EPA to Propose Repealing Clean Power Plan

WASHINGTON (Reuters) – The U.S. Environmental Protection Agency will propose repealing the Clean Power Plan – the Obama administration’s centerpiece regulation to fight climate change – and plans to solicit input on a rule to replace it, according to an EPA document seen by Reuters.

The decision marks the agency’s first formal step to sweep away the rule intended to cut carbon emissions from power plants, after President Donald Trump signed an executive order in March launching the EPA’s review.

The Republican president has expressed doubts about the science of climate change and has blamed former Democratic President Barack Obama’s efforts to cut carbon emissions for hurting the coal mining and oil drilling industries.

The Clean Power Plan, or CPP, was challenged in court by 27 states after Obama’s administration launched it in 2015. It is currently suspended by the D.C. Circuit Court of Appeals, which set a deadline of Friday for a status report from the EPA on how it plans to proceed.

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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.

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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.

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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.

Preparing Your Hot Mix Asphalt Plant for Air Permit Compliance Testing

The saying “Time flies” never seems more appropriate than when air permits need to be renewed for Hot Mix Asphalt (HMA) plants.

If your plant’s permit is expiring soon (or even if it’s a bit down the road), it may benefit you to review the EPA-mandated testing required under your state-issued air permit.  With this in mind, allow us to provide a brief overview about air emissions testing for Hot Mix Asphalt plants.

Mobile Asphalt Plant by Wikisay (Own work) [CC BY-SA 3.0 (http://creativecommons.org/licenses/by-sa/3.0) or GFDL (http://www.gnu.org/copyleft/fdl.html)], via Wikimedia Commons

Mobile Asphalt Plant by Wikisay http://creativecommons.org/licenses/by-sa/3.0

Why are Hot Mix Asphalt plants required to test air emissions?

In the past, HMA plants were notorious for generating noticeable levels of dust, smoke, odors, and noise.   In 1973, the EPA enacted New Source Performance Standards (NSPS), which required HMA producers to pass strict emission standards and install control systems to prevent the release of dust and smoke into the air. A facility must also meet stringent visible emissions tests in order to comply with regulations.  These NSPS rules have had a dramatic effect on the decreased levels of pollution emitted by HMA plants, and thus the testing continues to be a part of the regulations with which HMA plants must comply.

When do Hot Mix Asphalt plants need to test for air emissions?

The date by which an HMA plant must conduct compliance testing and submit a report to the state EPA office is outlined in each plant’s individual air permit.  In some cases, the air emissions test report may be due 12 months or more before the current permit expires.

It is important to note that new HMA plants are required to conduct performance testing within 60 days after achieving maximum production rate, but no later than 180 days after initial startup of the facility. (See 40 CFR 60 Subpart A §60.8)

Nearly all HMA plants operate on a limited calendar, with summer being the busiest season.  As a result, there are a limited number of days available to perform emissions testing.  It is best to plan testing so that it occurs earlier than the permit requires in case the weather causes a delay or cancellation of the intended testing.

How far in advance must Hot Mix Asphalt plants provide notice of testing to the state authorities?

NSPS rule 40 CFR 60 Subpart A §60.8 specifically requires owners to notify the state regulatory agency 30 days in advance of the anticipated test date.

The state authority may also require submission of protocols in advance of testing.  Check your individual air permit for your state’s test protocol submission rules.

What tests are required under NSPS 40 CFR 60 Subpart I – Standards of Performance for Hot Mix Asphalt Facilities?

 According to 40 CFR 60 Subpart I, the following EPA Methods are required for air compliance testing at Hot Mix Asphalt plants:

  • EPA Method 5 – Measures Filterable Particulate Matter (FPM)
  • EPA Method 9 – Measures Visible Emissions (VE)

Some states require additional particulate testing via EPA Method 202, although the NSPS does not require it.  Please check with your state regulatory agency for the requirements concerning your facility.

