DAQ-2024-008057

1

DAQC-466-24
Site ID 13031 (B5)

MEMORANDUM

TO: CEM FILE – PACIFICORP LAKE SIDE PLANT

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Paul Morris, Environmental Scientist

DATE: May 15, 2024

SUBJECT: Source: Units CTG11, CTG12, CTG21, and CTG22
Contact: Veronica Reyes – 801-796-1916
Tom Wiscomb – 801-220-2373
Location: 1825 North Pioneer Lane, Lindon, Utah County, UT
Test Contractor: Mostardi Platt
FRS ID#: UT0000004904900241
Permit/AO#: Title V operating permit #4900241002, dated July 16, 2021
Subject: Review of RA/PST Protocol dated May 1, 2024

On May 9, 2024, Utah Division of Air Quality (DAQ) received a protocol for a RA/PST (relative
accuracy/performance specification test) of the PacifiCorp Lake Side Plant Units CTG11, CTG12,
CTG21, and CTG22 in Lindon, Utah. Testing will be performed on June 18-26, 2024, to determine the
relative accuracy of the O2, NOX, and CO monitoring systems and conduct source compliance testing for
VOC and PM10 emissions.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK
3. RM 3A used to determine dry molecular weight of the gas stream: OK
4. RM 4 used to determine moisture content of the gas stream: OK
5. RM 7E used to determine NOX concentrations of emissions: OK
6. RM 10 used to determine CO concentrations of emissions: OK
7. RM 25A used to determine VOC concentrations of emissions: OK
8. RM 201A used to determine used to determine PM10 emissions: OK
9. RM 202 used to determine condensable particulate emissions: OK

6 , 3
2

DEVIATIONS: No deviations were noted.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send attached protocol review and test date confirmation notice.
YF,ffIE^HIVIOUNTAIN
May 1,2024
Mr. Bryce Bird, Director
State of Utah
Division of Air Quality
Department of Environmental Quality
194 North 1950 West
Salt Lake City, Utah 84114-4820
Attn: Rob Leishman
I,TAH DEPARTMENT OF
E}WIBONMENTAL OUALITY
MAY - I ?1]21
ilan .l
DIVISiON
c\<-\r t)$ecl
OF AIR QUALIT\'
Subject:
Dear Mr. Bird:
Notification of PacifiCorp's Lake Side Plant Units CTll, CTlz, CT21 and
CT22 Annual Source Emission Testing
PacifiCorp's Lake Side plant is scheduling the annual Relative Accuracy Test Audit (RATA),
Annual Quality Assurance of the Continuous Emission Monitoring Systons (CEMs) on Units
CTI l, CTl2, CT21 and CT22. The testing is scheduled to begin June 19, 2024. Enclosed is the
testing protocol that will be followed by our stack testing contractor, Montrose Air Quality
Services, LLC. Shown below is the testing schedule.
Date Unit Unit at
Load Activity
MWg
ITarget
Loadl
611812024 N/A 08:00-17:00 Mob/Set up N/A
6lt9/2024 CTG1 I 0700-1600 Gas RATA and
Particulate Matter
216-300
{270)
6120/2024 CTG12 0700-1600 Gas RATA and
Particulate Matter
216-300
{270\
612512024 CTG21 0700-1600 Gas RATA and
Particulate Maffer
243-347
{313 }
6/26t2024 CTG22 0700-1600 Gas RATA and
Particulate Matter
243-347
{313 }
Note: Test times are approximate and subject to change.
Should you have any questions regarding this testing schedule, please do not h€sitate to contact
VeronicaReyes at [phone] orTom Wisoomb at [phone].
Sincerely,,hh*
Dustian Weaver
Plant Manager, Lake Side Plant
Enclosures
cc: Youn Joo Kim - Region MII deoclosure
Veronica Reyes - Lake Side Plant deirclosrre
Tom Wiscomb -NTO 210
i
Source Test Plan lor 2O24
Testing
CTG1l, CTGL4 CTG21 and
PacifiCorp
Lake Side Power Plant
Lindon, Utah
Prepared For:
PacifiCorp - Lake Side Power Plant
1825 N. Pioneer Lane
Lindon, Utah
Compliance/RATA
CTG22
UTAH DEPAFTMENT OF
E}WIRONMENTAL OUAIJTY
MAY - 9 ')C?-4
#*s*^Bl'[ffi8$^,',
Prepared By:
Montrose Air Quality Services, LLC
99O West 43'd Avenue
Denver, Colorado 80211
i
For Submission To:
Utah Division of Air Quality
195 Nofth, 1950 West
Salt Lake City, Utah 84116
Document Number: GPO43AS-O3992O-PP-839
Proposed Test Dates: June 19-20 and 25-26,2fJ24
slAeffiEAlnoroaoartdtmorM }+?,NT\g[T
Review and Ceftification
I ceftify that, to the best of my knowledge, the information contained ln thls document ls
complete and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Date:412912024
Name:Title: eA/eC Anatyst
I have reviewed, technically and edltorially, details and other approprlate written materials
contained herein. I hereby certlfy that to the best of my knowledge the presented materlal
is authentic and accurate and conforms to the requlrements of the Montrose Quality
Management System and ASTM D7036-04.
Signature:
Name:
412912024
Account ManagerTim Wojtach
GP043AS-039920-PP-839 Page 2 of 50
I
Section
Table of Contents
Paoe
Introduction ............. ............ 5
1.1 Summary of Test Program .............. 5
L.2 Applicable Regulations and Emission Limlts ......7
1.3 Key Personnel........... ..... 9
Plant and Sampling Locatlon Descrlptlons............. .................10
2.1 Process Description, Operation, and Control Equipment ............. .....10
2.2 Flue Gas Sampling Locations.. .........10
2.3 Operating Conditions and Process Data...... .....11
2.5 Plant Safety ...................11
2.5.1 Safety Responsibilitles...... ....................11
2.5.2 Safety Program and Requlrements ........L2
Sampling and Analytical Procedures......... ...............14
3.1 Test Methods............ ....L4
3.1.1 EPA Method 1.............. ,........14
3.1.2 EPA Method 2.............. .........14
3.1.3 EPA Methods 3A,7E, and 10 ................,15
3.1.4 EPA Method 4............. .........16
3.1.5 EPA Method 201A........ ........L7
3.1.6 EPA Method 2O2.......... .......L7
3.L.7 .EPA Method 25A .......... ............t.. ....... 18tt
Quality Aszurance and Reporting........... ......:.........................20
4.L QA Audits.. ...................20
4.2 Quallty Control Procedures ..............20
4.2.1 Equipment Inspectlon and Maintenance ............. ...................20
4.2.2 Audit Samples. ......20
4.3 Data Analysis and Validatlon ...........20
4.4 Sample Identification and Custody ..................21
4.5 Quality Statement ........2L
4.6 Repofting ......2L
4.6.1 Example Report Format ........22
4.6.2 Example Presentation of Test Resu|ts.............. .......22
1.0
2.O
3.0
4.0
GP043A5-039920-PP-839 Page 3 of 50
t
List of Appendices
A Supporting Information ..........25
A.1 Units and Abbreviations............ .....26
A.2 Accreditation Information/Certlficatlons ..........34
*S" Field Work Safety P1an......... .................36
List of Tables
1-1 Summary of Test Program and Proposed Schedule ............. .................... 6
L-2 Repofting Units and Emission Limits .......7
1-3 Summary of Paft 60175 M Requirements...... ..,....... 8
1-4 Test Personnel and Responsibilities.... ..... 9
2-L Sampling Locations ...............10
4-L Example Emisslons Results..... ...............23
4-2 Example MTA Resu1ts.........,.. ..............24
List of Figures
3-1 EPA Methods2OLN2O2 Sampling Train........ ........15
3-2 US EPA Methods 3A,7E and 10 Sarnpling Train........ ..............16
3-3 US EPA Method 25A Sampling Train... ....19
4-l Typical Report Format .........22
GP043AS-039920-PP-839 Page 4 of 50
I
1.O Introduction
1.1 Summary of Test Program
PacifiCorp contracted Montrose Air Quality Servlces, LLC (Montrose) to perform a
compliance emissions test program on the sources listed in Table 1-1 at the Lake Side
Power Plant located in Lindon, Utah. In addition, a CEMS RATA will be conducted on the
sources listed in Table 1-1.
The compliance tests are conducted to determine compliance with the applicable emission
limits listed in Title V Operating Permit number 4900241002 issued by Utah Division of Air
Quality (UDAQ. The MTA is conducted to determine compliance with the applicable RA
requirements listed in 40 CFR Pafts 60 and 75.
