USEPA

1
USEPAs Proposed Competency Requirements for
Performing Acid Rain, CAIR Mercury
RATAs(Includes Protocol Gas Verification Program
Presentation)

• John Schakenbach, USEPA, CAMD
• EPRI CEM Users Group Meeting
• Phoenix, AZ
• May 9 - 11, 2007

2
Background

• 1970s stack test methods were developed
• 1990s complaints on quality of stack testing
• Dan Bivins worked on accrediting individuals and
  companies effort stalled
• 1999 Dan restarted accreditation effort both SES
  and EPA wanted it NELAC wanted to be in charge
  of it
• NELAC mainly involved in lab accreditation
• Proposed a fee-based State-by-State program no
  individual qualification requirement

3
Background

• 2001 Louisiana is only State with stack testing
  accreditation program
• Currently no other States have plans to adopt
  NELAC approach
• In 2001, to avoid State-by-State competency
  requirements and fees, ASTM got involved

4
Background

• In 2004, ASTM D 7036-04 became final
• Specifies general requirements for competence to
  perform air emissions tests of stationary sources
• Consensus-based, developed by representatives
  from large and small stack testing companies,
  State and federal govs, private industry
• Nationwide
• Based largely on ISO 17025

5
Background

• August 22, 2006 EPA proposed Part 75 rule
• Any AETB conducting RATAs of CEMS or sorbent trap
  monitoring systems, or Appendix E testing, or
  deriving default emission rates for LME units
  under this part must conform to the requirements
  of ASTM D 7036-04
• Not applicable to daily calibration error checks,
  daily flow interference checks, quarterly
  linearity checks or routine maintenance of CEMS
• Comment period closed Oct 23, 2006

6
ASTM D 7036-04, Standard Practice for Competence
of Air Emission Testing Bodies

• The following is a general summary of the
  Practice. Read the Practice for complete
  requirements.
• Scope
• Testing and calibration performed using standard
  methods, non-standard methods and methods
  developed by the AETB
• Applies to all bodies engaged in air emission
  testing
• Organization and Management
• Shall have a quality system to monitor and
  improve ability to deliver, measured by
  performance data

7
ASTM D 7036-04, Standard Practice for Competence
of Air Emission Testing Bodies

• Clear organizational structure
• Have a technical manager
• Have a quality manager
• Have a qualified individual on-site for each test
  project, who is qualified for each test method
  performed
• Upon request, provide documentation of compliance
  with Practice
• Document Control
• Sufficient to preclude use of invalid or obsolete
  documents
• Documents shall be uniquely identified
• Procedures for making document changes

8
ASTM D 7036-04, Standard Practice for Competence
of Air Emission Testing Bodies

• Quality System, Audit, and Review
• AETB shall have a quality policy commitment by
  top management to follow Practice
• Quality system to ensure consistent achievement
  of data, including quality objectives for AETB
  projects
• Quality manual (outline is provided at end of
  Practice) shall address all topics covered in the
  Practice
• Internal audits shall be conducted annually by
  AETB
• External audits (use of NACLA recognized bodies
  is encouraged) shall be performed if available
  and relevant
• AETB shall collect performance data and inform
  clients that it is available for review

9
ASTM D 7036-04, Standard Practice for Competence
of Air Emission Testing Bodies

• Personnel
• AETB management shall ensure competence of
  individuals performing testing or related
  activities, and formulate necessary training
  requirements
• Qualified individual shall meet experience
  requirements and pass qualification exam at least
  once every 5 years
• Accommodation and Environment
• To extent practical, ensure that environmental
  conditions do not invalidate measurement results
• Equipment and Reference Materials
• Proper equipment shall be available and
  calibrated with equip status labeled

10
ASTM D 7036-04, Standard Practice for Competence
of Air Emission Testing Bodies

• Measurement Traceability and Calibration
• All equipment shall be calibrated before use and
  be on a calibration schedule
• Reference materials shall be traceable to
  certified reference materials
• Test Methods
• AETB shall use latest edition of appropriate
  method
• Deviations shall be documented
• Site-specific test plan shall be used for each
  test project
• AETB shall have up to date instructions on use of
  all relevant equipment
• Uncertainty estimates for measurements shall be
  provided following test protocol can meet this
  requirement

11
ASTM D 7036-04, Standard Practice for Competence
of Air Emission Testing Bodies

• Handling of Sampling and Calibration Material
• AETB shall use chain of custody and other
  necessary procedures to protect integrity of
  sample calibration material
• Shall have a system for identifying samples
• Sample or calibration material abnormalities
  shall be recorded and client shall be consulted
• Records
• AETB shall establish and maintain procedures for
  storage, back-up, retrieval and protection of
  quality technical records
• Data and calculations shall be recorded at the
  time they are made and in enough detail to
  establish an audit trail
• Mistakes shall be crossed out, dated, signed, and
  the correct value entered

