Brian Mellor

About Brian Mellor

Brian Mellor works with Environmental Source Samplers, Inc. (ESS), an environmental consulting firm specializing in stack testing, CEMS Testing, and EPA air emissions compliance.

ESS has conducted international stack testing projects at Johnson Atoll, in the Philippines, the Dominican Republic, Hong Kong, and various parts of Europe. If you need a team that will do your international job with efficiency and effectiveness, call ESS at (910) 799-1055 or visit www.ESSKnowsAir.com.

Air Quality Control in Vietnam

Air Pollution Challenges in Vietnam

Air Pollution Challenges in Vietnam

After 2 months staffed, the Representative Office for Environmental Source Samplers, Inc. (ESS) in Vietnam is excited about the opportunities and challenges in regards to the air quality situation in the country. Air quality in Vietnam in modern times is a significant concern, particularly in Ho Chi Minh city, a primary focus city for government initiatives for sampling and pollution control activities. Ho Chi Minh City has been targeted as a serious air pollution area, due primarily to issues related to industrial production, transportation, and construction.

Air Pollution Challenges

Among the challenges is the high level of air pollution in the inner cities and Suburbs, but there are improvements. Tran Nguyen Hien, Head of the Natural Resources and Environmental Protection Department in Ho Chi Minh City, said the results of air-quality monitoring in 2012 showed improvement from previous years. Concentrations of NOx, benzene, and lead dropped significantly to reach the initial promulgated standards. But dust (particulate) and CO2 concentrations remain higher than the permitted standard. There are a number of reasons for this. In urban areas, concentrations of CO2 typically exceed the targets due to areas with dense traffic and inadequate infrastructure, leading to frequent congestion and traffic jams. In suburban areas, particulate pollution often comes from the manufacturing operations of local businesses.

Mr. Phung Chi Sy, Deputy Director of the Institute of Tropical Technology and Environmental Protection, says that of existing factories, only 10% have exhaust treatment system that satisfy standards. Very few companies invest in gas treatment systems, and for the ones that do the technology is typically outdated, offering no guarantee for meeting emission requirements. Of the remaining companies, many are not interested in the costs related to investing in exhaust or gas treatment systems. Fines are often less than the cost of investment, and so many of these companies will simply choose to pay the fines if infractions are discovered by inspection teams.

Overcoming the Challenges

According to Mr. Tran, the Department of Natural Resources and Environment has submitted to the HCMC People’s Committee a plan for reinvestment and rehabilitation of equipment and systems to control air and surface water, including new investments in surface water monitoring stations and the renovation of two automatic air monitoring stations. At the same time, the Department is working with relevant agencies to accelerate solutions in traffic congestion and infrastructure, including reconstruction of the traffic system in the inner cities. The hope is that this will lead to a decrease in traffic congestion.

In the suburbs, the Department plans to strengthen inspection activities and to levy sanctions against those companies with emissions violations. The first step involves increasing fines on the highest bracket to where they provide a significant deterrent to organizations in violation of the emissions standards. At the same time, the city plans on compiling a registry of the most serious violators, particularly those established in residential areas.

The Department of Environmental Protection believes that their new initiative will provide the basics for a consistent solution to air-pollution, that will maintain consistency even in the event of a significant change of focus or direction in the country’s manufacturing goals. In the long term, the goal is to provide solutions that will bring a future of clean air and healthy atmosphere to the citizens of Vietnam, and Ho Chi Minh City in particular. For experienced distributors of control equipment, and air quality consultancy firms like ESS, it is a new chance to cooperate with and support the city for clean air quality and control.

ESS was established in 1979 and has a history of over 30 years of providing stack testing, and air-quality consulting services, both domestically in the United States and internationally. Headquartered in Wilmington, North Carolina, ESS has been a leader in international Air Quality projects, mobilizing globally toHungary, the Dominican Republic, Haiti, and Hong Kong, the Philippines and Vietnam.Should you have needs or requirements, both domestic and internationally, give ESS a call today: 910-799-1055.

