listings above which contain the word "compounds" and for glycol ethers, the following applies: Unless otherwise specified, these listings are defined as including any unique chemical substance that contains the named chemical (i.e., antimony, arsenic, etc.) as part of that chemical's infrastructure.
1: X'CN where X = H' or any other group where a formal dissociation may occur. For example KCN or Ca(CN)22: Includes mono- and di- ethers of ethylene glycol, diethylene glycol, and triethylene glycol R-(OCH2CH2)n -OR' wheren = 1, 2, or 3R = alkyl or aryl groupsR' = R, H, or groups which, when removed, yield glycol ethers with the structure: R-(OCH2CH)n-OH. Polymers are excluded from the glycol category. Also excludes ethylene glycol monobutyl ether (EGBE) (2-Butoxyethanol) (Chemical Abstract Service (CAS) No. 111-76-2) and surfactant alcohol ethoxylates and their derivatives (SAED). 3: Includes mineral fiber emissions from facilities manufacturing or processing glass, rock, or slag fibers (or other mineral derived fibers) of average diameter 1 micrometer or less.4: Includes organic compounds with more than one benzene ring, and which have a boiling point greater than or equal to 100º C. 5: A type of atom which spontaneously undergoes radioactive decay.
Area EAF 114 Testing 2016 23 of 29 September 2016
Appendix C
Appendix CFrequently Asked Questions (FAQs) and Responses from Electric Arc Furnace
Information Collection Request in 2010
The following are questions and answers provided in 2010 for the initial EAF Area Source test program that may be relevant to the current re-test request in 2016.
1. The test request refers to "continuous mercury testing". Please verify that this refers to collecting a series of time-integrated sorbent trap samples (using Performance Specification (PS) 12A, PS 12B or EPA Method 30B) rather than using continuous emissions analyzers.
Response: The intention is that you collect mercury emissions data over 28 or 30 days of furnace operation as described below using one (or more) of three options.
a) One option is to use a mercury CEMS operated in accordance with PS 12A. With a PS 12A CEMS, you should collect data for 30 consecutive days and report daily average values. If you are required to use a mercury CEMS meeting PS 12A, e.g., by state regulation or permit, you must use this CEMS to satisfy this ICR.
b) The second option is to use an integrated sorbent trap monitoring system operated in accordance with PS 12B. With PS 12B monitoring, you should collect multiple integrated samples for up to 7 days each but no shorter than 24 hour sampling periods spanning a 4 week period overall, i.e., 28 days total.
c) The third option is to use EPA Method 30B. With EPA Method 30B, you may conduct each paired train test run for up to 24 hours for a total of 30 or more runs over the 30-day monitoring period.
2. Is proportional (i.e., adjusting for flow rate changes) sampling necessary for the long term mercury measurements? Is it necessary to operate the sampling system only when the EAF is operating and turn it off when the EAF is off?
Response: We understand that most, if not all, EAF capture and control systems operate with a continuous and constant rate induced draft (ID) fan. (For example, see question below.) As such, there is little need to adjust sampling rates to maintain proportional sampling rates and we are not requiring that you do so. Our primary data need for assessing the mercury emissions from EAFs is in terms of mass emissions rates expressed as lb/ton of raw steel produced. For the purposes of calculating mass emissions in units of lb/ton of raw steel produced, it is necessary to collect mercury samples only when the EAF is operating. At your option, you may coordinate operation of the sampling system (i.e., starting and stopping sample collection) with the EAF operation such that you collect mercury samples only when the EAF is operating (i.e., continuing heat cycle after heat cycle on your normal operating schedule without a system shutdown) provided that you document the sampling periods, coordinate mercury sampling with the corresponding stack gas flow rates, and describe the EAF operating periods clearly. In the end, you should have mercury emissions values spanning 30 days of documented continuous or intermittent EAF operation. We have also requested that you submit data for concentration measurements (g/dsm3) and mass rate (lb/hr) in order to provide data quality information (e.g., calculations). We expect that the vast majority of EAFs generally operate continuously over at least a 24-hour period with periodic shutdowns that may last for several hours or a few days.
3. In the Procedures for EAFs Operating on Reduced Schedules the first paragraph of the section refers to testing on 30 consecutive calendar days (using PS12A or 30B), sampling for four consecutive calendar weeks (using PS12B), and to sampling on each day the EAF operates. These approaches would yield 30 average daily measurements, four average weekly measurements, or an indeterminate number or average daily measurements, respectively. Please clarify the meaning of "eight daily average
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Appendix C
measurements" in this context (which presumably also will apply to the meaning of "three daily average mercury measurements" in the subsequent paragraph.
