DAQ-2025-001364

1

DAQC-225-25
Site ID 10096 (B5)
MEMORANDUM

TO: CEM FILE – SUNNYSIDE COGENERATION ASSOCIATES

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Rob Leishman, Environmental Scientist

DATE: February 26, 2025

SUBJECT: Source: Unit 1 – Fluidized Bed Combustion Boiler
Contact: Rusty Netz – 435-888-4476, ext. 107
Location: 1 Power Plant Road, Sunnyside, Carbon County, UT 84539
Test Contractor: Montrose Air Quality Services
FRS ID#: UT0000004900700030
Permit/AO#: Title V operating permit 700030005, dated March 8, 2023
Subject: Review of RA/PST Protocol dated February 18, 2025

On February 21, 2025, DAQ received a protocol for a RA/PST (relative accuracy/performance specification
test) of the Sunnyside Unit 1 in East Carbon, UT. Testing will be performed on June 10, 2025, to determine
the relative accuracy of the O2, CO2, NOx, SO2, and CO monitoring systems.

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: OK
5. RM 6C used to determine SO2 emissions: OK
6. RM 7E used to determine NOx concentrations of emissions: OK
7. RM 10 used to determine CO concentrations of emissions: OK
8. RM 19 used to determine volumetric flow: OK

DEVIATIONS: No deviations were noted.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send attached protocol review and test date confirmation notice.

ATTACHMENT: Sunnyside Cogeneration RATA, PM, and CO Test Protocol

1 8 2
lunnyside Cogentration Associates
P.O. Box 159 . Sunnyside, Utah 84539 . [phone] . Fax [phone]
l"'ebruary 18, 2025
UTAH DEPARTMFNT OF
ENVIRONMENTAL QUALITY
Rob Leishman
Division of Air Quatity
195 North 1950 West
Satt Lake City, Utah 841 l6
Re: RATA, PM and CO Test Protocot
Title V Permit Number # 700030005
DIVISION OF AIR QUALITY
Dear Mr. Leishman:
Included is the Test Protocol for the 2025 relative accuracy test audit (RATA ),CO compliance testing and PM LEE testing at SCA, which is schedulcd for.lune 10,
2025 andJune I 1,2022.
Montrose Air Quality Services will be performing the tests again this year, 'l'he
tests to be conducted are the relative accLlracy test audits for sullirr dioxide (SO2),
nitrogen oxide (NOx), oxygen (O2), Carbon Dioxide (CO2) and volumetric flow. Also,
being tested are carbon monoxide (CO) compliance and PM LEE testing compliancc.
Ifyou have any questions or concenls rcgarding the test protocol, please leel free
to call Rusty Netz or myself at [phone].
'l'hank You,
'-rtr"c,Aa,-f)ru&
Michael Moslcy
Agent for
Sunnyside Cogeneration Associates
cc. , Rusty Netz' Plant File
Source Test Plan
2025 Relative Accuracy Test Audits and
Compliance Testing
Unit EU#1
Sunnyside Cogeneration Associates
Sunnyside, Utah
Prepared For:
Su nnyside Cogeneration Associates
1 Power Plant Road
Sunnyside, Utah 84539
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-051173-PP-968
Proposed Test Date: June lO,2fJ25
Submittal Date: May 1O, 2(J25
- Ltf n-U-Of PARl Mt:NI OF
r r.t t, t t r o t'I'lt-- t'l lAL q!}lllY
DI\/ISiON OF A!R Ot,-IALITY
fth,#-laccraolitplE[rioudq6A M9NI\,9 l!
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:
2/r41202s
Title: eA/eC Anatyst
I have reviewed, technically and editorially, details and other appropriate written materials
contained herein. I hereby ceftify 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 D7036-04.
