Part A - Guidance and Procedures for Conducting Stationary Source Emission Measurements
Part A: Guidance and Procedures for Conducting Stationary Source Emission Measurements
1.0 Introduction
The guideline portion of the Ontario Source Testing Code (Code) covers comprehensively what needs to be done to generate an accurate, reliable and representative emission measurement from a stationary source.
The methods referred to in this code are the most reliable technical procedures available at the date of issue. However, as new and improved techniques become available, the methods will be revised, replaced or supplemented accordingly and the code will be appropriately amended.
Prior to implementing any of the methods referred to or described in this code, it is recommended that this introductory material be carefully reviewed. Outlined herein are the major requirements concerning the operating conditions of the process, the proper planning and execution of a source sampling test, the desirable qualifications of sampling personnel and the requirements for a satisfactory source testing report.
2.0 Purpose and Scope
This document standardizes sampling protocols and methods for stationary source emissions testing which may be required under Certificates of Approval, Regulation(s), by Provincial Officer’s Orders and Notices or as requested by the Ministry.
The Ministry, through its Standards Development Branch (Technology Standards Section), must be contacted prior to conducting a source test if any deviation from the methods and procedures included in this code is contemplated. Written approval must be obtained from the Ministry if any deviation is made to the methods cited herein.
3.0 Stack Sampling Team
The recommended qualifications for the stack sampling team are in Attachment 3.
4.0 Compliance Test
A compliance test is a source test conducted for the purpose of determining compliance with the Environmental Protection Act of Ontario, any other Ontario Act, regulations, or any other legal instrument promulgated thereunder (such as Certificate of Approval, Provincial Officer’s Order, notices, etc.), performed and reported in accordance with the requirements of this code.
The Ministry (Standards Development Branch, the appropriate District Office, and any other Ministry unit listed in the legal instrument requiring the source testing) must be advised, in writing (via email, fax, normal mail or courier) at least fifteen (15) days in advance of any proposed compliance testing (O. Reg. 419/05, Section 11(1)). If a shorter notice is required, contact the source testing specialist for guidance.
The proposed source testing strategy needs to be supported by terms of reference, in the form of a pre-test plan, with relevant process and test information. Following the submission and approval of the pre-test plan (by the Ministry’s Standards Development Branch), a minimum of fifteen days notice is required (O. Reg. 419/05, Section 11(1)) prior to the source testing. Also note that the pre-test plan needs to be submitted electronically, to the Ministry’s Standards Development Branch (email: source.testing@ontario.ca), and to any other Ministry unit requiring the testing or required to be notified by the legal document imposing the condition to test.
Note that the Ministry’s Standards Development Branch (SDB), or any other unit within the Ministry, is not responsible for the distribution of documents required to be submitted to the Ministry. The legal instrument, requiring the source testing, should be consulted to determine the recipients of the documents and the party responsible to distribute them.
The source test must be performed following the conditions stated in the Certificate of Approval, or as stated by any other legal instrument. If required, source testing staff from this Ministry’s Standards Development Branch must be allowed to tour the process, inspect the sampling site and witness the sampling tests.
It should be noted that there are instances where there is a need to improve the emissions data quality; such as, under the “emission refinement” concept of O. Reg. 419/05. Under this “emission refinement” concept, testing must be conducted comprehensively across a full range of operating conditions as according to Section 11(1)(2) of O. Reg. 419/05.
The source (for each set of operating conditions, if applicable) must be tested three times, sequentially, under similar process conditions after reaching steady state operation. The average of the three test results should be used to determine compliance and/or to refine the emissions data for that tested source.
A complete final report, prepared as outlined in this code’s Part A, Chapter 9, must be submitted to this Ministry’s Standards Development Branch and to the appropriate Ministry’s District or Area Office, within 90 days after completing the source test or within the time frame required by the Certificate of Approval condition or any other legal instrument.
The final source testing report needs to be submitted electronically and in hardcopy, to both the Ministry’s Standards Development Branch (electronically to: source.testing@ontario.ca) and the appropriate Ministry District Office. If a copy of the final report is required to be submitted to the Environmental Assessment and Approvals Branch, the recipient of the final report will be the Certificate of Approval Review Section’s applicable Unit (Air & Noise, Waste, or Water & Wastewater).
As the Ministry is limited to 10 MB for routine email, if the electronic copy of the report exceeds 10 MB, access to the Ontario Government’s Enterprise Email Services will be needed. When the source testing report is ready to be submitted, an email needs to be sent to the Ministry’s Standards Development Branch, to provide the required invitation to access the Enterprise Email Service.
4.1 Compliance Test under O. Reg. 419/05
Under O. Reg. 419/05, a facility has options on providing emission rates based on the quality of emission data. Under this data quality approach, two of the conditions that require source testing are highlighted in the following Chapters 4.1.1 and 4.1.2.
