Attachment 2 – FGSARAN TTU 

Attachment 2 

FGSARANTTU 

40 CFR 63 

MACT Performance Test Plan 

The Dow Chemical Company 

Midland, Michigan 

June 30, 2008 
Attachment 2 – FGSARAN TTU 

Page 1 

Table of Contents 

MDEQ TEST PLAN CHECK LIST

SECTION DESCRIPTION PAGE

1 Identification and Description of Source 2 

2 Description of Air Pollution Control Equipment 4 

3 Applicable Permit Number 5 

4 Identification of Pollutants to be Measured 5 

5 Description of Sampling Method 6 

6 Detailed Sampling and Analytical Procedures 6 

7 Sampling Conditions and Runs 9 

8 Block Flow Diagrams 9 

9 Estimated Flue Gas Condition 10 

10 Projected Operation Conditions 11 

11 Description of Process and Control Equipment to be Collected During Testing 11 

12 

Description of Any Monitoring Data to be Collected During the Test Period and 

Subsequently Reported 11 

13 Chain-of-Custody Procedure 11 

14 Field Quality Assurance and Quality Control Procedures 12 

15 Laboratory Quality Assurance and Quality Control Procedures 12 

16 Test Personnel 14 

 
Attachment 2 – FGSARAN TTU 

Page 2 

Introduction 

The Dow Chemical Company (Dow) is submitting this test plan supporting performance testing to be 

conducted in order to demonstrate compliance with 40 CFR 63, Subpart GGG and FFFF standard 

requirements. 

For consistency and to ensure that the proper test methods and procedures are implemented during 

testing, The Dow Chemical Company is submitting this test plan. The test plan is arranged according to the 

Michigan Department of Environmental Quality (MDEQ) Air Quality (AQD) Format for Submittal of 

Source Emission Test Plans and Reports (February 2008) guidance document. 

http://www.michigan.gov/deq/0,1607,7-135-3310_4106_5778---,00.html 

Sampling will be performed in strict accordance with 40 CFR 60, Appendix A test methods. There 

will be two variations. The inlet OHAP sample will not be corrected for spike recovery. This is a 

conservative measure because the inlet sample will not be corrected. This provides a worst cast denominator 

value for the DRE calculation. The inlet flow rate will be obtained by process instrumentation. EPA 

Methods 1 through 4 can not be safely performed on the inlet stream. 

Section 1 – Identification and Description of Source 

This section provides information pertaining to the identification and a brief description of the source 

to be tested. 

1A. CONTACT INFORMATION: 

Jim McGee 

The Dow Chemical Company – 

Michigan Operations 

1790 Building 

Midland, MI 48667 

Phone: (989) 636-2435 

Email: wmcgee@dow.com 

Jamie Dole 

The Dow Chemical Company – 

Michigan Operations 

1790 Building 

Midland, MI 48667 

Phone: (989) 636-5895 

Email: jsdole@dow.com 

1B. DESCRIPTION OF INDUSTRIAL PROCESS 

The Dow Chemical Company operates a chemical manufacturing facility in Midland, Michigan. 

This facility consists of numerous different chemical manufacturing processes. These chemical 

manufacturing processes include the 827-Building Process Unit (FGRule290) that is subject to provisions of 

40 CFR 63, Subpart GGG and the SARAN® Process Unit (EG35 & FGSARAN TTU) that is subject to the 

provision of Subpart FFFF. 

The 827-Bldg pharmaceutical manufacturing facility located at 827-Building is subject to Subpart 

GGG. This facility uses the SARAN® thermal treatment unit (TTU) to control process vent emissions. The 
Attachment 2 – FGSARAN TTU 

Page 3 

SARAN® TTU incorporates a halogen/halide scrubbing system that includes a water scrubber column 

followed by a caustic scrubber column. The SARAN® TTU also controls streams from the SARAN® Resin 

manufacturing. Emissions include vinyl chloride monomer from one process train, which is subject to 40 

CFR 41 Subpart F requirements, and vinylidene chloride monomer from the other process units, which will 

be subject to the 40 CFR 63, Subpart FFFF – MON MACT in 2008. Essentially all (99.9%) of the load to 

the TTU comes from SARAN®. 