The specific objectives are to:
o Measure emissions of PM/PMro/PMz.s dt the outlet of CTG11, CfGL2, CTG21
and CTG22
. Measure emissions of VOC at the outlet of CTG2I and C-fG22
. Determine the RA for the Oz, NOx and CO CEMS used to monitor emissions
from the outlet of CTG11, CTG12, CTG21 and CfG22
. Conduct the test program with a focus on safety
Montrose will provide the test personnel and the necessary equipment to measure emissions
as outlined in this test plan. Facility personnel wil! provide the process and production data
to be included in the final repoft. A summary of the test program and proposed schedule is
pre,sented in Table 1-1.
I
I
G P043AS-039920-PP-839 Page 5 of 50
)une t9,2024
Perform PM Testing
Perform PM Testing EPA 1, 2,3A,4,
20LN2O2
Perform PM, VOC Testing EPA 1, 2,3A,4,
25A,2OLA|2O2
Perform PM, VOC Testing
Perform Oz, NOx, CO RATA
EPA 1, 2,3A,4,
25A,2OLA{2O2
Table 1-1
Summary of Test Program and Proposed Schedule
To simplify this test plan, a list of Units and Abbreviations is included in Appendix A.
Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not
defined. Please refer to the list for specific details.
GP043AS-039920-PP-839 Page 6 of 50
L.2 Applicable Regulations and Emission Limits
The results from this test program are presented ln units consistent with those listed in the
applicable regulatlons or requirements. The reporting units and emission limits are
presented in Table 1-2.
Table 1-2
Repofting Unlts and Emission Limlts
1 In accordance with the UDAQ Permit, all PM/CPM will be reported as PMro or PMro/PMz.s, as
applicable.
cTGl1, CTG12 PMrol
lblhr
lh/MMBtrr
10.8
0.01
Permit 49OO24LOO2
cTG21, CfG22 PMro/PMz.sl lb/hr L4 Permit 49OO24LOO?
cTG11, CTG12 NOx
ppmvd@15o6 Oz
lb/hr
2.0
L4.9
Permit 49OO24LOO?
cTG11, CTG12 co
ppmvd@lSolo Oz
lb/hr
3.0
L4.t
Permit 49OO24LOO2
cTG21, ClG22 NOx
ppmvd@lSo/o Oz
lb/hr
2.0
18.1
Permit 490024L0O2
cfczl, CfG22 co
ppmvd@15olo Oz
lb/hr i
3.0
15.5
Permit 49OO24LOO2
cfczl, CfG22 voc
I
ppmvd@15Yo Oz 2.8 Permit 49OO24LOO2
The RA requirements are presented in Table 1-3.
G P043AS-039920-PP-839 Page 7 of 50
Oxygen (Oz)
40 CFR Paft75, Annual 3 7.5o/o of RM or *, O.7o/o Oz
Nitrogen Oxides (NOr)
ppmvd @ 157o Oz 40 CFR Part 50, PS-2 3 2O.Oo/o of RM or S 10.0olo of AS
40 CFR Part 50, PS-6 3 2O.Oo/o of RM or < 10.0olo of AS
40 CFR Part 75, Annual 3 7.5o/o of RM or + 0.015 lblMMBtu2
Carbon l.lonoxide (CO)
ppmvd @ 15olo Oz S 10o/o of RM or 3 59o of AS or S 5 ppmvd
co
3 2Oo/o of RM or 3 107o of AS
Table 1-3
Summary of Part 60175 RA Requirements
2 Alternate is for low emitter (average NOx RM emission rates are s O.2OO lblMMBtu)
GP043AS-039920-PP-839 Page 8 of 50
1.3 Key Personnel
A list of project participants is included below:
Facility Information
Source Location: PacifiCorp
Lake Side Power Plant
1825 N. Pioneer Lane
Lindon, Utah 84024
Project Contact: Tom Wiscomb
Role: Environmental Advisor
Telephone: 80l-220-2373
Veronica Reyes
Environmental Analyst
801-796-1916
Email: [e-mail] [e-mail]
Agency Information
Regulatory Agency:
Agency Contact:
Telephone:
Email:
Utah Division of Air Quality
Rob Leishman
801-536-4438
[e-mail]
Testing Company Information
Testing Firm: Montrose Air Quality Services, LLC
Contact: Craig Kormylo
Title: District Manager
Telephone: [phone]
Email : CKormyloGlmontrose-env.com
Laboratory Information
Laboratory: Montrose Air Quality Services, LLC
City, State: Denver, Colorado
Methods: 40 CFR Part 51, Appendix M, Methods 2OLAand2O2
Table 1-4 details the roles and responsibilities of the test team.
Table l-4
Test Personnel and Responsibilities
Post-test follow up
Facility interface, test crew coordination
Preparation, support PM
GP043AS-039920-PP-839 Page 9 of 50
2.O Plant'and Sampling Location Descriptions
2.L Process Description, Operation, and Control
Equipment
The Lake Side Power Plant comprises four combined-cycle combustion turbines designated
CTG11, CTG12, CTG21 and CTG22,
2.2 Flue Gas Sampling Locations
Actual stack measurements, number of traverse points, and location of traverse points will
be evaluated in the field as part of the test program. Table 2-1 presents the anticipated
stack measurements and traverse points for the sampling locations listed.
Table 2-1
Sampling Locations
Sample locations are verified in the field to conform to EPA Method 1.
Prior to commencing pollutant gas MTAs, gas stratification testing will be performed across
a grid of 12 points determined using EPA Method 1 in accordance with 40 CFR Part 60,
Appendix B, PS2 58.1.3.2 and 40 CFR Part 75, AppendixA, $6.5.6.1. Stratification testing
will be performed fortwo minutes pertraverse point in accordance with 40 CFR Part75,
Appendix A, 56.5.6.1(c). If diluent (Oz) and pollutant (NOx) concentrations are within 5o/o of
their mean concentrations, subsequent gas RATA testing will be performed at a single point
in the stack as allowed by 40 CFR Part 60, Appendix B, PS2 58.1.3.23 and 40 CFR Part 75,
Appendix A 56.5.6.3(b). If diluent and pollutant concentrations are within 10o/o of their
mean concentrations, MTA testing will be performed at three points located 0.4 meter, 1.0
3 PS2 prescribes a minimum of three sampling points, but states that "Other traverse points may be
selected, provided that they can be shown to the satisfaction of the Administrator to provide a
representative sample over the stack or duct cross section." Accordingly, if 40 CFR Part 75. Aooendix
A 66.5.6.3(b) allows MTA testing at a single traverse point, single-point testing can be assumed to
"provide a representative sample" for the purposes of 40 CFR Part 60. Aooendix B, Performance
Soecification 2.
-L20/*0.6 Isokinetic: 12 (3/ port)
Gaseous: See below
Isokinetic: 12 (3/port)
Gaseous: See below
*576/*2.7 Isokinetic: 12 (3/port)
Gaseous: See below
Isokinetic: 12 (3/port)
Gaseous: See belbw
GP043AS-039920-PP-839 Page 10 of 50
meter and 2.0 meters from the stack wall, as required by 40 CFR Part 60, Appendix B, PS2
58.1.3.2 and 40 CFR Paft 75, Appendix A, 96.5.6.1(a).
2.3 Operating Conditions and Process Data
Emission tests are performed when the units are operating normally.
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data collected includes the following parameters:
. Unit Load, MW
. Applicable CEMS data
2.5 Plant Safety
Montrose will comply with all safety requirements at the facility. The facility Client Sponsor,
or designated point of contact, is responsible for ensuring routine compliance with plant
entry, health, and safety requirements. The Client Sponsor has the authority to impose or
waive facility restrictions. The Montrose test team leader has the authority to negotiate any
deviations from the facility restrictions with the Client Sponsor. Any deviations must be
documented.
2.5.1 Safety Responsibilities
Planning
. Montrose must complete a field review with the Client Sponsor prior to the
project date. The purpose of the review is to develop a scope of work that
identifies the conditions, equipment, methods, and physical locations that will
be utilized alonp with any policies or procedures that will affect our worf
. We must reach an agreement on the proper use of client emergency seivices
and ensure that proper response personnel are available, as needed
. The potential for chemical exposure and actions to be taken in case of
exposure must be communicated to Montrose. This information must include
expected concentrations of the chemicals and the equipment used to identify
the substances.
o Montrose will provide a list of equipment being brought to the site, if required
by the client
Project Day
. Montrose personnel will arrive with the appropriate training and credentials
for the activities they will be performing and the equipment that they will
operate
. Our team will meet daily to review the Project Scope, Job Hazard Assessment,
and Work Permits. The Client Sponsor and Operations Team are invited to
participate.
