- Table 25 to Subpart UUU of Part 63—Requirements for Performance Tests for Inorganic HAP Emissions From Catalytic Reforming Units
As stated in § 63.1567(b)(2) and (3), you shall meet each requirement in the following table that applies to you.
| For each new and existing catalytic reforming unit using . . . | You shall . . . | Using . . . | According to these requirements . . . | 1. Any or no control system | a. Select sampling port location(s) and the number of traverse points | Method 1 or 1A (40 CFR part 60, appendix A), as applicable. | (1) If you operate a control device and you elect to meet an applicable HCl percent reduction standard, sampling sites must be located at the inlet of the control device or internal scrubbing system and at the outlet of the control device or internal scrubber system prior to any release to the atmosphere. For a series of fixed-bed systems, the outlet sampling site should be located at the outlet of the first fixed-bed, prior to entering the second fixed-bed in the series. | (2) If you elect to meet an applicable HCl outlet concentration limit, locate sampling sites at the outlet of the control device or internal scrubber system prior to any release to the atmosphere. For a series of fixed-bed systems, the outlet sampling site should be located at the outlet of the first fixed-bed, prior to entering the second fixed-bed in the series. If there is no control device, locate sampling sites at the outlet of the catalyst regenerator prior to any release to the atmosphere. | b. Determine velocity and volumetric flow rate. | Method 2, 2A, 2C, 2D, 2F, or 2G (40 CFR part 60, appendix A), as applicable. | c. Conduct gas molecular weight analysis. | Method 3, 3A, or 3B (40 CFR part 60, appendix A), as applicable | d. Measure moisture content of the stack gas | Method 4 (40 CFR part 60, appendix A) | e. Measure the HCl concentration at the selected sampling locations | Method 26 or 26A (40 CFR part 60, appendix A). If your control device is a wet scrubber or internal scrubbing system, you must use Method 26A | (1) For semi-regenerative and cyclic regeneration units, conduct the test during the coke burn-off and catalyst rejuvenation cycle, but collect no samples during the first hour or the last 6 hours of the cycle (for semi- regenerative units) or during the first hour or the last 2 hours of the cycle (for cyclic regeneration units). For continuous regeneration units, the test should be conducted no sooner than 3 days after process unit or control system start up. | (2) Determine and record the HCl concentration corrected to 3 percent oxygen (using Equation 1 of § 63.1567) for each sampling location for each test run. | (3) Determine and record the percent emission reduction, if applicable, using Equation 3 of § 63.1567 for each test run. | (4) Determine and record the average HCl concentration (corrected to 3 percent oxygen) and the average percent emission reduction, if applicable, for the overall source test from the recorded test run values. | 2. Wet scrubber | a. Establish operating limit for pH level or alkalinity | i. Data from continuous parameter monitoring systems | Measure and record the pH or alkalinity of the water (or scrubbing liquid) exiting scrubber every 15 minutes during the entire period of the performance test. Determine and record the minimum hourly average pH or alkalinity level from the recorded values. | ii. Alternative pH procedure in § 63.1573(b)(1) | Measure and record the pH of the water (or scrubbing liquid) exiting the scrubber during coke burn-off and catalyst rejuvenation using pH strips at least three times during each test run. Determine and record the average pH level for each test run. Determine and record the minimum test run average pH level. | iii. Alternative alkalinity method in § 63.1573(c)(2) | Measure and record the alkalinity of the water (or scrubbing liquid) exiting the scrubber during coke burn-off and catalyst rejuvenation using discrete titration at least three times during each test run. Determine and record the average alkalinity level for each test run. Determine and record the minimum test run average alkalinity level. | b. Establish operating limit for liquid-to-gas ratio. | i. Data from continuous parameter monitoring systems | Measure and record the gas flow rate entering or exiting the scrubber and the total water (or scrubbing liquid) flow rate entering the scrubber every 15 minutes during the entire period of the performance test. Determine and record the hourly average gas flow rate and total water (or scrubbing liquid) flow rate. Determine and record the minimum liquid-to-gas ratio from the recorded, paired values. | ii. Alternative procedure for gas flow rate in § 63.1573(a)(1) | Collect air flow rate monitoring data or determine the air flow rate using control room instruments every 15 minutes during the entire period of the initial performance test. Determine and record the hourly average rate of all the readings. Determine and record the maximum gas flow rate using Equation 1 of § 63.1573. | 3. Internal scrubbing system or no control device (e.g., hot regen system) meeting HCl outlet concentration limit. | Establish operating limit for HCl concentration. | Data from continuous parameter monitoring system. | Measure