By Gregory Salata, Ph.D., Kelso, WA

Many sampling programs include collection and analysis of an equipment blank to ensure there is no contribution of contaminants from the sampling equipment and associated process. To establish that sample collection procedures are contaminant free, an equipment blank is often collected. Equipment blanks are collected by passing water through the sample collection apparatus or utensil and collecting the water into the appropriate containers. To ensure that the water itself is contaminant free, the laboratory will supply the field crew with deionized (DI) water.

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On September 13, 2004, the EPA promulgated Maximum Achievable Control Technology (MACT) emissions standards for industrial boilers. Emission limits were established for total selected metals (TSM), mercury (Hg), and hydrochloric acid (HCl). The heat content and moisture content of the fuel is also discussed in the rule. The regulations include site-specific fuel analysis plans to demonstrate compliance. The regulations specify approved procedures for sample collection, sample processing, sample preparation, and chemical analysis. The approved methods are shown in Table 6 of the boiler MACT rule. The regulations also allow the use of equivalent methods and alternative methods. In order to meet site-specific emission limits, equivalent and alternative methods are often used in the fuel analysis plan. When alternative test methods are used a written request seeking approval of its use must be submitted to the EPA. The compliance date for these industrial boilers is September 13, 2007. Compliance can be demonstrated by fuel testing or with stack testing in combination with fuel testing.

This article is divided into two parts: recommended solid fuel testing techniques and recommended stack testing techniques for compliance with boiler MACT regulations.

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