More information on the news can be found at the following links:

Strengthening the Air Quality Control - Vietnam

Center for Environmental Monitoring Portal - Vietnam

Related Posts:

ESS Establishes and Staffs Office in Hanoi, Vietnam
ESS is Authorized Apex Equipment Distributor in Vietnam and SE Asia
ESS Attends World Bank Mission to Indonesia and Vietnam

ESS Establishes and Staffs Office in Hanoi, Vietnam

ESS Opens Office in Hanoi, VietnamEnvironmental Source Samplers, Inc. (ESS), an international air-quality consulting firm, has established its first official international representative office in Hanoi, Vietnam.  The commissioning of the Hanoi office marks a key stage in the execution of ESS strategy to capitalize on the growing demand for emissions testing and environmental consulting within the Southeast Asian region (see: ESS Attends World Bank Mission to Indonesia and Vietnam).  With the aim of obtaining clients and business in the region, ESS has hired two highly-qualified employees for the positions of Technical Sales Director and Sales Associate for the Hanoi office.

Mr. Nguyen Thai Lam is ESS-Vietnam’s Technical Sales Director.  Mr. Nguyen received his degree in Environmental Engineering from Hanoi University of Technology, Vietnam.  He has a decade of work experience for a variety of industrial sectors – covering engineering, project management, and the exploration and development of business opportunities.  Prior to joining ESS, Lam was employed as a Project Manager at Blue World Carbon as well as at AES Vietnam, where he progressed from Engineer to Regulatory Manager during the course of his employment.  He has knowledge and experience stemming from his involvement in many large-scale projects, including portfolio management and top-level consulting on carbon development for renewable energy projects.   Lam is dedicated to the challenge of learning and development, and has the goal of becoming an independent expert in the environmental field, with influence sufficient to change perceptions and behavior in regards to air quality and climate change in Vietnam and the surrounding region.

Assisting him in the position of Sales Associate is Ms. Dang Thi Thanh Tam.  Ms. Dang graduated from Hanoi Open University with a Bachelor’s Degree in Business Administration.  Prior to joining ESS, Tam worked with a number of International NGOs, coordinating multiple environmental projects with the World Bank Institute in Vietnam.   These projects concerned sustainable development, climate change, and raising public awareness in regards to environmental protection.  Tam also brings multinational and multicultural knowledge and experience to the office, having assisted in long-term voluntary projects working with foreign partners in Europe.  She joins ESS with the goal of contributing knowledge and capabilities to the company’s success as well as a desire to increase her own knowledge base for future endeavors.

The regional office in Hanoi, the opening of which was announced in December 2012, allows ESS to pair international expertise with local responsiveness in meeting the region’s air-quality needs. The ESS Hanoi office is excited by the upcoming opportunities and challenges presented by doing business in Vietnam and the surrounding region.

ESS was established in 1979 and has a history of over 30 years of providing stack testing and air-quality consulting services, both domestically in the United States and internationally.  Headquartered in Wilmington, North Carolina, ESS has a large client base in the Eastern United States, and in the past 18 months has performed emissions testing and monitoring projects in international venues such as the Dominican Republic, Haiti, and Hong Kong.

Contact ESS today to learn more about our air quality testing and consulting services in the U.S. and overseas:  910-799-1055.

Overcoming the Stack Testing Challenges of PM and Method 201a

Stack Test MethodologiesParticulate Matter (PM) is the term for solid or liquid particles found in the air – more accurately referred to as aerosols. Worldwide, most atmospheric aerosol particles (approximately 90%) are produced by ‘natural’ processes such as grinding and erosion of land surfaces resulting in dust, salt-spray formation in oceanic regions, biological decay, forest fires, chemical reactions of atmospheric gases, and volcanic injection. The balance of the PM is anthropogenic in source – from industry, agriculture, transport and construction. Particulate size, elemental breakdown and color can vary significantly between the many sources.

