AWMA Puget Sound Chapter Pacific Northwest International Section HANDS-ON EMISSIONS TESTING WORKSHOP Quality Assurance

1. A&WMAPuget Sound ChapterPacific Northwest International SectionHANDS-ON EMISSIONS TESTING WORKSHOPQuality Assurance, Calibrations, Chain of Custody, and More Jim Serne, PE, QSTI

2. Page 2 Presentation Overview Quality Assurance Calibrations Chain of Custody, Sample Handling & Transport Audit Samples Accreditation � QIs & AETBs

3. Introduction Emission Measurements are typically made to determine compliance with emission limits which are specified in federally and/or state enforceable rules. Penalties for non-compliance can be significant. Emissions Measurements must be �complete, representative, and of known precision and accuracy.� EPA has established QA requirements and QA guidance to ensure that emissions measurements meet the above objectives. Page 3

4. Page 4 Quality Assurance Quality Assurance (QA) requirements and guidelines can be found in: EPA Quality Assurance Handbook for Air Pollution Measurement Systems, Volume III - Stationary Source Methods (�QA Handbook�) 1977 version with supplements until 1988 1994 version Each EPA Reference Method has QA requirements Quality Assurance Project Plan (QAPP)

5. Quality Assurance Equipment, Reagent, and Performance Specifications (specified in the Reference Methods �RM�) Documentation (data sheets, field notes) Example data sheets in QA Handbook and RM Indelible Ink Do not erase mistakes, rather they must be lined out, initialed, and the correct data written above. Chain of Custody (to prevent losses, mixups, contamination, tampering, and to document the integrity of the data. Page 5

6. Quality Assurance Completeness is the percentage of the required field and lab measurements and all of the necessary documentation that was achieved. Completeness usually specified in QAPP. Representativeness is related to �when, how, and how many� measurements are taken. This often relates to the underlying regulation. i.e., source operating at maximum capacity, the averaging time of the standard, the maximum or minimum control device operating parameters, etc. Accuracy � degree of closeness or measurement deviation from true value Precision � reproducibility or repeatability or scatter from the true value Page 6

7. Page 7 Calibrations Calibration Procedures and Requirements have been specified for all equipment used to make emission measurements, such as: Dry Gas Meters (Meter Box) Pitots Thermocouples & T/C Readouts Balances Barometers Nozzles Analyzers

8. Calibrations Meter Box Calibrations & Calibration Checks � See Method 5 Initial or Annual � Calibration of DGM with Wet Test Meter or Critical Orifice (calibrated against a Wet Test Meter) at a minimum of three orifice settings Post-Test � 3-point calibration of DGM with Wet Test Meter or Critical Orifice (calibrated against a Wet Test Meter) at intermediate orifice setting from prior test Alt-009 � Check Yqa value for each test run. Average of 3-runs must be less than 5%, if not do Post-test Cal. DGM Field Audits or 10-minute Audits Page 8

9. Calibrations Pitot Calibrations Method 2 includes design specifications for Type S (Section 6.1) and Standard Pitots (Section 6.7) Calibration procedure in Section 10 Physical Dimensions & Alignment If design specs are met can use �baseline coefficient� value of 0.84 Wind Tunnel Calibration � typically yields 0.82 or 0.83 Unique ID # required on each pitot Page 9

10. Calibrations Nozzles Method 5 Section 10.1 calibration procedure Micrometer � average of triplicate measurements Measure to 0.1 mm (0.004 inch) Inspect for damage, nicks, dents, shape Unique ID # on nozzles Sizes in 1/16-inch increments Thermocouples Method 2 Section 10.3 calibration procedure Temperature Baths � ice bath & boiling water Within 1.5% of absolute temperature ALT-011 for post-test � single point calibration check Page 10

11. Calibrations Barometer Compare to Mercury Barometer National Weather Service (sea level value) Adjust to Stack Height (location of Meter Box) Balances NIST Weights Check Field Balances with Known Weight Page 11

12. Calibrations Analyzers for Gaseous Criteria Pollutants EPA Methods specify calibration procedure EPA Method 7E (replaced procedures previously in M6C) Use EPA Protocol Gases Low Level Gas-Less than 20% of span (may be zero gas) Mid Level Gas - 40 to 60% of span gas High Level or Span Gas Run average value must not exceed span gas value Page 12