12
ASTM D 7036-04, Standard Practice for Competence
of Air Emission Testing Bodies

• Reporting
• Test results shall be reported accurately,
  clearly, objectively and include specific
  information identified in the Practice
• Opinions and interpretations shall be clearly
  marked as such and the basis for them provided
• Signed statement by responsible official that the
  AETB conforms to the Practice during the test
  project
• Sub-contracting of Services
• AETB shall maintain a record of evidence that the
  subcontractor complies with Practice

13
ASTM D 7036-04, Standard Practice for Competence
of Air Emission Testing Bodies

• Outside Support and Supplies
• AETB shall ensure that purchased supplies or
  services comply with specified requirements prior
  to use records of such compliance checks shall
  be maintained
• Identification and Control of Non-conforming Work
• AETB shall have defined procedures to handle
  nonconforming work, including corrective actions
• Corrective Action
• Determine root cause of problem
• Document and implement any required changes
  resulting from corrective actions and monitor
  results to ensure effectiveness audits should be
  implemented

14
Summary of Significant Comments on Proposed Part
75 AETB Provision

• Comment Will increase cost and difficulty.
• Comment QSTI exams and accreditation are
  unavailable.
• EPA Comment Accreditation is not required.
  STAC is providing accreditation if a company
  chooses to be accredited. SES is improving and
  expanding the QSTI examination process. If an
  external exam is not available, a company may
  provide internal exams.

15
Summary of Significant Comments on Proposed Part
75 AETB Provision

• Comment Quality of data will not improve.
• Comment Should exclude testing done by plant
  employees.
• EPA Comment We are considering these and all
  other comments received.

16
Summary of Significant Comments on Proposed Part
75 AETB Provision

• Comment How will compliance be determined?
• EPA Comment
• 6.1.2, Appendix A of the proposed Part 75 rule
  has two ways an AETB can certify compliance
• A certificate of accreditation, or
• A letter of certification signed by senior
  management
• Every State has a field test observer program.
• A standardized State observer checklist is being
  developed
• EPA can use enforcement discretion.

17
Summary of Significant Comments on Proposed Part
75 AETB Provision

• Comment What happens when test methods are
  created or revised?
• EPA Comment
• All Qualified Individuals must re-test every 5
  years.
• If an external exam is unavailable, internal
  testing may be used to meet the requirements of
  D7036 until an external test is available.
• 8.1, 8.2, 8.4, 12.6 and 12.9 of D7036 require
  an AETB to provide training to keep personnel
  up-to-date for any new or revised methods, and to
  evaluate the effectiveness of such training.

18
Summary of Significant Comments on Proposed Part
75 AETB Provision

• Comment EPA should allow certification to other
  programs, e.g., Louisiana.
• EPA Comment
• LELAP was created before D7036 and was designed
  for Louisiana it is not a consensus standard.
• Some stack test companies intend to comply with
  both D7036 and LELAP.
• ASTM work group was trying to avoid
  State-by-State programs because companies would
  need to maintain and pay for the program in every
  State they do business.

19
Summary of Significant Comments on Proposed Part
75 AETB Provision

• Comment One commenter suggested that the term
  documented quality system was unclear.
• EPA Comment
• The term is generally described in D7036,
  Sections 7.2.1, 7.2.2, and Note 7.
• ANSI/ASQ E4-1994 defines a quality system as
• a structured and documented system describing
  the policies, objectives, principles,
  organizational authority, responsibilities,
  accountability, and implementation plan of an
  organization for ensuring the quality in its work
  processes, products, items, and services. The
  quality system provides the framework for
  planning, implementing, and assessing work
  performed by the organization and for carrying
  out required QA and QC.

20
Summary of Significant Comments on Proposed Part
75 AETB Provision

• Comment Several commenters suggested that a
  transition period should be provided before D7036
  is required.
• EPA Comment
• As of May 1, 2007, 54 QSTI (passed exam and
  experience requirements, and represent 34
  companies)
• Group 1 43
• (Methods 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 2H, 3, 3B,
  4, 5, 5B, 5D, 5E, 5F 17)
• Group 2 18
• (3B, 6, 6A, 6B, 7, 7C, 8, 11, 13A, 15A, 16A, 26,
  26A, 202)
• Group 3 34
• (3A, 6C, 7E, 10, 10B, 20 25A, and PS2, PS3,
  PS4, PS4A, PS5, PS6 PS7)
• Group 4 2
• (12, 29, 101, 101A, 102 Ontario Hydro Method)

21
Summary of Significant Comments on Proposed Part
75 AETB Provision

• Comment (Contd) Several commenters suggested
  that a transition period should be provided
  before D7036 is required.
• EPA Comment (Contd)
• SES is taking steps to improve and expand
  testing.
• Many AETBs are going through STAC accreditation
  others will choose senior management
  certification.
• If external exam not available, internal testing
  may be done until external exam is available.
• We understand the need for a transition period,
  especially for the new mercury test methods which
  are not yet available.