PM can have high levels of toxicity and is considered by the Clean Air Act as one of the Criteria Pollutants. Originally, the focus has been on Total Suspended Particulates (TSP), but over the past decade the EPA has put a greater emphasis on the measurement of smaller particles, those less than 10 and 2.5 microns in diameter (PM10 and PM2.5). This is due to the greater health risk associated with the smaller particles, which are capable of reaching into the lower regions of the respiratory system.

From an emissions sampling standpoint, this has increased the importance of quantifying emissions in specific size ranges, rather than the analysis of total filterable particulate (by EPA Method 5). The most widely accepted methodology for determination of PM10 and PM2.5 from stationary sources is Method 201a. This isokinetic method requires some of the same sampling equipment as Method 5, but includes the addition of sizing cyclone(s) upstream of the PM filter. What is not as well-known are the multiple challenges and limitations with Method 201a that can hamper testing or even make it unfeasible. Many of these challenges can be mitigated but require knowledge of the stack condition prior to the sampling date. Some of these major challenges are summarized below.

Test Port Size – As mentioned, the method requires a particular set of equipment: a probe (equipped with special pitot tube extensions and temperature sensor), in-stack PM sizing cyclone(s) and a nozzle. The cyclone and nozzle combination required for the method are typically stainless steel, inflexible, and have a wide circumference, often wider than the test ports installed in some of the older stacks. Method 5, typically, only requires 4″ test ports, but the 201a equipment requires a test port of 6″ minimum to fit the sampling probe inside, so a facility that is not prepared for 201a testing may find that its test ports are too small and testing cannot take place. Further, if the test port is long, an 8″ (minimum) test port may be required to prevent the nozzle from scraping the inside of the port wall. We urge our clients to properly verify test port configuration prior to our arrival on-site.

Moisture Level of the Stack (Saturated Stacks) – If water droplets are present in the stack, it is not possible to utilize the Method 201a cyclone. The spherical nature of PM is assumed when utilizing the Method 201a cyclone. If moisture is present, this can cause conglomerations of the PM and also cause the PM to stick to the cyclone walls. Additionally, the moisture-laden aerosol mists do not act spherically – thus biasing the results. The EPA-accepted measurement of fine particulates in saturated stacks is Method 5/202, which adds the total filterable PM and the condensable particulate matter (CPM). Although the US EPA has defined PM10 (or 2.5) in a saturated stack as the sum of the PM + CPM, it is clearly an overestimation of the stack emissions.

Temperature of the Stack – Another challenge with the method is dealing with the heat of the gas stream inside of the stack. If the stack gas temperature is over 30 degrees C (85 F), then the Facility must account for the measurement of CPM by Method 202. Therefore, PM10 (or 2.5) is measured as the sum of the filterable fine fraction plus the CPM.

Some of the equipment used in typical 201a trains has a temperature limit of approximately 260 degrees C (500 F) before problems occur with seizing, galling, or thermal breakdown. The method can be used at temperatures of up to 1,371 degrees C (2,500 F) but, in order to do this, it requires the usage of specialty high-temperature resistant material, which generally must be procured or prepared beforehand, and which can drastically influence the price of the testing.

Other Sampling Options/Purpose of Sampling – ESS frequently conducts engineering testing for clients evaluating flue gas streams for particulate matter. The analysis of such streams can provide useful information to control device manufacturers, efficiency experts, and boiler engineers. Although EPA Methodology is required for demonstration of compliance, ESS typically recommends other sampling methodologies for engineering testing.

Such methodologies can include isokinetic sampling on specialty media and analysis utilizing x-ray diffraction, computer-controlled scanning, electron microscopy, or GC/MS scanning. ESS frequently provides in-depth particulate analyses including particulate sizing and elemental composition. Depending on the goals of the sampling, ESS will propose the best methodology to meet your required outcome.  Read more about Stack Test Methodologies ESS is qualified to conduct.

Summary – These factors – port size, stack moisture level, flue gas temperature, and the purpose of the sampling – are all important considerations for your PM test series. The Method 201a/202 test takes more preparation than many other emissions test and requires more communication between the facility and the professional stack testing company being used for the conduct of the test.

