Preparing for Your Upcoming Stack Test

Source Emissions testing, or stack testing, is mandated by the Clean Air Act of the U.S. Environmental Protection Agency (EPA), which sets forth guidelines and requirements that must be met to determine a facility’s compliance with emission limits.  Any and all plants, factories, and facilities that utilize a stack as part of manufacturing or production operations are required to undergo stack testing in order to demonstrate compliance with current EPA standards.  There is more to stack testing than simple compliance, however.  A properly-executed testing plan gives you the diagnostic tools to help optimize your operations and improve energy efficiency — quality incentives for voluntary stack testing that is not simply driven by EPA requirements.  With careful preparation for stack-testing compliance and the proper execution of the test plan, a company can save money, protect workers, and effectively streamline their operations.

As a company prepares their facility for an upcoming stack test, reviewing the state-approved test plan is the best way to ensure that you understand all of the testing requirements.  Doing so is your greatest insurance that the stack testing results will show proper compliance with all relevant EPA air emission standards.  However, in many cases technical or legal jargon may make a portion or the entirety of the test plan difficult to understand, and it may not contain all of the required information necessary to conduct a successful test.  To assist you with this, we have put together the following Stack Testing Preparation Checklist to help you make sure that your company is properly prepared for your upcoming testing.  All items on this checklist should be reviewed with your qualified stack-testing team.

  1. What Load you will test at – This information is typically in your air permit, and/or determined by applicable federal/state  regulations.
  2. What Fuel you will burn – Different fuel types can have vastly different emission limits
  3. OSHA compliant platforms – How will the stack test team reach the sampling plane?
  4. Power Requirements – Do you have enough circuits?
  5. Safety/Insurance Concerns- What are your facility requirements?  Does your stack test company meet these requirements?
  6. Are your Test Ports free from blockage and EPA Method 1 Compliant?
  7. What Process Data are you required to document, and how will that data be logged?

Here at Environmental Source Samplers Inc., we’re familiar with the pitfalls a company can experience when faced with an upcoming test.  Advance preparation, with these guidelines in mind, will provide your company the ability to address any issues or questions prior to the stack testing date. Saving your company the time, hassle, and money that late revisions and changes inevitably cause.  These guidelines are also helpful in maintaining high levels of safety and compliance regardless of having a scheduled stack test or not, benefitting the overall operations and their environmental impact.

Choosing a stack testing company that has the appropriate background and experience for your industry will help ensure that your stack test will be successful.  The stack testing company should have the capability to execute the testing types and methodologies that govern your specific operations, while using equipment that is well-maintained and up-to-date.  Just as importantly, they should be current and informed on the changes and revisions to existing testing methodologies, since the EPA air emission limits and standards are subject to change as the Agency sees fit.

Stack testing is required and performed for the health and safety of the plant, the workers, and the environment.   It is also a diagnostic tool that provides insight into the efficiency of your operations.  However, whether you are testing for compliance or diagnostic purposes, careful preparation is the key to ensuring that your stack testing project gives you the data that you can use effectively.

Please contact the experts at Environmental Source Samplers (ESS) to learn more about their stack testing services:

Phone: 910-799-1055
Email: [email protected]
Website: www.ESSKnowsAir.com

Important Update Regarding Hurricane Florence

NJ Issues Advisory for Air Permits Issued Prior to 1998

 

***ESS can support all your air compliance testing needs in NJ and worldwide.  Please call 910.799.1055 for more information***

 

Immediate Action Required for Air Permits Issued Prior to 1998

Who is affected by this advisory?

Air-regulated facilities with equipment or sources permitted under pre-construction permits with activity numbers beginning with PCP96 and/or PCP97 are affected by this advisory; for example, PCP960001 and/or PCP970001. These activity numbers are referred to as pre-NJEMS and are permits that were approved before the existence of the DEP’s New Jersey Environmental Management System client-server application, commonly known as NJEMS.

 

What is the background information regarding this advisory?

Before 1998, facilities used paper forms to complete their air permit applications (pre-NJEMS permits). In 1998, the DEP implemented NJEMS, and the Remote AIMS Data Input User System (RADIUS) was used to allow for electronic submittal of air permit applications into NJEMS. After 1998, the pre-NJEMS permits were created in NJEMS for facilities that listed only one piece of equipment and no compliance plan. An activity number was created for each paper permit (the preconstruction permits beginning with 96 and/or 97). The DEP currently maintains about 5,000 preNJEMS permits, of which about 800 are expired.

[Read more…]

Industry Pushes EPA to Continue Implementing MATS Rule

In a letter to EPA air chief Bill Wehrum released July 10, Edison Electric Institute, along with other industry trade groups, urged the government to keep the air toxics standards largely intact.  The about-face comes after years of legal battles to halt implementation of the Mercury and Air Toxics Standards (MATS) earlier this decade.

“It is important to note that all covered plants have implemented the regulations and that pollution controls—where needed—are installed and operating,” the letter read.

“We believe a complete and robust RTR [Residual Risk and Technology Review] will recognize the capital investments already made for compliance and will allow the industry to continue full implementation of the MATS rule, which was completed in April 2016.”

“Therefore, we urge EPA to move forward with an RTR for power plants under CAA [Clean Air Act] section 112 and to leave the underlying MATS rule in place and effective.”

The letter comes as Wehrum said in April that EPA was still considering how to proceed after the Supreme Court’s ruling generally upholding the standards with concern over the expensive price tag associated with compliance measures.

The power industry appears to be seeking regulatory certainty after the bid to block the rule outright failed.  There is evidently concern that continued legal hesitation on the MATS rule could create additional problems.

See the letter here.

OSHA Enforcing New Silica Dust Standard

OSHA has released a memoradum outlining the provisions of its respirable crystalline silica in general industry and maritime standard.

