HomeMy WebLinkAboutDAQ-2024-011127-(1,a
Yr*gfls_g"nr Hunter Plant
1000 South Highway l0
P.O. Box 569
Castle Dale, UT 84513
August 14,2024
Mr. Bryce Bird, Director
Utah Department of Environmental Quality
Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake ciry, uT 84114-4820
Attention: Rob Leishman
RE: Notification of the Annual Quality Assurance Relative Accuracy Test Audit
Continuous Emission Monitoring Systems at PacifiCorp's Hunter Plant Units 1, 2,
(Title V Permit #f 500101004)
Dear Mr. Bryce Bird:
Please be informed, the PacifiCorp Hunter plant is scheduling the annual quality assurance Relative
Accuracy Test Audit (RATA) on the Continuous Emission Monitoring Systems (CEMS) on Units l, 2,
and 3. The testing is scheduled to begin October 15,2024.
Enclosed for your review is the testing protocol that will be followed by the stack testing team Montrose.
Shown below is the testing schedule.
Hunter Units 1-3 Testing Schedule - October 2024
on the
and 3.
UTAH DEPAR]I/FNI OF
DIVISION OF AIR OI'AI ITY
Unit Date Time Test
Load
Range
(MWsl
Load
Target
(MWs)
Load
Separation
(MWe)
1 70/Lsl2024
07:00-09:00 Mid Load Flow RATA 277-334 300 98
O9:30-09:30 Drop to Low Load 700-277 195 N/A
09:30-18:00 Stratification Test,
Low Load Gas and Flow RATA too-217 195 98
2 LOl76l2024
07:00-09:00 Mid Load Flow RATA 215-331 298 97
09:30-09:30 Drop to Low Load 100-215 794 N/A
O9:30-18:00 Stratification Test,
Low Load Gas and Flow RATA 100-215 194 97
3 LOltT/2024
07:00-09:00 Mid Load Flow RATA 206-332 299 105
09:30-09:30 Drop to Low Load 80-205 185 N/A
O9:30-18:00 Stratification Test,
Low Load Gas and Flow RATA 80-206 185 105
NOTE: Times are approximate and subject to change.
REVIEWEDInitials: RL Date: 10/23/2024Status: ReceivedFile ID#: 10237-B5
Should you have any questions regarding this testing schedule, please contact Jay Howard at (435) 748-
6519 or Tom Wiscomb at (801) 220-2373.
Managing Director, Hunter Power Plant
Altemate Designated Representative
Enclosures
Cc: Youn Joo Kim - EPA Region VIII ilenclosure
Tom Wiscomb - 210 NTO ilo enclosure
Craig Kormylo - Montrose w/o enclosure
Source Test Plan
2024 Relative Accuracy Test Audits
Units L, 2 and 3
PacifiCorp
Hunter Power Plant
Castle Dale, Utah
Prepared For:
PacifiCorp
L4O7 W North Temple, Suite 210
Salt Lake City, Utah 84116
Prepared By:
Montrose Air Quality Services, LLC
990 West 43rd Avenue
Denver, CO 80211
For Submission To:
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84116
Document Number; GPO43AS-O36892-PP-9O5
Proposed Test Dates: October 15 - 17, 2fJ24
Submittal Date: September 15, 2lJ24
AUG 22 2024
ESttoBd.lcF.Sol
srAeffi
--irfiH DEPARTMENT oF
E r.rvi io u n,t e urnu oturutty
DIVISION OF AIR OUALITY
M SgNT+PIT
Review and Ceftification
I certify that, to the best of my knowledge, the information contained in this document is
complete and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature:
Name:
BlL2/2024
QA/QC Analyst
I have reviewed, technically and editorially, details and other appropriate written materials
contained herein. I hereby certify that to the best of my knowledge the presented material
is authentic and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7O36-04.
,). r';l ,, i .t /sionature= /' '/' '+-L ' / Date:- .-. 1 i -L'7./.-- L,.-\/Blt2/2024
Name:Tim Wojtach Title:Account Manager
Matthew Parks
GP043AS-036892-PP-905
Table of Contents
Paoe
1.0 Introduction........ .,.................. 5
1.1 Summary of Test Program ............... 5
1.2 Applicable Regulations and Emission Limits ........6
1.3 Key Personnel.......... .............. 8
2.0 Plant and Sampling Location Descriptions...... ................9
2.t Process Description, Operation, and Control Equipment............ ........9
2.2 CEMS Description ........9
2.3 Flue Gas Sampling Locations .......10
2.4 Operating Conditions and Process Data..... .......10
2.5 PlantSafety......... .......10
2.5.1 Safety Responsibilities .......11
2.5.2 Safety Program and Requirements ............t2
3.0 Sampling and Analytical Procedures ............13
3.1 Test Methods....... ..........13
3.1.1 EPA Method 2G ......... .......,.13
3.1.2 EPA Method 2H...... .............,..15
3.1.3 EPA Method 4........ ....'..16
3.1.4 EPA Methods 3A, 6C, 7E, and 10 ...... ............t7
3.2 Process Test Methods............ .........19
4.0 Quality Assurance and Repofting......,. .........19
4.L QA Audits .........19
4.2 Quality Control Procedures .........19
4.2.1 Equipment Inspection and Maintenance .........19
4.2.2 Audit Samples .............19
4.3 Data Analysis and Validation ...............20
4.4 Sample Identification and Custody ..................20
4.5 Quality Statement .............20
4.6 Reporting ...............,.20
4.6.1 Example Report Format ................21
4.6.2 Example Presentation of Test Resu1ts.............. .......22
List of Appendices
Appendix A Supporting Information .., ......23
Appendix A.1 Units and Abbreviations ................24
Appendix A.2 Accreditation Information/Certifications...,.. ..............32
Appendix "S" Field Work Safety Plan .............34
GP043AS-036892-PP-905 Page 3 of 48
List of Tables
Table 1-1 Summary of Test Program and Proposed Schedule... .......... 5
Table 1-2 Reporting Units and Applicable Standards........... ............6
Table 1-3 Summary of Part60/75 RA Requirements....,.. .............,.. 7
Table 1-4 Test Personnel and Responsibilities.... .............8
Table 2-1 CEMS Information ................9
Table 2-2 Sampling Locations........... ..........10
Table 4-1 Example NOx (lblmmBtu) RATA Results - Unit Name .........22
List of Figures
Figure 3-1 EPA Method 2 Sampling Train........ .............,.14
Figure 3-2 EPA Method 4 Sampling Train ...... ........16
Figure 3-3 EPA Methods 3A, 6C, 7E, and 10 Sampling Train ....,.18
Figure 4-1 Typical Report Format .........2L
GP043AS-036892-PP-905 Page 4 of 48
1.O Introduction
1.1 Summary of Test Program
PacifiCorp contracted Montrose Air Quality Services, LLC (Montrose) to perform a RATA
program at Hunter Power Plant located near Castle Dale, Utah. Testing will be conducted in
accordance with the testing requirements of Utah Department of Environmental Quality
(UDEQ) Operating Permit 1500101004 and (as applicable) 40 CFR Parts 60 and 75.