For the purpose of conducting this performance test, the worst case emission scenario process vent 

emissions from both of the SARAN® manufacturing operations. 

1C. TYPE AND QUANTITY OF RAW AND FINISHED MATERIALS USED IN PROCESS

The 827-Bldg pharmaceutical process unit can manufacture a number of different pharmaceutical 

products on a batch campaign basis. The maximum mass loading of HAPs that 827-Bldg may generate and 

vent to the SARAN® TTU is insignificant compared to loading vented from SARAN® Resin manufacturing 

operations. Consequently, the worst case load to this SARAN® TTU is based on the HAP and organicchlorine load from the SARAN® Resin manufacturing unit. During testing, the worst case emission profile 

will be based on vinylidene chloride manufacturing. Samples will be collected while operations are 

manufacturing vinylidene chloride resin products. 

1D. DESCRIPTION OF CYCLICAL OR BATCH OPERATIONS THAT IMPACT EMISSION PROFILES:

The SARAN® TTU is a leveraged control device. The 827-Building HAP and halogen/halide load 

is insignificant in comparison to the load from the SARAN® Resin manufacturing process. The load is less 

then 0.1% of the total HAP load to the TTU. The worst case emission profile will be based on SARAN® 

Resin manufacturing process. 

The SARAN® Resin manufacturing uses the monomer vinylidene chloride (1,1 dichloroethene: 

C2H2Cl2) and vinyl chloride (chloroethene: CH2CHCl). Worst case organic-halogen load to the TTU occurs 

during the recovery step. Sampling will be coordinated so measurements are made during this step. 

1E. OPERATING PARAMETER REQUIREMENTS:

The table below outlines the basic operating parameters used to regulate these process units. 

Table 1.1 - Operating Parameter Summary

Process Unit HAP Control Equipment Parameter Limit 

827-Bldg PU HCl/Cl2, 

SARAN TM PU C2H2Cl2, CH2CHCl 

HCl/Cl2

SARAN® TTU 

• firebox 

• water scrubber 

• caustic scrubber 

SARAN® TTU 

• fire box: minimum temperature – 985°C 

• scrubbing system: minimum flow rate – 

35 gpm, minimum flow rate – 28 gpm

minimum pH: 8 
Attachment 2 – FGSARAN TTU 

Page 4 

1F. PROCESS RATE:

The processing rate that results in the worst case emission profile occurs during the monomer 

recovery step. The worst case emission profile is discussed in greater detail in Attachment 3. Due to the fact 

that the 827-Bldg PU makes up less than 0.1% of the HAP loading to the control device, only the SARAN®

Process Unit is considered. 

Table 1.2 Processing Rate Summary

Process Unit HAP Control Equipment Worst Case Emission Profile Scenario 

SARAN® PU HCl/Cl2, 

C2H2Cl2, 

CH2CHCl 

SARAN® TTU Vinylidene chloride SARAN® Resin 

manufacturing recovery step generates the 

worst case HCl/Cl2 emission profile. 

Sampling to target 2 trains in this step. 

Section 2 – Description of Air Pollution Control Equipment 

This section provides a brief description of air pollution control equipment associated with the 

process unit. The table below includes a brief description of the pollution control equipment used to comply 

with these standards. The description includes: 

• control device description; 

• operation parameters; 

• rated capacity and efficiency; and 

• maintenance history over the last 3 months. 