GP043AS-039920-PP-839 Page 11 of 50
Montrose will provide equipment that can lnterface with the client utilities
previously identified in the planning phase and only work with equipment that
our client has made ready and prepared for connection
We will follow client direction regarding drlving safety, safe work permitting,
staging of equipment, and other crafts or work in the area
As per 40 CFR Part 60 Subpaft A, Section 60.8, the facility must provide the
following provisions at each sample location:
o Sampling pofts, which meet EPA minimum requirements for testing. The
caps should be removed or be hand-tight.
o Safe sampling platforms
o Safe access to the platforms and test ports, including any scaffolding or
man lifts
o Sufficient utilities to perform all necessary testing
Montrose will use the client communication system, as directed, in case of
plant or pCIect emergency
Any adverse conditions, unplanned shutdowns or other deviations to the
agreed scope and project plan must be reviewed with the Client Sponsor prior
to continuing work. This will include any safe work permit and hazard
assessment updates.
Completion
. Montrose personnel will repoft any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site
. Montroseiwill clean up our work area to the same condition as it ryas prior to
our arrivJl I
. We will ensure that all utilities, connectlon points or equipment have been
returned to the pre-project conditlon or as stated in the safe work permit. In
addition, we will walk out the job completlon with Operations and the Client
Sponsor if required by the facility.
2,5.2 Safety Program and Requirements
Montrose has a comprehensive health and safety program that satisfies State and Federal
OSHA requirements. The program includes an Illness and Injury Prevention Program, site-
specific safety meetings, and training in safety awareness and procedures. The basic
elements include:
. All regulatory required policies/procedures and training for OSHA, EPA and
FMCSA
. Medical monitoring, as necessary
. Use of Personal Protective Equipment (PPE) and chemical detection equipment
. Hazard communication
GP043AS-039920-PP-839 Page 12 of 50
Pre-test and daily toolbox meetings
Continued evaluation of work and potentlal hazards
Near-miss and incident reporting procedures as required by Montrose and the
Client
Montrose will provide standard PPE to employees. The PPE will include but is not llmited to;
hard hats, safety shoes, glasses with side shlelds or goggles, hearing protectlon, hand
protections, and fall protection. In addition, our trailers are equipped with four gas detectors
to ensure that workspace has no unexpected equipment leaks or other ambient hazards.
The detailed Site Safety Plan for this project is attached to this test plan in Appendix "S".
a
a
a
GP043AS-039920-PP-839 Page 13 of 50
3.O Sampling and Analytical Procedures
3.1 Test Methods
The test methods for this test program have been presented in Table 1-1. Additional
information regarding specific applications or modifications to standard procedures is
presented below.
3.1.1 EPA Method 1, Sample and Velocity Traverses for Stationary
Sources
EPA Method 1 is used to assure that representative samples or measurements of volumetric
flow rate are obtained by dlviding the cross-sectlon of the stack or duct into equal areas,
and then locating a traverse point within each of the equal areas. Acceptable sample
locations must be located at least two stack or duct equivalent diameters downstream from
a flow disturbance and ohe-half equivalent diameter upstream from a flow disturbance.
3.1.2 EPA Method 2, Determination of Gas Velocity and Volumetric
Flow Rate (Type S Pitot Tube)
EPA Method 2 is used to measure the gas velocity using an S-type pitot tube connected to a
pressure measurement device, and to measure the gas temperature using a calibrated
thermocouple connected to a thermocouple indicator. Typically, Type S (Stausscheibe) pitot
tubes conforming to the geometric specifications in the test method are used, along with an
inclined manometer. The measurements are made at traverse points specified by EPA
Method 1. The molecular weight of the gas stream is determined from independent
measurements of Oz, COz, and moisture. The stack gas volumetric flow rate is calculated
using the measured average velocity head, the area of the duct at the measurement plane,
the ineasured average temperature, the measured duct statlc pressure, the molecular
weight of the gas stream, and the measured moisture.
The typical sampling system is detailed in Figure 3-1, as part of the EPA Method 2OLN2O?
sampling train.
GP043AS-039920-PP-839 Page 14 of 50
Figure 3-1
EPA Methods 2OlAl2O2 Sampling Train
3.1.3 EPA Methods 3A,7Et and 10, Determination of Oxygen,' Carbon Dioxide, Nitrogen Oxides, and Carbon Monoxide
Concentrations in Emissions from Stationary Sources
(Instrumental Analyzer Procedure)
Concentrations of Oz, COz, NOx, and CO are measured simultaneously using EPA Methods
34, 7E, and 10, which are instrumental test methods. Conditioned gas is sent to a series of
analyzers to measure the gaseous emission concentrations. The performance requirements
of the method must be met to validate the data.
Pertinent information regarding the performance of the method is presented below:
o A dry extractlve sampling system is used to report emissions on a dry
basis
o A paramagnetic analyzer is used to measure Oz
I}IERMOCOUPLE lHERM@OI,PI.E TTIERMOCOUPLE THERM@OITLE
I
E|tpty @dNlrcb)
l@irHp
(modn d/mtF)
(ntffi/tbilp)Slllca Gel
(,no.ilfld /,bAp)i,ANOMEIER +. VACUUM
- L|NE
BY.PASS VALVE
THERMOCOUPLES
ft.*r) VACUUMGAUGE
MANOMETER +
GP043AS-039920-PP-839 Page 15 of 50
o A nondispersive infrared analyzer is used to measure COz
o A chemiluminescent analyzer ls used to measure NOx
o A gas filter correlation nondispersive infrared analyzer is used to measure
co
o The alternative NOx conv€rter efficiency test described in EPA Method 7E
Section 16.2 is used (bag procedure)
o Anticipated calibration span values are -O-2Lo/o Oz, *g-2ge1o COz, -Q-29
ppm NOx, and -0-10 ppm CO
The typical sampling system is detailed in Figure 3-2.
Figure 3-2
US EPA Methods 3Ar 7E and 1O Sampllng Train
3.1.4 EPA Method 4, Determination of Moisture Content in Stack
Gas
EPA Method 4 is a manual method used to measure the moisture content of gas streams.
Gas is sampled through a probe and impinger train. Moisture is removed using a series of
pre-weighed impingers containing methodology-specific liquids and silica gel immersed in an
ice water bath. The impingers are weighed after each run to determine the percent
moisture.
SIGNAL
MASS FLOW@^ITROLLER/
CAL|ERAT|O,| GAS I/IANIFOLD
-rl
+
l,
'lir t\.WEND?Y+B'
RdATEETWMEilmvtE3---->I'
I€AIED
SAMPLE
UNE CALIBR^TIot{
GAS LINE
GP043AS-039920-PP-839 Page 16 of 50
l
!
Pertinent information regarding the performance of the method is presented below:
o Moisture sampling is performed as paft of the pollutant (Method
?OLA/ 2O2) sa m ple tra ins
o Since it is theoretically impossible for measured moisture to be higher
than psychrometric moisture, the psychrometric moisture is also
calculated, and the lower moisture value is used in the calculations
o Minimum Required Sample Volume: 21 scf
The typical sampling system is detailed in Figure 3-1, as part of the EPA Method 2OLA|202
sampling train.
3.1.5 EPA Method 2O1A, Determination of PMro and PMz.s Emissions
from Stationary Sources (Constant Sampling Rate Procedure)
To measure PMro and PMz.s, extract a sample of gas at a predetermined constant flow rate
through an in-stack sizing device. The particle-sizing device separates particles with nominal
aerodynamic diameters of 10 micrometers and 2.5 micrometers. To minimize variations in
the isokinetic sampling conditions, you must establish well-defined limits. After a sample is
obtained, remove uncombined water from the particulate, then use gravimetric analysis to
determine the particulate mass for each size fraction. The original method, as promulgated
in 1990, has been changed by adding a PMz.s cyclone downstream of the PMro cyclone. Both
cyclones were developed and evaluated as part of a conventional five-stage cascade cyclone
train. The addition of a PMz.s cyclone between the PMro cyclone and the stack temperature
filter in the sampling train supplements the measurement of PMro with the measurement of
PMz.s.
Without the addition of the PMz.s cyclone, the filterable particulate portion of the sampling
train may be used to measure total and PltLo emissions. Likewise, with the exclusion of the
PMro cyclone, the filterable particulate portion of the sampling train may be used to measure
total and PMz.s emissions.
The typical sampling system is detailed in Figure 3-1.
3.1.6 EPA Method 2O2, Dry Impinger Method for Determining
Condensable Particulate Emissions from Stationary Sources
The CPM is collected in dry impingers after filterable PM has been collected on a filter
maintained as specified in Method 2014 of Appendix M to 40 CFR 51. The organic and
aqueous fractions of the impingers and an out-of-stack CPM filter are then taken to dryness
and weighed. The total of the impinger fractions and the CPM filter represents the CPM.
Compared to the version of Method 202 that was promulgated on December L7, 1991, this
method eliminates the use of water as the collection media in impingers and includes the
addition of a condenser followed by a water dropout impinger immediately after the final in-
stack or heated filter. This method also includes the addition of one modified Greenburg
Smith impinger (backup impinger) and a CPM filter following the water dropout impinger.
