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Proposed Rule: Amendments to the Protocol Gas Verification Program and Minimum Competency Requirements for Air Emission Testing Presented at May 12, 2010 EPRI CEMUG Cleveland, OH by John Schakenbach Clean Air Markets Division, OAP, EPA . Background.

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Proposed Rule: Amendments to the Protocol Gas Verification Program and Minimum Competency Requirements for Air Emission TestingPresented atMay 12, 2010 EPRI CEMUGCleveland, OHbyJohn SchakenbachClean Air Markets Division, OAP, EPA


Background
Background Program and Minimum Competency Requirements for Air Emission Testing

  • On January 24, 2008, EPA promulgated a final rule requiring among other things:

    • Participation in a specialty gas vendor-funded PGVP for any vendor providing EPA Protocol gases; and

    • Minimum competency requirements for Part 75 stack testing

  • These two provisions are in litigation and were not put into effect

  • EPA has drafted proposed rule provisions that we believe address the identified issues


Major components of proposed pgvp
Major Components of Proposed PGVP Program and Minimum Competency Requirements for Air Emission Testing

  • Purpose of PGVP is to ensure accuracy of EPA Protocol gases

  • 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

  • Any production site choosing to participate must notify EPA each year by providing:

    • Specialty gas company name;

    • Name and address of each participating EPA Protocol gas production site; and

    • Name, email, and telephone number of production site contact person.

  • EPA will issue vendor ID numbers to participants


Major components of proposed pgvp cont d
Major Components of Proposed PGVP Program and Minimum Competency Requirements for Air Emission Testing(Cont’d)

  • EPA will post the participants on Agency web sites

  • Each year, EPA will hire a stack testing company (maybe a different company each year) to blindly procure up to 4 cylinders from each participating production site

  • After being notified that its cylinders are being audited by EPA (after cylinders have been shipped), a production site would cancel its invoice or credit the purchaser’s account, and pay NIST to analyze its cylinders and provide a report to EPA

  • A production site may be delisted for months if it fails to cancel its invoice or pay NIST to analyze and send a report to EPA or fails to provide contact information


Major components of proposed pgvp cont d1
Major Components of Proposed PGVP Program and Minimum Competency Requirements for Air Emission Testing(Cont’d)

  • Each year, EPA intends to audit all participating production sites

  • NIST expects to analyze all cylinders and provide EPA a report within 6 months of receipt of first batch of cylinders and has established cost containment/efficiency measures to help it do so

  • EPA will post audit results on-line:

    • Results will indicate whether cylinder meets the Part 75 performance specification of + 2% of cylinder tag value

    • Users can decide from whom they wish to purchase gases

  • Proposed rule establishes minimum criteria for the NIST cylinder analysis


Major components of proposed pgvp cont d2
Major Components of Proposed PGVP Program and Minimum Competency Requirements for Air Emission Testing(Cont’d)

  • After analysis, cylinders will have a NIST analyzed concentration, and will be returned to the production site

  • Recordkeeping/reporting will be required to help ensure that EPA Protocol gas cylinders being used by Part 75 sources are from participating production sites, and to inform cylinder selection for future audits

  • Participation in the PGVP would be allowed on and after the effective date of final rule

  • PGVP recordkeeping provisions would commence 6 months from the effective date of final rule

  • On and after January 1, 2011, PGVP data elements would be submitted prior to or concurrent with submittal of the relevant quarterly electronic data report


Major components of proposed pgvp concluded
Major Components of Proposed PGVP Program and Minimum Competency Requirements for Air Emission Testing(Concluded)

  • Elements to be reported through ECMPS and retained on-site for 3 years:

    • Gas level code (low, mid or high);

    • Code for type of EPA Protocol gas used with CEMS;

    • Start and end date and hour for EPA Protocol gas type code used with CEMS;

    • Code for type of EPA Protocol gas used with Test Methods 3A, 6C and 7E;

    • PGVP vendor ID (issued by EPA) for participating production site that supplied the cylinder; and

    • Start and end date and hour for PGVP vendor ID used with CEMS.


Major components of proposed aetb
Major Components of Proposed AETB Program and Minimum Competency Requirements for Air Emission Testing

  • 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 “Standard Practice for Competence of Air Emission Testing Bodies”

  • Testing must be conducted or overseen by at least one on-site Qualified Individual:

    • QI must be qualified for the methods employed in the test;

    • QI must conduct or oversee the test for the duration of the test; allowance is made for normal activities, e.g., bathroom, food breaks or emergencies; and

    • Only those portions of a test conducted or overseen by a QI may be used under Part 75.


Major components of proposed aetb cont d
Major Components of Proposed AETB Program and Minimum Competency Requirements for Air Emission Testing(Cont’d)

  • At the time of testing, the AETB provides a certification, to be retained on-site for 3 years, that it’s operating in conformance with ASTM D 7036. That certification is either:

    • A certificate of accreditation or interim accreditation for relevant test methods by a recognized, national accreditation body; or

    • A letter of certification for relevant test methods signed by AETB senior management.

  • The above certification and compliance with the QI requirements shall be sufficient proof of validity of test data that otherwise meet the requirements of Part 75


Major components of proposed aetb cont d1
Major Components of Proposed AETB Program and Minimum Competency Requirements for Air Emission Testing(Cont’d)

  • Elements to be reported through ECMPS and retained on-site for 3 years:

    • Name, telephone number and e-mail address of the Air Emission Testing Body;

    • Name of the on-site Qualified Individual, as defined in § 72.2 of this chapter;

    • For the reference method(s) that were performed, the date that the on-site Qualified Individual took and passed the relevant qualification exam(s) required by ASTM D 7036-04; and

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


Major components of proposed aetb cont d2
Major Components of Proposed AETB Program and Minimum Competency Requirements for Air Emission Testing(Cont’d)

  • To better ensure that an AETB is operating in conformance with ASTM D 7036, it is recommended that Part 75 source request that the AETB produce:

    • AETB’s quality manual;

    • Results of any external or internal audits performed by AETB during prior 12 mos;

    • Written description of any corrective actions being implemented by AETB during prior 12 mos; and

    • AETB’s training records for prior 12 mos.


Major components of proposed aetb concluded
Major Components of Proposed AETB Program and Minimum Competency Requirements for Air Emission Testing(Concluded)

  • AETB recordkeeping provisions would commence 6 months from the effective date of final rule

  • On and after January 1, 2011, AETB data elements would be submitted prior to or concurrent with submittal of the relevant quarterly electronic data report


Mercury free
Mercury-Free Program and Minimum Competency Requirements for Air Emission Testing

  • 100% Hg removal (from Parts 72 and 75)

  • The proposed rule would remove Hg monitoring, record keeping and reporting provisions that were finalized as part of CAMR which was vacated by the D.C. Circuit Court of Appeals


Public comments
Public Comments Program and Minimum Competency Requirements for Air Emission Testing

  • The EPA Administrator signed the proposed rule on April 29, 2010

  • Publication in the Federal Register is expected shortly

  • Comments may be submitted to Docket ID No. EPA-HQ-OAR-2009-0837

    • Comments may be submitted on-line at: www.regulations.gov

    • 30 day comment period

    • Positive and negative comments are equally valuable


Copy of presentation
Copy of Presentation Program and Minimum Competency Requirements for Air Emission Testing

  • This presentation is posted on the CAMD web site under Recent Additions:

    http://www.epa.gov/airmarkets/whatsnew.html


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