As in all things, experience is the key to success. ESS has conducted hundreds of tests for PM, CPM, PM10 and PM2.5 since 1979 and has the knowledge and experience to provide reliable and acceptable results for your engineering or compliance test program. If you require PM/PM10/PM2.5 testing – or other air emissions sampling services – give ESS a call today: 888-363-0039

ESS is Authorized Apex Equipment Distributor in Vietnam and SE Asia

Stack Testing ServicesEnvironmental Source Samplers, Inc. (ESS), an international air-quality consulting firm, is now an authorized distributor of Apex Instruments stack testing and monitoring equipment in Vietnam and the Southeast Asian region.

This distribution deal coincides with the commissioning and staffing of an ESS office in Vietnam, as part of a multi-pronged approach to providing air-quality consulting, monitoring, and emissions testing needs in the developing economies of Southeast Asia.

ESS was established in 1979 and has a history of over 30 years of providing stack testing, and air-quality consulting services, both domestically in the United States and internationally. Headquartered in Wilmington, North Carolina, ESS has a large client base in the Eastern United States, and in the past 18 months has performed emissions testing and monitoring projects in international venues such as the Dominican Republic, Haiti, Sweden, and Hong Kong.

Apex Instruments was established in 1988 and has more than 24 years experience in providing stack testing and monitoring equipment. Headquartered in Fuquay Varina, North Carolina, Apex has manufactured equipment for sampling emissions from industrial chimneys and smoke stacks using US-EPA guidelines. Apex equipment is designed by a staff of experienced stack testers who understand the compliance testing needs both in the United States and internationally, and has a distribution network that stretches around the globe.

ESS and Apex have 25 years experience of working together in the United States, and are excited by this new opportunity to leverage their joint strengths to service the air-quality needs of the new and developing economies in Vietnam, and elsewhere in Asia. But this push will not come at the expense of the same quality of domestic American service that has made ESS and Apex a leader in the emissions testing and air-quality consulting industry.

Should you have needs or requirements, both domestic and internationally, give ESS a call today: 910-799-1055

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NSHM Rule – Classification of Materials as Fuel or Waste for Combustion

Industrial PlantOn December 20, 2012, the US EPA promulgated several final rules for emissions standards for certain industrial boilers and incinerators. Also finalized at the same time was a rule that determines what standards apply to units that combust secondary materials, rather than traditional fuels. This rule is known as the Identification of Non-Hazardous Secondary Materials That Are Solid Waste (NSHM Rule), and it is important because the EPA determination of a particular fuel as a waste has ramifications for the unit in question. If a unit is firing a fuel determined as a waste, then it will be required to meet the more stringent standards for Commercial/Industrial Incinerators (CISWI), rather than the standards applicable to boilers, known under as MACT standards.

However, the criteria by which the EPA would determine whether a fuel is waste or non-waste has been very opaque since the outset, and early attempts to distinguish between the two categories were even a primary reason for earlier MACT and CISWI rules to be invalidated and vacated entirely. In 2011 EPA attempted to resolve this with the first NSHM rule, but again failed to establish clear and legally sound criteria for distinguishing between the fuel types. This led to the rule being reopened in March of 2011, the publishing of proposed changes in December of that year, and the Final Rule being promulgated in December of 2012.

The regulatory structure is one where the burden of proof is on the unit operator or owner of a unit firing secondary material to demonstrate that the fuel is not a waste, by demonstrating that it meets certain criteria to be a legitimate fuel, rather than the disposal of waste. For materials combusted by the generator (of the material) as fuels, these legitimacy criteria are demonstrated by whether the materials are:

  • Managed as a valuable commodity
  • Have sufficient heating value
  • Contain pollutants at levels comparable to or lower than a traditional fuel for the unit

For materials combusted by third parties (not the generator of the material), the material must meet those legitimacy criteria, and in addition must be either processed into non-waste by removing contaminants, or must be approved by a petition to the EPA.

Some materials that are combusted might be materials in the manufacturing process, and are known as ingredients. These ingredients can be defined as non-waste fuels by meeting a different set of legitimacy criteria.