GP043AS-039920-PP-839 Page 17 of 50
CPM is collected in the water dropout impinger, the modified Greenburg Smith impinger,
and the CPM filter of the sampling train as described in this method. The impinger contents
are purged with nitrogen immediately after sample collection to remove dissolved SOz gases
from the impinger. The CPM filter is extracted with water and hexane. The impinger solution
is then extracted with hexane. The organic and aqueous fractions are dried and the residues
are weighed. The total of the aqueous and organic fractions represents the CPM.
The potential artifacts from SOz are reduced using a condenser and water dropout impinger
to separate CPM from reactive gases. No water is added to the impingers prior to the start
of sampling. To improve the collection efficiency of CPM, an additional filter (the "CPM
filter) is placed between the second and third impingers.
The typical sampling system is detailed in Figure 3-1.
3.1.7 EPA Method 25A, Determination of Total Gaseous Organic
Concentration Using a Flame Ionization Analyzer
EPA Method 25A is an instrumental test method used to measure the concentration of THC
in stack gas. A gas sample is extracted from the source through a heated sample line and
glass fiber filter to an FIA. Results are repofted as volume concentration equivalents of the
calibration gas or as carbon equivalents.
Pertinent information regarding the performance of the method is presented below:
. Method Options:
o The integrated Tedlar bag sampling procedure from EPA Method 18 will be
used to collect the VOC samples. Analysis will be performed on-site.
. Method Exceptions' i i
o For gaseous emissions sampling, MDL are calculated for each analyzer.
The ISDL is equal to the sensitivity of the instrumentation, which is 2o/o of
the span value.
The typical sampling system is detailed in Figure 3-3.
GP043AS-039920-PP-839 Page 18 of 50
Figure 3-4
BtAS'
ROTAIIETER
wtlti FLow
CONTROL
VALVE
--->I'
HEATED
SAMPLE
LINE
*f
#l
1.
STACK
OATA
OUTPUT DAS
MASS FLOW CONTROLLER /
CALIBMTION GAS ITTAN|FOLD
EPA Traln
Page 19 of 50GP043AS-039920-PP-839
4.O Quality Assurance and Reporting
4.L QA Audits
Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality
assurance audits are performed as part of the test program to ensure that the results are
calculated using the highest quality data available. This program ensures that the emissions
data we report are as accurate as possible. The procedures included in the cited reference
methods are followed during preparation, sampling, calibration, and analysis. Montrose is
responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose
will also perform the sampling, sample recovery, storage, and shipping. Approved contract
laboratories may perform some of the preparation and sample analyses, as needed.
4.2 Quality Control Procedures
Montrose calibrates and maintains equipment as required by the methods performed and
applicable regulatory guidance. Montrose follows internal procedures to prevent the use of
malfunctioning or inoperable equipment in test programs. All equipment is operated by
trained personnel. Any incidence of nonconforming work encountered during testing is
reported and addressed through the corrective action system.
4.2.1 Equipment tnspection and Maintenance
Each piece of field equipment that requires calibration is assigned a unique identification
number to allow tracking of its calibration history. All field equipment is visually inspected
prior to testing and includes pre-test calibration checks as required by the test method or
regulatory agency.
4.2.2 Audit Samy'les
When required by the test method and available, Montrose obtains EPA TNI SSAS audit
samples from an accredited provider for analysis along with the samples. Currently, the
SSAS program has been suspended pendlng the availability of a second accredited audit
sample provider. If the program is reinstated, the audit samples will be ordered. If required
as part of the test program, the audit samples are stored, shipped, and analyzed along with
the emissions samples collected during the test program. The audit sample results are
reported along with the emissions sample results.
4.3 Data Analysis and Validation
Montrose converts the raw field, laboratory, and process data to reporting units consistent
with the permit or subpart. Calculations are made using proprietary computer spreadsheets
or data acquisition systems. One run of each test method is also verified using a separate
example calculation. The example calculations are checked against the spreadsheet results
and are included in the final report. The "Standard Conditions" for this project are 29.92
inches of mercury and 68 oF.
GP043AS-039920-PP-839 Page 20 of 50
4.4 Sample Identification and Custody
The on-site Field Project Manager will assume or assign the role of sample and data
custodian until relinquishing custody. The sample custodian will follow proper custody
procedures before departing from the test site including:
o Assign the unique sample identification number to each sample
. Attach sample labels and integrity seals to all samples
. Complete COC form(s), ensuring that the sample identification numbers on
the samples match the sample identlfication numbers on the COC
. Pack and store samples ln accordance with the test method requirements in
appropriate transport containers for protection from breakage, contamination,
or loss
. Keep samples in a secure locked area if not in the direct presence of Montrose
staff
The sample custodian will follow proper custody procedures upon arriving at the Montrose
office including:
. Remove samples and COC documents from vehicles and check into
designated secure sample holding areas
. Store samples requiring additional measures such as refrigeration or dry ice
appropriately
4.5 Quality Statement
Montrose is qualified to conduct this test program and has established a qpality
management sySJem that led to accreditation with ASTM Standard D7O36|O4 (Standard
Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual
functional assessments for conformance with D7036-04 which are conducted by the
American Association for Laboratory Accreditation (A2l-A). All testing performed by Montrose
is supervised on site by at least one Qualified Individual (QI) as defined in D7036-04
Section 8.3.2. Data quality obJectives for estimating measurement uncertalnty within the
documented limits in the test methods are met by using approved test protocols for each
proiect as defined in D7036-04 Sections 7.2.1and 12.10. Additional quality assurance
information is included in the appendices. The content of this test plan is modeled after the
EPA Emission Measurement Center Guideline Document (GD-042).
4.6 Reporting
Montrose will prepare a final report to present the test data, calculations/equations,
descriptions, and results. Prior to release by Montrose, each repoft is reviewed and certified
by the project manager and their supervisor, or a peer. Source test reports will be
submitted to the facility or appropriate regulatory agency (upon customer approval) within
30 days of the completion of the field work. The report will include a series of appendices to
GP043AS-039920-PP-839 Page 21 of 50
present copies of the intermediate calculations and example calculations, raw field data,
laboratory analysis data, process data, and equipment calibration data.
4.6.1 Example Report Format
The report is divided into various sections describing the different aspects of the source
testing program. Figure 4-1 presents a typical Table of Contents for the final report.
Figure 4-l
Typical Repoft Format
4.6.2 Example Presentation of Test Results
Table 4-1 presents the typical tabular format that ls used to summarize the compliance
results in the final source test report. Separate tables will outline the results for each target
analyte and compare them to their respective emissions limits.
Cover Page
Certification of Report
of Contents
Section
1.0 Introduction
2.O Plant and Sampling Location Descriptions
3.0 Sampling and Analytical Procedures
.0 Test Discussion and Results
5.0 Internal QA/QC Activities
Field Data and Calculations
Facility CEMS and Process Data
ILabffatory Analysis Data
Quality Assurance/Quality Control
Regulatory Information
GP043AS-039920-PP-839 Page 22 of 50
Table 4-1
Example Emissions Results
Date xx xx xx xx
Time xx xx xx xx
ProcGss Dat
Unit Load, MW xx xx xx xx
Sampling & Flue Gas Parametens
sample duration, minutes xx xx xx xx
Oz, o/o volume dry xx xx xx xx
COz, o/o volume dry xx xx xx xx
flue gas temperature, oF xx xx xx xx
molsture content, o/o volume xx xx xx xx
volumetric flow rate, dscfm xx xx xx xx
Plfto/Pllz.r
grldscf xx xx xx xx
1blhr xx xx xx xx
lblMMBtu xx xx xx xx
GP043AS-039920-PP-839 Page 23 of 50
Table 4-2 presents the typical tabular format that is used to summarize the RATA results in
the final source test report. Separate tables will outline the results for each CEMS
parameter/set of units and compare them to their respective RA requirements.