4.1.1 Highest Data Quality
Ontario Regulation 419/05 makes specific reference to the use of source testing for the purposes of determining an emission rate for use with an approved dispersion model. Specifically, paragraph 2 of Section 11(1), with respect to source testing must be met in order for the data to be considered of the highest data quality:
- The testing must be conducted comprehensively across a full range of operating conditions;
- The testing must be conducted according to a plan approved by the Director as likely to provide an accurate reflection of emissions;
- The Director must be given written notice at least fifteen (15) days before the testing and representatives of the Ministry must be given an opportunity to witness the testing; and,
- The Director must approve the results of the testing as an accurate reflection of emissions.
It is important to note that the testing must be conducted across a range of operating conditions, such that the potential variability in emissions with production rate or operating conditions can be determined. Examples of this could include tests at “maximum” and “typical” production rates, tests with and without a supplementary process operating (if this is a plausible scenario) and/or tests with varying products or production materials. It should be noted that consideration of variations in processing rates and operating scenarios could result in a number of permutations and combinations.
The testing must also be conducted according to an approved pre-test plan, the Ministry must be given the opportunity to witness the testing, and the Director must accept/approve the results. Proponents are strongly encouraged to contact the Technology Standards Section Manager, at the Ministry’s Standards Development Branch, for guidance in selecting the operating conditions for testing and confirmation/approval that the testing will satisfy Section 11(1) paragraph 2 of O. Reg. 419/05, prior to completion and submission of the pre-test plan.
4.1.2 Above Average Data Quality
The use of source testing to estimate emission rates is, in most cases, consistent with paragraph 1 of Section 11(1) of the O. Reg. 419/05 when:
- Source tests are validated; and,
- Source testing at one specific operating condition.
Validated source testing conducted at one specific operating condition is anticipated to provide above-average data quality of emission rate estimate.
Note: The most current version of O. Reg. 419/05 is required to be used when O. Reg. 419/05 is quoted by any Ministry issued legal instrument.
5.0 Pre-test Requirements
A preliminary survey should be conducted before proceeding to execute a source testing program. The following areas should be covered in the preliminary survey:
- Source and Process Information;
- Source Test Area Information; and,
- Preparation of Pre-test Plan (Attachment 2).
A brief outline of the information needed in each of these three areas is given below.
5.1 Source and Process Information
Prior to source testing, the source testing supervisor or leader should tour the plant in order to familiarize him or herself with the process and to collect and evaluate the pre-test information. From the evaluation of this information, the supervisor will be able to define the process conditions which must be maintained during the test and the modifications required at the sampling site to carry out a proper source test. The supervisor’s conclusions and recommendations regarding these matters must be discussed with the production personnel and the responsible company official for their concurrence.
The Ministry’s Standards Development Branch should be notified of any pre-test meeting in order to resolve any potential disagreement and to ensure a mutually satisfactory sampling program. The Ministry representative may participate in the meeting, if necessary.
5.2 Source Test Area Information
The North American Industry Classification System (NAICS) code (or codes) is required to be specified in this portion of the pre-test plan.
In this chapter, provide a brief description of the process under investigation and a flow diagram. The description should cover the type of process (cyclic, batch or continuous), the rate or capacity at which the process is normally run, the design rate of the process equipment and the temperature, pressure, characteristics of the contaminants and gas flow rates at which the contaminants are emitted in the atmosphere, the frequency of start-ups and shutdowns for continuous processes and an action plan for handling upset situations should also be mentioned.
This information is required to properly plan the sampling location, the number of points to be sampled, and to ensure that the location selected is free of flow disturbances and meets Part B requirements of this Code.
To accurately locate the point of emissions of the sources to be tested, provide the geographical coordinates of the sources to be tested. Two approaches can be used: latitude/longitude system, or the Universal Traverse Mercator (UTM) system. The UTM system provides coordinates (in meters) on a world wide flat grid for easy computation; while, the latitude/longitude system provides the location (in angles, minutes or arcs, and seconds of arcs) based on the Prime Meridian (Greenwich) and the Equator, as the reference planes.
The test area information also provides the source testing supervisor with the opportunity to personally verify the physical characteristics of the source (site) in order to evaluate potential test locations, considering such factors as:
- Safety related issues at the stack sampling site;
- Shelter for stack team personnel;
- Accessibility to the sampling location;
- Sampling platform space and scaffolding requirements; and,
- Availability of necessary power sources.
Note: It is suggested that the source testing supervisor check that the sampling platform and its access are in compliance with the Ontario Ministry of Labour (MOL) requirements and regulations if any.