Signature:
Name:Tim Wojtach
Date:
Title:
2/L4/2025
Account Manager
GP043AS-05 1 173-PP-968 Page 2 of 49
Table of Contents
Section Paoe
1.0 Introduction........ .................. 5
1.1 Summary of Test Program ............... 5
L.2 Applicable Regulations and Emission Limits ...... 6
1.3 Key Personnel........... ....... 8
2.0 Plant and Sampling Location Descriptions............. ................... 9
2.1 ProcessDescription,Operation,andControlEquipment............ ..........9
2.2 CEMS Description .............. 9
2.3 Flue Gas Sampling Locations ..........10
2,4 Operating Conditions and Process Data...... ......10
2.5 Plant Safety............. ........10
2.5.1 Safety Responsibilities ...........11
2.5.2 Safety Program and Requirements ..............L2
3.0 Sampling and Analytical Procedures .........13
3.1 Test Methods............ .....13
3.1.1 EPA Method 2............. ..........13
3.1.2 EPA Method 4............. ..........15
3.1.3 EPA Methods 3A, 6C, 7E, and 10 ........... ................16
3.1.4 EPA Method 5............. .........18
3.2 Process Test Methods............ ........20
4.0 Quality Assurance and Reporting........... ................20
4.1 QA Audits. .........20
4.2 Quality Control Procedures ..............20
4.2.1 Equipment Inspection and Maintenance .................20
4.2.2 Audit Samples ......20
4.3 Data Analysis and Validation ...........21
4.4 Sample Identification and Custody .......2t
4.5 Quality Statement .........21
4.6 Reporting .......21
4.6.1 Example Report Format ...........22
4.6.2 Example Presentation of Test Resu|ts.............. .......23
List of Appendices
Appendix A Supporting Information......... .....24
Appendix A.1 Units and Abbreviations ....25
Appendix A.2 Accreditation Information/Certifications........... .................33
Appendix "S" Field Work Safety Plan .............35
GP043AS-05 1 173-PP-968 Page 3 of 49
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 Part 60/75 RA Requirements....... ................7
Table 1-4 Summary of Emission Limits....... ........ B
Table 1-5 Test Personnel and Responsibilities.... ............. 9
Table 2-1 CEMS Information .........9
Table 2-2 Sampling Locations ........... ............... 10
Table 4-1 Example NOx (lblmmBtu) RATA Results - Unit Name ......23
List of Figures
FIGURE ........L4
3.1 US EPA METHOD 2 SAMPLING TRAIN ......L4
Figure 3-2 EPA Method 4 Sampling Train........ .......15
Figure 3-3 EPA Methods 3A, 6C, 7E, and 10 Sampling Train ............17
Figure 3-4 EPA Method 5 Sampling Train........ ...............19
Figure 4-1 Typical Report Format .................22
GP043AS-05 1 173-PP-968 Page 4 of 49
1.O Introduction
1.1 Summary of Test Program
Sunnyside Cogeneration Associates contracted Montrose Air Quality Services, LLC
(Montrose) to perform a testing program at Sunnyside Power Plant located near Sunnyside,
Utah. Testing will be conducted in accordance with the testing requirements of Utah
Depaftment of Environmental Quality (UDEQ) Operating Permit 700030002 and (as
applicable) 40 CFR Parts 60 and 75.
The specific objectives are to:
. Perform annual Relative Accuracy Test Audits (MTAs) on the Continuous
Emission Monitoring Systems (CEMS) installed on Unit EU#1
. Peform annual carbon monoxide (CO) compliance testing on the exhaust
stack of Unit EU#1
. Perform triennial Particulate Matter (PM) emissions testing on the exhaust
stack of Unit EU#1.
. 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.
GP043AS-0s 1 173-PP-968 Page 5 of 49
Volumetric Flow Rate RATA
COz, SOz, NO' MTAs
CO Compliance Test
EPA 1, 2,3,4
EPA 34, 6C,7E
EPA 10
>5 min
21 min
60 min
EPA 1, 2,3,4, 5
L.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
Unit EU#1
Unit EU#1
SOz, NO*, CO ppmvw, lb/mmBtu, lblhrUnit EU#1
Unit EU#1
GP043AS-05 1 173-PP-968 Page 6 of 49
The RA requirements are presented in Table 1-3.
Table 1-3
Summary of Paft 610175 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 < 0.200 lb/MMBtu)
Part 5O
Sulfur Dioxide (SOz)
lblhr PS-6 3 2O.Oo/o of RM or < 10.0olo of AS
lblmmBtu PS-5 < 2O.Oo/o of RM or < 10.0olo of AS
Nltrogen Oxldes (NOx as NOz)
ppmvd PS-2 3 2O.Oo/o of RM or < 10.0olo of AS
lblhr PS-6 3 20.0o/o of RM or < 10.0olo of AS
Part 75
Oxygen (Oz)
o/o volume dry App. B Sect, 2.3.1.2 Annual : < 7 .5o/o of RM or * O,7o/o COz
%o volume dry App. A Sect.3.3.3 Semiannual: S 10.0olo of RM or * 1.0olo COz
Carbon Dioxide (COz)
o/o volume dry App. B Sect. 2.3.1.2 Annual: < 7,5o/o of RM or + O.7o/o COz
o/o volume dry App. A Sect.3.3.3 Semiannual: < 10.0olo of RM or * 1.0olo COz
Volumetric Flow
dscfh App. B Sect. 2.3.1.2 Annual: < 7.5o/o of RM or + 1.5 fpstt)
dscfh App. A Sect.3.3.4 Semiannual: < 10.0olo of RM or + 2,0 fpstt)
Sulfur Dioxide (SOz)
ppmvw App. B Sect. 2.3.1.2 Annual: < 7.5o/o of RM or + 12 ppm SO2t2)
ppmvw App. A Sect. 3.3.1 Semiannual: 3 10.0olo of RM or + 15.0 PPm SOz(2)
Nitrogen Oxides (NOx as NOz)
lblmmBtu App. B Sect. 2.3,1.2 Annual: < 7.5o/o of RM or + 0.015 lblmmBtu(zl
lblmmBtu App. R Sect.3.3.2 Semiannual: < 10.0olo of RM or * 0.020 lblmmBtutzl
GP043AS-05 1 173-PP-968 PageT of 49
The applicable permit limits are presented in Table 1-4.