Table 4-2
Example RATA Results
1 xx/xx/xxxx xxxx-xxxx xx xx xx x xx
2 xvxx/xxxx xxxx-xxxx xx xx xx x xx
3 xvxx/xxxx xxxx-xxxx xx xx xx x xx
4 xx/xx/xxxx xxxx-xxxx xx xx xx x xx
5 xx/xx/xxxx xxxx-xxxx xx xx xx X xx
5 xx/xx/xxxx xxxx-xxxx xx xx xx x xx
7 xx/xx/xxxx xxxx-xxxx xx xx xx x xx
8 xx/xx/xxxx xxxx-xxxx xx xx xx x xx
9 xx/xx/xxxx xxxx-xxxx xx xx xx x xx
10 xx/xx/xxxx xxxx-xxxx xx xx xx x xx
11 xx/xx/xxxx xxxx-xxxx xx xx xx x xx
L2 xx/xx/xxxx xxxx-xxxx xx xx xx x xx
Averages xx xx xx x xx
Applicable Standard (AS)xx units
Standard Deviation xx
Confidence Coefficient (CC)xx
Bias Adjustment Factor (BAF)xx
Unit Load xx unlts
RA based on mean RM value xx o/o
RA based on AS xx o/o
M based on difference plus CC xx units
M based on absolute difference xx units
GP043AS-039920-PP-839 Page 24 of 50
Appendix A
Su pporting Information
Appendix A.1
Units and Abbreviations
GP043AS-039920-PP-839 Page 26 of 50
64\ ll?NI+gp"H
UNITS AND ABBREVIATIONS
@Xo/o 02 corrected to X% oxygen (corrected for dilution air)
lCCl absolute value of the confidence coefficient
ldl absolute value of the mean differencesoC degrees CelsiusoF degrees FahrenheitoR degrees Rankine
" HzO inches of water column
13.6 specific gravity of mercury
AH pressure drop across orifice meter, inches H2O
AP velocity head of stack gas, inches H2O
0 total sampling time, minutespg microgram
Pa density of acetone, mg/ml
tu density of water, 0.9982 g/ml or 0.002201 lb/ml
acfrn actual cubic feet of gas per minute at stack conditionsAn cross-sectional area of nozle(
A" cross-sectional area of stack, square feet (ff)
Btu British thermal unitB*, proportion by volume of water vapor in gas stream
Ca particulate matter concentration in stack gas, grlacf
Cers average unadjusted gas concentration, ppmv
Cot, measured concentration of calibration gas, ppmv
cf or ft3 cubic feetcfrn cubic feet per minuteCc", average gas concentration adjusted for bias, ppmv
CM average of initial and final system bias check responses ftom upscale calibration gas, ppmv
cm or m3 cubic metersCua actual concentration of the upscale calibration gas, ppmvCo average of initial and final system bias check responses from low]evel calibration gas, ppmv
Cp pitot tube coefficient
Cs particulate matter concentration in stack gas, gr/dscf
CS calibration span, % or ppmv
Cs measured concentration of calibration gas, ppmv
Cy manufactured certified concentration of calibration gas, ppmv
D drift assessment, % of spandcf dry cubic feetdcm dry cubic metersDn diameter of nozzle, inches
Ds diameter of stack, inches
dscf dry standard cubic feetdscfrn dry standard cubic feet per minutedscm dry standard cubic metersFd F-factor, dscf/MMBtu of heat input
fpm feet per minute
Fs feet per secondft feet
t( square feet
gram
gallonsgr grains (7000 grains per pound)gr/dscf grains per dry standard cubic feet
hour
s
gal
hr
GP043AS-039920-PP-839 Page 27 of 50
60 l*qN,T+gp.H
UNITS AND ABBREVIATIONS
I percent of isokinetic sampling' in inch
k kilo or thousand (metric units, multiply by 103)K kelvin (temperature)
K3 conversion factor 0.0154 gr/mg
l& conversion factor 0.002668 ((in. HgXft"))/((mlX"R))
kg kilogram
l$ pitot tube constant (85.49 fUsec)
kwscft thousand wet standard cubic feet per hourI liters
lb/hr pounds per hourlb/MMBtu pounds per million Btulpm liters per minutem meter or milliM thousand (English units) or mega (million, metric units)
m3 cubic meters
ma mass of residue of acetone after evaporation, mg
Md molecular weight of stack gas; dry basis, lbflb-mole
meq milliequivalent
mg milligram
Mg megagram (106 grams)
min minute
ml or mL milliliter
mm millimeterMM million (English units)MMBtu/hr million Btu per hour
mn total amount of particulate matter collected, mg
mol mole
mol. wt. or MW molecularweight
Ms molecular weight of stack gas; wet basis, lb/lb-mole
MW molecular weight or megawattn number of data points
ng nanogram
nm nanometer
Pu", barometric pressure, inches Hg
pg picogram
Ps stack static pressure, inches H2O
Pm barometric pressure of dry gas meter, inches Hg
ppb parts per billionppbv parts per billion, by volumeppbvd parts per billion by volume, dry basisppm parts per millionppmv parts per million, by volumeppmvd parts per million by volume, dry basisppmvw parts per million by volume, wet basis
Ps absolute stack gas pressure, inches Hg
psi pounds per square inchpsia pounds per square inch absolute- psis pounds per square inch gauge
Psta standard absolute pressure, 29.92 inches Hg
Qa volumetric flow rate, actual conditions, acftn
' Q. volumetric flow rate, standard conditions, scfrn
Qsto volumetric flow rate, dry standard conditions, dscfnr
R ideal gas constant 21.85 ((in. Hg) (ft3)y("R) (tbmote))
G P043AS-039920-PP-839 Page 28 of 50
60 ltgN,I+P.p.H
UNITS AND ABBREVIATIONS
SBrn4 post-run system bias check, % ofspan
SBi pre-run system bias check, % ofspan
scf standard cubic feetscffr standard cubic feet per hourscfrn standard cubic feet per minutescm standard cubic metersscmh standard cubic meters per hoursec second
sf, sq. ft., or d square feet
std standardt metric ton (1000 kg)
T o.szs t-value
T" absolute average ambient temperature, oR (+459.67 for English)
T. absolute average dry gas meter temperature, oR (+459.67 for English)
ton ort ton = 2000 pounds
tph ortons/hr tons per hour
tpy or tons/yr tons per year
T. absolute average stack gas meter temperature, oR (+459.67 for English)
T.,o absolute temperature at standard conditions
V volt
% volume of acetone blank, ml
V"* volume of acetone used in wash, ml
V" total volume H2O collected in impingers and silica gel, grams
Vm volume of gas sampled through dry gas meter, ft'
Vaqstd) volume of gas measured by the dry gas meter, corrected to standard conditions, dscfVma stack gas volume sampled, acf
Vn volume collected at stack conditions through nozzle, acf
% average stack gas velocity, feet per second
Vwcl*a1 volume of water vapor condensed, corrected to standard conditions, scf
V*i(.ro) volume of water vapor in gas sampled from impingers, scf
Vwss(sa) volume of water vapor in gas sampled from silica gel, scf
W watt
Wa weight of residue in acetone wash, mg
Wi,p total weight of impingers, grams
Wse total weight of silica gel, grams
Y dry gas meter calibration factor, dimensionless
GP043AS-039920-PP-839 Page 29 of 50
60 ltgN,r+gp.H
ACRONYMS
AAS atomic absorption spectroscopyACDP air contaminant discharge permitACE analyzer calibration error, percent of spanAD absolute differenceADL above detection limitAETB Air Emissions Testing BodyAS applicable standard (emission limit)ASTM American Society For Testing And MaterialsBACT best achievable control technologyBDL below detection limitBHP brake horsepowerBIF boiler and industrial fumaceBLS black liquor solidsCC confidence coefficientCD calibration driftCE calibration enorCEM continuous emissions monitorCEMS continuous emissions monitoring systemCERMS continuous emissions rate monitoring systemCET calibration enor testCFR Code of Federal RegulationsCGA cylinder gas auditCHNOS elemental analysis for determination of C, H, N, O, and S content in fuelsCNCG concentrated non-condensable gasCO catalytic oxidizerCOC chain of custodyCOMS continuous opacig monitoring systemCPM condensible particulate mafterCPMS continuous parameter monitoring systemCT combustion turbineCTM conditional test methodCTO catalytic thermal oxidizerCVAAS cold vapor atomic absorption spectroscopyDe equivalent diameter
DE destruction efficiencyDioxins polychlorinated dibenzo-pdioxins (pcdd's)DLL detection levellimitedDNCG dilute non-condensable gasECD electron capture detectorEIT Engineer ln TrainingELCD electoconductivity detector (hall detector)EMPC estimated maximum possible concentrationEPA US Environmental Protection AgencyEPRI Electric Power Research lnstituteES emission standard (applicable limit)ESP electrostatic precipitatorEU emission unitFCCU fluid catalytic cracking unitFGD flue gas desulfurizationFl flame ionizationFIA flame ionization analyzerFID flame ionization detectorFPD flame photometric detectorFPM filterable particulate matterFTIR Fourier-transform infrared spectroscopyFTPB field train proof blankFTRB field train recovery blankFurans polychlorinated dibenzofurans (pcdfs)GC gas chromatography
GP043AS-039920-PP-839 Page 30 of 50
66 lfgN,I*gp.H
ACRONYMS
GC/MS gas chromatography/mass spectroscopyGFMS graphite furnace atomic absorption spectroscopyGFC gas filter correlationGHG greenhouse gas
HAP hazardous air pollutant