The specific objectives are to:
. Peform annual Relative Accuracy Test Audits (RATAs) on the Continuous
Emission Monitoring Systems (CEMS) installed on Units 1, 2 and 3
. 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 will provide the process and production data
to be included in the final report. A summary of the test program and proposed schedule is
presented in Table 1-1.
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.
>5 min
21 minto/Ls/2024 Volumetric Flow Rate RATA
COz, SOz, NO,, CO RATAs
EPA 1, 2G/H,3,4
EPA 34,6C,7E, 10
Volumetric Flow Rate MTA
COz, SOz, NOr, CO MTAs
EPA 1, 2G/H,3,4
EPA 3A, 6C,7E, LO70/1612024
Volumetric Flow Rate RATA
COz, SOz, NO*, CO MTAs
EPA 1, zG/H,3, 4
EPA 3A, 6C,7E, tO
>5 min
21 minto/t7/2024
GP043AS-036892-PP-905 Page 5 of 48
1.2 Applicable Regulations and Emission Limits
The results from this test program are presented in units consistent with those listed in the
applicable regulations or requirements. The reporting units and emission limits are
presented in Table 1-2.
Table 1-2
Reporting Units and Applicable Standards
Volumetric Flow Rate
SOz, NO^, CO ppmvw, lblmmBtu, lblhr
GP043AS-036892-PP-905 Page 6 of 48
The RA requirements are presented in Table 1-3.
Table 1-3
Summary of Part 60175 RA Requirements
(1) Alternate is for low flow (RM measurements are < 10.0 fps)
(2) Alternate is for low emitter (average SOz or NOx RM concentrations are < 250 ppm, or average NOx RM emission
rates are s 0.200 lblMMBtu)
Paft 6O
Sulfur Dioxide (SOz)
lblhr PS.6 < 2O.Oo/o of RM or < 10.0olo of AS
Nitrogen Oxides (NO, as NOz)
lblhr PS.6 < 20.Oo/o of RM or < 10.0olo of AS
Carbon Dlonoxide (CO)
ppmvw PS.4A < 10o/o of RM or < 5o/o of AS or ldl + CC < 5 ppmvd CO
lblhr PS-6 < 20.Oo/o of RM or < 10.0olo of AS
lblmmBtu PS-6 < 2O.Oo/o of RM or < 10.0olo of AS
Part 75
Carbon Dioxide (COz)
o/o volume wet App. B Sect. 2.3.1.2 Annual: < 7.5o/o of RM or t 0,7o/o COz
o/o volume wet App. A Sect.3.3.3 Semiannual: s 10.0% of RM or * 1.0olo COz
Volumetric Flow
wscfh App. B Sect. 2.3.1.2 Annual: < 7.5o/o of RM or + 1.5 fps(l)
wscfh App. A Sect.3.3.4 Semiannual: < 10.0olo of RM or + 2.0 fps{1)
Sulfur Dioxide (SOz)
ppmvw App. B Sect. 2.3.1.2 Annual: < 7,5o/o of RM or + 12 ppm SOz{2)
ppmvw App. A Sect. 3.3.1 Semiannual: < 10.0olo of RM or + 15.0 ppm SO2(2)
Nitrogen Oxides (NOx as NOz)
lblMMBtu App. B Sect. 2.3.1.2 Annual: < 7.5o/o of RM or + 0.015 lblMMBtu(2)
lblMMBtu App. A Sect.3.3.2 Semiannual: < 10.0olo of RM or + 0,020 lblMMBtu(z)
GP043AS-036892-PP-905 PageT of 48
1.3 Key Personnel
A list of project participants is included below:
Facility Information
Source Location: PacifiCorp Hunter Power Plant
State Highway 10
Castle Dale, Utah 84513
Tom Wiscomb
Sr. Environmental Advisor
PacifiCorp
(801) 220-2373
Tom.Wiscom b@ pacificorp. com
Utah Depaftment of Air Quality
Rob Leishman
(801) s36-4438
RLeishman@utah.gov
Testing Company Information
Jay Howard
Sr. Environmental Analyst
PacifiCorp
(43s) 748-6sL9
Jay. Howard@ PacifiCorp.com
Project Contact:
Role:
Company:
Telephone:
Email:
Agency Information
Regulatory Agency:
Agency Contact:
Telephone:
Email:
Testing Firm:
Contact:
Title:
Telephone:
Email:
Montrose Air Quality Seruices, LLC
Craig Kormylo
District Manager
(303) 49s-3936
CKormylo@ montrose-env. com
Table 1-4 details the roles and responsibilities of the test team.
Table 1-4
Test Personnel and Responsibilities
Facility interface, test crew coordination
Preparation, suppoft PM
GP043AS-036892-PP-905 Page 8 of 48
2.O Plant and Sampling Location Descriptions
2.1 Process Description, Operation, and Control
Equipment
The Hunter Plant comprises three pulverized coal-fired boilers. Hunter Unit #1 is a dry-
bottom, tangentially-fired boiler rated at 480 gross megawatts (GMW) and equipped with a
fabric-filter baghouse for particulate matter (PM) control and a flue gas desulfurization
(FGD) scrubber for sulfur dioxide (SOz) control. Hunter Unit #2 is a dry-bottom,
tangentially-fired boiler rated at 480 GMW and equipped with low-NO* burners and overfire
air for nitrogen oxides (NO,) control, a fabric filter baghouse for PM control and an FGD
scrubber for SOz control. Hunter Unit #3 is a dry-bottom, wall-fired boiler rated at 495
GMW and equipped with low-NO, burners and overfire air for NOx control, a fabric filter
baghouse for PM control and an FGD scrubber for SO2 control. In accordance with
Conditions ILB.2 and II.B.3 of Utah Department of Environmental Quality (UDEQ) Operating
Permit 1500101003, the Unit #1, Unit #2 and Unit #3 exhaust stacks are equipped with
Continuous Emission Monitoring Systems (CEMS) to quantify carbon dioxide (COz), SOz and
NO" emissions. Units 1, 2 and 3 are equipped with CEMS to quantify carbon monoxide (CO)
emissions for comparison to UDEQ permit limits.
