METHOD 6C - DETERMINATION OF SULFUR DIOXIDE

EMISSIONS FROM STATIONARY SOURCES

Applicability and Principle

A sample is continuously extracted from the effluent stream portion of the sample stream
and conveyed to an instrumental analyzer using either ultraviolet (UV), nondispersive
infrared (NDIR), or fluorescence for the determination of SO2 concentrations.
Performance specifications and test procedures are provided to ensure reliable data.

The 2006 revisions to EPA Method 6C failed to properly address issues related to
"quenching" when fluorescence based analyzers are used for the determination of SO2
emissions. Accordingly, when a fluorescence based analyzer is used, BTS requires the
calibrations gas concentrations comply with the specifications of the prior version of
Method 6C, with the details specified in the "Proposed Deviations from this BTS
Template or the Method" section of this Template. The following paragraph indicates the
calibration gas specifications from the prior version of Method 6C:

For fluorescence-based analyzers, the O2 and CO2 concentrations of the calibration gases
as introduced to the analyzer shall be within 1 percent (absolute) O2 and 1 percent
(absolute) CO2 of the O2 and CO2 concentrations of the effluent samples as introduced to
the analyzer. Alternatively, for fluorescence based analyzers, use calibration blends of
SO2 in air and the nomographs provided by the vendor to determine the quenching
correction factor (the effluent O2 and CO2 concentrations must be known).

The principle of detection to be used during the test program will be

_____________________.

Apparatus

A measurement system for Sulfur Dioxide that meets the specifications in Section 13.0 of
this method will be used. Dual range analyzers may be used when needed, provided that
both ranges meet all the quality assurance requirements of this method. When an analyzer
is routinely calibrated with a calibration span of less than or equal to 20 ppmv, the
manufacturer's stability test (MST) is required (Table 7E-5 of Method 7E) prior to testing
and documentation will be included in the test report.

The Sample Probe will be glass, stainless steel, or equivalent, of sufficient length to
traverse the sample points. The sampling probe shall be heated to prevent condensation.

The Sample Line will be heated (sufficient to prevent condensation) stainless steel or
Teflon® tubing, to transport the sample gas to the moisture removal system.

The Moisture Removal System will be a refrigerator-type condenser or similar device to

continuously remove condensate from the sample gas while maintaining minimal contact
between the condensate and the sample gas. If a wet-basis system is being proposed,
details will be included at the end of this template in the protocol submittal.
The Sample Transport Lines will be stainless steel or Teflon tubing, to transport the
sample from the moisture removal system to the sample pump, sample flow rate control,
and sample gas manifold.

A Calibration Valve Assembly with a three-way valve assembly, or equivalent, for

introducing calibration gases either directly to the analyzer in direct calibration mode, or
into the measurement system at the probe in system calibration mode, will be utilized.
When in the system calibration mode, the system must be able to flood the sampling
probe and vent excess gas.

A Particulate Filter, either an in-stack or heated (sufficient to prevent water condensation)

out-of-stack filter will be used. All filters will be fabricated of materials that are
nonreactive to the gas being sampled. If an out-of-stack filter is used, it will be included in
the system bias test.

A Leak-free Pump, to pull the sample gas through the system at a flow rate sufficient to
minimize the response time of the measurement system will be used. The pump will be
constructed of any material that is nonreactive to the gas being sampled.

The Recorder will be a computerized data acquisition system, digital recorder or data
logger used for recording measurement data. The minimum data-recording requirement
is one measurement value per minute. A strip-chart recorder can only be used as a back-
up system.

Analytical Span and Calibration Gases

The span of the monitoring system is equivalent to the high-level calibration gas value
(see below) and will be selected such that to the extent practicable, the measured
emissions will be between 20 – 100% of the selected calibration span. In practical terms,
the span is selected such that a pollutant gas concentration equivalent to the emission
standard is not less than 30% of the span. If at any time during the run the measured gas
concentration exceeds the readable range of the analyzer, the run may be considered
invalid. If the average of any run exceeds the calibration span value, the run is invalid.

Allowable = __________ lb/hr MW = 64 lb/lbmole

Stack Flow = __________ dscfm

The in-stack concentration based on the emission standard and stack flow parameters is

(lb/hr) x (387 x 106) = __________ ppm.

(MW) x (dscfm) x 60

Note: when actual concentrations differ significantly from the standard, the span may
need to be modified accordingly, such that the method criteria for span selection are met.
Determining the emission standard is the first step in approximating the necessary span.

The high-level calibration gas sets the calibration span and results in measurements
being (to the extent practicable) equivalent to 20 to 100 percent of the span. Based on the
calculation above, the high-level gas (span) concentration to be used during the source
test will be ______________.
The mid-level calibration gas will be equivalent to 40 to 60 percent of the span. The
mid-level calibration gas concentration to be used during the source test will be
_______________.

The low-level calibration gas will be less than 20 percent of the calibration span. A zero
gas meeting the definition of "zero air material" in 40CFR72.2 may be used. The low-
level gas concentration to be used during the source test will be ______________.

The calibration gases will be SO2 in N2, SO2 in air or a calibration gas mixture, as
indicated in Section 7.1 of the method. The calibration gases will be (check one):

___ Certified within an uncertainty of 2.0 percent in accordance with "EPA

Traceability Protocol for Assay and Certification of Gaseous Calibration
Standards" (EPA Protocol gases). If a zero gas is used for the low-level gas,
it will meet the definition of "zero air material" in 40CFR72.2, as opposed to
being an EPA Protocol gas.

___ Blended gas mixtures meeting the protocol above, provided that the
additional gas components are shown not to interfere with the analysis.