HC hydrocarbonsHHV higher heating valueHPLC high performance liquid chromatographyHRGC/HRMS high-resolution gas chromatography/high-resolution mass spectroscopyHRSG heatrecoverysteam generatorlC ion chromatographyICAP inductively-coupled argon plasmography
ICPCR ion chromatography with a post-column reactorICP-MS inductively coupled plasma-mass spectroscopylR infrared radiationlSO lnternational Standards OrganizationkW kilowatts
LFG landfill gas
LHV lower heating valueLPG liquified petroleum gas
MACT maximum achievable control technologyMDI methylene diphyenyldiisocyanateMDL method detection limitMNOC maximum normal operating conditionsMRL method reporting limitMS mass spectrometryNA not applicable or not availableNCASI National Council For Air And Steam lmprovementNCG non-condensable gases
ND not detectedNDIR non-dispersive infraredNESHAP National Emissions Standards For Hazardous Air pollutants
NG natural gas
NIOSH National lnstitute For Occupational Safety And HealthNIST National lnstitute Of Standards And TechnologyNMC non-methane cutterNMOC non-methane organic compoundsNMVOC non-methane volatile organic compoundsNPD nitrogen phosphorus detectorNSPS New Source Performance StandardsOSHA Occupational Safety And Health AdministrationPAH polycyclic aromatic hydrocarbonsPCB polychlorinated biphenyl compoundsPCWP plywood and composite wood productsPE Professional EngineerPFAS per- and polyfluoroalkylsubstances (PFAS)Pl photoionization
PID photoionization detectorPM particulate matter
PMro particulate matter less than 10 microns in aerodynamic diameter
PMz.s particulate matter less than 2.5 microns in aerodynamic diameter
POM
PS
PSD
PSEL
PST
PTE
PTM
polycyclic organic matter
performance specifi cation
particle size distribution
plant site emission limits
performance specifi cation test
permanent total enclosure
performance test method
GP043AS-039920-PP-839 Page 31 of 50
66 lfgN,r+gp.H
ACRONYMS
QA/QC quality assurance and quality control
Ql Qualified lndividual
QSTI Qualified Source Testing lndividualRA relative accuracyRAA relative accuracy auditRACT reasonably avaihbb control technologyRATA relative accuracy test auditRCTO rotary concentrator thermal oxidizerRICE stationary reciprocating intemal combustion engineRM reference methodRTO regenerative thermal oxidizer
SAM sulfuric acid mist
SCD sulfur chemiluminescent detectorSCR selective catalytic reduclion systemSD standard deviationSemi-VOST semivolatile organic compounds sample trainSRM standard reference materialTAP toxic air pollutant
TBD to be determinedTCA thermal conductivity analyzerTCD thermal conductivity detectorTGNENMOC total gaseous non+thane non-methane organic compoundsTGNMOC total gaseous non-methane organic compoundsTGOC total gaseous organic compoundsTHC total hydrocarbonsTIC tentatively identified compoundTO thermal oxidizerTO toxic organic (as in EPA Method TO-15)TPM total particulate matterTSP total suspended particulate mafterTTE temporary total enclosureULSD ultra-low sulfur dieselUV ultraviolet radiation rangeVE visible emissionsVOC volatile organic compoundsVOST volatile organic sample trainWC water column
\ A /TP waste water treatment plant
G P043AS-039920-PP-839 Page 32 of 50
64\ lt?.N,f*9.II
CHEMICAL NOMENCLATURE
Ag
As
Ba
Be
c
silver
arsenic
barium
beryllium
carbonCd cadmiumCdS cadmium sulfide
CH2O formaldehyde
CH3CHO acetaldehyde
CH3OH methanol
CHr methane
C2H4O ethylene oxide
CzHe ethane
CaH4O acrolein
CaH6O propionaldehyde
CgHr propane
C6H5OH phenol
Se
SO,
Sog
SO,
TCDD
TCDF
TGOC
THC
TI
TRS
Zn
selenium
sulfur dioxide
sulfur trioxide
sulfur oxides
tetrachlorodibenzodioxin
tetrachlorodibenzof uran
total gaseous organic concentration
total hydrocarbons
thallium
total reduced sulfur compounds
zinc
Clz
clo2
co
Co
Coz
Cr
Cu
Eto
chlorine
chlorine dioxide
carbon monoxide
cobalt
carbon dioxide
chromium
copper
ethylene oxide
Hzo
EIOH ethyl alcohol (ethanol)
H2 hydrogen
HzO, hydrogen peroxide
HzS hydrogen sulfide
H2SO4 sulfuric acid
HCI hydrogen chlorideHg mercuryIPA isopropyl alcoholMDI methylene diphyenyl diisocyanate
MeClz methylene chloride
MEK methyl ethyl ketoneMeOH methanolMn manganese
nitrogen
ammonia
nickel
nitric oxide
nitrogen dioxide
nitrogen oxides
oxygen
P phosphorusPb leadPCDD polychlorinated dibenzo-p{ioxinsPCDF polychlorinated dibenzofurans
antimony
N2
NHa
Ni
NO
Noz
NO,
o2
GP043AS-039920-PP-839 Page 33 of 50
Appendix A.2
Accred itation Information / Certifications
$;Ae
Accredited Air Emission Testing Body
A2LA hos occredited
MONTROSE AIR QUALITY SERVICES
ln recogniiion of the successful completion of the joini A2LA ond Siock Testing Accreditotion Council (STAC)
evoluotion process, this loborotory is occredited to perform lesting octivities in complionce with
ASTM D7036:2@4 - Slondord Proctice for Competence of Air Emission Testing Bodies.
Americon Associofio n f or Loborotory AccreditotionqF
Vice Presidenl, Accredilotion Services
For lhe Accreditolion Council
Certificote Number 3925.0 1
Volid lo Februory28,2026
This accreditatinn prograrn is mt includ.ed und.er the A2LA II,AC Mutual Recognitinn Arrangernent.
i
t
t
PresenleQ lhis 27th doy of Februory 2024.
Appendix rrs"
Field Work Safety Plan
GP043AS-039920-PP-839 Page 36 of 50
M$SNIHIH
SITE SAFETY PLAN BOOKLET
Gustomer:
Location:
Units:
Client Project Manager:
Revision Date: January 21, 2022
GP043AS-039920-PP-839 Page 37 of 50
c lYlqsl+gfa
Page 1 of2
Site Safety Plan and JHA Purpose and lnstructions
Purpose
Employee safety is the top priority of Montrose Environmental Group. Allemployees must be
trained to assess and mitigate hazards. The District Manager and Project Manager are
responsible to ensure all hazards have been properly identified and managed. All employees
have Stop Work Authority in all situations where an employee feels they or their co-worker
cannot perform a job safely or if there is a task for which they have not been adequately trained.
The Site Safety Plan (SSP) has been developed to help assist Montrose test crews with
identifying physical and health hazards and determining how the hazards witl be managed.
Additionally, the SSP will help each crew manage the safety of the employees by providing
emergency procedures and information. The booklet contains a several safety forms that may
be required in the field.
lnstructions
The SSP consists of the following:
1. A Pre-Mobilization Test Plan - To be completed in it's entirety by the client project Manager
prior to the test.
2. A Job Hazard Analysis is a standardized, two-page, fillable form that is used to evaluated the
tasUsite's particular hazards and controls. The form also includes a daily toolbox topic and
daily hazard review with sign off by the team. The client Project Manager is responsible to
complete the JHA form through section 8. Upon arrival at the test site, the team will review the
form for accuracy, making any corrections required and complete the remainder of the JHA.
Section 9 will require at least three tasks, hazards and controls be identified for the project.
Each team member has the option to discuss making changes or adding to the JHA and must
sign on the Job Hazard Analysis form in agreement and sign in Section 10. The JHA is to be
modified when conditions change. ;A toolbox meeting with a daily topic in addition to a review;of
the hazard analysis is required dailil for the duration of the test. An additional sheet of paper !
with the toolbox topic and signatures can be added to the SSP packet.
3. Hazard Control Matrix - contains useful information on both engineering and
administrative controls that a crew can use to reduce or eliminate the hazards they have
observed plus applicable PPE that may be required.
4. Emergency Action Plan - The Job Supervisor/ Client Project Manager (CPM) will complete
the Emergency Action Plan form and ensure that all employees are familiar with the facility
emergency and evacuation procedures, assemblyl rally points, alert systems, and signals prior
to work commencing. ln the event of an emergency situation/ evacuation, the Job Supervisor/
CPM will maintain a roster and be responsible for accounting for all employees. The Job
Supervisor/ CPM will ensure that this Emergency Action Plan Form is completed,
communicated to allemployees, signed, and posted.
5. Additional Forms, as applicable
a. MEWP Lift lnspection Form
b. Heat Stress Prevention Form Based on Heat lndex
c. Extended Hours Form
AQS-FRM-1.13R1
Page 38 of 50GP043AS-039920-PP-839
o $q,H,I+gln
Page2ot2
Site Safety Plan and JHA Purpose and lnstructions
The SSP is a living document. The Project Manager should continually update their SSPs as
new information and conditions change or if new hazards are presented.