and record the HCl concentration in the catalyst regenerator exhaust gas using the colormetric tube sampling system at least three times during each test run. Determine and record the average HCl concentration for each test run. Determine and record the average HCl concentration for the overall source test from the recorded test run averages. Determine and record the operating limit for HCl concentration using Equation 4 of § 63.1567. | 4. Internal scrubbing system meeting HCl percent reduction standard | a. Establish operating limit for pH level or alkalinity | i. Data from continuous parameter monitoring system | Measure and record the pH alkalinity of the water (or scrubbing liquid) exiting the internal scrubbing system every 15 minutes during the entire period of the performance test. Determine and record the minimum hourly average pH or alkalinity level from the recorded values. | ii. Alternative pH method in § 63.1573(c)(1) | Measure and in record pH of the water (or scrubbing liquid) exiting the internal scrubbing system during coke burn-off and catalyst rejuvenation using pH strips at least three times during each test run. Determine and record the average pH level for each test run. Determine and record the minimum test run average pH level. | iii. Alternative alkalinity method in § 63.1573(c)(2) | Measure and record the alkalinity water (or scrubbing liquid) exiting the internal scrubbing system during coke burn-off and catalyst rejuvenation using discrete titration at least three times during each test run. Determine and record the average alkalinity level for each test run. Determine and record the minimum test run average alkalinity level. | b. Establish operating limit for liquid-to-gas ratio | Data from continuous parameter monitoring systems | Measure and record the gas entering or exiting the internal scrubbing system and the total water (or scrubbing liquid) flow rate entering the internal scrubbing system every 15 minutes during the entire period of the performance test. Determine and record the hourly average gas flow rate and total water (or scrubbing liquid) flow rate. Determine and record the minimum liquid-to-gas ratio from the recorded, paired values. | 5. Fixed-bed gas-solid adsorption system. Gas-solid | a. Establish operating limit for temperature | Data from continuous parameter monitoring system | Measure and record the temperature of gas entering or exiting the adsorption system every 15 minutes. Determine and record the maximum hourly average temperature. | b. Establish operating limit for HCl concentration | i. Data from continuous parameter monitoring systems | (1) Measure and record the HCl concentration in the exhaust gas from the fixed-bed adsorption system using the colormetric tube sampling system at least three times during each test run. Determine and record the average HCl concentration for each test run. Determine and record the average HCl concentration for the overall source test from the recorded test run averages. | (2) If you elect to comply with the HCl outlet concentration limit (Option 2), determine and record the operating limit for HCl concentration using Equation 4 of § 63.1567. If you elect to comply with the HCl percent reduction standard (Option 1), determine and record the operating limit for HCl concentration using Equation 5 of § 63.1567. | 6. Moving-bed gas-solid adsorption system (e.g., Chlorsorb TM System) | a. Establish operating limit for temperature | Data from continuous parameter monitoring systems. | Measure and record the temperature of gas entering or exiting the adsorption system every 15 minutes. Determine and record the maximum hourly average temperature. | b. Measure the chloride level on the sorbent entering and exiting the adsorption system. | Determination of Metal Concentration on Catalyst Particles (Instrumental Analyzer Procedure) in appendix A to subpart UUU; or EPA Method 5050 combined either with EPA Method 9056, or with EPA Method 9253; or EPA Method 9212 with the soil extraction procedures listed within the method. 1 | Measure and record the chloride concentration of the sorbent material entering and exiting the adsorption system at least three times during each test run. Determine and record the average weight percent chloride concentration of the sorbent entering the adsorption system for each test run. Determine and record the average weight percent chloride concentration of the sorbent exiting the adsorption system for each test run. |
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1 The EPA Methods 5050, 9056, 9212 and 9253 are included in “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication SW-846, Revision 5 (April 1998). The SW-846 and Updates (document number 955-001-00000-1) are available for purchase from the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402, (202) 512-1800; and from the National Technical Information Services (NTIS), 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. Copies may be inspected at the EPA Docket Center, William Jefferson Clinton (WJC) West Building (Air Docket), Room 3334, 1301 Constitution Ave. NW., Washington, DC; or at the Office of the Federal Register, 800 North Capitol Street NW., Suite 700, Washington, DC. These methods are also available at