Table 1-4
Summary of Emission Limits
1.3 Key Personnel
A list of project participants is included below:
Facility Information
Source Location: Sunnyside Cogeneration Associates
Sunnyside Power Plant
1 Power Plant Road
Sunnyside, UT 84539
Project Contact:
Role:
Company:
Telephone:
Email:
Agency Information
Regulatory Agency:
Agency Contact:
Telephone:
Email:
Rusty Netz
Environmental Advisor
Sunnyside Cogeneration Associates
(43s) 888-4476 xtoT
[e-mail]
Utah Depaftment of Air Quality
Rob Leishman
(801) s36-4438
[e-mail]
Testing Company Information
Testing Firm: Montrose Air Quality Services, LLC
Contact: Craig Kormylo
Title: District Manager
Telephone: [phone]
Email: [e-mail]
Carbon t{onoxide (CO)
Particulate Matter (PM)
40 CFR Part 63, Subpart UUUUU
GP043AS-051 173-PP-968 Page 8 of 49
Table 1-5 details the roles and responsibilities of the test team.
Table 1-5
Test Personnel and Responsibilities
Facility interface, test crew coordination
Preparation, support PMExecute stack platform
responsibilities
2.O Plant and Sampling Location Descriptions
2.L Process Description, Operation, and Control
Equipment
The Sunnyside Cogeneration Facility is a steam-electric generating power plant located in
Sunnyside, Carbon County, Utah. The plant consists of a circulating fluidized bed (CFB)
combustion boiler designated EU #1, an emergency backup diesel-fired pump, diesel storage
tanks, coal handling equipment, ash handling equipment and limestone handling equipment.
EU #1 has a rating of 700 mmBtu/hr and is equipped with limestone injection and a baghouse
for control of emissions. The EU #1 is fueled by coal refuse from the Sunnyside and Star
Point Refuse Piles. The flylbottom ash generated from the coal combustion is disposed of in
an on-site landfill or used for beneficial applications.
2.2 CEMS Description
The CEMS analyzers are presented in Table 2-1.
Table 2-1
CEMS Information
Unit EU#1
Flow Durag D-R 290 41.7243
Oz EcoChem MC3 425
COz EcoChem MC3 425
SOz EcoChem MC3 425
NOx EcoChem MC3 425
GP043AS-05 1 173-PP-968 Page 9 of 49
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 prior to 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 Paft 60 or within
the load levels required by 40 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.
GP043AS-051 173-PP-968 Page 10 of 49
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 performing and the equipment that they will
operate
. Our team will meet daily to review the Project Scope, lob 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 ports, 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 project 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-05 1 173-PP-968 Page 11 of 49
to continuing work. This will include any safe work permit and hazard
assessment updates.
Completion
Montrose personnel will report any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site
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:
a
a
a
a
a
a
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 repofting 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-051 173-PP-968 Page 12 of 49
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 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 measured average temperature, the measured duct static pressure, the molecular
weight of the gas stream, and the measured moisture.
Pertinent information regarding the performance of the method is presented below:
. Method Options:
o S-type pitot tube coefficient is 0.84
. Method Exceptions:
o None
The typical sampling system is detailed in Figure 3-1.
GP043AS-05 1 173-PP-958 Page 13 of 49
FIGURE 3-I
US EPA METHOD 2 SAMPLING TRAIN
GP043AS-05 1 173-PP-968 Page 14 of 49
3.1.2 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
GP043AS-05 1 173-PP-968 Page 15 of 49
SAII{PLE UNE
T
IN STACK FILTER
(fir(ffitit)
BYfASSVALVE(*rr.4!d, VACUUM GAUGETHERMOCCTJPLESJI
I{ANOI'ETER +
3.1.3 EPA Methods 3A, 5C, 7E, and 1O
Determination of Oxygen, Carbon Dioxide, Sulfur Dioxide, Nitrogen Oxides,
and Carbon Monoxide Concentratlons 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:
r Method Options:
NO and NOz are measured separately and summed to repoft NO'
emissions
The alternative NO, converter efficiency test described in EPA Method 7E
Section 16.2 may be used (bag procedure)
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. Appendix A, 66.5.6.1(c). tf 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.
Appendix A 86.5.6.3(b). If diluent and pollutant concentrations are within
10o/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. Appendix A. 66.5.6.1(a).
The typical sampling system is detailed in Figure 3-3.
GP043AS-05 1 173-PP-968 Page 16 of 49
Figure 3-3
EPA Methods 3A, 6C, 7Et and 1O Sampling Train
MASS FLO/VCONTROIER/
CAUMATIOII GAS MANIFOLD
GP043AS-05 1 173-PP-968 Page 17 of 49
3.1.4 EPA Method 5
Determination of Particulate Matter from Stationary Sources
EPA Method 5 is a manual, isokinetic method used to measure FPM emissions. The samples
are analyzed gravimetrically. This method is performed in conjunction with EPA Methods 1
through 4. The stack gas is sampled through a nozzle, probe, filter, and impinger train. FPM
results are repofted in emission concentration and emission rate units.
Pertinent information regarding the performance of the method is presented below:
o In accordance with 40 CFR Part 63, Subpart UUUUU, the target sample
volume is 70.63 dscf
In accordance with 40 CFR Paft 53, Subpaft UUUUU, the front-half
temperature is set to 320'+25'F
o To simplify shipping arrangements to remote locations, stainless steel
probe liners and nozzles are used. Aftereach run, the nozzle and probe
liner are brushed and washed a total of six times with reagent-grade
acetone to assure complete recovery of all pafticulate matter. The brush is
given a final rinse with acetone and the nozzle and probe liner are given a
final rinse with acetone and all rinsate is collected into the appropriate
sample container.