___ Calibration gases will be prepared from EPA Protocol gases using Method
205. Separate procedures for Method 205 will be included in the protocol.
Note: Part 75 applications require EPA approval for the use of Method 205.

Analyzer Calibration

The analyzer calibration error check (or system calibration test for dilution systems)
will be conducted by introducing the low-level, mid-level, and high-level gases to the
analyzer (or through the entire measurement system, introduced at the probe, for a
dilution system). During this check, no adjustments to the system will be made except
those necessary to achieve the correct calibration gas flow rate at the analyzer. The
analyzer responses to each calibration gas will be recorded. The analyzer calibration
error check will be considered invalid if the gas concentration displayed by the analyzer
exceeds ±2 percent of the span for any of the calibration gases, or > 0.5 ppmv absolute
difference.

The sampling system bias check will be performed by introducing first an upscale gas
(mid-range or high-level, whichever more closely approximates the stack concentration)
at the calibration valve assembly installed at the outlet of the sampling probe, and then
the low-level gas. During this check, no adjustments to the system will be made except
those necessary to achieve the correct calibration gas flow at the analyzer. This check
will be considered invalid if the difference between the calibration bias check and the
calibration error check for the same calibration gas exceeds + 5% of the span, or > 0.5
ppmv absolute difference.

During the initial sampling system bias check, the measurement system response time
is determined, as detailed in Sections 8.2.5 and 8.2.6 of Method 7E.

Documentation that an interference check has been conducted in accordance with Section
8.2.7 of Method 7E will be available on-site and will be included in the final test report.
Any specific technology, equipment or procedures intended to remove interference
effects will be operating properly during the stack test. The Alternative Interference
Check listed in Section 16.1 of Method 6C may be used instead.

Stratification Determination

Prior to sampling, or as part of the first test run, a stratification check must be performed
in accordance with Section 8.1.2 of Method 7E. If more than one instrumental method
that requires a stratification check is being performed, the stratification check need only
be done on one of them. A stratification check is not required for stacks < 4 inches in
diameter.

The stratification check will be conducted at either (1) twelve traverse points selected in a
accordance with EPA Method 1, or (2) three traverse points spaced on a line passing
through the centroidal area at 16.7, 50.0 and 83.3 percent of the measurement line. Each
point will be sampled for a minimum of twice the response time.

The minimum number of traverse points required for sampling will be determined as
follows. If each traverse point differs from the mean by no more than the least restrictive
of:

Difference from mean Stratification Class Number of required sample

points
+ 5% or + 0.5 ppm Unstratified A single point that most
closely matches the mean.
Between + 5% and + 10%, or between Minimally stratified Three (3) sample points spaced
+ 0.5 ppm and + 1.0 ppm at 16.7, 50.0 and 83.3 percent
of the measurement line. *
Greater than + 10% and greater than Stratified Twelve (12) sample points
+ 1.0 ppm located consistent with EPA
Method 1 criteria.

* For a minimally stratified stack with an internal diameter greater than 2.4 meters (7.8
feet), the three sampling points may be located at 0.4 meters (1.3 feet), 1.0 meters (3.28
feet) and 2.0 meters (6.56 feet) along the measurement line showing the highest average
concentration. This option will only be available if the stratification check consisted of
twelve points.

Emission Measurement Test Procedure

The sampling probe will be placed at the first sample point and sampling will begin at the
same rate used during the bias check. A constant rate + 10 percent will be maintained
during the entire sample run. Sampling will commence only after twice the response
time has elapsed. Sampling will be conducted for an equal length of time at each traverse
point.

Immediately following the completion of the test period and hourly during the test period,
the low-level calibration gas and an upscale calibration gas (the mid-level or high-level as
appropriate) will be re-introduced one at a time to the measurement system at the
calibration valve assembly. No adjustments to the measurement system will be made
until both the low-level and upscale bias and drift checks are made. The analyzer
response will be recorded. If the bias values exceed the specified limits, the test results
preceding the check will be invalidated and the test will be repeated following corrections
to the measurement system and full recalibration. If the drift values exceed the specified
limits, the run may be accepted but the test measurement system will be fully recalibrated
and the results reported using Eqn. 7E-5b (Eqn. 7E-5a if a non-zero gas is used for the
low-level calibration gas) of Method 7E.

Measurement System Performance Specifications

Drift, less than or equal to ±3 percent of the span value for the low-level or upscale gas.
Sampling System Bias, less than or equal to +5 percent of span value for the low-level
or upscale gas. Calibration Error, less than or equal to ±2 percent of span for each
calibration gas.

An alternative acceptance criteria for each of these measurements is less than or equal to
+ 0.5 ppmv absolute difference.

Emission Calculation

The average gas effluent concentration will be determined from the average gas
concentration displayed by the gas analyzer and is adjusted for the zero and upscale
sampling system bias checks, as determined in accordance with the procedures specified
above. The average gas concentration displayed by the analyzer may be determined by
averaging all of the effluent measurements indicated by the data acquisition system for
the test run. The minimum frequency for data recording will be one-minute averages
during the run. A chart recorder will only be used as a backup to the data acquisition
system. The effluent gas concentration will be calculated using Eqn. 7E-5b (Eqn. 7E-5a if
a non-zero gas is used for the low-level calibration gas) of Method 7E.

CMA
Cgas = (Cavg – Co) ____________ Eqn. 7E-5b
CM – Co

CMA - COA
________________
Cgas = (Cavg – CM) + CMA Eqn. 7E-5a
CM – Co

Emissions will be presented in the following units:

___________________________________.

Proposed Deviations from this BTS Template or the Method

(Insert any proposed deviations here)