2.2 CEMS Description
The CEMS analyzers are presented in Table 2-1.
Table 2-1
CEMS Information
Unit 1
Flow Teledyne Monitor Labs Model 150 105
COz Thermo Fisher Model 41OiQ 113
SOz Thermo Fisher Model 43iQ 111
NOx Thermo Fisher Model 42iQ tt2
CO Thermo Fisher Model 48iQ
Unit 2
Flow Teledyne Monitor Labs Model 150 205
COz Thermo Fisher Model 41OiQ 2L3
SOz Thermo Fisher Model 43iQ 211
NOr Thermo Fisher Model 42iQ 2t2
CO Thermo Fisher Model 48iQ
Unit 3
Flow Teledyne Monitor Labs Model 150 30s
COz Thermo Fisher Model 410iQ 313
SOz Thermo Fisher Model 43iQ 311
NO,Thermo Fisher Model 42iQ 3L2
CO Thermo Fisher Model 48iQ
cP043AS-036892-PP-905 Page 9 of 48
2.3 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 2-2 presents the anticipated
stack measurements and traverse points for the sampling locations listed.
Table 2-2
Sampling Locations
Sample location(s) are verified in the field to conform to EPA Method 1. Acceptable cyclonic
flow conditions are confirmed priorto testing using EPA Method 1, Section 11.4.
2.4 Operating Conditions and Process Data
Emission tests are performed while the source/units and air pollution control devices are
operating at the conditions required by the applicable regulation. The units are tested when
operating at greater than 50o/o of rated capacity, as required by 40 CFR Part 60 or within
the load levels required by a0 CFR Paft 75.
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)
. Relevant CEMS Parameters
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.
Flow: 16 (a/port)
Gaseous: 12 (3/port)3228 / 7O.O 2388 / 7.4
Flow: 16 (4/port)
Gaseous: 12 (3/port)
3228 / t0.s 26t6 / 8.s Flow: 16 (4/port)
Gaseous: f2 (3/port)
GP043AS-036892-PP-905 Page 10 of 48
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 along with any policies or procedures that will affect our work
. We must reach an agreement on the proper use of client emergency services
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.
. 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 peforming 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.
. Montrose will provide equipment that can interface 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 driving safety, safe work permitting,
staging of equipment, and other crafts or work in the area
. As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the
following provisions at each sample location:
o Sampling pods, 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 pr{ect emergency
. Any adverse conditions, unplanned shutdowns or other deviations to the
agreed scope and project plan must be reviewed with the Client Sponsor prior
GP043AS-036892-PP-905 Page 11 of48
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
o Montrose will clean up our work area to the same condition as it was prior to
our arrival
. We will ensure that all utilities, connection points or equipment have been
returned to the pre-project condition or as stated in the safe work permit. In
addition, we will walk out the job completion 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
. Pre-test and daily toolbox meetings
. Continued evaluation of work and potential 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 limited to;
hard hats, safety shoes, glasses with side shields or goggles, hearing protection, 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".
GP043AS-036892-PP-905 Page 12 of 48
3.O Sampling and Analytical Procedures
3.1 Test Methods
The test methods forthis 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 2G, Determination of Stack Gas Velocity and
Volumetric Flow Rate with Two-Dimensional Probes
EPA Method 2G is used to measure the velocity pressure and the yaw angle of the flow
velocity vector in a stack or duct using a 2-D probe. Alternatively, these measurements are
made by operating one of the three-dimensional (3-D) probes described in Method 2F,in
yaw determination-only mode. From these measurements and a determination of the stack
gas density, the average near-axial velocity of the stack gas is calculated. The near-axial
velocity accounts for the yaw, but not the pitch, component of flow. The average gas
volumetric flow rate in the stack or duct is then determined from the average near-axial
velocity.
Peftinent information regarding the performance of the method is presented below:
. Target and/or Minimum Required Sample Duration: >5 minutes
The typical sampling system is detailed in Figure 3-1.
GP043AS-036892-PP-905 Page 13 of 48
Figure 3-1
EPA Method 2 Sampling Train
THERMOCOUPLE
I
I
+
GP043AS-036892-PP-905 Page 14 of 48
3.1.2 EPA Method 2H, Determination of Stack Gas Velocity Taking
into Account Velocity Decay Near the Stack Wall
EPA Method 2H is used to measure the stack gas velocity for calculating the volumetric flow
rate while taking wall effects into account. To do this, a wall effects adjustment factor is
determined. The factor is used to adjust the average stack gas velocity obtained using EPA
Method 2,2F, or 2G while taking velocity decay nearthe stack or duct wall into account.
The method contains two possible procedures: a calculational approach which derives an
adjustment factor from velocity measurements and a default procedure which assigns a
generic adjustment factor based on the construction of the stack or duct.
The calculational procedure derives a wall effects adjustment factor from velocity
measurements taken using Method 2,2F, or 2G at 16 (or more) traverse points specified in
EPA Method 1 and a total of eight (or more) wall effects traverse points specified under this
method. The calculational procedure based on velocity measurements is not applicable for
horizontal circular ducts where build-up of particulate matter or other material in the bottom
of the duct is present.
A default wall effects adjustment factor of 0.9900 for brick and mortar stacks and 0.9950
for all other types of stacks and ducts may be used without taking wall effects
measurements in a stack or duct.
When the calculational procedure is conducted as paft of a relative accuracy test audit
(RATA) or other multiple-run test procedure, the wall effects adjustment factor derived from
a single traverse (i.e., single RATA run) may be applied to all runs of the same RATA
without repeating the wall effects measurements. Alternatively, wall effects adjustment
factors may be derived for several traverses and an average wall effects adjustment factor
can be applied to all runs of the same RATA.