5.3 Preparation of Pre-Test Plan Document
The pre-test plan document should cover:
- Relevant process information;
- Appropriate stack gas sampling details; and,
- Equipment and Methods to be used in stack gas sampling.
A copy of the “Guidebook to Prepare a Pre-Test Plan Document” along with its set of forms is provided in Attachment 2 for the user. The pre-test plan should be prepared in accordance with this guidebook.
5.3.1 Appropriate Process Information
This chapter of the pre-test plan should indicate the relationship of the source or process under investigation to the overall or other plant process (i.e., other lines or processes that may affect the emissions of the source or process under investigation).
5.3.2 Appropriate Stack Gas Sampling Details
The stack gas sampling portion of the pre-test plan should cover the location of the sampling points (supported with a diagram) and minimum number of sampling points needed for the stack test as per Part B. Also, the stack gas velocity and flowrate have to be determined as per Part C.
5.3.3 Equipment and Methods Used for Gas Sampling
The pre-test plan document should indicate which methods will be used for sampling specific contaminants (e.g., particulate matter, SO2, NOx, volatile organic compounds (VOCs), etc.). It should be noted that molecular weight of the stack gas (dry basis) and its moisture content must be determined as per Parts D and E respectively.
Specific methods to be used for determining the concentration of particulate, SO2, NOx, CO, VOCs, O2, CO2, among others, are listed in Attachment 1.
6.0 Conducting a Source Sampling Test
A source sampling test is performed in order to measure the emissions of an air contaminant from an industrial operation or a process. The rate and magnitude of these emissions vary with changes in the production rate and the process operating parameters and pollution abatement device. It is therefore crucial for the proper interpretation of the test results that all parameters affecting the emissions be closely monitored during the execution of the source sampling.
Standardized forms provided within individual methods should be used to ensure that all required information is obtained. Models of the formats to be used in the field, laboratory and calculations are included in the various methods. Ink should always be used to record data. Source testing field data sheets and process data sheets should clearly indicate the date and the “clock” time that the test took place.
7.0 Quality Assurance and Quality Control
7.1 Planning the Test Program
A Quality Assurance/Quality Control (QA/QC) program should define the objectives and functional activities designed to achieve accurate and representative data from a sampling program or a source sampling test. Detailed and specific QA/QC activities should be developed for each test program, based on the specific reference method being used.
7.2 Chain-of-Custody Procedure for Source Sampling
As part of the overall quality assurance activities associated with collection and analysis of source samples, particular attention should be directed to the handling of the sample and the analysis report.
Source test results, and the sample itself, are used to prove the compliance status of the facility. The test results should show that they accurately represent the conditions that prevailed at the time the test was conducted. This proof requires the demonstration of the following:
- The sample being collected properly;
- The sample being handled properly;
- The sample being analyzed in accordance with specified test procedures and the calculated results documented; and,
- The test report being prepared completely and accurately.
Failure to comply with these requirements may be grounds for the Ministry’s Director to reject the results.
For typical formats of forms used for laboratory, container labels, and on the chain-of- custody receipts, refer to Parts B to H of this document or to the specific reference sampling method being used.
7.3 Frequently Encountered Errors in Source Sampling
The errors involved in the application of all methods described in this code are, in most cases, random in nature and will vary from source to source and from sampling team to sampling team. The computation procedure for the estimation of these random errors is given in the literature
In addition to these random errors, errors of bias may be associated with methods for specific contaminants due to either poor collection efficiencies or errors associated with the analytical techniques. If such errors exist, they are discussed in the description of the individual methods.
When sampling for particulate matter, metal emissions, organic compounds emissions, or gaseous emissions with moisture saturated streams; it is important to sample the gas stream isokinetically as sub- and super-isokinetic sampling would result in over or under estimation of the contaminant emission respectively.
To obtain a representative sample for calculating the contaminant emission rate, it is of utmost importance to position the sampling ports at a suitable location. Failing to take into account the impact of flow disturbance before and after the sampling location can affect the results.
Also, it is necessary to separate the sample from the parent stream without creating a disturbance and to avoid any physical and chemical changes in the contaminants collected from the gas sample that may alter its characteristics.
8.0 Sampling Methods For Measuring Stack Gas Contaminants
This Code is comprised of test Methods ON-1 to ON-7 which describes the apparatus and techniques used to conduct source testing. Limitations on the applicability of the methods are stated within each method.
A list of acceptable reference test methods for the determination of the emission rates and concentrations of other contaminants is given in Attachment 1. Where no reference method is listed, or an alternate method is proposed, the Ministry’s Source Assessment Specialists need to be contacted for guidance.
