Source Evaluation Society
Newsletter
P. O. Box 12124
Research Triangle Park, North Carolina 27709
Volume XXXIII, No. 2 Quarterly April - June 2009
OFFICERS BOARD OF DIRECTORS
President, Bob Finken (Delta Air Quality) David Bagwell (1 term)
Vice President, Roy Owens (Owens-Corning) Robert Mann (1 term)
Secretary, Angela Hansen (AmTest Air Quality) Augie de la Vega (2 terms)
Treasurer, Robin Segall (EPA) Glenn England (Past President)
EDITOR EDITORIAL COMMITTEE
Roger Shigehara (Emission Monitoring) Larry Cottone (CCI Env. Consultants)
SOCIETY NEWS ITEMS
· 2010 SES Conference Announcement
· The New SES Website Is Live
· SES Logo Contest
· SES Data Quality Committee Report
· Privatization of EPA’s Audit Sample Program
· What Will Changes in Emission Legislation Mean for the Pollution Monitoring Industry?
· SES Membership Update
2010 SES Conference Announcement
SAVE THE DATE!!
34th annual SSSAAP Conference
March 7-12, 2010 at the Bay Point Marriott Resort in Panama City Beach, FL.
Abstracts for consideration to the program can be submitted to
Problem Board again this year--
Do you have a problem you have thought of or encountered that you would like to have answers for but don't want to ask? Do you want to see what others would do in the same situation? Feel free to submit any question/problem to and we will ask for you (anonymously of course!). The questions will be offered up for open discussion during the conference.
Contact DeAnna Oser () or Larry Cottone
() with questions or for more information!
The Source Evaluation Society announces the location and dates for the
2010 Stationary Source Sampling & Analysis for Air Pollutants XXXIV Conference!
Conference Chair DeAnna Oser, Co-Chair Larry Cottone
The only resort to be named a “Top 25 in America” by both Tennis Illustrated and Golf Illustrated.
The 1100-acre, award-winning resort is situated on a beautiful wildlife sanctuary overlooking scenic St. Andrews Bay and just minutes away from the Gulf of Mexico. With numerous activities, a private beach area, and the only Nicklaus Golf Course in Northeast Florida, this is going to be great!
· 316 guest rooms, with 78 one- and two-bedroom golf villas, http://www.marriottbaypoint.com/
· 40,000 square feet of event space, for meetings, Four onsite restaurants, including 30 Degree Blue, Kingfish and Limes
· 36 holes of championship golf, featuring two courses - the Meadows Course & the Nicklaus Design Course , the only one in North West Florida - a clubhouse, & golf shop
· Recreational activities, including parasailing, bay seaplane rides, volleyball, and more
· Serviced by airports: Panama City (PFN)(10 minutes), Fort Walton Beach (VPS)(90 minutes), Pensacola(PNS)(90 minutes), Tallahassee (TLH)(120 minutes)
The New SES Website Is Live
The updated SES web site is live and ready to view. SES would like to thank Steve Eckard of Enthalpy Analytical for offering the web development services of his brother David Eckard to develop and populate the new web site. David will serve as the SES web master during the transition to the new web site. Together with the help of Gail Westlin and Tom Rose this project is finally a reality!
You will notice a Forums link on the front page. If you want to participate in the forums you will need a username and password. David Eckard is working to assign your username and password, so look for an e-mail with that information soon. A list of the present forums and moderators is shown below.
General / Eddie Clemons /CEMs / Angela Hansen /
Mercury / Robin Segall /
QSTI
VOCs and M18 / Steve Eckard /
Wet Chemistry and Manual Methods / Jason Bouwman /
SES is always looking for volunteers, and there may be need for additional Forum Administrators. If you have a particular area of expertise, we hope you will volunteer. SES can easily add additional forum topics upon request. When a post is made, it will be approved by the Forum Administrator before it is posted. This will eliminate spam, keep inappropriate language off the board, keep subjects on track, and keep the tone appropriate. We hope to achieve an open exchange and not censor comments. The moderator will get a notification when a comment is posted, so, they will not have to check the web site every day to see if something is waiting for their approval.