  • In lieu of heating values, consider the contribution made by the material to the production or manufacturing process.
  • In lieu of evaluating inputs, the contaminant comparison is made by comparing the product produced using the secondary materials to products made using virgin materials.

Ingredient materials meeting these legitimacy criteria can be combusted by both the generator and third parties without requirement for processing or a petition.

Another step taken in the December 2012 rule was the creation of an additional mechanism to identify non-waste fuels by categorical determination. Under this aspect, the EPA may consider any relevant factor, and can list a material as a non-waste fuel even when it does not meet one or more of the legitimacy criteria. These listed fuels can then be combusted without making individual determinations that the fuel is legitimate. However, this mechanism does not apply to materials used as ingredients.

There are already four (4) categories of materials that have been established to not be wastes when combusted, they are:

  • Scrap tires that are not discarded and are managed under established tire collection programs
  • Resinated wood
  • Coal refuse recovered from legacy piles and processed in the same manner as currently generated coal refuse
  • Dewatered pulp and paper sludges that are not discarded and are generated and burned on-site by pulp and paper mills

Future potential categorical listings may also include construction and demolition wood, paper recycling residuals, railroad ties, and treated wood.

The compliance deadline for Boilers is three years, and for CISWI units is five years. Regardless, it is important to make the determination of fuel classification in the immediate, to prepare strategies for compliance with these new emission limits. If an operator combusts a waste after the compliance deadline for the CISWI, even if the waste is burned inadvertently, or if process data is not maintained on secondary materials being burned, then the unit would immediately become a CISWI and be regulated as such for six (6) months. Due to the more stringent requirements, in practical terms this means that many units would have to be shut down for that period of time.

In all aspects of compliance with MACT and CISWI, and other EPA rules and regulations, ESS has experience and the network to facilitate any air-quality needs. For assistance with topics from emissions testing to control device strategies, we are here to assist.  Please call our experts at (910) 799-1055.

Boiler MACT, CISWI, and NHSM Rule Updates

Boiler MACT, CISWI, and NHSM Rule UpdatesAdjustments to the Final Standards For Major and Area Source Boilers an Certain Incinerators

On December 20th, 2012, the U.S. EPA finalized a set of adjustments to Clean Air Act Standards for boilers and certain solid waste incinerators (CISWI). These adjustments to the standards came in response to public comment, petition, and critique following the initial finalization of the rules in March of 2011. The finalized adjustments and rule ostensibly represent an attempt to seek middle ground between the lessening of toxic air-pollutants, while providing a reprieve on the already-burdened industry in the slowly-recovering economy.

Unit-Specific Standards and Compliance

One set of adjustments in the finalized ruling revolve around the creation of new subcategories of specific types of units, in an attempt to provide appropriate regulations for a wide variety of unit types that have significant variations in use, fuels, and emissions output. Some new sub-categories include units that burn light/heavy industrial liquids, coal fluidized bed units, and dual-fuel fired boilers. In addition, certain area source boilers are being reconsidered based on seasonal or limited use, easing the compliance burden for less-frequently used units. These categorical regulations, along with adjustments made to emissions standards for pollutants including Particulate Matter (PM), Carbon Monoxide (CO), and Mercury (Hg), allow the EPA to estimate that most of the existing 1.5 million boilers operating in the United States will already be in compliance with the new standards, and many of those left can demonstrate compliance with work-practice standards, rather than performance tests.

Compliance Dates

Another of the adjustments deals with the dates that facilities must come into compliance with the new standards. For existing Area Source Boilers, initial notification has been extended to January 20, 2014, and the initial tune-up requirements for boilers subject to work practice standards have been extended to March 21, 2014. The date of initial compliance for all units has also been extended until March 21, 2014, as well, with the possibility of requesting an initial year if necessary to integrate the proper control equipment. For existing major source boilers, the date for initial compliance has been extended to early 2016, with an additional year upon request as needed. For CISWI units, existing incinerators have to comply no later than early 2018, while new incinerators will need to meet the standards 180 days following publication in the Federal Register.