A testing protocol (that includes the reference test method used, deviations and modifications to the reference, and sampling strategies), encompassed in the pre-test plan, needs to be agreed upon between the source operator, source tester and the Ministry’s Source Assessment Specialist to ensure that a common understanding is reached on what is the acceptable test protocol for a particular application, under a particular set of operating conditions.
9.0 Reporting Requirements
Data collection is the responsibility of the stack sampler or consultant. The source testing supervisor should ensure that the process and test data is collected and recorded accurately and completely, and included in the final report along with all pertinent process information recorded during testing.
Source testing reports need to be submitted to the Ministry’s Standards Development Branch, to the appropriate District or Area Office, and any other Ministry unit listed in the legal instrument requiring the testing, within 90 days after completion of the test (or within the time frame stated in the Certificate of Approval or any other legal instrument, as it may apply) and should contain the information required in the reference method(s). The final report should also include a list of problems and process upset conditions encountered during testing, deviations from the prescribed method(s), and their potential impacts on the final result.
Source testing report organization is provided in Attachment 2, Chapter 7.
The source testing reports, sent to Ministry, are required to be submitted electronically and in hardcopy. The electronic copy is intended to expedite receiving and processing source testing reports.
Note that in those cases that submission of documents are required by other units within the Ministry, you are directed to follow instructions on submissions from the issuer of the request.
Electronic routine email (external and internal) is limited to 10 MB. If the electronic copy of the report exceeds 10 MB, you will need to access our Enterprise Email Services. When the source testing report is ready to be submitted, you will be required to send an email to the Source Assessment Specialist, for him or her to provide you with the necessary invitation to access the Enterprise Email Service.
10. Limitations To Source Testing
It is recognized that there will be many processes and situations which may limit the application of the methods described in this code, such as:
- Corrosive or highly reactive components;
- High vacuum or pressure;
- High gas temperature;
- High gas moisture content;
- High and low gas velocity;
- Very small and very large duct cross-sections;
- Complex flow patterns; and,
- Fluctuations in velocity, particulate loading, and temperatures, due to uncontrollable process variations
The following are guidelines to overcome some of these adverse conditions:
- Corrosive or Highly Reactive Components – Use special materials such as glass, quartz or Teflon.
- High Vacuum Sources – (found before exhaust fans and high natural draft stacks). Operation of sampling train pump before and after probe insertion to avoid escaping of the impinger solution into the filter holder; gas volume drawn before and after insertion should not be included in sample volume.
- High Pressure Sources – Port sealed tightly yet allowance for freedom of movement of the probe; e.g., gas valve and packing gland incorporated in port.
- High Temperature Source – Quartz probe liner or water cooled probe with temperature control to avoid cooling below dew point; shielded and aspirated thermocouple.
- High Moisture Content Source – Probe temperature maintained above the dew point; probe sheathed with insulation layer within an outer layer to prevent droplets from impinging on the actual probe, creating cooling via evaporation; locate filter between third and fourth impinger (Method ON-5).
- High Velocity Source – Sampling site is relocated or duct or stack expanded to reduce velocity; pumps of sufficient capacity to maintain the required sampling rates are used.
- Low Velocity Source – In the range of 1.5 to 3.0 m/s (5 to 10 ft/s) an inclined manometer with a scale of 0 to 0.6 kPa (0 to 2.4 in.H2O) is used; below 1.5 m/s (5 ft/s), the sampling site is relocated or the duct constricted to increase the velocity.
11.0 References
- Alberta Environment, Alberta Stack Sampling Code, Publication # Ref.: 89, ISBN: 0- 7732-1406-2, 1995.
- Alberta Environment, Methods Manual for Chemical Analysis of Atmospheric Pollutants, Second Edition, 1981.
- Environment Canada, Pollution Measurement Division, Health and Safety Guidelines for Source Testing, November 1994.
- Environment Canada, Reference Method EPS 1/RM/8, Reference Methods for Source Testing: Measurement of Releases of Particulates from Stationary Sources, December 1993.
- Ministry of Environment and Energy, Province of Ontario, Source Testing Code, Version 2, Report # ARB-66-80, November 1980.
- Ministry of Environment, Lands and Parks, Province of British Columbia, Stationary Emission Testing Code, Version 1, September 1994.
- State of Oregon, Department of Environmental Quality, Source Sampling Manual, Volumes I and II, January 1992.
- United States Environmental Protection Agency, Code of Federal Regulations, Title 40 Part 60, Appendix A, Method 1, July 1. 1994.
- United States Environmental Protection Agency, Quality Assurance Handbook for Air Pollution Measurement Systems, Volume III, Stationary Source Specific Methods, EPA-600/4-77-027
Footnotes
- footnote[1] Back to paragraph Brenchley, D.L., Industrial Source Sampling, Ann Arbor Science Publishers, Inc., Ann Arbour Michigan, 1973.