22
List of Qualified Individuals

• www.sesnews.org
• Stack Tester Qualification Program
• List of Qualified Individuals
• Frequently Asked Questions
• Info on Exams

23
How to Get ASTM D 7036-04

• To get a copy of ASTM D 7036-04, Standard
  Practice for Competence of Air Emission Testing
  Bodies
• e-mail service_at_astm.org
• web www.astm.org
• phone [phone]
• fax [phone]
• cost 35

24
USEPAs Proposed Protocol Gas Verification Program
25
What is the Problem?

• Historically, blind audits of calibration gases
  have shown poor quality initially.
• SO2 RATA using plants incorrect cal gas (low by
  15). Source could underreport SO2 by 15 and be
  undetected for at least 6 months.

26
Why is Accurate Cal Gas Important?

• Only daily assurance CEM is really working
• Reference Method analyzers need accurate
  calibration gases to produce accurate RATA
  results.

27
Purpose of Blind Audits

• Help vendors improve gas quality
• Help sources identify good vendors

28
Background

• 1970s -1996, 2003, and 2006 EPA audited gases
• Posted results (except for 2006)
• In 1995, one vendor off by -16.3 (CEM would
  underreport)
• Strong utility and vendor support
• Auditing strongly correlated with improved gas
  quality

29
Audits Can Be Effective
1992 1993 1994 1995 1996 2003
30
Background

• August 22, 2006 EPA proposed Part 75 rule
• Any specialty gas company advertising,
  distributing, or certifying gas as EPA Protocol
  Gas must participate in the Protocol Gas
  Verification Program.
• Comment period closed Oct 23, 2006

31
EPA Protocol Gas Verification Program

• Created by EPA and specialty gas vendors
• Funded by specialty gas vendors
• Guided by an Advisory Group
• EPA
• Gas vendors
• ICAC
• EPRI
• SES
• NACAA (STAPPA/LAPCO)
• Administered by ICAC

32
EPA Protocol Gas Verification Program

• Institute of Clean Air Companies
• Annually
• Solicits gas producers to participate
• Collects sufficient funds for program operation
  and disburses funds
• Develops list of participants
• Helps communicate results
• Advisory Group
• Negotiates contracts with third party sampling
  agent and lab and ICAC administrative costs
• Sub group recommends gases to be audited

33
EPA Protocol Gas Verification Program

• Third Party Sampling Agent
• Obtains sample of unused, unexpired, EPA Protocol
  Gas cylinders sample is blind to gas producers
• Ships cylinders to lab following chain of custody
  procedures
• Third Party Analytical Verification Lab
• Analyzes cylinders and reviews certificates of
  analysis
• Reports results to EPA
• Assists gas vendors upon request
• Ships cylinders and certificates of analysis back
  to owner following chain of custody procedures

34
EPA Protocol Gas Verification Program

• EPA
• Provides overall technical oversight
• Final selection of gases to be audited each year
• Informs ICAC and gas vendors of audit results
• Posts final audit results on web site
• Specialty Gas Producers
• Follow the EPA traceability protocol in making
  EPA Protocol Gas
• Participate in and fund the PGVP if they
  advertise, distribute, or certify EPA Protocol
  Gas

35
Summary of Comments on Proposed Part 75 PGVP
Provision

• Council of Industrial Boiler Owners was concerned
  about effects on gas supply and cost, and
  suggested at least a one year transition period
  before the PGVP takes effect.
• One gas vendor submitted late comments against
  the program and several organizations submitted
  late supportive comments.

36
Next Steps

• The proposed Part 75 rule is expected to become
  final late summer.
• EPA will get the word out.
• Once rule takes effect, utilities should
  remember
• Anyone performing Part 75 RATAs, Appendix E or
  LME testing must comply with ASTM D 7036.
• Any EPA Protocol Gases used must be from vendor
  participating in the PGVP.

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For a Copy of Presentation

• www.epa.gov/airmarkets, click on Recent
  Additions, scroll to the presentation
• or
• John Schakenbach
• Phone [phone]
• schakenbach.john_at_epa.gov