When are air emissions test reports due to the state regulatory office?

It depends.  For instance, South Carolina requires a hard copy in office (not just postmarked) by the 30th calendar day post-test, but North Carolina allows 60 days to submit the report.

However, we recommend that you consult your air permit for a specific answer.  Your state-issued air permit will outline all the specifics for your emissions compliance requirements.

Does ESS test air emissions at Hot Mix Asphalt plants?

Yes.  ESS currently conducts air emissions testing for Hot Mix Asphalt plants in North Carolina, South Carolina, and Virginia.

With some of the most experienced testing staff in the industry, ESS can meet all of your testing needs for a competitive price.  Our staff of professionals strives to provide courteous, timely service that exceeds client expectations.

Call us at 1-888-363-0039 or send an e-mail to sales@essknowsair.com to discuss your specific air testing needs.  We will be happy to assist you.

Sulfuric Acid Mist Sampling and Controlled Condensate (NCASI Method 8a) Testing

Criteria Pollutants and MACT related air toxics such as Mercury and HCl get a lot of attention in the field of air-quality analysis and emissions testing (stack testing), but other, less-known pollutants can and do cause issues for facilities. Sulfuric Acid Mist (H2SO4) is one such pollutant.

 

Sulfuric acid emissions

Sulfuric acid emissions have traditionally been measured using EPA Method 8. This method utilizes the principle of selective solvent absorption (SSA) and captures sulfur trioxide (SO3) and H2SO4 in an isopropyl alcohol (IPA) solution, and SO3 in a low concentration of hydrogen peroxide. A drawback to this method, however, is that it was developed and originally promulgated to determine SO3/H2SO4 emissions from stationary sources in the absence of other particulate matter. The principal drawback is the absence of a filter to effectively remove PM and other pollutants prior to the capture of H2SO4 in IPA. This can lead to interference from a number of filterable particulates and other pollutants, such as ammonia, and may result in emissions reading much higher than expected, making it difficult to achieve compliance with the emissions standards.

 

NCASI Method 8a

NCASI Method 8a, originally Conditional Test Method (CTM)-013, was developed as an alternative to EPA Method 8, and uses a heated quartz filter for capturing particulates, thereby eliminating the potential for interference from particulate sulfate and other interference. For sources that are having trouble with obtaining low emissions of H2SO4, and particularly those that have been using ammonia-injection control technology, the use of this method can result in a significant reduction in reported emissions from the source, by removing these varying interferences.

The quartz filter is maintained at temperatures above 500 degrees F, allowing the gaseous SO3/H2SO4 to pass through and be selectively condensed in a temperature-controlled condenser. The condenser cools the flue gases below the dew point of the SO3/H2SO4, but above the dew point of water, eliminating the potential for interference from SO2. The method was developed and validated as an alternative for determining sulfuric acid emissions from combination boilers and recovery furnaces equipped with dry particulate control devices, and tested extensively on kraft recovery furnaces. It was specifically approved by the EPA for use on recovery furnaces in 1996.

 

Potential Issues

There are two potential issues with utilizing this method. The first is that it utilizes special equipment that not many testing firms have. The equipment costs several thousand dollars, which creates a large up-front cost to conducting tests using this method. The second is that the method is not specifically approved for any units other than recovery furnaces, and compliance tests performed by this method must be approved by state regulators on a case-by-case basis.

 

Call in the Professionals

ESS, an air-testing firm out of Wilmington, North Carolina, has the equipment and experience to conduct this test method for facilities that are currently or potentially regulated for H2SO4. ESS has requested and received variances from state regulators for use on biomass boilers, paper mills, and ceramic kilns for compliance-level testing. In all cases so far, the use of this alternative method has greatly improved the reported emissions of H2SO4, and helped our clients achieve compliance with the emissions standards their units are subject to.

If your facility is expected to be regulated for sulfuric acid mist, you need a testing partner that can achieve the best results. Give ESS a call today at  (910) 799-1055.

