NESHAP for Area Source Boilers (40 CFR 63, Subpart JJJJJJ)

2017-04-20 NESHAP for Area Source Boilers (40 CFR, Subpart JJJJJJ)

The national emission standards for hazardous air pollutants (NESHAP) for area source boilers (40 CFR part 63, Subpart JJJJJJ) was published in the Federal Register on March 21, 2011 and EPA finalized changes to the rule in the Federal Register on February 1, 2013 and on September 14, 2016. The September 14, 2016, action announced EPA’s final decisions on five issues regarding the February 1, 2013, amendments for which reconsideration was granted.

ESS provides comprehensive emissions testing services to meet the federal and state requirements for industrial boilers, including Subpart JJJJJJ, Subpart DDDDD, Title V, and more.  See our list of capabilities for more information or call 910.799.1055 for more information.

[Read more…]

EPA Answers 63 Questions About the Boiler MACT (40 CFR 63 Subpart DDDDD)

2017-04-04 EPA Q&A DDDDD

GENERAL

Q1. Can a boiler that combusts both gas and oil average its emissions when firing gas with those when firing oil?

A: As stated in 63.7522, emission averaging is only allowed between units in the same subcategory. Averaging emissions of a dual fuel unit burning oil with the emissions of the same unit when burning gas is not permitted. Under 63.7520(c), the unit’s compliance would be based on the emissions when firing oil.

 

Q2. Can a facility that is currently a major source of HAP become an area source before the first substantive date of the Major Source Boiler MACT (i.e., 2016), and comply with the Area Source Boiler MACT/GACT (NESHAP JJJJJJ) provisions? The EPA’s memorandum that was published in 1995 specifically noted the first substantive compliance date of a MACT rule as the last day to switch to an area source, before Once In, Always In takes effect.  Does this memorandum still represents EPA’s policy?

A: The “Once In Always In” Policy does represent the Agency’s policy. You are correct that a source must reduce their emissions below major source thresholds prior to the compliance date of the rule.

 

Q3. Can a facility that is a major source boiler become an area source boiler? If so, what is the latest date by which it may do so, and what has to happen by then?

A: A facility would need to become an area source before the first applicable compliance date, which would be January 31, 2016 for existing sources. The facility would need to show that their potential to emit HAP is less than 10/25 TPY, and a federally enforceable permit restriction would be one way to show emissions are below major source levels.

[Read more…]

Three Decades of Condensable Particulate Matter (CPM) Regulation

2017-03-17 Three Decades of CPM Regulation

WHAT IS CONDENSABLE PARTICULATE MATTER?

Condensable Particulate Matter (CPM) is material that is in a vapor state at stack conditions, but condenses and/or reacts upon cooling and dilution in the ambient air to become solid or liquid Particulate Matter (PM) immediately after discharging from the stack.  All CPM is assumed to be in the PM2.5 size fraction.

HOW DID EPA CPM REGULATIONS DEVELOP?

1987  After promulgating the PM10 National Ambient Air Quality Standards (NAAQS) the EPA began recommending that, in certain circumstances, states consider including the condensable portion of PM10 emissions in the determination of total and fine PM emissions from major stationary sources.

1991  EPA Promulgated Method 202.  The original Method used wet impingers – in which sulfur dioxide was captured and formed sulfur trioxide and sulfuric acid artifacts. This caused captures to be biased high by improperly quantifying the sulfuric artifacts as condensable PM.

[Read more…]

EPA News: For the First Time in 40 Years EPA to Put in Place a Process to Evaluate Chemicals that May Pose Risk

2017-01-13 First Time 40 Years Chemical Review

WASHINGTON–The Environmental Protection Agency (EPA) is moving swiftly to propose how it will prioritize and evaluate chemicals, given that the final processes must be in place within the first year of the new law’s enactment, or before June 22, 2017.

“After 40 years we can finally address chemicals currently in the marketplace,” said Jim Jones, EPA’s Assistant Administrator for the Office of Chemical Safety and Pollution Prevention. “Today’s action will set into motion a process to quickly evaluate chemicals and meet deadlines required under, and essential to, implementing the new law.”