Our web master has included the EPA Air RSS feed on the right side of the site. If you have ideas for other RSS feeds that would be appropriate to include, submit your idea to SES and we will try to add them.
The new web site also includes downloadable copies of the second edition of the SES safety manual. It is located in the SES Members Only area of the web site under Safety Guidelines Handbook. Feel free to print and distribute the handbook to anyone in your company.
At this point, you do not need to use the Login area unless you are participating in a forum discussion. At a future date, we may require user names and passwords to allow on-line dues payment etc. For now the newsletter and membership directory will still be available in a password-protected format for SES members.
SES Logo Contest - Submittal Deadline Extended
As a perfect way to add to the changing image of our new SES website, the SES Board would like to update the existing SES logo. We are asking SES members to take part in a contest to replace the current SES logo with a new design. Please send your submissions to the SES Secretary Angela Hansen at by July 31, 2009. A Super Secret Panel of seasoned expert judges will choose the best logo. The designer of the best logo will be awarded a gift certificate for $100 for Amazon.com AND bragging rights.
Tips and Rules:
· Serious entries only
· Stacks are cool, smoking stacks not so much
· Unlimited number of entries for any individual are acceptable
· Camera ready artwork not necessary, but clean images appreciated (GIF file 100 x 100 pixels)
· All entries become the property of SES
We look forward to receiving your entries!
SES Data Quality Committee Report
Roger T. Shigehara & Walter S. Smith
40 CFR Part 51, Methods for Measurement of Filterable PM10 and PM2.5 and Measurement of Condensable Particulate Matter Emissions from Stationary Sources, was proposed in the Federal Register on March 25, 2009 (http://edocket.access.gpo.gov/2009/pdf/E9-6178.pdf)
The Agency reopened the comment period for the proposed rule until June 26, 2009. In case you’re interested, the docket accessible at http://www.regulations.gov. The Docket ID Number is EPA–HQ–OAR–2008–0348.
SES is investigating the possibility of forming a consensus group (see minutes of SES annual meeting). There is, of course, no need to form one, if no one is interested. DQC is conducting a survey of its members to determine the number of interested individuals. If you are interested in participating in any work group to work on test methods, please email your name and test methods of interest to Roger Shigehara (). There was only one party that expressed interest during this last quarter.
Privatization of EPA’s Audit Sample Program
(“Coming Soon - Audit Samples Will Be Required for All Compliance Test Programs”)
Jeffrey W. Burdette, Principal
National Air Measurements Practice Leader
TRC
EPA is “restructuring” the audit sample program and proposing changes that will have a significant impact on all federally required compliance test programs involving non-CEMS parameters. EPA has issued a Federal Register notice on June 16 (FR/ Vol. 74, No. 114/Tuesday, June 16, 2009/Proposed Rules) describing the program changes and comments are due to EPA by July 16, 2009. Over the last year, TNI (The NELAC Institute) has formed a committee (called the Stationary Source Audit Program Committee or SSAS Committee) to develop consensus based standards for a privatized audit sample program as outlined in the proposed EPA rule. The TNI Voting Draft Standard for Participants (Volume 1 Module 3) for participation in the program by facilities, source testing firms, and laboratories can be reviewed at: http://www.nelacinstitute.org/ under “News” dated May 15, 2009. Only TNI members may provide comments directly to TNI on the Voting Draft Standards (VDS). Written comments can be given to SSAS Committee Members, who can then present them to TNI. A quick summary follows:
· EPA is getting out of the role of supplying audit samples – which will be assumed by a pool of accredited audit sample providers (AASP). Historically, EPA provided audit samples free of charge to regulatory agencies.
· EPA is removing language from all individual methods in Parts 51, 60, 61 and 63 that require audit samples and proposing a revision to the General Provision clause of each Part to require audit samples be used in all compliance tests, if available – this represents a substantial expansion of this program as previously only a handful of methods stated that audit samples should be analyzed if available.