Non-Hazardous Secondary Materials (Fuel versus Waste)

The final adjustments made to the NHSM rule represent another step in the long attempt by the EPA to properly define waste versus fuel, and how units are classified and subject to rules and different emissions limits as based on those classification. The classification of waste versus fuel will be a subject in an upcoming entry, but in short the new ruling allows for self-evaluation using certain “legitimacy criteria” — such as whether or not the materials are managed as a valuable commodity, have sufficient heating value, and contain Clean Air Act pollutants at levels comparable to or lower than a traditional fuel that the combustion unit is capable of burning.

Outreach

The EPA has announced its intention to partner with the US Department of Energy (DOE), through its regional Clean Energy Application Centers, to provide site-specific technical and cost information to the major source facilities currently burning coal or oil in their boilers. Technical experts will visit these facilities and discuss compliance strategies, information on potential funding and financing, and analysis of energy assessment and boiler tune-up options. The US Department of Agriculture (USDA) will likewise be reaching out to facilities that have boilers that burn biomass to make sure that operators understand the regulations and how they apply to the units in question.

More information on this program can be found at the following link:
http://www1.eere.energy.gov/manufacturing/states/pdfs/incentives_boiler_mact.pdf

For more information on the Final Standards, visit the following link:
http://www.epa.gov/airquality/combustion/actions.html

 

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New RICE Rules for MACT Standards and Compliance
Stack Testing Methods

Environmental Source Samplers to Open Office in Asia in 2013

Environmental Source Samplers, Inc.Air quality consulting firm Environmental Source Samplers, Inc. (ESS) announced that it will be opening an office in Vietnam in 2013, to capitalize on growing demand for emissions testing and environmental consulting within the Southeast Asian region.

Headquartered in Wilmington, North Carolina, ESS has been a leader in international Air Quality projects, mobilizing globally to Hungary, the Dominican Republic, Haiti, and Hong Kong within the last 14 months. The projects included air-monitoring and emissions testing for World Bank and local environmental requirements, process improvement, and vendor guarantees. Past international mobilizations have included other points in Europe, Central America, the Caribbean, and the Pacific Region, including a decommissioned munitions base in Johnston Atoll, and Relative Accuracy Test Audit (RATA) sampling in the Philippines.

The decision to open an office in Asia was made after developing relationships with the Public Sector Liason Officers for the World Bank, and Air-Quality conferences and missions in Hong Kong, Vietnam, and Indonesia. The events allowed ESS to gain an insider’s view into the region’s air-quality needs and priorities, and ESS management determined that there was both a sustainable market for air-quality analysis, and existing market conditions that would allow ESS to leverage its expertise in international project management and state of the art methodologies, in order to compete effectively.  (See: ESS Attends World Bank Mission to Indonesia and Vietnam.)

The regional office will allow ESS to pair international expertise with local responsiveness in meeting the region’s air-quality needs. ESS will utilize its staff of experienced, QSTI-certified project managers, along with regional technicians to assist. This strategy will lead to cost savings in labor, equipment, and shipping prices, while not sacrificing the quality of project execution and client deliverables. This will also enable ESS to provide much-needed knowledge transfer of emissions testing and monitoring methodologies to regional employees, enabling them to better serve their own communities as their countries and economies continue to develop.

ESS is excited by the upcoming opportunities and challenges the new office will bring in 2013, and expects to have another successful year, both internationally and with their established domestic clients in the United States.

Related Post:

International Stack Testing – Challenges and Solutions

ESS Attends World Bank Mission to Indonesia and Vietnam

Environmental Source Samplers, Inc. (ESS) president Mark Looney (pictured at left) recently attended a trade mission to Indonesia and Vietnam, from October 16th to the 26th, 2012. The mission, organized by the World Bank’s Private Sector Liaison Officers, offered the chance for an international delegation of companies to meet with representatives from the World Bank, Asian Development Bank, Millennium Challenge Corporation and the Governments of the two countries. The program presented a unique opportunity for ESS and other companies in attendance to learn first-hand about the business environment in Indonesia and Vietnam, as well as projects financed by the International Finance Institutions (IFIs).