The typical sampling system is detailed in Figure 3-4.
GP043AS-05 1 173-PP-968 Page 18 of 49
Figure 3-4
EPA Method 5 Sampling Train
THERMOCOUPLES
FILTER
HOLER THERMOCOJPLE
ITHMMOCOUPLE
THERMMOUPLE
HEATEDPROEE
NOZZLE-----+
ITYPE'S
HTOT
1m mL I EmilyC,^I??\qlJG rdml @dtiq,hottp) zoobms
. Rq4GFNl .co!ffiNSNG stica Gei
MAt,lOtvlEIER --o
@dnntno tP)-'REAGErr'i - (ffndtrqurto rp)
@e rnad tip)
BYPASS VAVE
THERMOCOUPLES @,dJU.) VACUUY GAUGEJI
ORIFICE
MAIN
VALVE(.wrr.<l4a )
MA.IOMETER -------+
GAS
EXIT
Page 19 of 49
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 paft 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
repofted and addressed through the corrective action system.
4.2.t Equipment Inspection 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
repofted along with the emissions sample results.
GP043AS-05 1 173-PP-968 Page 20 of 49
4.3 Data Analysis and Validation
Montrose convetts 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 repoft. The "standard Conditions" for this project are 29.92
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 uncertainty 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.t and 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 Repofting
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 certified
by the project manager and their supelisor, or a peer. Source test repofts 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.
GP043AS-05 1 173-PP-968 Page 21 of 49
4.6.L 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 Repoft Format Cover Page
of Report
of Contents
1.0 Introduction
2.0 Plant and Sampling Location Descriptions
3.0 Sampling and Analytical Procedures
4.O 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
Quality Assurance/Quality Control
Regulatory Information
GP043AS-05 1 173-PP-968 Page 22 of 49
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 repoft. 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 (!b/mmBtu) RATA Results - Unit Name
1 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/xxlxxxx 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
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
Confi dence Coefficient (CC)xx
Bias Adjustment Factor (BAF)xx
Unit Load XX units
RA based on mean RM value XX o/o
RA based on AS XX o/o
RA based on difference plus CC xx units
RA based on absolute difference xx units
GP043AS-05 1 173-PP-968 Page 23 of 49
Appendix A
Supporting Information
Appendix A.1
Units and Abbreviations
Page 25 of 49
M l*?N,r+p.LI
@x%02
lccl
ldloc
oF
oR
" HzO
13.6
AH
AP
e
ug
Pa
P*
acfm
An
&
Btu
BE
ca
Cers
Coi,
cf or fts
cfm
CG".
CM
cm or m3
Cue
co
cp
cs
CS
cs
cv
D
dcf
dcm
Dn
D"
dscf
dscfm
dscm
Fd
fpm
fps
ft
ff
s
gal
gr
gr/dscf
hr
UNITS AND ABBREVIATIONS
conected to X% orygen (corrected for dilution air)
absolute value of the confidence coefficient
absolute value of the mean differences
degrees Celsius
degrees Fahrenheit
degrees Rankine
inches of water column
specific gravity of mercury
pressure drop across orifice meter, inches HrO
velocity head of stack gas, inches H2O
total sampling time, minutes
microgram
density of acetone, mg/ml
density of water, 0.9982 g/ml or 0.002201 lb/ml
actual cubic feet of gas per minute at stack conditions
cross-sectional area of nozzle,ft'
cross-sectional area of stack, square feet (ft')
British thermal unit
proportion by volume of water vapor in gas stream
particulate matter concentration in stack gas, gr/acf
average unadjusted gas concentration, ppmv
measured concentration of calibration gas, ppmv
cubic feet
cubic feet per minute
average gas concentration adjusted for bias, ppmv
average of initial and final system bias check responses from upscale calibration gas, ppmv
cubic meters
actual concentration of the upscale calibration gas, ppmv
average of initial and final system bias check responses from low-level calibration gas, ppmv
pitot tube coefficient
particulate matter concentration in stack gas, gr/dscf
calibration span, % or ppmv
measured concentration of calibration gas, ppmv
manufactured certified concentration of calibration gas, ppmv
drift assessment, % of span
dry cubic feet
dry cubic meters
diameter of nozzle, inches
diameter of stack, inches
dry standard cubic feet
dry standard cubic feet per minute
dry standard cubic meters
F-factor, dscf/MMBtu of heat input
feet per minute
feet per second
feet
square feet
gram
gallons
grains (7000 grains per pound)
grains per dry standard cubic feet
hour
GP043AS-05 1 173-PP-968 Page 26 of 49
66 l'lo..N,I+gP.H
I
in
k
K
K3
1&
kg
&
kwscfh
I
lb/hr
lb/MMBtu
lpm
m
M
m3
ma
Md
meq
mg
Mg
min
ml or mL
mm
MM
MMBtu/hr
mn
mol
mol. wt. or MW
Ms
MW
n
ng
nm
oI bar
pg
Ps
P,
ppb
ppbv
ppbvd
ppm
ppmv
ppmvd
ppmvw
Ps
psi
psia
psig
Psto
Q,
Q.