Table 2 - Control Device Summary 

Control Device Operating Parameter Capacity 

3-Month Maintenance 

History 

SARAN® TTU – 

Burner 

minimum temperature = 985C 3 MM Btu/hr None 

SARAN® TTU – 

water scrubber 

minimum flow rate = 35gpm 2000 CFM 

SARAN® TTU – 

caustic scrubber 

minimum flow rate = 28 gpm 

minimum pH = 8 

2000 CFM 

A new blower is scheduled 

to be installed in June 2008. 

This blower should improve 

halogen scrubbing. 
Attachment 2 – FGSARAN TTU 

Page 5 

Section 3 – Applicable Permit Number & Emission Standards 

The table, below summarize the applicable SARAN® TTU permit citations. 

Table 3 - Renewable Operating Permit: List of facilities that vent to the SARAN® TTU 

Permit Numbers: MI-ROP-A4033 

Facility ROP Table Number Applicable Emission Standard 

827-Building Table F-1.18 

FGPHARMA 

Halide/Halogen Mass Removal Efficiency > 95% 

demonstrated during worst case emission profile 

conditions. 

827-Building Table F-1.7 FGRule290 827-Buiding operates in compliance with Michigan Air 

Rule R 336.1290 (Rule 290). There is no applicable

halide/halogen emission or removal standard specific to 

the SARAN® TTU process vents. 

564-Building Table E-1.25 EG35 564-Building SARAN® Resin manufacturing operations 

has no applicable halide/halogen emission or removal 

standard specific to the SARAN® TTU process vents. 

564-Building Table F-1.4 

FGSARANTTU 

564-Building manages the SARAN® TTU in compliance 

with the provisions of FGSARANTTU. This table has no 

applicable halide/halogen emission or removal standard 

specific to the SARAN® TTU process vents. 

564- Building Table F-1.9 

FGVinylchloride 

564 and 684-Buildings comply with 40 CFR 61, Subpart 

A, Subpart F, and Subpart V; and 40 CFR 63, Subpart J – 

Polyvinyl Chloride MACT. These regulations have no

applicable halide/halogen emission or removal standard 

specific to the SARAN® TTU process vents. 

564-Building Table F-1.30 (proposed) 

FGMON 

Halide/Halogen Mass Removal Efficiency > 99% & HAP 

>98% demonstrated during worst case emission profile 

conditions. 

Section 4 – Identification of Pollutants to be Measured

The table below lists all the pollutants to be measured during this performance test. 

Table 4 - Pollutants to be Measured 

Control Device Pollutants 

SARAN® TTU • Hydrogen Chloride: HCl 

• Chlorine: Cl2

• 1,1-Dichloroethene (Vinylidene Chloride): C2H2Cl2

• Chloroethene (Vinyl Chloride): CH2CHCl 

• Methyl Propenoate (Methyl Acrylate): C4H6O2
Attachment 2 – FGSARAN TTU 

Page 6 

Section 5 – Description of Sampling Method 

The table below provides a description of the sampling trains to be used to collect measurements and 

samples during the performance test. These methods will be performed according to the protocol listed in 

the appropriate Appendix A, 40 CFR 60 EPA Reference Test Method. Schematic diagrams can be found in 

the EPA Reference Test Methods. 

Table 5 - Sampling Method 

Regulation 

Control 

Device 

Sample/ 

Measurement

Sampling 

Location Sampling Method 

Water Scrubber 

Inlet 

EPA Method 26 

Caustic Scrubber 

Inlet 

EPA Method 26 

HCl, Cl2

Caustic Scrubber 

Outlet 

EPA Method 26A 

EPA Method 1 - 4 

Firebox Inlet EPA Method 18 – bag dilution 

method. Flow by process 

instrumentation. 

C2H2Cl2, 

CH2CHCl, 

C4H6O2

Caustic Scrubber 

Outlet 

EPA Method 18 and Method 25A 

– direct interface continuous 

sample extraction method. 

Subpart GGG & 

Subpart FFFF 

SARAN® 

TTU 

Flow Rate Caustic Scrubber 

Outlet 

EPA Methods 1, 2, 3 or 3A, and 4. 