Each completed SSP should be maintained with the Test Plan in the office for a period of 3
years. There will be an audit process developed for the Site Safety Plans.
AQS.FRM-1.13R1
Page 39 of 50G P043AS-039920-PP-839
Page 1 of 2
PRE-MOBI LIZATION TEST IN FORMATION
Source Tvpe: New Source: _ Revisit:_ Prj#/Date/Tech:
Coal Fired Electric Utility: _ Ethanol Plant: _ ChemicalMfg. of
CemenULime Kiln Plant: _ Specialty Mfg. of:Other:
Anticipated Effluent Composition - check all that apply and fill in expected concentration in ppmlo/o
lf other, explain:
Flammable: Toxic: Corrosive: Dust:
Engineering Controls to be lmplemented:
tr
co
tr
NOx
tr
SOz
tr
other
tr
voc
PROJECT NAME/LOCATION:
TEST DATE:
PROJECT #:
PROJECT MANAGER:
TEST SCOPE:
SITE CONTACT: Name:Contact Phone:
Additional Safety Equipment Required:
Personalgas monitors, T ;
Respiratory Protection: I i
Half Face_ Full Face_ HEPA Filters_ Supplied Air: _ (Safety Dept. Approvat)
Approximate Flue Gas Temperatures, (F)
below 210 210 to 450 450 to 950 above 950 other
lf other, explain:
Approximate Duct Pressure, (iwg):
lf other,
AQS-FRM.1.17
tr
below
explain: _
tr
other
Etrtr
-3 -3 to +3 +3 to +7 above +7
GP043AS-039920-PP-839 Page 40 of 50
eA sqN r \g[[
PRE.MOBI LIZATION TEST I NFORMATION
- Sampling Location: Stack Port _ Duct Port _
.
Opproximate Sampling Platform Height, (ft)
trtr
above 100 other
lf other, explain:
Access and Protection:
Elevators: _ Ladders: _ ME\ /P Lift: _ Scaffold: _ Equipment Hoist: _
Guardrails: _ Toe plate: _ Engineered Tie Off Points: _ Heat Shield: _
Other:
Describe how equipment will be mobilized to the sampling location:
Page 2 of 2
below 6 6 to 50 50
tr
to 100
tr
Additional !nformation :
Effluent Chemical Requlatory Limits
Gas Name Chemical
Formula
Cal OSHA PELI
(ppm)
CaI OSHA
STEL2
(onml
NIOSH REL
TWA3 (ppm)
Cal OSHA
Ceiling
(oom)
IDLH.
(ppm)
Carbon Monoxide co 25 200 35 200 1,200
Nitric Oxide
"
NO,25 ND5 251 ND 100
Sulfur Dioxide SOz 2 5 2 ND 100
Hydrogen Chloride HCI 0.3 2 ND 2 50
Hydrogen Sulfide HzS 10 15 10 (10 min.)c 50 100
)alifomia Occupational Safety and Health Administration (OSHA) Pemissible Exposurc Linit (PEL) based on an 8-hour shifr;
2: Cal OSHA Short-term Exposurc Limlt (STEL) based on a 1*minute peiod;
3: National lnstitute lor Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) Time-weighted Average (TWA) based
on an 8-hour shift;
4: lmmediately Dangercus to Life or Heafth (IDLH);
5: Not Defined (ND);
C: Ceiling Linit - Maximum allowable human exposurc limit for an aitbome orgaseous suDsfarrce, which is not to be exceeded, even
momentaily.
Prepared by:
Reviewed by:
Date:
Date:
AQS-FRM-1.17
GP043AS-039920-PP-839 Page 41 of 50
0lient ]ontact Name )ate
Facility SSP Writer PM
Olient Rep I
Job Preparation
I loU Site Walk Through Compteted
! Sate Work Permit Received ftom Client
I
E Site Specific Training Complete
lf the heat index is expected to be above 9'l', fill out the Heat Stress Prevention Form.
en MoN I RS)sr Job Hazard Analysis
PPE E Hard Hats E Safety Glasses ! Safety Toe Shoe/Boot ! Hearing Protection ESafeV Spotter
E Hi-Ms Vests E Hamess/Lanyard* E Goggtes E personal Monitor Type:
E Metatarsal Guards E Hot Gloves E Face Shield E Respirator Type:
ENomex/FRC El Oher PPE:
1of3
1.
a
2.
4.
5.
AQS-FRM.1.18
Page 42 of 50
lnformation/Emorgency Preparedness
lf non-emergency medical attention is needed, call: AXIOM #: 877-502-9466.
Plant Emergency # Certified First Aid Person:
EMS Location Evacuation Routes Rally Point
Severe Weather Shelter Location Eye Wash & Safety Shower Location
Operational: EIYes ENo
lnformation: (!ist type):
Stack Gas Temp. (oF) Stack Gas Press. ("H2O) Stack Gas Components:
Stack Gas lnhalation Potential? Eyes El ruo tf ves. see List of Hazard chemicats.
Risk
E] time Pressure
E u.t ot p.cedures
E Monotonous Activig
E Remote Work Location
E Exfeme temps, wind >30mph
El First day back after time off
EI , tz trrstritt
E] Personal illness/fatigue
E uuttipte job locations
E Wo*ing > 8 consecutive days
E Vague work guidance
E otrer:
Physical Hazards
Dust Hazards
Thermal Bum !
Electrical Hazards
lnadequate Lighting
Slip and Trip
Hand Protection
Secondary Permits
Working from Heights
See also Sect.7
Electrical
Lifting
Respiratory
See also Sect. I
Hazards for Consideration
Hazard Controls
! Dust Mask ! Goggles E Other:
EI Hot cloves E Heat Shields E Otrer eroteaive Ctofrin{l
E Connections Protected from Elements ! External GFCI trOtrei
E Xe Rating Requirement Q lnfinsically Safe Requirement
E lnstall Temporary Lighting fl Headlamps
! Housekeeping E Barricade Area E Oher:
E cut Resisent Gtoves El pincn pts. Et o"ntl otrer:
E Hot Work E Confined Space I Excavation
E fatting objec{s E Fall protection E Orop zone protection E natform load ratings
! ScattotO inspection E L"dder inspec{ion E Barricades for equipment
E Exposed wire/connector E Verify equipment groundinS E Arc Flash
f] Crane lift plan E] Rbging inspecUon E fag lines used E Hoists in place
! Unexpected exposure E Chemical E Dust (combustible) fl pel provided
E Ca.t idges or supplied air available E Gas detection
GP043AS-039920-PP-839
ea moN r r!!i)r Job Hazard Analysis
Additional Work Place Hazards
Procedures - check all that apply - *indicates additional form must be completed or collected from client
E Heat Stress Prevention* E Confined Space' E MEWp' E Roof Wo* E ScaffotO
E] CotA Weather Work I Hazardous Energy Controt' E Exposure Monitoring E Other:
From Heights
Fall Protection if] Fixed Guardrails/Toe boards E fatt Prevention PPE Waming Line System
Falling Objects Protecton iE Sanicading E t'tetUng I ttouse Keeping fiTehered Tools ECatcn BhnketorTarp
Fall Hazard Communication ! tr AdjacenVOverhead Workers I Confactor Contact E Client Contact
Other Considerations
Environmental Hazards - Weather Forecast
E HeaUColo Etigtrrring E Rain Q Snow E lce E Tomado E Wind Speed
Steps for Mitigation:
ectrical Safety Planning
PlantHookup: Ettov El22Ol24Ov E +aov E Generator !Hardwiredintopanet
Electrical Classified Area: fJYes I No Trailer Grounded: E yes E ruo Plug Type
Electrical Hook Up Responsibility:
ist of Hazardous Chemicals
E Acetone E NitricAcio
Other Chemicals:
I Hydrogen Peroxide E Compressed Gases
E Hexane E Sulfuric Acid E lsopropyl Alcohol ! Flammable Gas
EI Toluene E Hydrochloric Acid E UquiO Nitrogen ! Non-Flammable Gas
E xzS E Carbon Monoxide
Steps for Mitigation:
lildlife/Fauni in Area
E Poison trv E Poison Oak fllnsects:
I
!Wildlife:
Personnel w/ known allergies to bees stings or oher allergens? [ Yes Eruo
2of3
0.
7.
8.
9.Hazards and Steps
Task
a 1
2
3
I
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
AQS-FRM-1.18
Page 43 of 50G P043AS-039920-PP-839
JHA REVIEW: Crew Names & Signatures
Printed Name Siqnature Date Printed Name Sionature Date
ea M()N I R()st Job Hazard Analysis 3of3
JHA Meetinq & Review
to review:
o Change in conditions o Extended work hours o Daily Safety Topic
o New workers or contractors o Occunence of near misses or injuries
demonstrates that site conditions and hazards have not changed ftom the original SSP. lf changes did occur, make the
updates to this JHA and add notes as applicable in Section g.