The delegation kicked off in Jakarta, Indonesia from October 16th to the 20th, and traveled to Hanoi and Ho Chi Minh City, Vietnam from October 21st to 26th. Mission attendees were briefed on recent trends and prospects for the emerging and developing markets, methods for improving efficiency and ways to meet the demands of new consumer markets. They were also given an insider view of upcoming pipeline projects financed by the multilateral development banks and information on bank strategies to provide for sustainable development – finding the balance between economic growth and the protection of the natural environment that is frequently difficult to obtain in emerging and developing economies. In addition, the program provided a great opportunity for networking and forging contacts and relationships with other key players in international development and environmental protection.

As an emissions-testing firm with experience in international mobilizations, ESS actively pursues opportunities to develop relationships with international organizations, in the private sector as well as the multilateral development banks such as the IDB and ADB, and the program provided a great opportunity to develop strategies in moving forward.

Mr. Looney, upon completion of the mission, said: “The World Bank PSLO Mission to Indonesia and Vietnam has given us the chance to interact, within a small group setting, with many potential business partners in these target markets, including government agencies and regional business representatives. When developing relationships and opportunities within international and developing markets, an opportunity for personal interaction is invaluable. In two weeks in this mission, we feel that we have learned more about the market and its inner workings than could have been learned remotely in two years or more.”

Read the original PSLO/World Bank Press Release.

Also learn more about common challenges and solutions found with international projects and mobilizations.

 

Contact:

 

Mark Looney
Environmental Source Samplers, Inc.
436 Raleigh Street
Wilmington, N.C., 28412
910-799-1055
ess@essknowsair.com
http://www.ESSKnowsAir.com

 

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Subpart IIII

In a previous blog entry regarding the ZZZZ and JJJJ RICE Rules , we discussed the National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustions Engines (RICE NESHAP), and the New Source Performance Standards (NSPS) for Spark Ignition RICE Units, more commonly referred to as Subparts ZZZZ and JJJJ, respectively. There is another related rule that bears consideration, and that is Subpart IIII, the NSPS for Compression Ignition Internal Combustion Units (CI ICE).

There are two basic types of Stationary Reciprocating engines: spark ignition and compression ignition. Spark ignition engines use a spark, across a spark plug, to ignite a compressed fuel-air mixture. Typically, fuels for these engines are gasoline and natural gas. Compression ignition engines compress air to a high pressure, heating the air to the ignition temperature of the fuel, which is then injected. The high compression ratio used for compression ignition engines results in a higher efficiency than is possible with spark ignition engines. Diesel fuel oil is normally used in compression ignition engines, although there are dual-fueled varieties, where natural gas is compressed with the combustion air, and diesel oil is injected at the top of the compression stroke to initiate combustion.

The requirements of the Subpart IIII standards, particularly as they are related to performance testing, are dependent on the size of the engine, the manufacture date, the cylinder displacement, and whether it is used for emergency or non-emergency purposes. The EPA defines an emergency engine as one that is used for the purpose of maintenance checks and readiness testing, and is operated less than 100 hours per year. The owner of the emergency engine can NOT connect the engine to the grid under financial incentive and maintain the unit status as an emergency engine. Therefore, a peak shaving engine will not be classified as an emergency unit under the definitions of the Subparts.

For engines that are required to comply with Subpart IIII, including those engines located at Area Sources and engines less than or equal to 500hp located at Major Sources, there are no further requirements under the RICE NESHAP (Subpart ZZZZ). A Major Source is one that has the potential to emit 10 tons per year of any individual Hazardous Air Pollutant (HAP), or 25 tons per year of all HAPs. An Area Source is any source that is not considered a Major Source under this definition.