Measurements will be collected 

during Method 26A sampling. 

 

Section 6 – Detailed Sampling and Analytical Procedures 

The sampling and analytical procedure to be followed during the performance test is designed to 

demonstrate compliance with the process vent standard requirement

As described in Section 1, the worst case emission profile with respect to OHAP & halogen/halide 

mass loading to the SARAN® TTU occurs during the SARAN® Resin monomer recovery step. The 

performance test will be conducted while the process unit is in the operating step that generates the worst 

case emission profile. The sampling procedure includes the following steps: 

1. Documenting the sample location dimensions and using the EPA Reference Method 1 Duct 

Dimension and Flow Disturbance Chart to determine traverse points. 

2. Collection volumetric flow rate measurements using EPA Reference Methods 1 thru 4 during 

Method 26A sampling at the caustic scrubber outlet location. Firebox inlet volumetric flow rate will 

be measured using process instrumentation. Safety concerns make using EPA Reference Methods 1 

through 4 not possible. 

3. For Method 26 and 26A sampling, one sampling train per location, per run, will be collected. A 

minimum of 3 runs will be collected. Each run will be a minimum of one hour in duration. Sampling 

trains per location will be coordinated so that collection is simultaneous. 
Attachment 2 – FGSARAN TTU 

Page 7 

4. For Method 18 inlet sampling, one sampling train per location, per run, will be collected in TedlarTM 

Bags diluted with nitrogen to prevent condensation. EPA Method 40 CFR 60, Appendix A, Method 

18 paragraph 8.2.1 Integrated Bag Sampling and Analysis, will be followed during sample 

collection. A minimum of 3 runs will be collected. Each run will be a minimum of one hour in 

duration. Sampling trains per location will be coordinated so that collection is simultaneous. 

5. For Method 18 and 25A outlet sampling, exhaust gas will be continuously extracted from the stack 

and transported through a heat-traced sample line to a mobile analytical laboratory. Sample gas will 

be routed to a gas chromatography system to measure 1,1-dichloroethylene and a flame ionization 

detector to measure total hydrocarbons. 

The methods provided in the table below will be used to collect samples for demonstration of 

compliance. Samples will be collected by an independent contractor. 

Table 6 - Sampling and Analytical Plan1

Sampling 

Location 

Sampling 

Method Sampling Plan Analytical Method Analytical Plan 

Firebox 

Inlet 

Method 18 Single point sampling with 

TedlarTM bags nitrogen. 

Method 18 – Gas 

Chromatography 

Method 18 Method 18 – Gas 

Chromatography 

Caustic 

Scrubber 

Exit 

Method 

25A 

Sample gas will be routed 

from the stack to a gas 

chromatography system 

and TOC CEMS located in 

a mobile laboratory located 

near the base of the stack. 

Method 25A – Total 

Hydrocarbons 

OHAP and MA stack gas 

concentration 

measurements will be 

made on-site using gas 

chromatography. 

TOC concentration 

measurements will be 

made using an FID 

CEMS. 

Firebox Exit Method 26 Single point sampling with 

standard impingers to 

compensate for condensate. 

Method 26 – Ion 

Chromatography 

Water 

Scrubber 

Exit 

Method 26 Single point sampling with 

standard impingers to 

compensate for condensate. 

Method 26A – Ion 

Chromatography 

Method 

26A 

Method 26A – Ion 

Chromatography 

Samples will be shipped 

off site to independent 

laboratories for analysis. 

Caustic 

Scrubber 

Exit Methods 1, 

2, 3, & 4 

Isokinectic sample 

collection. 

Method 1, 2, 3, & 4 

Flow Rate 

Measurements will be 

collected and 

summarized by the 

sampling firm. 