When the Toxic Substances Control Act (TSCA) was enacted in 1976, it grandfathered in thousands of unevaluated chemicals that were in commerce at the time. The old law failed to provide EPA with the tools to evaluate chemicals and to require companies to generate and provide data on chemicals they produced.

[Read more…]

EPA News: EPA Report Shows Air Emissions of Toxic Chemicals from Industrial Facilities Down More Than Half Since 2005

2017-01-13 Toxic Air Emissions Down 56 Percent

WASHINGTON — The U.S. Environmental Protection Agency today released its annual Toxics Release Inventory (TRI) National Analysis, which shows releases of toxic chemicals into the air fell 56% from 2005-2015 at industrial facilities submitting data to the TRI program.

“Today’s report shows action by EPA, state and tribal regulators and the regulated community has helped dramatically lower toxic air emissions over the past 10 years,” said Jim Jones, EPA Assistant Administrator for the Office of Chemical Safety and Pollution Prevention. “The TRI report provides citizens access to information about what toxic chemicals are being released in their neighborhoods and what companies are doing to prevent pollution.”

The report shows an 8% decrease from 2014 to 2015 at facilities reporting to the program contributed to this ten-year decline. Hydrochloric acid, sulfuric acid, toluene and mercury were among chemicals with significantly lower air releases at TRI-covered facilities. Medical professionals have associated these toxic air pollutants with health effects that include damage to developing nervous systems and respiratory irritation.

[Read more…]

OSHA News: US Department of Labor Issues Final Rule to Lower Beryllium Levels

2017-01-06 New OSHA Rule for Beryllium Exposure

WASHINGTON – A new rule issued today by the U.S. Department of Labor’s Occupational Safety and Health Administration dramatically lowers workplace exposure to beryllium, a strategically important material that can cause devastating lung diseases. The new beryllium standards for general industry, construction and shipyards will require employers to take additional, practical measures to protect an estimated 62,000 workers from these serious risks.

Beryllium is a strong, lightweight metal used in the aerospace, electronics, energy, telecommunication, medical and defense industries. However, it is highly toxic when beryllium-containing materials are processed in a way that releases airborne beryllium dust, fume, or mist into the workplace air that can be then inhaled by workers, potentially damaging their lungs.

Recent scientific evidence shows that low-level exposures to beryllium can cause serious lung disease. The new rule revises previous beryllium permissible exposure limits, which were based on decades-old studies.

[Read more…]

EPA News: EPA Names First Chemicals for Review Under New TSCA Legislation

EPA News: 10 Chemicals Under TSCA Review

WASHINGTON – Today, EPA is announcing the first ten chemicals it will evaluate for potential risks to human health and the environment under TSCA reform.

“Under the new law, we now have the power to require safety reviews of all chemicals in the marketplace.” said Jim Jones, assistant administrator of the of Office of Chemical Safety and Pollution Prevention. “We can ensure the public that we will deliver on the promise to better protect public health and the environment.”

The first ten chemicals to be evaluated are:

  • 1,4-Dioxane
  • 1-Bromopropane
  • Asbestos
  • Carbon Tetrachloride
  • Cyclic Aliphatic Bromide Cluster
  • Methylene Chloride
  • N-methylpyrrolidone
  • Pigment Violet 29
  • Tetrachloroethylene, also known as perchloroethylene
  • Trichloroethylene

Toxic Substances Control Act (TSCA) as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act, requires EPA to publish this list by December 19, 2016. These chemicals were drawn from EPA’s 2014 TSCA Work Plan, a list of 90 chemicals selected based on their potential for high hazard and exposure as well as other considerations.

When the list is published in the Federal Register it will trigger a statutory deadline to complete risk evaluations for these chemicals within three years.  This evaluation will determine whether the chemicals present an unreasonable risk to humans and the environment. If it is determined that a chemical presents an unreasonable risk, EPA must mitigate that risk within two years.

