Golden Stack Testing Nuggets

EPA Proposes Changes to Clean Air Act Standards for Boilers and Incinerators

2011-12-05T06:02:00.001-08:00

WASHINGTON – The U.S. Environmental Protection Agency (EPA) is proposing changes to Clean Air Act standards for boilers and certain incinerators based on analysis, review and consideration of data and input from states, environmental groups, industry, lawmakers and the public.

The proposed reconsideration targets public health protection through significant reductions in toxic air pollutants, including mercury and soot, while increasing the rule’s flexibility and addressing compliance concerns raised by industry and labor groups.

The changes also propose to cut the cost of implementation by nearly 50 percent from the original 2010 proposed rule while maintaining health benefits. These standards are pursuant to requirements laid out in the 1990 Clean Air Act Amendments.

http://t.co/SeEyx8qg

Nitric Acid Plants: Proposed NSPS Revisions

2011-10-12T05:38:00.000-07:00

PROPOSED REVISIONS TO NEW SOURCE PERFORMANCE STANDARDS
(NSPS) FOR NITRIC ACID PLANTS

• On September 30, 2011, the U.S. Environmental Protection Agency (EPA) proposed to
strengthen air pollution limits for nitric acid plants. Most nitric acid is used to produce
fertilizer.

• The proposed standards, known as New Source Performance Standards (NSPS), would limit
emissions of nitrogen oxides (NOx) from new, modified, and reconstructed nitric acid plants.
NOx is a key ingredient in the formation of ground-level ozone (smog). It also contributes to
the formation of fine particle pollution.

• Currently, the NOx emissions limit is 3.0 pounds of NOx per ton of nitric acid produced. The
Agency is proposing to lower the limit to 0.50 pounds NOx per ton of nitric acid produced.
EPA estimates that this proposed rule would reduce NOx emissions from these facilities by
2,000 tons per year.

• Nitric acid plants are likely to use selective catalytic reduction (SCR) as the control
technology to meet these limits.

• There are an estimated 40 nitric acid plants in the US. This rule would only apply to those
facilities if they modified their production facilities. EPA estimates that six new facilities
will come on line over the next 5 years and be subject to these requirements.

• EPA will take public comment on the proposal for 45 days following publication in the
Federal Register. EPA will hold a public hearing, if one is requested.

EPA Fact Sheet:
http://www.epa.gov/ttn/oarpg/t3/fact_sheets/20110930NitricAcidNSPSfs.pdf

Proposed Rule:
http://www.epa.gov/ttn/oarpg/t3/fr_notices/20110930NitricAcidNSPS.pdf

Condensable Particulate Matter - Exceptions to the Rule

2011-08-15T05:07:00.000-07:00

With the recent revisions to Method 202 for condensable particulate matter (CPM), the US EPA included an exception to the requirement to extract the CPM filter (the secondary filter that is located between the “warm” and “cold” sections of the impinger train). The exception is subject to the following conditions:

1. The source temperature is less than 85°F;

2. Sampling is done using an in-stack filter (Method 17 or Method 201A)

3. The analytical laboratory is able to obtain a stable weight for the CPM filter (suggesting a lack of high vapor pressure sulfate species).

Sampling for CPM under essentially ambient stack conditions is somewhat unusual, and is not something the analytical laboratory is likely to expect. Testers collecting samples under these circumstances should take care to notify the laboratory, both on the chain of custody and by way of a separate note or phone call.

EPA Admits Error in Proposed Mercury MACT Rule

2011-05-25T12:35:00.000-07:00

May 25, 2011 - Power News (http://bit.ly/iC00D9):

The Environmental Protection Agency (EPA) has acknowledged in a letter to non-profit power trade organization Utility Air Regulatory Group (UARG) that it made a conversion error in the way mercury emissions data was calculated to set limits for the agency’s mercury maximum achievable control technology (MACT) floor in the proposed Mercury and Air Toxics Standards (MATS) rule.

EPA Assistant Administrator for Air and Radiation Gina McCarthy wrote that the error would be corrected and results presented within a week, but that the corrections were not expected to have an “appreciable impact” on the pollution controls required to meet the new standards.

