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What Is New/Updated in Air Quality?

TRC Companies, Inc.

August 2011

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Overview

• Part 75 Industries– On March 28, 2011, EPA issued its final rule to

establish two ongoing regulations that EPA believes will ensure the accuracy of calibration gases and the competency of emission stack testers. These two regulations are: Air Emission Testing Bodies (AETB) Protocol Gas Verification Program (PGVP)

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AETB

• Air Emission Test Body (ASTM D7036)

• Effective date as pertains to Part 75 testing:– March 27, 2012

• Background– Initial rule January 24, 2008 was petitioned and EPA

subsequently stayed this provision. On March 11, 2011 EPA reissued the final rule.

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Stack Testing Companies Requirements

• Companies must– Develop a quality system, quality manual, and

quality policy. – Perform audits of activities annually. – Provide a Quality Individual (QI) on-site for each

test project who is qualified for each test method performed.

– Maintain records.– Certify conformance with ASTM D 7036 using

outside source (STAC) or self certify.

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Stack Testing Companies Requirements

• Individuals must– Meet experience requirements– Pass a qualification exam on specific test methods

and carry certification on-site. – Sign a statement that all test projects conducted

under his supervision will conform to the Quality Manual and to this practice in all respects.

– Re-take and pass a qualification exam at least once every 5 years.

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Plant Requirements for AETB

• Any RATAs, Appendix E NOx testing or low mass emission testing at a Part 75 source must be performed by an air emission testing body (AETB) that certifies conformance with ASTM D 7036

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Plant Requirements for AETB

• Testing must be overseen and supervised by at least one on-site Qualified Individual– QI must be qualified for the methods employed in

the test.– QI must oversee and supervise the test for the

duration of the test; on-site.– Only those portions of a test overseen and

supervised by a QI may be used under Part 75.

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Plant Requirements for AETB

• At the time of testing, the owner/operator will collect the following information from the AETB :– Name, telephone number and email address of the AETB;– Certificate of accreditation or interim accreditation for relevant

test methods by recognized national accreditation body; or– Letter of certification for relevant test methods signed by

AETB senior management; and – Name of the on-site Qualified Individual (QI);– For the reference method(s) that were performed, the date

that the on-site Qualified Individual took and passed the relevant qualification exams; and

– The name and e-mail address of the qualification exam provider

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Plant Requirements for AETB

• This collected data is to be in an electronic format:– Recordkeeping/reporting is required to help assure

that Part 75 stack testing is conducted by AETBs that conform with ASTM D 7036.

– AETB recordkeeping provisions for Part 75 sources would commence 365 days after publication of rule.

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References

• Reporting instructions are on EPA CAMD web site for AETB and PGVP

• A rule fact sheet, and the final rule are posted at: http://www.epa.gov/airmarkets/emissions/rules.html

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PGVP

• EPA’s Protocol Gas Verification Program

• Effective date May 27, 2011

• History

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PGVP

• Any Part 75 source using EPA Protocol gas must obtain it from an EPA Protocol gas production site participating in the PGVP.

• Any Method 3A, 6C or 7E using EPA Protocol gas for testing on a Part 75 source, must obtain the gas from a participating production site (RATAs).

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Approved Vendors

• Current list of approved vendors:– http://www.epa.gov/airmarkets/emissions/pgvp-

vendorID.html

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References

• 2010 Report of Vendors• ECMPS Reporting Information• Complete information AETB & PGVP

– www.epa.gov/airmarkets/emissions/rules.html

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SSAP

• Stationary Source Audit Program

• History– Old Program

– Restructuring & Privatizing the Audit Sample Program

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SSAP

• When are Audits Samples Required?– EPA specified that “the requirement to use an audit

sample during a compliance test will apply to all test methods for which a commercially available audit exists”.

– The source owner, operator, or representative of the tested facility shall obtain and audit samples, if commercially available, for each test method used for regulatory compliance purposes.

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SSAP

• No Audit Samples are required for the following test methods:– Methods 9, 22, 303 – Methods 3A, 3C, 6C, 7E, 10, 25A– Method 18– Methods 318, 320, and 321

• State & Local agencies have the approval to waive Audit Requirements.

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SSAP

• Before regulations can be implemented the following will need to be completed:– EPA needs to approve a voluntary consensus body

(VCB) program to administer the audit program regulations

– EPA has to approve the acceptance criteria and concentration ranges

– Providers must be accredited to VCB standards– 2 providers must have an audit samples available

to be commercially viable– Audit samples and providers must be listed on EPA

TTN web site for at least 60 days.

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SSAP

• Check EPA TTN EMC web site– You have 60 days AFTER the audit samples and

providers are listed on the EPA web site, before audit samples are required for compliance testing.

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Resources

• EPA Web Site

– www.epa.gov/ttn/emc

• TNI Web Site

– http://www.nelac-institute.org/cms/posts/130582776.php

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