Response: Our intent in this test request is to obtain 30 days of mercury emissions data for EAFs operating on a continuous schedule. The ideal scenario would be that you would collect mercury emissions data continuously over 30 contiguous days of EAF operation. We recognize that some EAFs may operate for only a few days per week. If you normally operate your EAF on a reduced schedule (e.g., a few days per week or only one or two shifts a few days a week) and can provide documentation for the last three months as such,* you may submit data spanning 30 consecutive days (or four consecutive calendar weeks) if there are at least eight operating days during this period. If you do not operate the EAF for at least 8 days (i.e., 192 hours) during this 30-day period, you must extend the monitoring period until you have mercury emissions data for at least eight EAF operating days. We recognize that sampling in this manner may span periods of intermittent EAF operation. It is not necessary that you collect samples only when the EAF is operating for the purposes of calculating mass emissions in units of lb/ton of raw steel produced. At your option, you may coordinate operation of the sampling system (i.e., starting and stopping sample collection) with the EAF operation such that you collect mercury samples only when the EAF is operating provided that you document the sampling periods, coordinate mercury sampling with the corresponding stack gas flow rates, and describe the EAF operating periods clearly. In the end, you should have four or more PS 12B mercury emissions values spanning 28 days of continuous or intermittent EAF operation that is also documented.
Similarly, for the control device applied to fugitive emissions, we are requesting testing for all days that the EAF operates during a 7-day period with either one time-integrated sample from PS12B or daily averages from PS 12A or EPA Method 30B. If the EAF operates less than three days during this period,* the testing should continue beyond the 7 days until you have emissions data for at least 3 days of EAF operation. Please note that it is important to submit documentation to qualify for the reduced sampling if the EAF is operating on a reduced schedule (bottom of page 15 of the ICR Enclosure 2).
* If your EAF does not operate every day, please submit documentation (such as copies of heat sheets showing operating days and hours) that shows the reduced operating schedule has been in place for at least three (3) months from receipt of this letter.”
From the ICR:
“We understand that some EAFs may not operate during each shift every day or may not operate every day. For EAFs that do not operate for full days or every day during the week, sampling for mercury emissions from the primary control device must be performed for each day the EAF operates, even if it operates for only part of the day, for 30 consecutive calendar days when using PS 12A or EPA Method 30B, or for four (4) consecutive calendar weeks when using PS 12B. If the sampling term described above does not provide at least 8 daily average measurements, the EAF facility must continue sampling and obtain a minimum of 8 daily average mercury measurements for the primary control device.
“Sampling for mercury emissions for the control device for fugitive emissions from melting and tapping (if different from the primary control device) for an EAF not on a full operating schedule must be performed for seven (7) consecutive calendar days when using PS12A or EPA Method 30B, or for one (1) calendar week when using PS 12B. If the sampling term described above does not provide at least three (3) daily measurements for the fugitive emission control device, the EAF facility must continue sampling and obtain a minimum of three (3) daily average mercury measurements for the fugitive emission control device.
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Appendix C
“If your EAF does not operate every day and you qualify for the minimum sampling requirements above, please submit documentation (such as copies of heat sheets showing operating days and hours) that shows this reduced operating schedule has been in place for at least three (3) months from the date of this letter.”
4. Please clarify the agency's expectations regarding spike recovery requirements in the mercury sorbent trap methods. Since mercury levels will be extremely uncertain and probably will be unpredictable, it may not be possible to spike traps at levels that will comply with the usual requirements of 50-150% of mass collected. For the power generation ICR, EPA made such allowances - particularly for oil fired boilers. In that case, 50 ng was the default spike mass, and most of the sample masses we collected were near detection limits (~1-5 ng).
Response: See language below from PS 12B (there is similar language in Section 8.2.6.1 of EPA Method 30B).
“8.1.2 Pre-sampling Spiking of Sorbent Traps. Based on the estimated Hg concentration in the stack, the target sample rate and the target sampling duration, calculate the expected mass loading for section 1 of each sorbent trap (see Section 12.1 of this performance specification). The pre-sampling spike to be added to section 3 of each sorbent trap must be within ± 50 percent of the expected section 1 mass loading. Spike section 3 of each sorbent trap at this level, as described in Section 6.1.3 of this performance specification. For each sorbent trap, keep a record of the mass of Hg added to section 3. This record must include, at a minimum, the identification number of the trap, the date and time of the spike, the name of the analyst performing the procedure, the method of spiking, the mass of Hg added to section 3 of the trap (μg), and the supporting calculations. "
The key words here are "expected" and "estimate". You need to make a reasonable estimate of the amount of Hg that will be captured, spike the third section of the trap within 50 percent of that estimate, and keep a record of the "supporting calculations" which is the information you used to calculate or estimate the expected amount. We understand that the initial estimates may be significantly different from the amount actually collected in the first section of the trap since the criteria for establishing the amount to spike is based on the estimated expected mass loading and not the actual. As the monitoring for this extended monitoring program will mean repetitive changes of the sorbent trap, we would expect that you would revise the basis for estimating future expected amounts and adjust the spike amount accordingly.