Qsto
R
UNlTS AND ABBREVIATIONS
percent of isokinetic sampling
inch
kilo or thousand (metric units, multiply by '103)
kelvin (temperature)
conversion factor 0.0154 gr/mg
conversion factor 0.002668 ((in. HgXftr))/((mlX'R))
kilogram
pitot tube constant (85.49 fUsec)
thousand wet standard cubic feet per hour
liters
pounds per hour
pounds per million Btu
liters per minute
meter or milli
thousand (English units) or mega (million, metric units)
cubic meters
mass of residue of acetone after evaporation, mg
molecular weight of stack gas; dry basis, lb/lb-mole
milliequivalent
milligram
megagram (106 grams)
minute
milliliter
millimeter
million (English units)
million Btu per hour
total amount of particulate matter collected, mg
mole
molecular weight
molecular weight of stack gas; wet basis, lb/lb-mole
molecular weight or megawatl
number of data points
nanogram
nanometer
barometric pressure, inches Hg
picogram
stack static pressure, inches H2O
barometric pressure of dry gas meter, inches Hg
parts per billion
parts per billion, by volume
parts per billion by volume, dry basis
parts per million
parts per million, by volume
parts per million by volume, dry basis
parts per million by volume, wet basis
absolute stack gas pressure, inches Hg
pounds per square inch
pounds per square inch absolute
pounds per square inch gauge
standard absolute pressure, 29.92 inches Hg
volumetric flow rate, actual conditions, acfm
volumetric flow rate, standard conditions, scfm
volumetric flow rate, dry standard conditions, dscfm
ideal gas constant 21.85 ((in. Hg) (ft3)y(("R) (lbmole))
GP043AS-05 1 1 73-PP-968 Page 27 of 49
66 ll?,N,I+gp.H
UNITS AND ABBREVIATIONS
SBRnar post-run system bias check, % of span
SBi pre-run system bias check, % ofspan
scf standard cubic feetscfh standard cubic feet per hourscfm standard cubic feet per minutescm standard cubic meters
scmh standard cubic meters per hoursec second
sf, sq. ft., ord square feetstd standardt metric ton (1000 kg)
T o.gru t-value
T" absolute average ambient temperature, oR (+459.67 for English)
Tm absolute average dry gas meter temperature, oR (+459.67 for English)
ton or t 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"to absolute temperature at standard conditions
V" volume of acetone blank, ml
V", volume of acetone used in wash, ml
Vr" total volume H2O collected in impingers and silica gel, grams
V, volume of gas sampled through dry gas meter, ft'
Vnlstd) volume of gas measured by the dry gas meter, corrected to standard conditions, dscf
V* stack gas volume sampled, acf
Vn volume collected at stack conditions through nozzle, acf
Vs average stack gas velocity, feet per second
Vrc(std) volume of water vapor condensed, conected to standard conditions, scf
V*("to) volume of water vapor in gas sampled from impingers, scf
Vmg(sto) volume of water vapor in gas sampled from silica gel, scf
W watt
W" weight of residue in acetone wash, mg
Wi,p total weight of impingers, grams
Wss total weight of silica gel, grams
Y dry gas meter calibration factor, dimensionless
voll
Page 28 of 49GP043AS-05 1 173-PP-968
66 lt?.N,r+gp.I
AAS
ACDP
ACE
AD
ADL
AETB
AS
ASTM
BACT
BDL
BHP
BIF
BLS
cc
CD
CE
CEM
CEMS
CERMS
CET
CFR
CGA
CHNOS
CNCG
COcoc
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
continuous 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
fl ame photometric detector
filterable particulate matter
Fou rier-transform i nfrared spectroscopy
field train proof blank
field train recovery blank
polychlorinated dibenzofurans (pcdf s)
gas chromatography
GP043AS-05 1 173-PP-968 Page 29 of 49
6/} IT?,NI+S'S.T
GC/MS
GFAAS
GFC
GHG
HAP
HC
HHV
HPLC
HRGC/HRMS
HRSG
IC
ICAP
ICPCR
ICP-MS
IR
tso
KW
LFG
LHV
LPG
MACT
MDI
MDL
MNOC
MRL
MS
NA
NCASI
NCG
ND
NDIR
NESHAP
NG
NIOSH
NIST
NMC
NMOC
NMVOC
NPD
NSPS
OSHA
PAH
PCB
PCWP
PE
PFAS
PI
PID
PM
PMro
PMz.s
POM
PS
PSD
PSEL
PST
PTE
PTM
ACRONYMS
gas chromatogra phy/mass spectroscopy
graphite furnace atomic absorption spectroscopy
gas filter correlation
greenhouse gas
hazardous air pollutant
hydrocarbons
higher heating value
high performance liquid chromatography
high-resolution gas chromatography/high-resolution mass spectroscopy
heat recovery steam generator
ion chromatography
inductively-coupled argon plasmography
ion chromatography with a post-column reactor
inductively coupled plasma-mass spectroscopy
infrared radiation
lnternational Standards Organization
kilowatts
landfill gas
lower heating value
liquified petroleum gas
maximum achievable control technology
methylene diphyenyl diisocyanate
method detection limit
maximum normal operating conditions
method reporting limit
mass spectrometry
not applicable or not available
National Council For Air And Steam lmprovement
non-condensable gases
not detected
non-dispersive infrared
National Emissions Standards For Hazardous Air Pollutants
natural gas
National lnstitute For Occupational Safety And Health
National lnstitute Of Standards And Technology
non-methane cutter
non-methane organic compounds
non-methane volatile organic compounds
nitrogen phosphorus detector