The group had said in a May 6 letter to the EPA that the MACT rule is one of the "most far-reaching and expensive rules" the agency had ever proposed under the Clean Air Act. The EPA asked for information of "unprecedented size and scope," including historic information on hazardous air pollutants that required electric generating units to conduct more than $100 million of stack sampling for emissions.

The UARG said it was concerned that the EPA had not allotted enough time to review all the data collected. A review of the information in the "limited time" made available for public comment showed several errors that "warrant withdrawal of the current proposal, re-analysis of the data, and re-proposal once the errors have been addressed."

One glaring error regarding MACT standards for mercury was that the EPA concerned how the EPA converted historical emissions data to common emission units. "Specifically, the conversion factor EPA used to convert measurements reported in terms of lb/GWh to lb/MWh is incorrect by a factor of 1,000," the group asserted. "As a result, the emissions of the unit chosen as the single best performing mercury source are actually 1,000 times higher than those EPA assumed in setting the new source MACT limit for mercury."

The group also charged that the conversion error pervades EPA's mercury MACT floor analysis for existing units. "At least half of the 40 units identified as 'best performing' have actual emissions 1,000 times higher than EPA used in its MACT floor analysis."

The UARG also found errors in the EPA's MACT limits for mercury for units designed to burn coal. For units burning coal of more than 8,300 BTH/hour, the limit is 1.0 lb/10 BTU or 0.008lb/GWh. But the "required heat rate to convert from the proposed input limit to the proposed output limit is 8,000 BTU/KWh, which is unrealistically low value for a coal-fired power plant," the group said.

Addressing that concern, McCarthy said in her letter on Thursday that revised calculations resulted in only a slight increase of that limit, however, from 1.0 to 1.2 pounds per BTU. "We estimate that this change will lessen our expected mercury reductions by about half of a ton, not changing our projected 90 percent reduction from the mercury in the coal used by power plants."

McCarthy also acknowledged the UARG's concerns as "possible discrepancies" regarding the EPA's calculations, and she said the EPA would "fully consider" the UARG's comments and other comments provided during the comment period.

"We have revised these mercury calculations and will include them in the docket this week to ensure that this information is publicly available," she wrote. "We do not expect this change to have any appreciable impact on the controls that will be needed for compliance or on the analyses underlying the proposal."

Sources: POWERnews, EPA, UARG, www.vnf.com

Boiler MACT Effective Date Delayed...

2011-05-17T07:18:00.000-07:00

May 16, 2011 - The EPA has announced the next step on air toxics standards for boilers and certain incinerators. The agency is allowing time to seek and review additional public input on new standards. Potential compliance activities for the rule include work practice standards, fuel analysis (additional options currently under consideration) and performance testing (stack tests).

Boiler MACT site: http://www.epa.gov/airquality/combustion

Fact Sheet: http://www.epa.gov/airquality/combustion/docs/20110516nextstepfs.pdf

Notice: http://www.epa.gov/airquality/combustion/docs/20110516nextstep.pdf

Action:

On May 16, 2011, EPA announced its next step in allowing time to seek and review additional public input on the final standards for boilers and certain solid waste incinerators issued in February 2011.
Following the April 2010 proposals, the agency received more than 4,800 comments from businesses and communities, including a significant amount of information that industry had not provided prior to the proposals.
Based on this input, EPA made extensive revisions to the standards. For example, EPA made revisions to the proposed subcategories and to some of the proposed emissions limits.
In December 2010, EPA requested additional time for review to ensure the public’s input was fully addressed. However, the court granted EPA only an additional 30 days, resulting in the February 2011 final rules.
The agency is reconsidering the standards because the public did not have sufficient opportunity to comment on these changes, and, as a result, further public review and feedback is required to meet the legal obligations under the Clean Air Act.
EPA is also issuing a stay to delay the effective date of the standards for major source boilers and commercial and industrial solid waste incinerators. The stay will allow the agency to seek additional public comment before requiring thousands of facilities across multiple, diverse industries to make investments that may not be reversible if the standards are revised following reconsideration and a full evaluation of all relevant data.
The stay will remain in place until the proceedings for judicial review of these rules are completed or EPA completes its reconsideration of the standards, whichever is earlier.
EPA understands that members of the public may wish to submit additional data. Any additional data and information related to affected sources and their emissions that the public would like the agency to consider should be submitted by e-mail to combustionsurvey@erg.com by July 15, 2011.
This approach will help ensure that the final standards are protective, cost-effective, practical to implement and consistent with the requirements of the Clean Air Act.