Under the newly amended law, EPA must release a scoping document within six months for each chemical. This will include the hazard(s), exposure(s), conditions of use, and the potentially exposed or susceptible subpopulation(s) the agency plans to consider for the evaluation.

Additional chemicals will be designated for evaluation, and all of the remaining Work Plan chemicals will be reviewed for their potential hazard and exposure. For each risk evaluation that EPA completes, TSCA requires that EPA begin another. By the end of 2019, EPA must have at least 20 chemical risk valuations ongoing at any given time.

For more on the chemicals listed and additional information: https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/evaluating-risk-existing-chemicals-under-tsca

###

EPA MEDIA CONTACT:

Cathy Mibourn

milbourn.cathy@epa.gov

(202)-564-7849

 

The Benefits of Automated Particulate Analysis by SEM-EDS

Automated Particle Analysis by SEM/EDS

When encountering puzzling particulate results, questions arise such as:

What species of particulate are in this sample?

What is the chemical composition of these particles?

What is the particle size distribution of this sample?

Automated particle analysis by Scanning Electron Microscopy and Energy Dispersive X-ray Spectrometry (SEM-EDS) provides a method to answer questions about particle populations that arise in a very wide range of industries. Some examples of SEM-EDS application include: wear particle analysis, size distribution of pharmaceutical ingredients, source determination of airborne particulate, and nanoparticle characterization.  SEM-EDS can also determine whether non-process related particulate is biasing the catch through identification of particle species and chemical composition.

SEM-EDS is a powerful analytical tool for obtaining concise information about a particulate sample.

Figure 1: Representative Automated Particle Analysis High Contrast

Figure 1: Representative Automated Particle Analysis High Contrast

The first step in SEM/EDS automated particle analysis is to acquire a background image with sufficient contrast between the background and the particles so that image analysis can differentiate between them (Figure 1).  For automated image analysis systems, a “particle” is defined as a set of contiguous pixels all of which are brighter (or more rarely, darker) than the threshold brightness used to define the surrounding “background” pixels.

Next, particles are recognized by the image analysis system (which is a part of the SEM/EDS software).  Figure 2 shows the same field of view as Figure 1, except that there is indication of the particle count that the system has identified.  The analysis system saves the location of each particle and then two-dimensional size and shape parameters for each particle are determined. Typical parameters include maximum, minimum and average diameters, perimeter, and aspect ratio.

Figure 2: Representative Automated Particle Analysis

Figure 2: Representative Automated Particle Analysis

Once the particles in the field of view are recognized, the automation system of the microscope conducts a chemical analysis of each particle to acquire the signature on an EDS spectrum.  A typical example appears as Figure 3.  A peak in the EDS spectrum indicates the presence of the corresponding element in the particle which can then be classified based on its composition.  In Figure 3, the spectrum shows the particle to be composed of Iron (Fe) and Oxygen (O), indicating an Iron Oxide particle.

Once every particle in the field of view is recognized and its dimensions and composition saved, the microscope moves to a new field of view and the process is repeated until a set number of particles or a predetermined number of fields of view have been analyzed.  Using this systematic analysis sampling allows for the characterization (size, shape, composition) of hundreds and even thousands of particles in just a few hours without operator involvement beyond the initial setup.

Figure 3: Representative EDS Spectrum of Automated Particle Analysis

Figure 3: Representative EDS Spectrum of Automated Particle Analysis

Finally, the results are tabulated, giving a complete picture of the particle types, sizes, and shapes.  The tabulation is entirely customizable since all of the data (size, shape, composition) is stored for each individual particle.