ESS Conducts H2 Gas Test at Coca-Cola Factory in Hanoi, Vietnam

Environmental Source Samplers, Inc.October, 2013 – Hanoi, Vietnam – Environmental Source Samplers, Inc. (ESS) continues growth in the Asian market with recent air emissions and ambient test programs for clients in Vietnam where ESS has a established an office. ESS most recently secured a contract to sample for hydrogen gas at the Coca-Cola factory in Hanoi.

The project was conducted in October 2013 and led by ESS President Mark Looney, QSTI. ESS sampled for H2 gas at multiple electric forklift charging stations and surrounding areas.

When lead acid batteries are being recharged they generate hydrogen gas that is explosive. During all lead acid battery charging processes H2 is produced. If certain charging equipment and/or batteries are not functioning properly, cells are damaged, or ventilation systems are inadequate, H2 generation can be significantly greater than the lower explosive limit (LEL).

Coca Cola Factory, VietnamDepending on the metal alloy composition in lead-acid batteries, a battery being charged can generate two highly-toxic byproducts in addition to H2. One is arsine (arsenic hydride, AsH3) and the other is stibine (antimony hydride, SbH3). Generally, the air levels of these metal hydrides tend to remain well below the current occupational exposure limits during battery charging operations. However, their possible presence re-enforces the need for adequate ventilation systems.

Many industrial plants in Vietnam utilize electric forklifts and other equipment powered by these types of batteries. ESS can refine the Facility Health and Safety Plan, develop a sampling/test protocol for industrial hygiene targets, and then execute the project to conduct all the required testing.

ESS maintains its competitive advantage by continuing to build on international experiences, developing offices in strategic markets and assuring client satisfaction on every project. The ESS network of reputable vendors and service providers enables us to drive all our projects to completion on-time and on-budget.

Founded in 1979, ESS has been conducting point source, ambient and industrial hygiene air quality testing and consulting, and utilizes modern and consistently maintained equipment to conduct its testing services world-wide. ESS is qualified to conduct a wide range of air testing methodologies in almost any environment – and for almost any industry. ESS clients have easy access to the reliable and accurate reporting of test results through a secure online client portal, accessible through the website, www.essknowsair.com.

To learn more about ESS and air-quality testing services in Asia, the U.S., and beyond, please call (910) 799-1055, or visit www.essknowsair.com.

Related Posts:
Air Quality Control in Vietnam
ESS Conducts Isokinetic Training for Vietnam Department of Natural Resources and Environment

ESS Secures RATA and Performance Testing Projects in Philippines

Air Emissions Testing PhilippinesHanoi, Vietnam: Environmental Source Samplers, Inc. (ESS) continues growth in the Asian market with recent relative accuracy test audit (RATA) and air emissions test programs for clients in the Philippines region. ESS most recently secured 2013 annual contracts for emissions testing and RATA sampling for Taheiyo Cement’s San Fernando Plant and Shell’s Batangas Refinery.

The sampling at Shell Batangas Refinery will include the conduct of three (3) RATAs at multiple sources for the evaluation of oxygen (O2), carbon dioxide (CO2), sulfur dioxide (SO2), oxides of nitrogen (NOx) and carbon monoxide (CO).

The sampling at Taheiyo San Fernando Cement Plant includes the measurement of dioxins/furans (TCDD/TCDF), hydrogen chloride (HCl), and particulate (PM) for performance testing purposes.

As ESS’s work has grown in the Asian market, it has been ever important to maintain staff and a local presence in these markets. In January 2013, ESS opened an Asian headquarters in Hanoi, Vietnam. In early February, ESS signed an agreement with Berkman Systems, the most established Philippines environmental consulting firm, to partner in specialty air quality consulting projects.

This partnership allowed ESS to combine its presence with Berkman’s operations in Metro Manila, Cebu and Davao, and to provide cost effective solutions and superior technical support for clients’ consulting and air testing needs.

