Stack Testing for Dummies

At long last - the new book, Stack Testing for Dummies has emerged from the Wiley & Sons presses.  The book, authored by Dr. Scott Swiggard and Ron McCulloch of Golden Specialty, Inc., provides an overview of basic stack emissions testing principles and practices, and serves as a guide for environmental managers who purchase testing services.

This installment of the For Dummies series from Wiley Publishing covers:

• Air quality history, rules and the essential objectives of air emissions testing
• Major types of tests and test methods (manual, instrumental, continuous)
• Selecting a quality provider (accreditation, quality systems, capabilities and costs: both up-front and hidden)
• Elements of planning a test
• Online resources (technical and administrative)
• Common stack testing equations, unit conversions and physical constants

Proposed EPA Air Toxics Standards for PVC Production

• On April 15, 2011, the Environmental Protection Agency (EPA) proposed a rule to update emissions limits for air toxics from polyvinyl chloride production (PVC production).
• The proposal requires facilities that produce PVC to reduce emissions of harmful toxic airemissions, improving air quality, and protecting public health in communities where these facilities are located.
• Exposure to toxic air pollutants can cause respiratory problems and other serious health issues, and can increase the risk of developing cancer. In particular, children are known to be more sensitive to the cancer risks posed by inhaling vinyl chloride, one of the known carcinogens emitted by this source category.
• The rule proposes maximum achievable control technology (MACT) standards for major and generally available control technology (GACT) for area sources of PVC production.  Emissions sources addressed in the proposed rule include PVC process vents, stripped resin,equipment leaks, wastewater, heat exchangers, and storage vessels.
• The proposed rule would set emission limits and work practice standards for total organic air toxics, and also for three specific air toxics: vinyl chloride, chlorinated di-benzo dioxins and furans (CD/DF), and hydrogen chloride. This is a change from the 2002 rule, which set an emission limit for vinyl chloride, and used vinyl chloride as a surrogate for all other air toxics.
• PVC production includes the manufacture of resins that are used to make a large number of commercial and industrial products at other manufacturing facilities. These products include plastic end products, such as latex paints, coatings, adhesives, clear plastics, rigid plastics, and flooring.
• There are currently 16 major and one area source of PVC production facilities in eight companies in the United States, in eight states, as follows (with number of facilities in each state): Delaware (one), Illinois (one), Kentucky (one), Louisiana (six), Michigan (one), Mississippi (one), New Jersey (two), and Texas (four). There are no small businesses.
• PVC production does not include chemical manufacturing process units that produce vinyl chloride as the monomer, or other raw materials used in the PVC polymerization process.
• The annual emission reductions of the proposed rule are estimated to be 1,570 tons total HAP, including 135 tons of vinyl chloride, 33 tons of hydrogen chloride, and 0.022 gram CDDF.
• To determine the proposed emissions limits, EPA gathered information on PVC production through review of previously collected information, current literature, data from the National Emissions Inventory, and meetings and voluntary information submissions by industry and the industry trade association. Also, the Agency collected information from PVC production facilities using the authority under the Clean Air Act (Section 114), in the form of an electronic survey and requirement for emission testing of toxic air pollutants and toxic air pollutant surrogates,such as total hydrocarbons.
• The review of existing data and consideration of new data have resulted in proposed emission limits that are more stringent than those in the 2002 and 2007 rules.
• EPA estimates an overall total capital investment of $16 million, with an associated total annualized cost of $20 million, to meet the rule requirements.
• The proposed rule would replace the previous rule for larger emitting PVC production facilities (major sources) EPA issued in July 2002. That rule was vacated by the District of Columbia Circuit Court as a result of a petition. The proposed rule would also amend the existing air toxic rule for smaller emitting PVC production facilities (area sources) that EPA issued in 2007.
• EPA will accept comment on the proposal for 60 days after publication in the Federal Register.

Source: http://www.epa.gov/ttn/oarpg/t3/fact_sheets/pvcpropfs20110415.pdf

Golden Specialty was active in the Section 114 testing that led to the proposed rule.  For more information on how we can help meet your needs in this area, contact Scott Swiggard, PhD, QSTI (sswiggard@goldenspecialty.com; 713-306-2208) or Ron McCulloch, MS, QSTI (rmcculloch@goldenspecialty.com; 919-274-6299).

Professional Credentials in Air Emissions Testing

From the LinkedIn Environmental Consulting Professionals Group:

http://linkd.in/fI4kKt

To take root, professional environmental credentials seem to need a combination of 1) narrow purpose, 2) at least conceptual buy-in across the discipline, and 3) a regulatory driver.  As an air emissions testing professional, I had been a Qualified Environmental professional (QEP), but let that certificate lapse when I saw that it did not fit my particular situation, and had no motivating force other than my own desire to rise to a particular standard. 

In air emissions testing, the case of Qualified Source Testing Individual (QSTI) credentials has taken a somewhat different path.  The EPA has tried in somewhat varying forms over the last 20 years, to bring such a program to life, but it took a handful of dedicated practitioners more than 10 years of sustained efforts to gain traction and acceptance in the industry.  That traction further gave rise to an ASTM standard (D7036), which requires among other things, that practitioners' teams include qualified individuals (QIs).  QSTIs practicing within their particular subgroups meet the definition of QIs.  When a test method is not included in a QSTI subgroup, dedicated QI training and examination is necessary.

The latest and perhaps most significant brick in this pavement is an EPA rule that requires firms performing emission tests at Part 75-regulated facilities to comply with the ASTM D7036 standard.  This is expected to culminate in a requirement for these firms to be fully accredited in the standard.  With that, firms will have to be accredited and individuals will have to be qualified or certified as a part of that accreditation. 

Focused purpose and widespread industry acceptance lead to the machine's conception and put it into motion, but  regulatory requirement is the fuel that ultimately sustains the credential.

Golden Specialty is the first firm to attain interim ASTM D7036 accreditation, and is active in promoting the standard and assisting other firms in reaching this milestone.  For more information, contact Scott Swiggard, PhD, QSTI (sswiggard@goldenspecialty.com ; 281-984-7021) or Ron McCulloch, MS, QSTI (rmcculloch@goldenspecialty.com; 919-274-6299).