13. Sample Log & Chain of Custody To prevent losses, mixups, contamination, tampering, and to document the integrity of the data. Complete list of samples Prepared in field during or after sample train recovery Document each sample fraction Often a separate sample log or COC for each Method Instructions for laboratory Document who handles the samples from sample recovery person in field to sample receiver at laboratory Custody seals on samples or sample boxes & coolers Photographs of samples Page 13

14. Sample Transport or Shipping Sample preservation requirements, such as keep chilled or add preservative Test firm deliver directly to laboratory Commercial carriers, such as FedEx or UPS Many types of samples must be shipped as hazardous materials Solvent rinses Acids from metals train IATA Requirements and Hazardous Goods Training Special shipping containers Special packaging and procedures to ship samples that must be kept cold. Page 14

15. Audit Samples - History Many EPA RM specify that an Audit Sample be obtained and analyzed along with the field samples, if such an Audit Sample exists. Historically, EPA provided Audit samples and maintained a database of Audit results. Implementation of the Audit Program was the responsibility of the State / Local Agency. EPA-RTP funded a contractor that prepared and shipped EPA Audit Samples to State or Local Agencies. This approach has / is ending No more Audit samples are being made and audits are only available until the EPA inventory runs out. Page 15

16. Restructuring the Audit Sample Program Privatization of the EPA Stationary Source Audit Program (SSAP) EPA is amending the General Provisions to Parts 51, 60, 61, & 63 Makes the Facilities responsible for obtaining the Audit Samples EPA can take enforcement actions against the facility if Audits are not acquired and analyzed. Proposed revisions in Federal Register on June 16, 2009 Promulgation is expected by May 31, 2010 Implementation to begin 30 days after promulgation date, if audits are available. Page 16

17. EPA Introduction to Restructured Audit Program �Quality assurance is an important part of evaluating the validity of compliance test data. One way of checking the quality of the data obtained during compliance tests is to use audit samples. Audit samples are samples whose true value is known to the supplier but not to the user and are analyzed alongside the samples collected in the field during the compliance test to evaluate the quality of the data. In the past, there were no private entities who supplied stationary source audit samples, so EPA provided them free of charge to regulatory agencies. Over the past few years with the emergence of field sampling and laboratory accreditation programs, there has been an increasing need for such samples and a number of private providers have emerged. EPA believes it is no longer necessary for it to supply audit samples and, therefore, has decided to restructure the audit program to allow private accredited suppliers to provide audit samples to industries for use in compliance testing at stationary source facilities.� Page 17

18. Another Perspective on Audit Program Restructuring Historically, less than 25% of all compliance tests included Audit samples. The ordering of Audit samples was the responsibility of the State or Local Agency, and many agencies did not bother to order EPA Audit samples. EPA was unable to �force� State / Local Agencies to use Audit samples. By restructuring the Audit Program, EPA has shifted the responsibility and cost for acquiring and analyzing Audit samples to the facility. A huge increase in the usage of Audit samples will result. Providers are eager to sell Audit samples. Page 18

19. SSAS Terminology & Players Providers � the firms that make and sell SSAS. Accreditors � the firms that evaluate and accredit the Providers Participants � Facilities at which compliance tests are conducted, Testers that conduct compliance tests, Laboratories which analyze the samples. Page 19

20. Audit Samples � TNI SSAS Program In response to EPA privatization of Audits, The NELAC Institute (TNI) formed an �Expert Committee� to develop �standards� for the Providers, Participants, and Accreditors of Stationary Source Audit Samples (SSAS) SSAS Expert Committee consists of representatives of EPA, State Agencies, Providers, Laboratories, Testers, and Accreditors Standards available at TNI web site. Subcommittee is currently setting acceptance criteria and audit sample concentration ranges for each analyte. The acceptance criteria are being set based on statistical analysis of the data in EPA�s Audit Sample database. Page 20

21. Audit Program � Expanded Reach Increased number of Audits because all facilities must acquire and analyze them, not just the facilities in the 10 or 15 states that traditionally ordered Audits from EPA. Providers are developing Audits for all EPA Methods, including Method 5. Providers are developing additional analytes, such as HF, HBr, Cl2, and Br2 for Method 26/26A EPA has promised to enforce the amended General Provisions by taking enforcement actions against facilities that do not report Audit sample results with compliance tests. Facilities will likely rely on the Testers to acquire Audit samples Page 21