· TNI is currently establishing the requirements for Facilities, Regulatory Agencies, Stationary Source Testers, Laboratories, Providers, and Provider Accreditors
· For audits of parameters that typically exist in gaseous form at ambient conditions, the audit material is anticipated to be provided in compressed cylinders and sampled using the reference method sampling train on-site during the compliance test program.
· The responsibility for ordering audit samples, the cost of the audit samples, and the cost of the analyses will all need to be funded by the industrial source owner – which means it’s likely the testing company will have to arrange for these audits as well as the reporting. Testing companies will need to include these added costs in their proposals and test programs.
· The program is supposed to start on October 1, 2009 (start of the next governmental fiscal year).
· EPA has stated that they may take “enforcement action” on facilities that do not participate in the audit program.
A couple of key elements that we believe need to be clarified:
1. How many audits will be required on a given test program – certain SSAS committee members believe an audit per source per parameter is warranted.
2. What happens if an audit fails the acceptance criteria – will the agency reject the test results and does the test need to be performed again – if so, at whose cost?
3. What if you fail to obtain an audit for one parameter of a test program – will the test results be rejected?
4. What are the real national costs of the program versus the value added (i.e. there is the potential for thousands of audit samples). In the FR notice, EPA estimated the cost of the program to industry nationwide to be between $100,000-$150,000 per year. Because the actual audit sample price has not been established by the providers it is uncertain on what costs this estimate is based. EPA estimated that the cost of the audit program per test program will be less than $1000 per test. Again, this cost estimate appears very low.
The TNI SSAS Program committee is chaired by Maria Friedman of Test America and although the committee members are not currently listed on the TNI website, all the minutes from the previous SSAS Expert Committee meetings, as well as the attendees, are available at the TNI website under “Committees”.
We suggest that SES Members do the following:
· Review EPA’s Federal Register notice and provide comments to EPA before July 16, 2009.
· Visit the TNI website and obtain a copy of the SSAS Voting Draft Standard for Participants (Volume 1 Module 3).
· Review the referenced TNI VDS documents and submit comments or request clarifications where appropriate. Submit your comments in writing to the SSAS Committee.
· Reach out to industry clients or industry groups to be sure they are aware of the proposed changes as well as the possible cost increases and encourage them to review and comment
· Check with the local / State Agency representatives to see how prepared they are to administer their portion of this program
What Will Changes in Emission Legislation Mean
for the Pollution Monitoring Industry?
Marcus Pattison
Environmental Technology Publications
The current calm in the pollution monitoring industry belies the challenges ahead. Requirements for reducing the emissions of air pollution have been evolving since middle of the 20th century and are currently a complex medley of limits, targets and caps. Sources must not only comply with rigid emission limits but must also provide emissions data to a number of different agencies and bodies to comply with the different legislative formats and reporting systems at the regional, national and international level. The international community is currently working to improve the co-ordination between monitoring systems and the legislation they support - for example, the EU aims to improve the alignment between the Large Combustion Plant Directive and the Integrated Pollution Prevention and Control Directive. But what will these and other changes in emission legislation mean for the pollution monitoring industry?
· more pollutants will require monitoring from a greater number of sources (for example, mercury is rapidly moving up the agenda in the EU, USA and Asia ahead of the legally binding UN EP Global Treaty on Mercury to be set in 2013);
· advanced systems and methods will be required to measure lower and lower concentrations of pollutants as emission limits tighten;
· speciation of pollutants such as PM10/2.5 will become a priority as non-attainment areas struggle to determine how best to target reductions;
· increased accuracy will become paramount as pollutants such as N2O, CH4 and possibly Hg are introduced to trading markets in the EU and USA. Once a monetary value comes into play, measurement accuracy becomes an economic target as well as an environmental one. Emission factors may be called into question, with real data being used to confirm or refute;
· as legislation and action plans grow in number and stringency, the importance of monitoring and quantifying this pollution in an accurate and transparent manner will become a priority. Real-time and on-line reporting systems will be the aim for most large sources.