 

1

 June 30, 2008 – Page Revised. Table 6 Sampling Location description updated for the second and fifth rows to clarify 

the sampling location, and the Analytical Plan entry for the first row was updated to read “OHAP” instead of “HAP”. 
Attachment 2 – FGSARAN TTU 

Page 8 

Bag Dilution Technique 

Method 18, "Measurement of Gaseous Organic Compound Emissions by Gas Chromatography" will 

be used to determine the concentrations of OHAP in the sample gas. Method 18 uses a gas chromatograph

equipped with a flame ionization detector (GC/FID) to measure hydrocarbon compounds. Inlet samples will 

be measured using the Tedlar bag sampling procedures describe in Method 18 Section 8.2.1.4.2, Integrated 

Bag Sampling and Analysis, Second Alternative Procedure. This procedure involves collecting an integrated 

sample in a Tedlar bag that has been pre-filled with a known amount of nitrogen. A known amount of 

sample to be metered into the bag. This procedure will provide the desired dilution over the 1-hour period 

test run period. The bags will be analyzed on-site using a GC/FID. 

The GC to be used for the incinerator sampling will be equipped with a appropriate column and a flame 

ionization detector (FID). The FID signals will be processed using a PeakSimple chromatography data 

system (or equivalent system) operated out of a Window 2000 based PC system. The GC column ovens will 

be operated using a temperature program to provide adequate separation of the compounds of interest and 

timely elution of heavier compounds. Nitrogen will be used as the carrier gas. All instrument components in 

contact with the sample gas will be made of stainless steel, Teflon, or glass and will be heated to prevent 

condensation. The contents of the sample loop will be injected onto the GC columns and the sample analysis 

will be initiated approximately every 14 minutes. Certified compressed gas standards will be used to 

calibrate the GC. 

The calibration gases will provide information to be used to speciate, identify specifically and quantitate 

compounds in the samples. The GC will be calibrated directly using these gases to establish linearity across 

the ranges of concentrations found in the stack gas. Linearity of the FID response will be determined using 

three different calibration gas concentrations. A least-squares equation (y = mx + b) will be calculated from 

this calibration. 

The mid-level gas for each compound will be analyzed after the bags are analyzed. If this post-test check is 

not within 5% of the initial calibration curve, the three-point calibration will be repeated and the combined 

pre and post-test calibration data will be used to calculate concentrations. If this post-test check is within 5% 

of the initial calibration curve, the initial calibration curve will be used to calculate concentrations. Due to 

the high level of the sample, spiking of the bags will not be performed. A low spike recovery would allow a 

correction to increase the sample results and thus increase the inlet loading, therefore assuming 100 percent 

recovery is a conservative approach for the inlet samples and DRE determinations. The concentrations of 

hydrocarbons in the samples will be corrected to a dry basis for reporting purposes. 

Calibration gas certification sheets, sample chromatograms, the sample run log, and calibration QA/QC will 

be included in the appendix of the report. 
Attachment 2 – FGSARAN TTU 

Page 9 

Section 7 – Sampling Conditions and Runs 

The table below summarizes the number and length of sampling runs which will constitute a 

complete test. 

Table 7 - Test Condition Summary2

Control Device 

Condition 

Number Runs Operating Condition Summary 

SARAN® TTU 1 3 Samples will be collected during maximum SARAN® 

Resin recovery step – target 2 units in step. A run will 

consist of one sampling train. One sampling train will 

be located at each of the four sampling locations. 

Section 8 – Block Flow Diagrams 

The following figures illustrate block flow diagram for this process unit. Dimensioned sketches 

showing all sampling ports in relation to breeching and upstream and downstream gas flow disturbances are 

illustrated in Figure 8. Flow rate measurements will be made at traverse points according to the duct diagram 

grid below. 