5. With respect to EPA Method 30B, what length and number of test runs are you expecting per each operating day? Table 1 indicates that daily averages should be reported. This seems to indicate more than one test run per day. Is this correct? Can you define daily averages?
Response: We understand that EPA Method 30B is designed as a short term test method (run times typically range from 30 minutes to 2 or 3 hours). For the purposes of this program, you may apply EPA Method 30B in a single run up to 24 hours in duration adjusting sampling rates and spike levels accordingly. Alternatively, you may conduct multiple EPA Method 30B test runs each day (e.g., 3 8-hour runs) that would produce an average mercury emissions values for each 24-hour period. As with any mercury monitoring approach, it is important to measure and report the EAF stack flow rates each day corresponding to the mercury sampling period(s) in order to calculate the mass emissions rates for each test run and the daily mass emissions rates.
6. In terms of the National Institute of Standards and Technology (NIST) traceable spikes for EPA Method 30B, although EPA 30B is a short term sampling method, it can run up to 24 hours using the right type of trap. Can one (1) pair of EPA Method 30B traps be run for 24 hours (or time of operations during that 24 hr period) – are any spiked traps needed? If so, what spiking level?
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Appendix C
Response: We expect you to conduct at least three EPA Method 30B test runs with the traps spiked in accordance with the procedures in the method (e.g., section 8.2.6) during the 30-day test period. You should estimate the spike levels based on knowledge available at the time of testing and consistent with the procedures in the method. You may need to conduct additional spiked test runs once you begin to collect mercury analyses data in order to conform to the method’s confirmation requirements.
7. EPA Method 30B is a recommended method for mercury, swapping out tubes every 24 hours. Is it necessary to man the consoles for 24 hours monitoring meter volumes or is it acceptable to set the sampling systems for the appropriate sample rate and visit the site daily. We intend to connect meter temperatures to a data logger. The stack flow rate at the facility does not vary and is monitored by a flow CEMS. 30. Also, if EPA Method 30B can be used to collect 24-hour samples for mercury concentrations using an automated data logger, can the samples be collected from a single point within the exhaust stack without performing a stratification test?
Response: You may use an automatic data logger to collect the necessary sampling data as required in 8.3.3.3 of EPA Method 30B, making sure the sample flow rate is maintained throughout the 24 hrs (or shorter sampling period). The stack flowrate can be monitored by the flow CEMS as along as it meets the general flow requirements of this test request. For single point sampling, place the sampler at a point that is 1/3 of the diameter of a stack; or, for a positive pressure baghouse, in the middle of the compartment.
8. Regarding the PM samples, Table 1 specifies a minimum sample run time but does not address a minimum sample volume. Has one been established?
Response: For the purposes of this program, we believe that sampling for a minimum period of 3 hours and spanning an integral number of heat cycles is the more appropriate driver. We also believe that sampling under such conditions will produce data of a quality necessary for assessing EAF emissions control performance.
9. Facilities with very variable schedules may not be able to show an exact pattern of their variable schedule for the three months prior to receipt of the Section 114 test request.
Response: As long as a variable pattern is obvious from the documentation for the three months prior to receipt of the test request, the facility will not need to be operating all day during the 30-day period of mercury testing. It is not a requirement that there be an exactly matching pattern for the previous three months, just documentation that the operating schedule is variable and not continuous. As an example for the extreme case, we do not want to see a plant suddenly saying that they are operating only two days a month when they had been operating continuously (around the clock, seven days a week) prior to receipt of the test request.
10. Does a facility need to report tons of raw steel even when they do not monitor this parameter or it is inappropriate for the facility?
Response: The requirement to report the amount of “raw steel” produced during the test period can be replaced with tons of "liquid steel" or "cast steel" as appropriate for the facility. The facility should note in their response that these are the units that are monitored for steel production at their facility. Each facility must describe clearly in their response how and where the reported quantity of steel production was determined.
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Appendix C
11. PS 12B - Section 8.2.2 requires that the sampler record gas flow meter reading, stack temperatures and flow meter temperatures, temps of heated equipment and probes if heated. In this instance where the sampling occurs for one week, can we record initial volume and heated temperatures at the beginning of the week and end of week sampling ONLY.
Response: We expect that you would use adsorbent trap CEMS that meet PS12B would include automatic data loggers for recording the stack and sample volume data. We do intend that the system collect data in accordance with the frequencies specified in PS 12B (see section 8.2.2). See also response to FAQ #4 which discusses whether you need to adjust sampling rates to maintain proportional sampling every hour.
12. PS 12B - Section 8.2.3 requires moisture determination. EAF moisture is usually in the 1-2% range, much like ambient conditions. Can we utilize average of moisture data from previous stack tests as a default factor? If not, then we can pre-measure silica in the 12B sample train and measure moisture pickup after the end of each weekly sample period?