Table A: Percent Distribution of Particles by Mass with Corresponding Emission Rate

Amount of Particulate Emitted in One (1) Hour = 10 lbs


Particle Size
(microns)

Distribution
(%)

Particle Emission Rate
(lb/hr)

0.5 – 1.0


53.05


5.305

1.0 – 2.5 37.25 3.725
2.5 – 5.0 7.57 0.757
5.0 – 7.5 1.44 0.144
7.5 – 10 .40 0.04
10 – 25 0.28 0.028
25 – 50 0.00 0
50– 100 0.01 0.001
>100 0.00 0
TOTALS 100 10

ESS provides emissions testing, air quality analysis, and consulting services for manufacturers, municipal water treatment plants, public utilities, paper mills, and other industrial facilities in the US and overseas.  Since its inception in 1979, ESS has conducted thousands of emissions tests and provided countless hours of environmental consulting services.  ESS specializes in conducting the EPA testing methods for all applicable EPA subparts, such as: NSPS (40 CFR 60), NESHAP (40 CFR 63), RATA (40 CFR 75), and various other federal and state regulations.

We are committed to the highest standards of integrity, excellence and customer service.  ESS continues to invest in facilities, equipment, education, and safety to provide a broad range of services to meet our clients’ varying needs.

Adapted from information available at: http://mvascientificconsultants.com/

 

Scientists Find Way to Convert CO2 Into Ethanol

CO2 to Ethanol

Scientists at the Oak Ridge National Laboratory in Tennessee have discovered a chemical reaction to turn CO2 into ethanol, potentially creating a new technology to help avert climate change. Their findings were published in the journal ChemistrySelect.

Researcher had hoped to convert carbon dioxide that had been dissolved in water to methanol, a chemical released naturally by volcanic gases and microbes, which can cause blindness in humans if ingested.

But instead of methanol, they discovered they had ethanol, a primary component of gin and also a potential fuel source. Surprised, the team realized that not only was their new material converting the carbon dioxide to ethanol, it needed very little outside support.

The material is a small chip–about a square centimeter in size–covered in spikes, each just a few atoms across. Each spike is constructed out of nitrogen with a carbon sheath and a small sphere of copper embedded in each tip. The chip is dipped into water and carbon dioxide is bubbled in. The copper acts as a small lightning rod, attracting electricity and driving the first steps of the conversion of the carbon dioxide and water into ethanol, before the molecules move to the carbon sheath to finish the process.

Read more about this exciting development in the full article from Popular Science.

ZZZZ Compliance Testing and Portable Analyzers

Reciprocating Internal Combustion EngineSeveral million stationary reciprocating engines are in use throughout the United States. These engines, in general industry use, provide shaft power to drive process equipment, compressors, pumps, standby generator sets and other machinery. The uses are similar in agriculture, with many engines serving the purpose of driving irrigation pumps. Reciprocating engines also find wide application in municipal water supply, wastewater treatment, and in commercial and institutional emergency power and load-managing stations.

Many of these engines are subject to the RICE NESHAP, promulgated  by the EPA under 40 CFR 63, Subpart ZZZZ. Under Subpart ZZZZ, an owner/operator must demonstrate compliance by stack testing at the outlet exhaust to demonstrate the concentration of Carbon Monoxide (CO) in the stack exhaust of < 23 ppmvd at 15% O2.

This testing is typically conducted using continuous emissions monitors (CEMS), under EPA Test Methods 3a and 10, which provide the most accurate data possible on gaseous emissions. This approach is the gold standard for Subpart ZZZZ compliance testing and, as such, it is the methodology ESS uses.

An alternative approach to 3a and 10 is using ASTM D6522-00.  Rather than using CEMS, ASTM D6522-00 utilizes portable monitors, such as Testo 320s or 350s, for the reading of gaseous emissions.  While this method is EPA-approved for the conduct of ZZZZ testing for all engine ratings, it has been our experience that it simply does not provide the high-level accuracy we demand of our equipment.

However, with any methodology and any test series, an experienced partner is the most crucial component to conducting a successful test, properly compiling and submitting the data, and working with state and federal requirements.

Since 1979, ESS has had the personnel and equipment to help your facility demonstrate compliance with any state and federal air-quality and emission requirement. If a stack test is required for your facility, give ESS a call today at (910) 799-1055.

Learn more:
Your One Stop Shop for RICE NESHAP ZZZZ Compliance
A Guide To Subpart ZZZZ and JJJJ RICE Rules
New RICE Rules for MACT Standards and Compliance