 

2

 June 30, 2008 – Page Revised. Table 7 Operating Condition Summary column heading and information was updated 

to correct two typographical errors. Heading on last column changed from “Condition Operation Conditions Summary” 

to “Operating Condition Summary,” and the number of samples taken in this column was changed from “three” to 

“four”. 
Attachment 2 – FGSARAN TTU 

 Page 10 

Figure 8 - SARAN® TTU Schematic Diagram

Fire Tube

Flow

Caustic

Scrubber

Sampling

Ports

Quench

HCl/Cl2 Inlet Sample Port

Outlet Sample Point Data:

Diameter = 8.5 in

Velocity ~ 34.7 ft/sec

Flow Rate ~ 49,000 acfhr

Flow Rate ~ 49,000 scfhr

Temp ~ 70 F

H2O ~ 2 %

CO2 ~ 3%

O2 ~ 15%

N2~ 82%

Water

Scrubber

Packing

OHAP Inlet 

Sample Port

SARAN® Resin Production

827-Bldg Process Unit SARAN® 

TTU

827-Close Vent System

water

scrubber

caustic

scrubber

atmosphere

quench 

column

Section 9 – Estimated Flue Gas Condition 

The Table below summarized the flue gas conditions. 

Table 9 - Estimated Flue Gas Conditions 

Process Stack ID Flue Gas Parameter 

FGSARAN 

TTU 

SV35101 Gas velocity ~ 2000 afpm 

Flow rate ~ 49,000 acfhr & scfhr (note, minimum standard correction) 

Temperature ~ 70 °F 

Major gas stream component concentrations: ~2% H2O, ~4% CO2, ~ 15% 

O2, and ~ 81% N2
Attachment 2 – FGSARAN TTU 

 Page 11 

Section 10 – Process Operation Conditions 

The projected process operating conditions during which the performance test will be run are 

summarized in the table below. 

Table 10 - Projected Process Operation Conditions 

Process Projected Process Operating Condition 

FGSARANTTU Samples collection will coincide with worst case the 

halide/halogen worst case emission profile. SARAN®

Resins recovery step – target 2 units in step for worst 

case HAP load 

Section 11 – Description of Process and Control Equipment to be Collected During 

Testing 

A description of process and control equipment to be collected during the performance test is 

summarized in the table below. 

Table 11 - Process Data Collected During Testing

Operating Parameters 

Process Parameter Unit minimum or 

maximum Note 

827-Bldg 

(SARAN® TTU) 

process step 

SARAN®-TTU temperature 

SARAN®-TTU quench flow 

SARAN®-TTU water flow 

SARAN®-TTU caustic flow 

SARAN®-TTU pH 

NA 

°F 

gpm 

gpm 

gpm 

NA 

NA 

minimum 

NA 

minimum 

minimum 

minimum 

Process step disclosure 

may be confidential 

business information 

requiring separate cover 

disclosure 

Section 12 – Description of Any Monitoring Data to be Collected During the Test 

Period and Subsequently Reported (e.g., CEMS) 

This section is not applicable to this performance test. This process unit is not required to 

incorporate any monitoring data collection such as continuous emission monitoring systems (CEMS) into 

unit operations. 

Section 13 – Chain-of-Custody Procedure 

The independent firm contracted to manage and execute sample collection, sample analysis, and 

report generation will manage Chain-of-Custody (COC) procedure use. Samples will be logged prior to 

shipment. A copy of the Chain of Custody will remain with Dow and a copy will be sent with the samples, 

to the analytical laboratory. Copies of the COCs will be provided in the test report appendix.
Attachment 2 – FGSARAN TTU 

 Page 12 

Section 14 – Field Quality Assurance and Quality Control Procedures 

Specific data quality objectives for each measurement are presented in the table below. The 

sampling and analytical procedures to be used are standard EPA Methods. Each method has minimum 

quality control checks. Adherence to the prescribed QC procedures will ensure data quality meets applicable 

method standards.

