ACCREDITATION AND REGULATION IN THE U.S. THE CHANGING LANDSCAPE

Transcription

1 ACCREDITATION AND REGULATION IN THE U.S. THE CHANGING LANDSCAPE

2 The Presenter Background OVERVIEW Accreditation Basics Current Status Issues

3 Vice-President, Air Measurement Services, Southeast Region, Montrose Environmental Formerly President of Entec Services 35 years industrial experience 10 years in source testing Immediately prior to joining Entec, spent 4 ½ years in Europe as Head of Technical Support for Mirant PRESENTER J SUTTON

4 Entec started business since 1993 with corporate offices in Birmingham, Alabama and Divisional Offices in Birmingham, AL Mobile, AL Baton Rouge, LA Raleigh, NC Kannapolis, NC Montrose started business in 2012 with the acquisition of SCEC in Orange, CA and acquired Entec Services in 2013 Montrose is now the largest source testing company in the U.S. Offices throughout the U.S. with corporate office in Irvine, CA Full range of source testing Entec has interim accreditation through STAC (ASTM D7036) and LELAP accreditation (Louisiana) MONTROSE ENVIRONMENTAL

5 ??? MONTROSE FAMILY OF COMPANIES

6 ABC Coke REPRESENTATIVE CUSTOMERS

7 Accreditation concerns have been around since the beginning of stack testing in the U.S. (1970 s) In the late 70 s, testing community tried to establish standards (unsuccessfully) Major push by EPA in mid-90 s which also failed Afterwards, some states instituted their own requirements (ex: LELAP) Testing community again began work on developing standards, procedures, etc. in 2003 Source testing is highly fragmented (there are an estimated 400 different firms that conduct testing) BACKGROUND

8 The ASTM standard only applies to USEPA Part 75 Relative Accuracy Tests (RATA s) - EPA Acid Rain Regulation After March 27, 2012, each Part 75 stack test or RATA must be performed by an Air Emission Testing Body (AETB), as defined in 40 CFR 72.2, and at least one Qualified Individual (QI), as defined in 72.2, must be on-site during the testing Also established the Protocol Gas Verification Program (PGVP) Related but not part of the Part 75 regulations is the Stationary Source Audit Sample program ACCREDITATION BASICS

9 ASTM Standard D7036 Issued in 2004 Establishes accreditation standards for Air Emission Testing Bodies (AETB s) Qualified Individuals (QI s) Performance based, consensus standard Based largely on ISO Accredited AETB (per STAC) Firms that have achieved Interim Accreditation have demonstrated that they have developed a quality management system that conforms to ASTM D7036 (19 Total) Accredited firms have demonstrated, through a field assessment, that they operate in accordance with ASTM D7036 (3 Total) STAC (Stack Testing Assessment Council) A not-for-profit organization formed in 2005 STAC developed and administers a program to accredit stack testing companies to the ASTM D7036 competency standard Many STAC companies are active on the ASTM D7036 committee ACCREDITATION BASICS - AETB

10 Monitor and improve performance Corrective actions No undue pressure Independence of judgment and integrity Personnel must be aware of the extent of their responsibilities Competent technical manager Quality manager who has responsibility for the quality system and its implementation QI on-site for each test project ACCREDITED AETB REQUIREMENTS

11 A2LA? ACCREDITATION PROCESS

12 Qualified Individual (QI) Meets specific experience requirements Passed an emissions testing knowledge exam (QI Exam) Agrees that all projects conform to the requirements of the ASTM standard QSTI Program A voluntary certification program to prove compliance with QI requirements Program initiated in 2003 Administered by SES (Source Evaluation Society) Assess the knowledge and capabilities of stack testing individuals Issues QSTI and QSTO (observer) certifications to individuals SES (Source Evaluation Society) The trade association of source testing companies Its mission is to advance the applied sciences relating to source evaluation with respect to air pollution and air pollution control by: Promoting the development of concepts and techniques Encouraging related professional development and knowledge Striving to ensure the highest professional standards by its members ACCREDITATION BASICS - QSTI

13 Qualified Group 1 Isokinetic test methods Group 1A Stack gas velocity & flow rate measurements Group 2 Wet chemistry test methods Group 3 Gaseous pollutants instrumental methods CEMS Performance Specifications CEMS RA requirements of part 75 Group 4 Hazardous metals test methods Group 5 Part 75 CEMS RATAs QSTI GROUPS

14 In QSTI Approved Individuals held a total of 1250 Group certifications In QSTI Approved Individuals hold a total of 2189 Group certifications Exam pass rates have gone from 40.5 % in 2008 to 66.3 % in 2014 Approximately 40% of stack testers now have at least one certification QSTI STATUS Methods Group Approvals Distribution Group 1 Group 2 Group 3 Group 4 Group 5

15 Accreditation requirements are in effect for Part 75 RATA s (a miniscule amount of the overall testing conducted annually) STAC still needs to be granted the authority to provide full accreditation to the standard. A2LA (A TNI FSMO Accreditation Body) has a MOU with STAC to provide assessments under the standard Twenty-two companies have received interim or full accreditation through STAC (which can t provide direct accreditation) Companies currently still have the option of self-certifying that they are in compliance with the standard SES s QSTI program has become the industry standard for determining individual competence The industry is seeing the development of a two-tiered structure among testing firms ( larger accredited vs. smaller non-accredited firms) In the past year, the 23 firms that achieved interim accreditation have consolidated down to 18 CURRENT STATUS

16 The relationship between A2LA and STAC Uncertainty about how national accreditation standards will impact state requirements Possibility that both may be in effect for some time Uncertainty about the timing of EPA s extension of requirements to other areas (ex: Part 60) Possibility of the development of a two-tiered structure among testing firms ( accredited vs. nonaccredited) No standardized QSTI exams for all test methods UNRESOLVED ISSUES

17 The path to accreditation has been long and fraught with ambiguity in the rules, constant changes and tension between the national government and local constituents EPA is forcing changes with the revised Part 75 rules but has stopped short of full implementation EPA s lack of consistency between the various regulations (Part 75 vs. Part 60) will create problems for stack testing companies Dual accreditation standards (state vs. national) will also pose problems The current wave of consolidations may have an impact on future developments towards national accreditation ACCREDITATION SUMMARY

18 To ensure that EPA Protocol gases meet the accuracy requirements of 40 CFR Part 75 To assist calibration gas consumers in their purchasing decisions To provide an incentive for gas vendors that perform well in the audits to continue to use good practices To encourage gas vendors that perform poorly in the audits to make improvements PROTOCOL GAS VERIFICATION PROGRAM

19 SSAP is a way for the EPA to privatize audit samples An audit sample is obtained from NELAC based on anticipated emissions and/or limit. The audit sample(s) are transported in the field with the samples and then are sent to the laboratory for analysis (with the field samples). One audit sample is required per compliance test. On June 16, 2012, two (2) providers were approved Samples must be coordinated with source owner/operator, and local regulatory agency STATIONARY SOURCE AUDIT PROGRAM

20 PSD and Title V Greenhouse Gas Tailoring Rule Changes. By the end of April 2015, EPA will complete a study on remaining GHG permitting burdens that would exist if the program applied to smaller sources. EPA will consider the results of the study to complete a rule by April 30, Many subparts are now requiring ERT reporting. For more info go to: UPCOMING REGULATIONS

21 J Sutton 30 Monroe Dr., Pelham, AL 35124, USA P F MONTROSE-ENV.COM JOHN (J ) SUTTON PRESIDENT CONTACT INFORMATION