New Source Performance Standards
Occupational Safety And Health Administration
polycyclic aromatic hydrocarbons
polychlorinated biphenyl compounds
plywood and composite wood products
Professional Engineer
per- and polyfluoroalkyl substances (PFAS)
photoionization
photoionization detector
particulate matter
particulate matter less than 10 microns in aerodynamic diameter
particulate matter less than 2.5 microns in aerodynamic diameter
polycyclic organic matter
performance specifi cation
particle size distribution
plant site emission limits
performance speciflcation test
permanent total enclosure
performance test method
GP043AS-05 1 173-PP-968 Page 30 of 49
66 ltgN,r+P"p.H
OA/OC
QI
QSTI
RA
RAA
RACT
RATA
RCTO
RICE
RM
RTO
SAM
SCD
SCR
SD
Sem|-VOST
SRM
TAP
TBD
TCA
TCD
TGNENMOC
TGNMOC
TGOC
THC
Ttc
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 cond uctivity 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 identifi ed 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
GP043AS-05 1 173-PP-g68 Page 31 of 49
66 l,lgN,T+gI"E
CHEMICAL NOMENCLATURE
Ag
As
Ba
Be
c
silver
arsenic
barium
beryllium
carbonCd cadmiumCdS cadmium sulfideCH2O formaldehyde
CH3CHO acetaldehyde
CH3OH methanol
CHr methane
C2H4O ethylene oxide
CzHo ethane
CaHIO acrolein
CaH6O propionaldehyde
CsHa propane
C6H5OH phenol
Clz chlorine
ClO2 chlorine dioxide
CO carbon monoxideCo cobaltCOz carbon dioxide
Cr chromiumCu copperEtO ethylene oxideEIOH ethyl alcohol (ethanol)
Se
Soz
Sor
SO,
TCDD
TCDF
TGOC
THC
TI
TRS
Zn
selenium
sulfur dioxide
sulfur trioxide
sulfur oxides
tetrachlorod ibenzodioxi n
tetrachlorod ibenzof ura n
total gaseous organic concentration
total hydrocarbons
thallium
total reduced sulfur compounds
zinc
H2
Hzo
ArOz
HzS
H2SOl
HCt
Hg
IPA
MDI
MeCl2
MEK
MeOH
Mn
N2
NHs
Ni
NO
Noz
NO,
o2
P
Pb
PCDD
PCDF
Sb
hydrogen
water
hydrogen peroxide
hydrogen sulfide
sulfuric acid
hydrogen chloride
mercury
isopropyl alcohol
methylene diphyenyl diisocyanate
methylene chloride
methyl ethyl ketone
methanol
manganese
nitrogen
ammonia
nickel
nitric oxide
nitrogen dioxide
nitrogen oxides
orygen
phosphorus
lead
polychlorinated dibenzo-p{ioxins
polychlorinated dibenzofurans
antimony
GP043AS-05 1 173-PP-968 Page 32 of 49
Appendix A.2
Accreditation Informatio n / Certifications
Page 33 of 49
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Appendix rrs"
Field Work Safety Plan
64\ }*?,NI+R[T
SITE SAFETY PLAN BOOKLET
Project:
Customer:
Location:
Units:
Client Project Manager:
Revision Date: January 21,2022
GP043AS-05 1 173-PP-968
,ar,,ML)N lR(.))t
Site Safety
Page 1 of2
Plan and JHA Purpose and lnstructions
Purpose
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 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 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 37 of 49GP043AS-05 1 173-PP-968
c IYIQN,I+glI Page 2 ol 2
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 offtce for a period of 3
years. There will be an audit process developed for the Site Safety Plans.
GP043AS-05 1 173-PP-968
PROJ ECT NAM E/LOCATION :
TEST DATE:
PROJECT #:
PROJECT MANAGER:
TEST SCOPE:
SITE CONTACT: Name:Contact Phone:
livrMUNlRt)5t,
Page I of 2
PRE.MOBILIZATION TEST INFORMATION
Source Tvpe: New Source: _ Revisit:_ Prj#/Dateffech:
Coal Fired Electric Utility: _ Ethanol Plant: _ Chemical Mfg. of
CemenULime Kiln Plant: _ Specialty Mfg. of:Other:
Anticipated Effluent Composition - check all that apply and fill in expected concentration in ppm/%
tr
co
tr
NOx
tr
SOz
tr
voc
tr
other
lf other, explain:
Flammable:Toxic: Corrosive: Dust:
Engineering Controls to be lmplemented:
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)
tr
below 210 210 to 450 450 to 950 above 950 other
lf other, explain:
Approximate Duct Pressure, (iwg):
tr
below
trtr tr
above
tr
+7 other-3 -3 to +3 +3 to +7
lf other, explain:
AQS.FRM-1.17
GP043AS-05 1 173-PP-968 Page 39 of 49
,ar . MUN l RLf )t-
Sampling Location: Stack Port _
Approximate Sampling Platform Height, (ft)
PRE.MOBILIZATION TEST INFORMATION
Page 2 ot 2
u
6to50
tr
other
tr
50 to 100
Duct Port _
tr
above'100below 6
lf other, explain:
Access and Protection:
Elevators: _ Ladders: _ MEWP Lift: _ Scaffold: _ Equipment Hoist: _
Guardrails: _ Toe plate: _ Engineered Tie Off Points: _ Heat Shield: _
Other:
Describe how equipment will be mobilized to the sampling location:
Additional lnformation:
Effluent Chemical Requlatory Limits
Gas Name Chemical
Formula
Cal OSHA PEL1
(ppm)
3al OSHA
STEL2
looml
NIOSH REL
nilN (ppm)
Cal OSHA
Ceiling
{ooml
IDLH4
(ppm)
3arlcon Monoxide CO 25 200 35 200 1,200
Nitric Oxide NO,25 ND5 25 ND 100
Sulfur Dioxide SOz 2 5 2 ND 100
Hvdrooen Chloride HCt 0.3 2 ND 2 50
Hydrogen Sulfide HzS 10 15 10 (10 min.)c 50 100
)alifomia Occupational Safety and Health Administration (OSHA) Permr.ssrb/e Exposure Limit (PEL) based on an g-hour shift;
2: Cal OSHA Shodlerm Exposure Limit (STEL) based on a 1S-minute period;
3: National lnstitute for Occupational Safety and Heafth (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 aibome or gaseous substance, which is nof fo be exceeded, even
momentaily.