GP043AS-036892-PP-905 Page 15 of 48
3.1.3 EPA Method 4
Determination of Moisture Content in Stack Gas
EPA Method 4 is a manual, non-isokinetic method used to measure the moisture content of
gas streams. Gas is sampled at a constant sampling rate 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.
The typical sampling system is detailed in Figure 3-2.
Figure 3-2
EPA Method 4 Sampling Train
SATT'PLE LINE
VACUUM
LINE
ADAPTOR
(sladddlp)
BY.PASS VALVE(,iNdt6.) VACUUM GAUGETHERMOCCXJPLESII
VALVE(w*dlull)
Iv|ANOITJETER
-o
GP043AS-036892-PP-905 Page 16 of 48
3.L.4 EPA Methods 3A, 6C,7E, and 1O
Determination of Oxygen, Carbon Dioxide, Sulfur Dioxide, Nitrogen Oxides,
and Carbon Monoxide Concentrations in Emissions from Stationary Sources
(Instru mental Analyzer Procedures)
Concentrations of Oz, COz, SOz, NOx, and CO are measured simultaneously using EPA
Methods 3A, 6C, 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:
. Method Options:
o Sampling is performed using a dilution probe
o NO and NOz are measured separately and summed to report NO*
emissions
o The alternative NOx converter efficiency test described in EPA Method 7E
Section 16.2 may be used (bag procedure)
o Gas stratification testing is performed across a grid of 12 points
determined using EPA Method 1 in accordance with 40 CFR Part 60,
Appendix B. PS2 68.1.3.2 and 40 CFR Part 75. Appendix A. 66.5.6.1.
Stratification testing is performed for two minutes per traverse point in
accordance with 40 CFR Part 75. Aooendix A.56.5.6.1(c). If diluent and
pollutant concentrations are within 5o/o of their mean concentrations,
subsequent gas MTA testing is performed at a single point in the stack as
allowed by 40 CFR Part 60. Appendix B. PS2 68.1.3.2 and 40 CFR Part 75.
Aooendix A 56.5.6.3(b). If diluent and pollutant concentrations are within
l0o/o of their mean concentrations, RATA testing is performed at three
points located 0.4 meter, 1.0 meter and 2.0 meters from the stack wall,
as required by 40 CFR Part 60. Appendix B. PS2 68.1.3.2 and 40 CFR Part
75. Aooendix A. 66.5.6.1(a).
The typical sampling system is detailed in Figure 3-3.
GP043AS-036892-PP-90s Page 17 of 48
Figure 3-3
EPA Methods 3A, 6C,7E, and 1O Sampling Train
SIG}IAL
MASS FLOA/CONTROI.ER/
CAUEIATIOT GASMANIFOLO
GP043AS-036892-PP-905 Page 18 of 48
3.2 Process Test Methods
The applicable regulations do not require process samples to be collected during this test
program.
4.O Quality Assurance and Reporting
4.1 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 peform 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.L Equipment fnspection 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 Samples
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 pending 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.
GP0434S-036892-PP-90s Page 19 of 48
4.3 Data Analysis and Validation
Montrose converts the raw field, laboratory, and process data to repofting 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 are29.92
inches of mercury and 68 oF.
4.4 Sample Identification and Custody
No samples are required to be recovered for this test program.
4.5 Quality Statement
Montrose is qualified to conduct this test program and has established a quality
management system that led to accreditation with ASTM Standard D7036-04 (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 (A2lA). 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 unceftainty within the
documented limits in the test methods are met by using approved test protocols for each
project 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 report is reviewed and ceftified
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
25 days of the completion of the field work. The report will include a series of appendices to
present copies of the intermediate calculations and example calculations, raw field data,
laboratory analysis data, process data, and equipment calibration data.
4.6.I 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 4-1
Typical Report Format Cover Page
Ceftification of Repoft
ble of Contents
Section
1.0 Introduction
2.0 Plant and Sampling Location Descriptions
3.0 Sampling and Analytical Procedures
4.0 Test Discussion and Results
5.0 Internal QA/QC Activities
Appendices
A Field Data and Calculations
B Facility CEMS and Process Data
C Laboratory Analysis Data
D Quality Assurance/Quality Control
E Regulatory Information
GP043AS-036892-PP-905 Page 21 of 48
4.6.2 Example Presentation of Test Results
Table 4-1 presents the typical tabular format that is used to summarize the 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 4-1
Example NOx (lblmmBtu) RATA Results - Unit Name
I xx/xx/xxxx XXXX.XXXX xx xx XX X xx
2 XX/XX/XXXX xxxx-xxxx XX XX XX X XX
3 xxlxx/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
6 XX/XX/XXXX XXXX-XXXX XX XX XX x XX
7 xx/xx/xxxx xxxx-xxxx xx xx xx x XX
8 XXlXX/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
t2 XXlXX/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 units
RA based on mean RM value xx o/o
M based on AS xx o/o
RA based on difference plus CC XX units
M based on absolute difference xx units
GP043AS-036892-PP-90s Page 22 of 48
Appendix A
Su pporting Information
Appendix A.1
Units and Abbreviations
GP043AS-036892-PP-905 Page 24 of 48
6/i\lt?.N,r+gLI
UNITS AND ABBREVIATIONS
@Xo 02 corrected to X% orygen (corrected for dilution air)
lCCl absolute value of the confidence coefficient
ldl absolute value of the mean differencesoC degrees CelsiusoF degrees FahrenheitoR degrees Rankine
" HrO 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
e total sampling time, minutespg microgram
P" density of acetone, mg/ml
p* density of water, 0.9982 g/ml or 0.002201 lb/ml
acfm actual cubic feet of gas per minute at stack conditions
An cross-sectional area ol nozzle, f(
A" cross-sectional area of stack, square feet (ft')
Btu British thermal unit
B* proportion by volume of water vapor in gas stream
Ca particulate matter concentration in stack gas, gr/acf
Cr,s average unadjusted gas concentration, ppmv
Coi, measured concentration of calibration gas, ppmv
cf or ft3 cubic feetcfm cubic feet per minute
Cc"" average gas concentration adjusted for bias, ppmv
CM average of initial and final system bias check responses from upscale calibration gas, ppmv
cm or mt cubic meters
Crur actual concentration of the upscale calibration gas, ppmv