The standard’s provisions, which will be enforceable beginning June 23, establish a new 8-hour time-weighted average permissible exposure limit, action level and associated ancillary requirements.

The agency will offer compliance assistance during the first 40 days of enforcement and will continue to issue interim enforcement guidance until a compliance directive on the new standards is finalized.

OSHA’s Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime discusses methods of compliance, such as using engineering and work practice controls, assessing exposure levels, respirator use, medical surveillance and written exposure plans.

Fuel Economy Reaches New Record, Manufacturers Meet Greenhouse Gas Standards, EPA Reports Show

EPA issued two annual reports that provide information on fuel economy and greenhouse gas emissions from light duty vehicles in the United States. The reports show auto manufacturers continue to innovate and make progress increasing fuel economy and reducing pollution.

The Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975-2017 report is the authoritative reference for real world fuel economy, technology trends and tailpipe carbon dioxide emissions, for new personal vehicles sold in the U.S. every year since 1975.  The report shows fuel economy for the U.S. fleet continues to improve.  Model year (MY) 2016 vehicle fuel economy was 24.7 mpg, slightly higher than MY 2015, and a record high overall. Since MY 2004, fuel economy and CO2 emissions have improved in ten out of twelve years.

The Manufacturer Performance Report assesses compliance performance for individual automakers and for the U.S. fleet as a whole with the greenhouse gas emissions standards for light duty vehicles.  This year’s report shows all manufacturers are in compliance with the standards.

EPA, the Department of Transportation, and the California Air Resources Board implement coordinated regulations for passenger cars and light trucks on fuel economy and GHG emissions.

The Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975-2017: https://www.epa.gov/fuel-economy-trends/highlights-co2-and-fuel-economy-trends

Manufacturer Performance Report:  https://www.epa.gov/regulations-emissions-vehicles-and-engines/greenhouse-gas-ghg-emission-standards-light-duty-vehicles.


Source:
EPA Press Office ([email protected])


ESS provides emissions testing, air quality analysis, and ambient air testing services for municipal water treatment plants, public utilities, manufacturers, paper mills, and other industrial facilities in the US and overseas.  Since its inception in 1979, ESS has conducted thousands of emissions tests and provided countless hours of environmental consulting services.  ESS specializes in conducting the EPA testing methods for all applicable EPA subparts, such as: NSPS (40 CFR 60), NESHAP (40 CFR 63), RATA (40 CFR 75), and various other federal and state regulations.

Call us at 910.799.1055 to request a quote for your next stack emission test project.

What is the Ozone Transport Region and Why Are States Suing the EPA to Enforce It?

Although the issue of pollution carriage was first addressed by the EPA in 1990, there appears to be a growing concern among state regulatory authorities that the current measures taken by the EPA are not stringent enough.  This article will provide an overview of existing regulations and current complaints against the EPA in an effort to inform readers of this re-emerging air quality regulation issue.

What is the Ozone Transport Region?

In 1990, Congress established the Ozone Transport Region (OTR) in the federal Clean Air Act (Section 184(a)) in order to address air pollution in downwind states that is caused by activities in upwind states.  The OTR is essentially a single, 13-state ozone nonattainment area.  The original member states of the OTR are: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, parts of Virginia and the District of Columbia.

The Clean Air Act contains what is known as a “good neighbor” provision, which requires states to examine whether pollution generated in their state contributes to poor air quality in another. If a significant contribution is found, the state must adopt measures to alleviate this contribution and include these measures in its State Implementation Plan. EPA must approve these plans.

[Read more…]

Delaware Plans to Sue EPA for Upwind Air Pollution Relief

Delaware state authorities said Tuesday that they intend to sue the U.S. Environmental Protection Agency for failing to curb the upwind air pollution generated by power plants in neighboring Pennsylvania and West Virginia.

“The Clean Air Act entitles Delaware to relief from upwind pollution and the remedy we are seeking is reasonable and within EPA’s authority and responsibility to grant,” said Delaware Governor John Carney.  The governor’s statements come after four petitions to the EPA in 2016 were unsuccessful in bringing relief from the pollution.

Delaware authorities claim that about 90 percent of the smog in Delaware is caused from uncontrolled emissions in upwind states.  The carriage of air pollution from other states is cited by Delaware’s Department of Natural Resources and Environmental Controls as the reason Delaware struggles to meet federal air quality standards.

“It is now time for EPA to hold upwind sources accountable for ozone emissions that are impacting downwind states,” the department’s secretary, Shawn Garvin, said.

 

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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.

[Read more…]

EPA Announces Intent to Revisit Provisions of Phase 2 Heavy-Duty Rules

 

WASHINGTON — The U.S. Environmental Protection Agency (EPA) announced today its intent to revisit provisions of the Phase 2 Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines following concerns raised by stakeholders in the trailer and glider industry.

“In light of the significant issues raised, the agency has decided to revisit the Phase 2 trailer and glider provisions,” said EPA Administrator Scott Pruitt. “We intend to initiate a rulemaking process that incorporates the latest technical data and is wholly consistent with our authority under the Clean Air Act.”

Background: 

In September 2011, EPA and the National Highway Traffic Safety Administration (NHTSA) issued greenhouse gas (GHG) emissions and fuel efficiency standards for medium- and heavy-duty vehicles for model year 2014-2018 (“Phase 1”). These standards applied to newly manufactured engines, tractors, vocational vehicles, large pickups, and vans. In October 2016, EPA and NHTSA updated the standards for medium- and heavy-duty vehicles MY 2021-2027 (“Phase 2”), and regulated trailers and gliders – for the first time under the GHG program – with compliance deadlines beginning in 2018.

Contact Information: ([email protected])

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