Qualified Source Test Individual SES QSTI Certification/Verification Program AETB Accreditation. Proposed EPA Regulations

Transcription

1 Qualified Source Test Individual SES QSTI Certification/Verification Program AETB Accreditation Proposed EPA Regulations Howard F. Schiff TRC Environmental Corporation Member of Source Evaluation Society (SES) Stack Testing Accreditation Council (STAC) Technical Assessment Board 1

2 Acronyms AETB QI QSTI Air Emission Testing Body/ASTM D7036 Qualified Individual/ASTM D7036 Qualified Stack Testing Individual (SES) 2

3 Historical Overview of Accreditation/Certification Progress 3

4 The 1970 s SES Formed Aim And Objective Of Providing Certification SES Appoints A Committee To Study The Issue SES Abandons Certification Need, Costs, an Staff Demands Cited 4

5 The 1990 s EPA Committee On National Accreditation Of Environmental Labs Formed 1990 ~ SES Asked EMB To Take On The Accreditation Issue NELAC Formed 1999 ISO Developed 5

6 The 2000 s Draft NELAC Standard Proposed. SES Objects to the NELAC Draft SES Decides to Support Development of a Written Standard and Endorse a Organization NELAC Field Activity Chapter Passes a Standard 6

7 The 2000 s (cont.) ASTM Standard Under Development Based On ISO SES QSTI Program Beginning ASTM D7036 Finalized Standard Practice for Competence of Air Emission Testing Bodies 7

8 The 2000 s (cont.) 2004 SES Qualification Committee Formed (again) QSTI Program Developed st QSTI Exams Given Groups I & II st Group III Exams Given st Group IV Exams Given 8

9 The 2000 s (cont.) 2006 Stack Testing Accreditation Council (STAC) Formed SES Members SES Agrees to Support STAC 2007 EPA Part 75 Revisions Include Requirements for Organizations to Conform to ASTM D EPA Part 75 Revisions Reproprosed 9

10 QSTI (QI) 10

11 Definition of Qualified Individual (ASTM D Section 8.3) To be deemed a qualified individual under this practice, an individual shall: Meet the experience requirements of Pass a qualification exam meeting the requirements of Sign a statement, to be kept on file with the AETB, agreeing that all test projects conducted under his/her supervision will conform to the AETB s quality manual and to this practice in all respects A qualified individual must re-take and pass a qualification exam at least once very five years to retain their status as a qualified individual. 11

12 Definition of Qualified Individual (ASTM D Section 8.3) At a minimum, an individual seeking qualification shall meet the following experience requirements prior to taking the qualification exam: Participation in at least ten tests that employ the method(s) for which they are seeking qualification, or Completion of at least one year of general air emissions testing experience. Such experience should include where applicable: a. instrument calibration, b. equipment preparation and packing, c.field set up, d.equipment operation and data recording, e.sample recovery, handling, and custody, f. sample analysis g. Data reduction including relevant calculations, h. Quality control, and i. Reporting. 12

13 QI (QSTI) Requirements Pass Group Method Exams QSTI Qualification Application to Source Evaluation Society Application form Education background Experience Conducted at least 10 test for each method 13

14 QI (QSTI) Requirements (cont.) Completion of at least 1 year of general air emissions Total years testing Experience should include (check all that apply): [ ] Test methods [ ] Plant/Process Operation Coordination [ ] Calibration/preparation/packing [ ] Sample recovery/handing/custody [ ] Set-up at test site [ ] Quality Assurance/Quality Control [ ] Sample analysis [ ] Reporting [ ] Procedure Compliance [ ] Safety training [ ] Data Reduction (Calculations, data validation, and interpretation) [ ] Test planning [ ] Equipment operation/data recording [ ] Troubleshooting [ ] Training 14

15 QI (QSTI) Requirements (cont.) Project descriptions 2 separate projects for each method group References Supervisor State agency representative Client Colleague 15

16 External Exam Provider Source Evaluation Society (SES) QSTI Exam Group 1 EPA methods manual volume and flow measurements and particulate Group II EPA methods manual gaseous pollutants source sampling methods 16

17 External Exam Provider Source Evaluation Society (SES) (cont.) QSTI Exam Group III EPA methods Gaseous pollutants instrumental methods and CEMS performance specifications Group IV EPA methods Hazardous metals measurement methods 17

18 QSTI Credentials from SES 18

19 AETB Accreditation STAC Stack testing accreditation council ( Interim accreditation Final accreditation AETB will provide on-site a QI for every test program QI is either AETB certified or external (QSTI) AETB will certify QI for methods not covered by an external exam with an internal exam 19

20 Proposed Rule: Amendments to the Protocol Gas Verification Program and Minimum Competency Requirements for Air Emission Testing Federal Register June 11, CFR Part 75 Continuous Emission Monitoring Section Certification, Quality Assurance and QC Procedures 75 Appendix A Section Requirements for Air Emission Testing 20

21 Major Components of Proposed AETB 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

22 Major Components of Proposed AETB (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 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 22

23 Major Components of Proposed AETB (Cont d) Elements to be reported through ECMPS and retained on-site for 3 years: Name, telephone number and 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 ; and The name and address of the qualification exam provider. 23

24 Major Components of Proposed AETB (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. 24

25 Major Components of Proposed AETB (Concluded) AETB recordkeeping provisions would commence 6-12 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 Date to change to days after Final Rule Published in the Federal Register, sometime at the end of November or early December. Rule to be effective days post publication and compliance implementation 1 year from effective date. 25