Co average of initial and final system bias check responses from low-level calibration gas, ppmv
Ce pitot tube coefficient
C. particulate matter concentration in stack gas, gr/dscf
CS calibration sPan, % or PPmvCs measured concentration of calibration gas, ppmv
Cv manufactured certified concentration of calibration gas, ppmv
D drift assessment, % of spandcf dry cubic feet
dcm dry cubic meters
Dn diameter of nozzle, inches
Ds diameter of stack, inches
dscf dry standard cubic feetdscfm dry standard cubic feet per minutedscm dry standard cubic meters
Fd F-factor, dscf/MMBtu of heat input
fpm feet per minutefps feet per secondft feet
ft2 square feetg gramgal gallonsgr grains (7000 grains per pound)
gr/dscf grains per dry standard cubic feet
GP043AS-036892-PP-905 Page 25 of 48
6 l!"{?.N,I+gLE
UNITS AND ABBREVIATIONS
I percent of isokinetic samplingin inch
k kilo or thousand (metric units, multiply by t03)K kelvin (temperature)
K3 conversion factor 0.0154 gr/mg
tq conversion factor 0.002668 ((in. Hg)(ftr))/((mlx'R))
kg kilogramKp pitot tube constant (85.49 fUsec)
kwscfh thousand wet standard cubic feet per hourI literslb/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 metersma mass of residue of acetone after evaporation, mg
Md molecular weight of stack gas; dry basis, lb/lb-mole
meq milliequivalentmg milligram
Mg megagram (106 grams)min minute
ml or mL millilitermm millimeterMM million (English units)MMBtu/hr million Btu per hour
mn total amount of particulate matter collected, mg
mol mole
mol. wt. or MW molecular weight
Ms molecular weight of stack gas; wet basis, lb/lb-mole
MW molecular weight or megawattn number of data points
ng nanogramnm nanometer
Po, barometric pressure, inches Hg
pS picogram
Ps stack static pressure, inches H2O
P. 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
P" absolute stack gas pressure, inches Hg
psi pounds per square inchpsia pounds per square inch absolutepsig pounds per square inch gauge
P"ta standard absolute pressure, 29.92 inches Hg
Q" volumetric flow rate, actual conditions, acfm
Q. volumetric flow rate, standard conditions, scfm
Q"to volumetric flow rate, dry standard conditions, dscfm
R ideal gas constant 21.85 ((in. Hg) (ft3)y(('R) (lbmole))
GP043AS-036892-PP-905 Page 26 of 48
UNITS AND ABBREVIATIONS
SBRn,r post-run system bias check, % of span
SBr pre-run system bias check, % of span
scf standard cubic feetscftr standard cubic feet per hour
scfm standard cubic feet per minutescm standard cubic metersscmh standard cubic meters per hour
sec second
sf, sq. ft., or ft2 square feet
std standardt metric ton (1000 kg)
T o.grs 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 or t ton = 2000 pounds
tph or tons/hr tons per hour
tpy or tons/yr tons per year
Ts absolute average stack gas meter temperature, oR (+459.67 for English)
Tsto absolute temperature at standard conditions
6ri\ l+?,N,T+gp.E-
v"
Vt"
Vm(sto)
Vro
v"
Vrc(sto)
V*i("ta)
Vreg(std)
W
wa
Wr.p
Wss
volt
volume of acetone blank, ml
volume of acetone used in wash, ml
total volume H2O collected in impingers and silica gel, grams
volume of gas sampled through dry gas meter, ftr
volume of gas measured by the dry gas meter, corrected to standard conditions, dscf
stack gas volume sampled, acf
volume collected at stack conditions through nozzle, acf
average stack gas velocity, feet per second
volume of water vapor condensed, conected to standard conditions, scf
volume of water vapor in gas sampled from impingers, scf
volume of water vapor in gas sampled from silica gel, scf
watt
weight of residue in acetone wash, mg
total weight of impingers, grams
total weight of silica gel, grams
dry gas meter calibration factor, dimensionless
GP043AS-036892-PP-905 Page 27 of 48
6 lYl?N,T+gp.E
AAS
ACDP
ACE
AD
ADL
AETB
AS
ASTM
BACT
BDL
BHP
BIF
BLS
CC
CD
CE
CEM
CEMS
CERMS
CET
CFR
CGA
CHNOS
CNCGco
coc
COMS
CPM
CPMS
CT
CTM
CTO
CVAAS
D"
DE
Dioxins
DLL
DNCG
ECD
EIT
ELCD
EMPC
EPA
EPRI
ES
ESP
EU
FCCU
FGD
FI
FIA
FID
FPD
FPM
FTIR
FTPB
FTRB
Furans
GC
ACRONYMS
atomic absorption spectroscopy
air contaminant discharge permit
analyzer calibration error, percent of span
absolute difference
above detection limit
Air Emissions Testing Body
applicable standard (emission limit)
American Society For Testing And Materials
best achievable control technology
below detection limit
brake horsepower
boiler and industrial furnace
black liquor solids
confidence coefficient
calibration drift
calibration error
continuous emissions monitor
continuous emissions monitoring system
continuous emissions rate monitoring system
calibration error test
Code of Federal Regulations
cylinder gas audit
elemental analysis for determination of C, H, N, O, and S content in fuels
concentrated non-condensable gas
catalytic oxidizer
chain of custody
conlinuous opacity monitoring system
condensible particulate matter
continuous parameter monitoring system
combustion turbine
conditional test method
catalytic thermal oxidizer
cold vapor atomic absorption spectroscopy
equivalent diameter
destruction efficiency
polychlorinated dibenzo-p-dioxins (pcdd's)
detection level limited
dilute non-condensable gas
electron capture detector
Engineer ln Training
electoconductivity detector (hall detector)
estimated maximum possible concentration
US Environmental Protection Agency
Electric Power Research lnstitute
emission standard (applicable limit)
electrostatic precipitator
emission unit
fluid catalytic cracking unit
fl ue gas desulfurization
flame ionization
fl ame ionization analyzer
flame ionization detector
flame photometric detector
fi lterable particulate matter
Fourier{ransform infrared spectroscopy
field train proof blank
field train recovery blank
polychlorinated dibenzofurans (pcdfs)
gas chromatography
GP043AS-036892-PP-905 Page 28 of 48
6ri\ M?,N,T+ST.E
ACRONYMS
GC/MS gas chromatography/mass spectroscopyGFAAS graphite furnace atomic absorption spectroscopyGFC gas filter correlationGHG greenhouse gas
HAP hazardous air pollutant
HC hydrocarbonsHHV higher heating value
HPLC high performance liquid chromatographyHRGC/HRMS high-resolution gas chromatography/high-resolution mass spectroscopyHRSG heat recovery steam generator
lC ion chromatographyICAP inductively-coupled argon plasmography
ICPCR ion chromatography with a post-column reactorICP-MS inductively coupled plasma-mass spectroscopylR infrared radiationISO lnternational Standards OrganizationkW kilowattsLFG landfill gas