Table 14 - Process Field QAQC Summary 

Sample 

Matrix 

Target 

Compound EPA Method Field QAQC Methodology 

HAP (C2H2Cl2, 

CH2CHCl) & 

VOC (C4H6O2) 

Method 18 

THC Method 25A 

System Calibration 

Line Bias checks 

Response time 

Method 26 

Gas 

HCl/Cl2

Method 26A 

Filed Blanks: 

• HCl: H2SO4 Impinger 

Solution; 

• Cl2: NaOH Impinger 

Solution 

Section 15 – Laboratory Quality Assurance and Quality Control Procedures 

Laboratory QAQC 

Personnel performing field and laboratory activities will be responsible for continually monitoring 

compliance with the quality assurance objectives outlined in the applicable EPA Method. 

All sampling and analytical procedures are EPA or ASTM published methods. Calibration of 

analytical instrumentation to acceptable limits will be in accordance with the applicable EPA or ASTM 

method. Calibration and sample spike analytical records and associated log notes will be supplied in the 

appendix to the final test report. 

The TRC project manager will be responsible for conducting a review to determine whether all 

requirements for analytical activities have been fulfilled and that complete records exist. Each analytical 

data set will be peer reviewed and then checked by a QA/QC officer. A summary of applicable QAQC 

checks will be supplied in the final test report. This summary will include: 

• Test Method; 

• Calibration Results; 

• QA Spike Recovery Results; 

• Field Blank Results; and 

• Duplicate Analysis Results. 
Attachment 2 – FGSARAN TTU 

 Page 13 

To ensure accurate results, strict quality assurance and control measures will be followed. All testing 

will be performed following standard EPA protocols as outlined in Title 40 Code of Federal Regulations Part 

60 Appendix A. The test data will be thoroughly documented and checked for completeness. 

Method 18 Inlet - Certified compressed gas standards will be used to calibrate the GC. The 

calibration gases provided information used to separate-, identify specifically and quantitate compounds in 

the samples. The GC will be calibrated directly using these gases to establish linearity across the ranges of 

concentrations found in the stack gas. Linearity of the FID response will be determined using three different 

calibration gas concentrations. A least-squares equation (y = mx + b) will be calculated from this calibration. 

The mid-level gas will be analyzed before and after each test run. If this post-test check is not within 5% of 

the initial calibration curve, the three-point calibration will be repeated and the combined pre and post-test 

calibration data will be used to calculate concentrations. The concentrations of hydrocarbons in the samples 

will be corrected to a dry basis for reporting purposes. If this post-test check is within 5% of the initial 

calibration curve, the initial calibration curve will be used to calculate concentrations. 

 Due to the high level of the sample, spiking of the inlet bags will not be performed. A low spike 

recovery would allow a correction to increase the sample results and thus increase the inlet loading, therefore 

assuming 100 percent recovery is a conservative approach for the inlet samples and DRE determinations. All 

other bags will be spiked per Method requirements. 

Corrective Action 

Any error, deficiency, deviation, or QC result that falls outside EPA Method established acceptance 

criteria will be investigated. The investigation of the issue and any corrective actions will be documented 

and reported to the project management. 

Data Acceptance 

To assess overall data quality, the completed data set for a compliance burn will be reviewed by the 

project manager. The project manager will review analytical data for completeness and preparing a QAQC 

summary report for submittal in the final test report. 
Attachment 2 – FGSARAN TTU 

 Page 14 

Section 16 – Test Personnel 

Dow will contract TRC Environmental to perform this test. TRC will manage and execute sample 

collection, sample analysis, QAQC, and report generation. Dow’s internal stack sampling resource is 

managed by Chuck Glenn. Mr. Glenn is a subject matter expert and will assist Dow in overseeing the 

execution of this test program. 

Chuck Glenn 

The Dow Chemical Company 

Texas Operations 

2301 Brazosport Bldg 

Freeport, TX 77541 

Phone: (979) 238-9109 

Email: CEGlenn@dow.com 

Mike Krall 

TRC Environmental 

2100 Kramer Lane, Suite 800 

Austin, TX 78758 

Phone: (512) 684-3417 

Email: mkrall@trcsolutions.com