Regarding stack testing, an owner or operator of a CI ICE non-emergency unit built after 2007 with a displacement of >30L must demonstrate compliance by a performance test (stack test) for emissions of Particulate Matter (PM) and Oxides of Nitrogen (NOx). There are two methods for demonstrating compliance with either pollutant. The first is to show a percent reduction in emissions, and requires sampling for that pollutant at both the inlet and outlet to the control device for the source. Per IIII requirements, NOx must be reduced by 90% and PM by 60%. The second option is to limit the mass emission rate in the exhaust and only requires sampling at the outlet of the unit. The emission limit for NOx is 1.6 g/KW-hr (1.2 g/HP-hr). The emission limit for PM is 0.15g/KW-hr (0.11 g/HP-hr). In addition to the initial compliance performance test, owners of such engines must then perform annual performance tests to prove continued compliance with the standards.

The NESHAP and NSPS rulings can be an impenetrable maze without expert assistance, and the performance testing requirements can have a substantial impact on a facility’s operating budget. It is important to have a partner that is reliable and knowledgeable when approaching the many new emissions requirements being promulgated by the EPA and state governments. For assistance with your compliance needs, and performance testing requirements, ESS is available to help. If you believe you will or may have compliance issues under Subpart IIII, ZZZZ, or JJJJ, give us a call or an email today: 910-799-1055

ESS Announces Successful Completion of Industrial Air Testing Project in the Dominican Republic

The successful completion of an international stack testing project in the Dominican Republic by Environmental Source Samplers, Inc. (ESS) has led directly to a new air testing contract for ESS  in Port Au Prince, Haiti.  The project in Haiti was awarded and mobilized within a four day timeframe.

 

Wilmington, N.C., September 2012 — Environmental Source Samplers, Inc. (ESS), an established leader in emissions testing both domestic and internationally, today announced a successful conclusion to an air-testing project at a power facility in San Pedro de Macoris, Dominican Republic.

The power company is a client that ESS has performed stack testing services for in prior years, the last project completed in December of 2006. ESS has multiple clients in the Dominican Republic, and often performs work in the Caribbean, on average at least once a year. ESS mobilized a three-man crew from September 5th through 12th, 2012.

The project purpose was in-house engineering analysis for quality control and quality assurance, and to demonstrate compliance with emissions requirements as stipulated by the International Development Bank (IDB). ESS utilized USEPA 40 CFR Part 60 methodologies for all sampling requirements at the facility in San Pedro.

In addition to the successful completion of this project, ESS realized benefits in networking that will be invaluable in future endeavors into the Dominican and its neighboring country. Several contacts made during the course of the project have already led to further planned projects, and ESS personnel will be mobilizing to another power facility to perform sampling in Port Au Prince, Haiti, in the following week. The Haiti mobilization presents the challenge of a severely truncated lead and planning time. ESS was initially contacted regarding the project on Thursday, September 21st, awarded the work on Friday, September 22nd, and is planning to mobilize no later than Monday, September 24th.

Such needs for quick response and flexibility in operations are frequently the case in air-testing projects both domestic and international. Changes in project scope and requirements, late additions to air-testing needs and late changes in schedule are a common occurrence, but without preparation and experience these common occurrences can become extreme difficulties when mobilizing internationally. ESS has the competitive advantage of experience, drawn from international projects conducted in such locations as Hong Kong, the Dominican Republic, Hungary, and other points in Europe. The ESS network of reputable vendors and service providers help drive projects to completion within the required timeline and budget.

Founded in 1979, ESS has been performing industrial air quality testing since that time, and has developed into a leader within the field. ESS utilizes modern, consistently maintained equipment to conduct its stack testing services throughout the U.S. and abroad. They are qualified to conduct a wide range of EPA test methodologies among various air emissions sources and industries. ESS clients have easy access to the reliable and accurate reporting of stack test results through a secure online client portal.

For more information about ESS, please visit their company website at http://www.ESSKnowsAir.com and their blog at http://www.ESSKnowsAir-Blog.com.
Contact:

Brian Mellor
Environmental Source Samplers, Inc.
436 Raleigh Street
Wilmington, N.C., 28412
910-799-1055
ess@essknowsair.com
http://www.ESSKnowsAir.com

 

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