LHV lower heating valueLPG liquified petroleum gas
MACT maximum achievable control technologyMDI methylene diphyenyl diisocyanateMDL 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 PollutantsNG natural gasNIOSH 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 products
PE Professional EngineerPFAS per- and polyfluoroalkyl substances (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 polycyclic organic matterPS performance specificationPSD particle size distributionPSEL plant site emission limitsPST performance specification testPTE permanent total enclosurePTM performance test method
GP043AS-036892-PP-905 Page 29 of 48
64\ |,}?.N,I+P"LE
QfuQC
QI
QSTI
RA
RAA
RACT
RATA
RCTO
RICE
RM
RTO
SAM
SCD
SCR
SD
Semi-VOST
SRM
TAP
TBD
TCA
TCD
TGNENMOC
TGNMOC
TGOC
THC
Trc
TO
TO
TPM
TSP
TTE
ULSD
UV
VE
voc
VOST
WC
WWTP
ACRONYMS
quality assurance and quality control
Qualified lndividual
Qualified Source Testing lndividual
relative accuracy
relative accuracy audit
reasonably available control technology
relative accuracy test audit
rotary concentrator thermal oxidizer
stationary reciprocating internal combustion engine
reference method
regenerative thermal oxidizer
sulfuric acid mist
sulfur chemiluminescent detector
selective catalytic reduction system
standard deviation
semivolatile organic compounds sample train
standard reference material
toxic air pollutant
to be determined
thermal conductivity analyzer
thermal conductivity detector
total gaseous non-ethane non-methane organic compounds
total gaseous non-methane organic compounds
total gaseous organic compounds
total hydrocarbons
tentatively identified compound
thermal oxidizer
toxic organic (as in EPA Method TO-15)
total particulate matter
total suspended particulate matter
temporary total enclosure
ultra-low sulfur diesel
ultraviolet radiation range
visible emissions
volatile organic compounds
volatile organic sample train
water column
waste water treatment plant
Page 30 of 48
64\ l,l?N,T+gp.E
silver
arsenic
barium
beryllium
C carbonCd cadmiumCdS cadmium sulfide
CH2O formaldehyde
CH3CHO acetaldehyde
CH3OH methanol
CHr methane
C2H4O ethylene oxide
C3H4O acrolein
CaH6O propionaldehyde
CsHe propane
C6H50H phenol
CHEMICAL NOMENCLATURE
Ag
As
Ba
Be
Se
Soz
Sos
SO,
TCDD
TCDF
TGOC
THC
TI
TRS
Zn
selenium
sulfur dioxide
sulfur trioxide
sulfur oxides
tetrachlorodibenzodioxin
tetrach lorod ibenzofuran
total gaseous organic concentration
total hydrocarbons
thallium
total reduced sulfur compounds
zinc
CzHe
CI,
ClO2 chlorine dioxide
CO carbon monoxideCo cobalt
CO, carbon dioxide
Cr chromiumCu copperEtO ethylene oxideEIOH ethyl alcohol (ethanol)
H2 hydrogen
HzO water
HrOz hydrogen peroxide
HrS hydrogen sulfide
H2SO4 sulfuric acid
HCI hydrogen chlorideHg mercuryIPA isopropyl alcoholMDI methylene diphyenyl diisocyanate
MeCl2 methylene chloride
MEK methyl ethyl ketoneMeOH methanolMn manganese
N2 nitrogen
NH. ammonia
Ni nickelNO nitric oxide
NOz nitrogen dioxide
NO, nitrogen oxides
02 orygen
P phosphorusPb leadPCDD polychlorinated dibenzo-p-dioxinsPCDF polychlorinated dibenzofurans
Sb antimony
Page 31 of 48
Appendix A.2
Accreditation Informatio n / Certifications
Page 32 of 48
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Appendix rrs"
Field Work Safety Plan
Page 34 of 48
M M?.,N,T+g[F'
SITE SAFETY PLAN BOOKLET
Project:
Customer:
Location:
Units:
CIient Project Manager:
Revision Date: January 21,2022
GP043AS-036892-PP-905
l1v r Ntt)N I kt),r I
Site Safety Plan and JHA Purpose and lnstructions
Purpose
Page 1 of 2
Employee safety is the top priority of Montrose Environmental Group. All employees 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 will 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 entire$ 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 daily 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, assembly/ 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 all employees, 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 36 of 48GP043AS-036892-PP-905
c^ lYlqf ItgPI Page2of 2
Site Safety Plan and JHA Purpose and Instructions
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 37 of 48GP043AS-036892-PP-905
riv vVtUN l Rt )51
PRE-MOBILIZATION TEST INFORMATION
Source Tvpe: New Source: _ Revisit:_ Prj#/Date/Tech:
Coal Fired Electric Utility: _ Ethanol Plant: _ Chemical Mfg. of
CemenUlime Kiln Plant: _ Specialty Mfg. of:
Anticipated Effluent Composition - check all that apply and fill in expected concentration in ppm/%
tr
other
lf other, explain:
Flammable: Toxic: Corrosive: Dust:
Engineering Controls to be lmplemented:
Page 1 of2
tr
co
tr
VOC
tr
SOz
tr
NOx
PROJ ECT NAM E/LOCATION :
TEST DATE:
PROJECT #:
PROJECT MANAGER:
TEST SCOPE:
SITE CONTACT: Name:Contact Phone:
Additional Safety Equipment Required:
Personal gas monitors: _
Respiratory Protection :
Half Face_ Full Face_ HEPA Filters_ Supplied Air:
-
(Safety Dept. Approval)
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, explain:
AQS.FRM.1.17
trtrtrtr
-3 -3 to +3 +3 to +7 above +7 other
GP043AS-036892-PP-90s Page 38 of 48
O" \ M\)N I kt ).ll
PRE.MOBILIZATION TEST INFORMATION
Sampling Location: Stack Port _ Duct Port
-Approximate Sampling Platform Height, (ft)
Page 2 of 2
tr
below 6
lf other, explain:
nntrtr
6 to 50 50 to 100 above 100 other
Access and Protection:
Elevators: _ Ladders:
-
MEWP Lift:
-
Scaffold:
-
Equipment Hoist:
-
Describe how equipment will be mobilized to the sampling location:
Other:
Additional lnformation :
Effluent Chemica! Requlatorv Limits
Gas Name Chemical
Formula
Cal OSHA PELI
(ppm)
Cal OSHA
STEL2
(oom)
NIOSH REL
TWA3 (ppm)
Cal OSHA
Ceiling(ooml
IDLH4
(ppm)
Carbon Monoxide CO 25 200 35 200 1,200
Nitric Oxide NO,25 ND5 25 ND 100
Sulfur Dioxide SOz 2 5 2 ND 100
Hvdroqen 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) Permissible Exposure Limit (PEL) based on an B-hour shift;
2: Cal OSHA Shoftlenn Exposure Limit (STEL) based on a 1s-minute period:
3: National lnstitute for Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) Time-weighted Average (TWA) based
on an 8-hour shift;
4: lmmediately Dangerous to Life or Health (IDLH);
5: Not Defined (ND);
C: Ceiling Limit - Maximum allowable human exposure limit for an airbome or gaseous subsrance, which is not to be exceeded, even
momentarily.