Prepared by:
Reviewed by:
AQS.FRM-1.17
GP043AS-05 1 173-PP-968
Date:
Page 40 of 49
Job Hazard Analysis 1of3/ai
1.
\ tu\()N I KL))t
2.
Client :ontact Name )ate
Facilitv SSP Writer )M
Client Rep
plete
out the Heat Stress Prevention Form.
Job Prepara
! ..tou sitt
E sate w
tion
rWalk Through Completed ! Site Specific Training Com
ork Permit Received from Client
lfthe heat index is expected to be above 91', fil
Facility lnformation/Emergency 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: EYes ENo
Source lnformation: (list type):
Stack Gas Temp. ("F) Stack Gas Press. ("H2o) Stack Gas Components:
Stack Gas lnhalation Potential? EYes E ruo tf ves. see List of Hazard Chemicats.
RIsk
E time Pressure E Remote Work Location E > 12 hr shift E Wo*ing > 8 consecutive days
E Lr"k of pro""drr"" E Extreme temps, wind >30mph E Personal illness/fatigue E Vague urork guidance
E Monotonous Activity E Firct day back after time off El lltuttipte joU locations E Other:
PPE E Hard Hats I Safety Glasses [Safety Toe Shoe/Boot ! Hearing Protection [safety Spotter
E Hi-Vis Vests E Harness/Lanyard. E Goggles E Personal Monitor Type:
E Metatarsal Guards E Hot Gloves E Face Shield E Respirator Type:
ENomex/FRC E Other PPE:
AQS-FRM.1.18
Page 41 of 49
Physical Hazards
Dust Hazards
Thermal Bum
Electrical Hazards
lnadsquate Lighting
Slip and Trip
Hand Protection
E Hot Gloves I neat Shields ! Otrer Protective Clothing:
E Connections Protected from Elements I Extemal GFCI EOther:
E Xe nating Requirement E lntrinsically Safe Requirement
E lnstall Temporary Lighting E Headlamps
E Housekeeping El Banicade Area E Other:
fl Cut Resistrant Gloves E pincn ms. E General E Etectricat g imlaa nesiiant
Potential Hazards for Consideration
Secondary Permits i E not Work E Confined Space ! Excavation
Working from Heights i E frtting objects E Fall protection EI Orop zone protection E platform load ratings
See alro sec{. 7 i f] scarou inspection E Ladder inspeaion E Banicades for equipment
Electrical I E Exposeo wire/connector E Verify equipment grounding E Arc Flash
Lifting ! E Crane lift plan E Rigging inspection E fag lines used E Hoists in place
Respiratory i E Unerpected exposure E Chemical ! Dust (combustible) E PEL provided
see atso Sect. 8 i E Cartridqes or supplied air available E Gas detection
GP043AS-051 173-PP-968
riv\ MtlN I Rtlst
Additional Wo* Place Hazards
Job Hazard Analysis
7.
8.