Response: Either of the two approaches that you suggest is fine.
13. PS 12B - With regards to access to sample train, is it possible to have the sample train meter box down near ground level and have a long tube from sample probe?
Response: Yes.
14. This question comes from a facility that operates on a reduced schedule. In earlier discussions, industry representatives noted that some facilities only melt on the weekends. In response, EPA agreed to allow such facilities to fulfill their data collection obligations by submitting data from at least eight (8) operating days. In previous correspondence with EPA, an "operating day" was defined as a day with at least one full shift of melting operations. However, in the Q & A document circulated last week, the instruction included an obligation to test for 192 hours. This number of hours would require a facility to operate at least one melting shift for 24 days per month. There are some facilities that operate from Friday pm through Monday am to take advantage of lower utility costs. We request that a facility that conducts testing that includes melting operations of at least one shift of melting on Friday, full days on Saturday and Sunday and another full shift of melting on Monday, should count that as four days of testing.
Response: We agree that a facility that operates at least one shift of melting on Friday, full days on Saturday and Sunday and another full shift of melting on Monday would count as four days of testing. A shift is typically an 8-hr period, and operating only one shift per day would still count as an operating day. If a facility only operates on weekends, they should sample on all weekends while they are operating for all four (4) weekends over the 28-30 day period. Although we state that 8 “daily” tests are sufficient for some facilities that only operate on weekends, we do not mean that other facilities can stop at eight daily tests even though they typically operate more that eight days during a 30-day period. Documentation of the past three months of operation is needed to be able to submit less than four full operating weeks of data.
In summary, if a facility is operating on a reduced schedule they must sample every day that they operate in the 28- to 30-day timeframe. The 8 day minimum only applies to these facilities that operate on a reduced schedule, where the total number of operating days in the 28- to 30-day period may be less than 8 days. In this case, the facility must keep sampling past the 30 day time period until they reach the 8 operating day minimum of data. Note that there is no exact number of hours required to fulfill the testing requirement.
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Appendix C
For the specific case above where normal operation is one shift on Friday, all day (3 shifts) Saturday and Sunday, and one shift Monday, here are two examples of how they could sample:
1. EPA Method 30B traps used to cover each operating day (1 to 3 shifts) over the 30-day period. That would give 16 test results or measurements for 16 operating days.2. PS-12B traps used to cover each 4-day weekend for four weekends. That would give us four “weekly” average samples over the 30-day period (where we accept their 4 operating days as an operating week).
15. For an EAF that operates 24 hours per day, 7 days per week, if during the 30-day EPA Method 30B sampling period one or more pair of tubes fails to meet the EPA Method 30B % RD, post-test leak rate or some other method performance criteria, is it acceptable to extend the sampling period to replace lost sample pairs?
Response: Yes, it is acceptable to extend the sampling period in order to replace samples invalided due to method performance criteria. Please document the reasons for the invalidated sample pairs in your emissions test report.
16. If test run times are slightly less than 240 minutes does this invalidate the test run?
Response: For the purposes of the EAF emissions testing, a test run with a sampling time or sample volume slightly less (e.g., < 20 percent difference) than the prescribed conditions does not invalidate the run. Please, report the discrepancy in the comment section of the ERT or the applicable spread sheet.
17. If a test run terminates during a melt cycle does this invalidate the test run?
Response: For a test run that would otherwise meet the prescribed sample time or volume before completion of a process cycle, you should continue the test run until the completion of the process cycle (e.g., melt cycle).
18. Number of EPA Method 30B spiked traps--Section 8.2.6 of EPA Method 30 B states that three sets of paired samples, where one of each pair which is spiked with a known level of Hg, are collected and analyzed per test. Will this be a sufficient amount of spiked traps for the 30-day test?
Response: Yes, as long as the process is relatively consistent over the 30-day test period, it would be sufficient to use three sets of spiked/unspiked sample tubes to assess sample bias. However, please be aware that often testers collect one or two extra spiked/unspiked pairs to ensure that they have three that meet the criteria.
19. EPA has specified 24-hr sample times for EPA Method 30B sampling. However, trap replacement takes 15 to 30 minutes. Does each test run need to be exactly 24 hours?
Response: It is not necessary that each test run be exactly 24 hours; the time (e.g., 30 minutes) allowed for removing and replacing traps is reasonable. Please clarify the test run start and end times clearly in the report so that we can adjust the data, if necessary and as appropriate.
20. The instructions for EPA Method 30B testing requires 30 consecutive days of testing. For days when the EAF is scheduled for no production is it necessary to conduct sampling?
Response: The ICR requires testing during the periods the EAF operates, so there is no need for emissions testing (i.e., EPA Method 30B performance) when the EAF is not operating.
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