22. Consequences of Failed Audit Sample �The audit sample must be analyzed by the same analyst using the same analytical reagents and analytical system as the compliance samples. Retests are required when there is a failure to produce acceptable results for an audit sample. However, if the audit results do not affect the compliance or noncompliance status of the affected facility, the compliance authority may waive the reanalysis requirement, further audits, or retests and accept the results of the compliance test.� Statistically, based on EPA�s historical data, approximately 1 of every 10 audits may be failed. Page 22

23. Information on SSAS Program EPA � OAQPS - RTP Candace Sorrell (919) 541-1064 sorrell.candace@epa.gov TNI www.nelac-institute.org SSAS Expert Committee � Maria Friedman (714) 656-4311 Maria.Friedman@testamericainc.com Page 23

24. Accreditation of Test Firms and Testers - Background Part 75 will specify that a Qualified Individual (QI) be onsite to conduct all Part 75 required emissions testing and that the Test Firm (AETB) meet ASTM D 7036 requirements. EPA originally promulgated rule on January 20, 2008 - litigated Proposed Rule Signed by EPA Admin - April 29, 2010 Amendments to Minimum Competency Requirements for Air Emission Testing Comment Period is open now Page 24

25. Qualified Individuals - QI Source Evaluation Society developed examinations for stack testers Currently exams for four �groups� of methods Group 1 � Basic Knowledge & Basic Isokinetic Methods � Methods 1 through 5 Group 2 � Manual or Wet Chemistry Gaseous Pollutant Methods Group 3 � Gaseous Pollutant Instrumental Methods Group 4 � Hazardous Metals Methods QSTI � Qualified Source Test Individual � pass exams and submit documentation of experience QSTO � Qualified Stack Test Observer � State / Local Agency Staff Page 25

26. Test Firm Certification Test Firms must comply with ASTM D7036 �Standard Practice for Competence of Air Emission Testing Bodies� ASTM D7036 is a quality management standard Test Firm / AETB can certify compliance by self certification or by use a third party accrediting organization. Source Testing Accreditation Council (STAC) Page 26

27. ASTM D7036 � What is Competence Competence � the ability to consistently produce acceptable data of known and documented quality. An AETB shall be considered competent if it has in place and continually operates under a quality system meeting the requirements of this practice. ASTM D7036 is for use by AETBs in developing quality, administrative, and technical systems that govern their operations. The AETB shall have in place a structure, including a quality system that enables it to continually monitor and improve its ability to deliver its scope of services. Quality Manual � Must follow ASTM D7036 outline which cross references ISO standards. Page 27

28. AETB Requirements � All Addressed in Quality Manual Document Control System Quality System, Audit & Review Personnel Training & Management Equipment & Reference Materials Measurement Traceability & Calibration Use Appropriate Methods for Sampling, Analysis, Handling, Transport, Storage,�� Handling of Sampling & Calibration Material Records Reporting Purchasing of Supplies Sub-Contracting � (Sub-Contractors must also be competent) Corrective Actions Policy & Procedures Page 28

29. 29 Major Components of Proposed Part 75 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 75.

30. 30 Major Components of Proposed Part 75 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 7036. 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

31. 31 Major Components of Proposed Part 75 Elements to be reported through ECMPS and retained on-site for 3 years: Name, telephone number and e-mail 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 7036-04; and The name and e-mail address of the qualification exam provider.

32. 32 Major Components of Proposed Part 75 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 months; Written description of any corrective actions being implemented by AETB during prior 12 months; and AETB�s training records for prior 12 months.

33. 33 Major Components of Proposed Part 75 AETB recordkeeping provisions would commence 6 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

34. Information on Accreditation Requirements EPA Clean Air Markets Division � Washington, DC John Schakenbach (202) 343-9158 Schakenbach.john@epa.gov Source Evaluation Society (SES) � List of QSTIs & QSTOs www.SESNews.org Source Testing Accreditation Council (STAC) List of AETBs www.betterdata.org Page 34

35. QUESTIONS OR COMMENTS Jim Serne, PE, QSTI (919) 256-6231 (919) 302-2520 - cell jserne@TRCSolutions.com Greg Lipnickey, QSTI (425) 489-1938 (206) 851-3748 - cell glipnickey@TRCSolutions.com Page 35