EPA Revisions to Method 301 Validations

2011-05-16T06:52:00.000-07:00

On May 10, 2011 the U.S. Environmental Protection Agency issued a revision to its Method 301 Validation process. Method 301 is used when a source owner or operator proposes to use a new or alternative source emissions sampling method to meet an EPA compliance requirement for stack testing. The method specifies procedures for determining and documenting the precision and bias of measured concentrations from various media (e.g., sludge, exhaust gas, and wastewater) at the level of an applicable standard for a source.

Revised Rule: http://www.epa.gov/ttn/oarpg/t3/fr_notices/20110512method301.pdf.

Fact Sheet: http://www.epa.gov/ttn/oarpg/t3/fact_sheets/20110512method301fs.pdf

Method 301 affects/applies to you if you want to propose a new or alternative test method to meet an EPA compliance requirement.

You would use Method 301 whenever you propose to use a test method to meet an EPA compliance requirement other than a method required under a 40 CFR part 63 rule. The method specifies procedures for determining and documenting the precision and bias of measured concentrations from various media (e.g.,

sludge, exhaust gas, wastewater) at the level of an applicable standard for a source. Bias (or systemic error) is established by comparing your proposed method against a reference value. A correction factor is employed to eliminate/minimize bias. This correction factor is established from data obtained during your validation test. Methods that have bias correction factors outside a specified range are considered unacceptable. Method

precision (or random error) at the level of the standard must be demonstrated to be as precise as the validated method for acceptance.

EPA proposed five major technical changes to Method 301. These technical changes include the following:

Replacing the Practical Limit of Quantitation (PLQ) with a procedure to determine the Limit of Detection (LOD)
Revising the bias acceptance criteria and eliminating correction factors
Revising precision acceptance criteria when using analyte spiking
Allowing analyte spiking even when there is an existing test method
Establishing new procedures for ensuring sample stability

Other clarifications from EPA include:

Amendments to Method 301 do not apply to methods submitted for approval prior to promulgation.
Method 301 can be used whether or not a validated method exists.
Inadvertantly, in Section 5 of Method 301, “reference materials” was followed by “(analytes).” This parenthetical was modified for clarification purposes.
A few commenters expressed concern that the standard against which precision and bias are compared is not required to be compared against a true value, usually a traceable standard. EPA agreed that the reference material should be compared to a traceable standard.
EPA has approved methods demonstrated with sequential sampling to determine the precision of a proposed alternative method in the past. The final method explicitly states that sequential sampling procedures are allowed.
If an alternative method is being compared to a validated test method as part of the Method 301 validation and an audit sample for the validated method exists, then an audit should be used for the validated method.
Method 301 previously lacked specific procedures for ensuring that samples collected under proposed alternative methods were analyzed within an appropriate time. EPA revised Section 7.4 to include a requirement to calculate the difference in the sampling results at the minimum and maximum storage times, determine the standard deviation of the differences, and test the difference in the results for statistical significance by calculating the t-statistic and determining if the mean of the differences between the initial results and the results after storage is significant at the 95 percent confidence level. The method will continue to require a precision of ± 20 percent when only the required three runs per test are performed. However, EPA have added an option to allow test methods with a precision greater than ± 20 percent, but less than ± 50 percent, provided that the user collect nine sample runs per test during any compliance testing where the method is used.
EPA proposed to replace the Practical Limit of Quantitation (PLQ) determination with a procedure to determine the Limit of Detection (LOD), and clarified the terms and equations for that procedure.

Stack Testing for Dummies

2011-04-26T07:03:00.000-07:00

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

2011-04-25T07:04:00.000-07:00

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

2011-04-24T18:15:00.001-07:00

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).