Prepared by:
Reviewed by:
Date:
Date:
AQS-FRM-1.17
GP043AS-036892-PP-905 Page 39 of 48
Slient 3ontact Name )ate
=acility SSP Writer )M
3lient Rep I
plete
out the Heat Stress Prevention Form.
Job Prepara
[ .too site
I sate w
tion
rWalk Through Completed E Site Specific Training Com
crk Permit Received from Client
lf the heat index is expected to be above 91 ", fil
1of3
1.
/aY . r\1 (rr\ I lr\)\t Job Hazard Analysis
Enor Rl*
E Tlme Pressure f] Remoie Work Location E > 12 hrshlft [ worting > 8 consecutive days
E Lack of procsdures E Extreme temps, wind >30mph E Personal illnessffatigue E Vague work guidance
E Monotonous Activity El first aay back after time off El uuttipte joo locations El other:
Hazards
Dust Hazards
Thermal Bum
Electrical Hazards
lnadequate Lighting
Slip and Trip
Hand Protection
Secondary Permits
Working ftom Heights
Soo sl.o Soct,7
Electrical
Lifring
Respiratory
See also Sect. I
Hazards for Consideration
Hazard Controls
E] Dust Mask E Goggles E Other:
E Hot Gloves E] Heat Shields E o&rer Protective Clothlng:
E Connections Protected from Elements I External GFCI f]Other:
E Xe nating Requirement E] lntrinsically Safe Requirement
E hstall Temporary Lighting I Headlamps
! Housekeeping E Barricade Area E Other:
El cut Resistant Gloves E pincn Rs. E C'eneral E ebcricat E lmpact Resistant
E other:
E Hot Work E Confined Space ! Excavation
E fattng objecls ! Fall protection EJ Orop zone protection E] Phtform load ratings
f] ScafoU inspeclion E Ladder inspection E] Baricades for equipment
I Exposed wire/connector El Verify equipment grounding E Arc Flash
! Crane lift plan fl Rigging inspection EI fag lines used tf Hoists in place
E Unexpected exposure E Chemical f] Dust (combustible) n PEL provided
E C".tridoes or suoolied air available E Gas detection
RequiredPPE DHardHats !safetyGlasses flSafetyToeShoe/Boot IHearingProtection lsafetySpotter
E Hi-Vis Vests E Harness/Lanyard. E Goggles E Personal Monitor Type:
E Metatarsal Guards E Hot Gloves ! Face Shield E Respirator Type:
ENomex/FRC E Otner PPE:
2.
3.
4.
5.
AOS-FRM-1.18
Page 40 of 48
Facility lnformation/Emergency Preparedness
lf non+mergency medical attention is needed, call: AXIOM #: 877-502-9466.
Plant Emergency #
EMS Location
Certified First Aid Person:
Evacuation Routes Rally Point
Severe Weather Shelter Location Eye Wash & Safety Shower Location
Operational: EYes ENo
Source lnformation: (list type):
Stack Gas Temp. ("F) Stack Gas Press. ("H2O) Stack Gas Components:
Stack Gas lnhalation Potential? EVes E ruo lf yes. see List of Hazard Chemicals
GP043AS-036892-PP-905
rfvrMt)NIRL))t
Additional Work Place Hazards
Job Hazard Analysis 2of3
7.
8.
Critical Procedures - check all that apply - *indicates additional form must be completed or collected from client
E Heat Stress Prevention* E Confined Spacet E MEWP. E Roof Work E Scaffold
E CoU Weather Work f] Hazardous Energy Control' E Exposure Monitoring E Other:
Working From Heights
Fall Protection
Falling Objects Pptecdon
Fall Hazard Communication
iE f ixeO Guardrails/Toe boards E Fall Prevention PPE Warning Line System
iEl e""ioaing E Netting ! House Keeping ETethered Tools ECatctr BlanketorTarp
i D RojacenUOverhead Workers E Contractor Contact fl Client Contact
Other Considerations
Environmental Hazards - Weather Forecast
E Heavcold ELigntning E Rain E snow E lce E Tornado I wind Speed
Steps for Mitigation:
Electrical Safety Plannlng
ptant Hook up: f] t tov E 22ot24ov E +aov EI Generator E Hard wired into panel
Electrical Classified Area: EYes fl No Trailer Grounded: E Yes E f'lo Plug Type
Electrical Hook Up Responsibility:
ist of Hazardous Chemicals
E Acetone E ruitric Acid
other chemicals:
E Hydrogen Peroxide E Compressed Gases
E Hexane E Sufiuric Acid E lsopropyl Alcohol I Flammable Gas
E Toluene E Hydrochloric Acid E liqulo Nitrogen ! Non-Flammable Gas
E Hzs E Carbon Monoxide
Steps for Mitigation:
lildlife/Fauna in Area
E Poison lvy ! Poison oak Elnsects:!Wildlife:
Personnel w/ known allergies to bees stings or other allergens? ! Yes E tto
9.Hazards and Mitigation
1
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3
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3
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2
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1
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AQS-FRM-1.18
Page 41 of 48GP043AS-036892-PP-905
,'
3 of 36vrrVt()NlK\))l Job Hazard Analysis
,HA REVIEW: Crew Names & Slgnatures
Printed Name Signature Date Printed Name Siqnature Date
11 JHA Meetino & Review
to review:
o Change in conditions o Extended work hours o Daily Safety Topic
o New workers or contractors o Occurrence of near misses or injuries
demonstratos that site conditions and hazards have not changed from the original SSP. lf changes did occur, make the
updates to this JHA and add notes as applicable in Section 9.