Mark Looney, President of ESS, stated: “. . . with the combined technical strengths of ESS and Berkman, we have created a dominant partnership in the Philippines. ESS is proud of our growing list of clients and our ongoing relationship with Berkman.”

Founded in 1979, ESS has been conducting point source, ambient and industrial hygiene air quality testing and consulting. ESS utilizes modern and consistently maintained equipment to conduct its testing services world-wide. They are qualified to conduct a wide range of air testing methodologies in almost any environment – and for almost any industry.

ESS clients have easy access to the reliable and accurate reporting of test results through a secure online client portal. ESS maintains its competitive advantage by continuing to build on international experiences, developing offices in strategic markets and assuring client satisfaction on every project. The ESS network of reputable vendors and service providers enables us to drive all our projects to on-time and on-budget completion.

To learn more, visit www.essknowsair.com (available in both English and Vietnamese) or call directly at (800) 245-3778. 

 

Related Posts:
ESS Asia Attends PCAPI Convention, Philippines
ESS Establishes and Staffs Office in Hanoi, Vietnam
International Stack Testing – Challenges and Solutions

ESS in the Philippines

ESS Conducts Isokinetic Training for Vietnam Department of Natural Resources and Environment

Isokinetic Emissions Sampling Training, VietnamHanoi, Vietnam, June 2013 — Environmental Source Samplers, Inc. (ESS) continues growth in the Asian market with the award of a recent government contract to provide isokinetic emissions sampling training to the Vietnam Department of Natural Resources and Environment (DONRE) – Thai Nguyen office. The Thai Nguyen province selected eleven (11) of their most qualified technicians to attend the ESS training seminar to further focus their Apex Instruments isokinetic sampling skills.

Workshop instruction was led by ESS President Mark Looney, QSTI. The object of this 1-day seminar was to introduce basic isokinetic principles and source sampling skills to the DONRE technicians.

This course assisted the students in their review of source testing and broadened their sampling skills. The workshop helped the students develop the ability to plan, guide, evaluate, and perform source-sampling measurements to determine rates of emission from stationary sources. The course also provided a cursory review of EPA Methods 1 through 5.

The course provided the students with:

  • The knowledge and nomenclature of the isokinetic stack testing equipment
  • An understanding of why the prescribed methods are used
  • A review of the basic operation of the isokinetic sampling equipment
  • An introduction to the calibrations and calculations that are a part of the reference methods
  • A field sampling exercise to demonstrate the knowledge of conducting/operating Method 5 Isokinetic sampling equipment.

As ESS’s work has grown in the Asian market, it has been ever important to maintain staff and a local presence in these markets. In January 2013, ESS opened an Asian headquarters in Hanoi, Vietnam. In early February, ESS signed an agreement with Berkman Systems which allowed us to combine our presence with their operations in Metro Manila, Cebu and Davao. ESS continues to provide cost effective solutions and superior technical support for of our client’s consulting and air testing needs.

ESS is proud of our growing list of clients and our development with key provincial government agencies such as Thai Nguyen DONRE.

ESS maintains its competitive advantage by continuing to build on international experiences, developing offices in strategic markets and assuring client satisfaction on every project. The ESS network of reputable vendors and service providers enables us to drive all our projects to on-time and on-budget completion.

Founded in 1979, ESS has been conducting point source, ambient and industrial hygiene air quality testing and consulting. ESS utilizes modern and consistently maintained equipment to conduct its testing services world-wide. They are qualified to conduct a wide range of air testing methodologies in almost any environment – and for almost any industry. ESS clients have easy access to the reliable and accurate reporting of test results through a secure online client portal. accessible at their main website, essknowsair.com.

To learn more about ESS and their air quality testing services in Asia, the U.S. and beyond, please call (910) 799-1055  or visit http://www.essknowsair.com.

 

Ministry of Natural Resources and Environment, Vietnam Apex Instruments

 

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.