Day Diecusslon Topic lnitials
2
3
4
5
6
7
8
I
t0
1',|
AQS-FRM-1.18
Page 44 of 50GP043AS-039920-PP-839
o MoN I RO)r
Poge 1 of 2
EMERGENCY ACTION PLAN FORM
' The Job Supervisor/ Glient Project Manager (CPM) will ensure that all employees are familiar with the facility emergency and eyacuation
. procedures, assembly/ rally points, alert systems, and signals prlor to work commencing. ln the event of an emergency satuation,
evacuation, the Job Supervisorl GPM will maintain a roster and be responsible for accounting for alt employees. The Job Supervisor/
CPM will ensure that this Emergency Action Plan Form is completed, communicated to al! employees, and posted.
.Uou mu3t tollow the cllent's emergency actlon plan flrst and notlfy your Supervlror lmmedlately.
.lf lncldent ls llte thrsatenlng, CALL 911 IMMEDIATELLY
.E non-emergency medical attention is needed, call AXIOM Medical number: 877-502-9465.
1 MEG Job Supervisor/ GPM's Name:
2 MEG Job Supervisor/ CPM's Telephone Number:
3 MEG Job Safety Supervisor (if applicabte):
4 MEG Job Safety Supervisor's Telephone Number:
5 Plant's Emergency Telephone Number:
6 Local Hospital/ Clinic Telephone Number:
7 Emergency Ops Radio Channel:
8 Plant's #1 Contact Person's Name:
9 Plant's #1 Contact Person's Telephone Number:
10 Plant's #2 Contact Person's Name:
11 Plant's #2 Contact Person's Telephone Number:
12 Designated Assembly Point Location:
13 Evacuation Routes:
14 Severe Weather Shelter Location:
15 Eye Wash and Safety Shower Location:
16 The First Aid Kit is Located:
17 The Fire Extinquisher is Located:
AQS-FRM-1.11
GP043AS-039920-PP-839 Page 45 of 50
a^ lYlg,s,I+gft
AQS-FRM.1.11
GP043AS-039920-PP-839
Poge 2 of 2
EMERGENCY EVACUANON Al{D ASSEMBLY MAP
1 Facility Name:
2 Facility Alarm (Circle):YES or NO
3
Alarm Tones:
IIICAUGAS:.
iUATE:
lD.
4 Designated Shelter(sl Description:
5 Designated Assembly Point(s) Description:
N*+,
s
Dtlwlhe evacuatbn and assemblv mao here
EMERGENCY ACTION PLAN FORM AND EVACUATION ASSEMBTY MAP REVIEW: Crew Names and Sirnatures
Printed Name:Sionature:Date: Printed Nome:Sionature: Date:
Page 46 of 50
a
MON I ROSE
Page 1 of '1
Daily MEWP Lift lnspection Form
All checks must be completed prior to each work shift, before operation of the MEWP lift. This checklist must be used
atthe beginning of each shift or following 6 to 8 hours of use.
MEWP Lift Model #:Seria! Number:
Make:Rented or Owned:
. Check "Yes' if an item is adequate, operational, and safe.o Check 'No' to indicate that a repair or other conective action is required prior to use.. Check'N/A'to indicate 'Not Applicable."
Items to be lnspecbd
1. All MEWP lift components are in working condition (i.e. no loose or missing parts, tom orloose hoses, etc.) - if something can be easily loosened by hand then it is not sufficient.
2. Hydraulic fluid level is sufficient, with the platform fully lowered
3. Hydraulic system pressure (see manufacturer specs) is acceptable.
lf the pressure is low, determine cause and repair in accordance with accepted procedures
as outlined in service manual.
4. Tires and wheel lug nuts (for tightness)
5. Hoses and cables (i.e. worn areas or chafing)
6. Platform rails and safety gate (no damage present)
7. Pivot pins secure
8. Welds are not cracked and structural members are not bent or broken
9. Warning and instructional labels are legible and secure, and load capacity is clearly marked.
'10. Manufacture/s lnstruction Manual is present inside the bucket
1 't. Base controls (switches and push buttons) can be properly operated
12. Platform conditions are safe (i.e. not sfipiery)
13. Fire extinguisher is present, mounted and fully charged, located inside the bucket
14. Headlights, safety strobe light and back-up alarm are functional
15. Workplace is free of hazards (overhead powerlines, obstructions, level surface, high winds,
etc.) *Do not operate if winds are 20 mph, unless otfielvise specified by manufacturcr
rccommendations.
Yes No N/A
Dtrtr
trtrn
n
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n
!
tr
tr
tr
tr
tr
!
D
tr
tr
tr
tr!
trD
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ntr
trtr
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!tr
trtr
i
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trtr
trtr
Operator Name & Signature Location Date
Ground Control Name & Signature Location Date
Harness lnspections:
Printed Name Signature Date
Printed Name Signature Date
Printed Name
GP043AS-039920-PP-839
Date
AQS-FRM-1.16
Page 47 of 50
Signature
64\ SqNI+R9I Page 1 of 1
Extended Hours Safety Audit
Project Number:Date:Time:
When a project is expected to extend past a 14-hour work day, this form must be completed to evaluate
the condition of the crew, and the safety of the work environment.
Permission to proceed into extended work hours must come from a District Manager (DM) or Regional Vice
President (RVP). Technical RVPs can authorize moving forward, if they are in the field or if they are
managing the project.
1. Hold test crew meetinq Test crew initiats:
The test leader should look for signs of the following in their crews:
o lnitability. Lack of motivationo Headacheso Giddiness
o Fatigue
r Depression
o Reduced alertness, lack of concentration and
memory
The test leader should assess the environmental and hazardous concems:
o Temperature and weather o Hoistingo Lighting o PPE (i.e. respirators, etc.)o Working from Heights o Pollutant concentration in ambient air (SOz,
HzS, ect.)
Notifv DM or RVP
The PM must contact either the DM or RVP to discuss the safety issues that may arise due to the
extended work period. lf the DM is the acting PM on the job site, they must contact the RVP.
During this time, they can come to an agreement on how to proceed. ltemsto discuss include:
. Reason for extended hourso Reason for delay
' Production limitationso lmpending Weather
Contact the client
The PM, DM or RVP must discuss with client any identified safety concerns, the client's needs and
mutually agree on how to proceed. Discussion should also include the appropriate rest period
needed before the next day's work shift can begin. The DM and/or a RVP must be informed on the
finaldecision.
FinalOutcome:
Approver:
2.
3.
OOlAS-SAFETY-FM.3
Page 48 of 50GP043AS-039920-PP-839
a
af, llq,H,I+g[[Page 1 of 1
Heat Stress Prevention Form
This form is to be used when the Expected Heat lndex is above 91" F, and is to be kept with project
documentation.
Proiect Manaqer (PM):Exoected Hioh Temo:
Date(sl:Expected Heat lndex:
Review the signs of Heat Exhaustion and Heat Stroke
lf Heat lndex is above 91' F:r Provide cold water and/or sports drinks to all field staff (avoid caffeinated drinks and energy
drinks which can increase core temperature).
o Bring no less than one gallon of water per employeer lf employee(s) are dehydrated, on blood pressure medication or not acclimated to heat,
ensure they are aware of the heightened risk for heat illnesso Provide coolhead bandsfuestVetc.o Have ice available to employees. lmplement work shift rotations and breaks, particularly for employees working in direct
sunlight.o Provide as much shade at the jobsite as possible, including tarps, tents or other acceptable
temporary structures.o PM should interview each field staff periodically to evaluate for signs of heat illness
lf Heat lndex is above 103' F:o Employees must stop for drinks and breaks every hour (about 4 cups/hour). Employees are not permitted to work alone for more than one hour at a time without a
break offering shade and drinks. Employees should wear cool bands and vests if working outside more than one hour at a
timer PM should interview each field staff every 2 hours to evaluate for signs of heat illness
1.
2.
3.
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OOlAS-SAFETY.FM.5
Page 49 of 50GP043AS-039920-PP-839
t
4
?
This is the Last Page of This Document
If you have any questions, please contact one of the following
individuals by email or phone.
Name:
Title:
Region:
Email:
Phone:
Name:
Title:
Region:
Email:
Phone:
Craig Kormylo
District ManagerlVP Technical
Great Plains Region
CKormyl o@ montrose-env. co m
303-810 -2849
I
Timothy Wojtach
Account Manager
Gtuat Plalns Region, Denver Office
TWojtach @ montrose-env. com
303-670-0530 ext. 14304
I,TA}I DEPAFruENT OF
E}WIRONMENIAL OtruJNT
MAY - I 2024
DIVISION OF AIR QUAUTV
I
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+
J
GP043AS-039920-PP-839 Page 50 of 50