Day Dlrcucrlon Toplc lnl0dr
2
3
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5
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AQS.FRM-1.18
Page 42 of 48GP043AS-036892-PP-905
ljv i M()N I KL)\t
Poge 1 of 2
EMERGENCY ACTION PLAN FORM
The Job Supervisor/ Client Project Manager (CPM) will €nsure that all employees are familiar with the facility emergency and evacuation
procedures, assembly/ rally points, alert systems, and slgnals prlor to work commencing. ln the event of an emergency sltuatlon/
evacuation, the Job Supervisor/ GPM will maintain a roster and be responsible for accounting for all employees. The Job Supervisor/
CPM wlll ensure that thls Emergency Action Plan Form ls completed, communlcated to all employees, and posted.
.You must follow the client's em€rgoncy action plan first, and notify your Supervisor immediately.
.lf incident ls life threatenlng, CALL 9'll IMMEDIATELLY
.lf non-emergency medical attention is needed, call A)(IOM Medical number: 877-502-9466.
AQS-FRM-1.11
GP043AS-036892-PP-905
1 MEG Job Supervisor/ CPM's Name:
2 MEG Job Supervisor/ GPM's Telephone Number:
3 MEG Job Safety Supervisor (if applicable):
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 PIant'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 Extinguisher is Located:
Page 43 of 48
,6rrM()NlKt))t Poge 2 of 2
EMERGENCY EVACUATION AND ASSEMBLY MAP
1 Facility Name:
2 Facility Alarm (Circle):YES or NO
3
Alarm Tones:
FIRE:
SHELTER.IN.PLACE:
AfUED.
4 Designated Shelter(s) Description:
5 Designated Assembly Point(s) Description:
N*+,
s
EMERGENCY ACTION PIAN FORM AND EVACUATTON ASSEMBTY MAP REVIEW: Crew Names and Signatures
Printed Nome:Signature:Dote:Printed Name:Signoture:Date:
AQS-FRM-1.11
GP043AS-036892-PP-905 Page 44 of 48
.,tvl
[v r r!1\rN I irt,l\t
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#:Serial Number:
Make:Rented or Owned:
. Check "Yes" if an item is adequate, operational, and safe.. Check "No" to indicate that a repair or other corrective action is required prior to use.o Check "N/A" to indicate "Not Applicable."
Items to be lnspected
1. All MEWP lift components are in working condition (i.e. no loose or missing parts, torn or
loose 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. wom 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 cleady marked.
10. Manufacturer's lnstruction Manual is present inside the bucket
11. Base controls (switches and push buttons) can be properly operated
12. Platform conditions are safe (i.e. not slippery)
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 otherwlse specifled by manufacturer
recommendations.
Yes
!
D
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tr
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!
tr
tr
tr
tr
N/A
tr
tr
tr
No
tr
!
tr
trtr
DN
trtr
ND
trtr
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trn
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trtr
Operator Name & Signature Location Date
Ground Control Name & Signature Location Date
Harness lnspectlons:
Printed Name Signature Date
Printed Name Signature Date
Printed Name
GP043AS-036892-PP-905
Date
AQS-FRM.1.16
Page 45 of 48
Signature
a- .lY
c/,\ MONTROSE
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 initials:
. Temperature and weather . Hoisting. Lighting . PPE (i.e. respirators, etc.). Working from Heights . 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:
a
a
I
a
Reason for extended hours
Reason for delay
Production limitations
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
final decision.
FinalOutcome:
Approver:
2.
3.
OOlAS-SAFETY-FM.3
Page 46 of 48
The test leader should look for signs of the following in their crews:
. lrritability. Lack of motivationo Headaches. Giddiness
. Fatigue. Depression. Reduced alertness, lack of concentration and
memory
The test leader should assess the environmental and hazardous concerns:
GP043AS-036892-PP-905
1.
2.
MUN I RUsb
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 Manaoer (PM):Exoected Hiqh Temp:
Date(s):Exoected 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 allfield staff (avoid caffeinated drinks and energy
drinks which can increase core temperature).
o Bring no less than one gallon of water per employee. 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 cool head bands/vests/etc.. Have ice available to employees. lmplement work shift rotations and breaks, particularly for employees working in direct
sunlight.. Provide as much shade at the jobsite as possible, including tarps, tents or other acceptable
temporary structures.. PM should interview each field staff periodically to evaluate for signs of heat illness
lf Heat lndex is above 103' F:. 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 drinkso Employees should wear cool bands and vests if working outside more than one hour at a
time. PM should interview each field staff every 2 hours to evaluate for signs of heat illness
3.
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OOlAS-SAFETY-FM.5
Page 47 of 48GP043AS-036892-PP-90s
1n.
This is the Last Page of This Document
If you have any questions, please contact one of the following
individuals by email or phone.
Na me : Cra ig Kormylo
Title: District Manager
Region: USA - Stack - Great Plains - Operations
Email : CKormylo@montrose-env.com
Phone: (303) 495-3936
Name: Glen Capra
Title: Vice President
Region: USA - Stack
Email : GCapra@montrose-env.com
Phone: (5t2) 772-6450
UTAH DFPNRTVTTT OrEI vlRo_ryM.E-NfAL a uA L I rY
AUG 2 2 ?a24
D,VISION OF AIR QUAI ITY
GP043AS-036892-PP-905 Page 48 of 48