ritical Proceduros - check all that apply - *indicates additional form must be completed or collected from client
E tteat Stress Prevention* E Confined Space* E MEWP- E Roof Work E ScaffotO
E Cota Weather Work ft Hazardous Energy Control. f] Exposure Monitoring E Other:
From Heights
Fall protection iE fixeO Guardrailsffoe boards E Fall Prevention PPE Warning Line System
Falling Objects protec{on !E aanicaOing El ttetting E House Keeping fiTethered Tools ECatctr BlanketorTarp
Fall Hazard Communication i tr AdjacenUOverhead Workers E Contractor Contact E Client Contact
Other Considerations
Environmental Hazards - Weather Forecast
E HeaUCold ELigtrtning E Rain E snow I lce E Tornado f] wind Speed
Steps for Mitigation:
Electrical Safety Planning
PlantHookup: Ettov rl22ot24ov E +aov E Generator EHardwiredintopanel
Electrical Classified Area: EYes I No Trailer Grounded: E yes E ruo flug Type
Electrical Hook Up Responsibility:
ist of Hazardous Chemicals
E Acetone E Nitric Acid
othor chomicals:
! Hydrogen Peroxide E compressed Gases
El Hexane E Sulfuric Acid E lsopropyl Alcohol I Flammable Gas
E Toluene E Hydrochloric Acid E liquio Nitrogen I Non-Flammable Gas
E Hzs E Carbon Monoxide
Steps for Mitigation:
Wildlife/Fauna in Area
E Poison rrv E Poison oak Elnsects:flwildlife:
Personnel w/ known allergies to bees stings or other allergens? f] Yes Eruo
Hazards and Steps
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
AQS-FRM-1.18
Page 42 of 49GP043AS-051 173-PP-968
JHA REVIEVII: Crew Names & Slgnatures
Printed Name Signature Date Printed Name Signature Date
iav\ Mt,lN I RL)}1 Job Hazard Analysis 3of3
11
AOS-FRM-1.18
Page 43 of 49
JHA Meetino & Review
to review:. Change in conditions o Extended work hours o Daily Safety Topic
o New workers or contractors o Occunence of near misses or in.iuries
domonstrates that site conditions and hazards have not changed from the origina! SSP. If changes did occur, make the
updates to this JHA and add notes as applicable in Section 9.
Dey Dlrcurslon Toplc lnldalr
2
3
4
5
6
7
I
I
10
1',l
GP043AS-05 1 173-PP-968
/at , r"vl(./r\ I irt/\l
Poge 7 of 2
EMERGENCY ACTION PLAN FORM
The Job Supervisor/ Client Project Manager (CPM) will ensure that all employees are familiar with the facility emergency and evacuation
proceduros, assembly/ rally points, alort 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, communicatod to all employees, and postod.
.You must follow the client's emergency action plan first, and notify your Supervisor immediately.
.lf lncident is life threatening, CALL 911 IMMEDIATELLY
.lf non-emergency medical attention is needed, call AXIOM Medical number: 877-502-9466.
AQS-FRM-1.11
GP043AS-05 1 173-PP-968
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:
I 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 Ihe First Aid Kit is Located:
17 Ihe Fire Extinguisher is Located:
Page 44 of 49
C', Mt)N I Rt))t Poge 2 of 2
EMERGENCY EVACUATION AND ASSEMBLY MAP
AQS-FRM-1.11
GP043AS-0s 1 173-PP-968
1 Facility Name:
2 Facility Alarm (Circle):YES or NO
3
Alarm Tones:
FIflE:
cHEM|CAU
SHELTER-IN.PUCE: ,
EVACUATE:
4 Designated Shelter(s) Description:
5 Designated Assembly Point(s) Description:
N
-1.w{ ErY
s
EMERGENCY ACTION PLAN FORM AND EVACUATION ASSEMBLY MAP REVIEW: Crew Names and Signatures
Printed Nome:Signature: Dote:Printed Name:Sionature:Date:
Page 45 of 49
rly r r\t L) r\ I l(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:
o Check "Yes" if an item is adequate, operational, and safe.o Check "No" to indicate that a repair or other corrective action is required prior to use.r 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, tom 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 clearly ma*ed.
10. Manufacturer's lnstruction Manual is present inside the bucket
11. Base controls (switches and push buttons) can be propedy 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 otherwise specified by manufacturer
recommendations.
Yes
tr
D
tr
tr
tr
tr
tr
tr
!
tr
n
tr
tr
n
!
No
tr
!
tr
N/A
tr
!
D
Dtr
trtr
tr!
trtr
trtr
!!
!!
trtr
tr!
trtr
tr!
trn
Operator Name & Signature Location Date
Ground Control Name & Signature Location Date
Harness lnspections:
Printed Name Signature Date
Printed Name Signature Date
Printed Name
GP043AS-05 1 173-PP-968
Date
AQS-FRM-1.16
Page 46 of 49
Signature
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 o Hoistingo Lighting o PPE (i.e. respirators, etc.). Working from Heights r 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
t
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
finaldecision.
FinalOutcome:
Approver:
2.
3.
OOlAS-SAFETY.FM-3
Page 47 of 49
The test leader should look for signs of the following in their crews:
o lrritabilityo Lack of motivation. Headaches. Giddiness
o Fatigue. Depression. Reduced alertness, lack of concentration and
memory
The test leader should assess the environmental and hazardous concerns:
GP043AS-05 1 173-PP-968
dr\MoN I R05b
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 Temo:
Date(s):Exoected Heat lndex:
t.
2.
Review the signs of Heat Exhaustion and Heat Stroke
lf Heat lndex is above 91" F:. 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 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 drinks. 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.
OOlAS-SAFEW-FM-5
Page 48 of 49
- cml. @lc.|.r.--r"r" I
Niu*a orrcmltlnt ffi Nauea o. tmitlnt
R.9fd,reatpul*
-
--
Rapid,st@nSpulse
Mu$r.@mps I uryto* (i)
GP043AS-0s 1 173-PP-968
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: Craig Kormylo
Title: District Manager
Region: USA - Stack - Great Plains - Operations
Email: [e-mail]
Phone: [phone] r
Name: Glen Capra
Title: Vice President
Region: USA - Stack
Email : [e-mail]
Phone: (5L2) 772-6450
II =_i
nivtstoN oF AtR or_l^t tTY
Page 49 of 49