Follow NEMC
 |
 |
 |
Implementation Experience with ASTM D7036: What Emission Testing Firms, Accreditation Bodies, Regulators, and the Regulatory Community Need to Know
Oral Presentation
Prepared by D. Elam, Jr.
Summa Consultants, Inc., 100 Deerfield Trail, Chapel Hill, NC, 27516-9510
Contact Information: delam@summaconsultants.com; 919-967-0500
ABSTRACT
Beginning March 27, 2012, each Part 75 stack test or relative accuracy test audit (RATA) must be performed by an “Air Emission Testing Body” (AETB), as defined in 40 CFR 72.2 (i.e., the “Minimum Competency Rule”, and at least one “Qualified Individual” (QI), as defined in §72.2, must be on-site during the testing (see Part 75, Appendix A, Section 6.1.2). By definition, an AETB is a source testing firm that conforms to ASTM D7036, Standard Practice for Competence of Air Emission Testing Bodies.
Although the Minimum Competency Rule allows an AETB to limit the scope of ASTM D7036 conformance to Part 75 test programs, the ASTM standard is intended to apply to all work that an AETB performs, including Part 60 and performance engineering test programs. Further, the Source Evaluation Society (SES) awards the Qualified Source Testing Individual (QSTI) credential, which can satisfy the QI requirement of ASTM D7036; however, there are timing differences in QI and QSTI requirements, which can be challenging to differentiate. The result is that a seemingly straightforward regulatory requirement can be confusing and challenging.
This presentation examines three key areas.
1. The requirements of ASTM D7036 and the Minimum Competency Rule and the relationship between the two.
2. The experience of the Stack Testing Accreditation Council (STAC), an Accreditation Body focused on ASTM D7036, with assessments of AETB’s.
3. The results of queries of EPA’s Emission Collection and Monitoring Plan System (ECMPS) database, the system that Part 75 sources use to report Part 75 test programs.
The presentation will shed light on the challenges associated with the proper implementation of ASTM D7036, providing valuable insights to regulators, the regulated community, AETBs, and other Accreditation Bodies. These insights will enable all parties to develop strategies to quickly identify problems with ASTM D7036 conformance. Such information will allow the selection of properly qualified AETBs and when necessary, be helpful in the establishment and evaluation of effective correction action plans.
Oral Presentation
Prepared by D. Elam, Jr.
Summa Consultants, Inc., 100 Deerfield Trail, Chapel Hill, NC, 27516-9510
Contact Information: delam@summaconsultants.com; 919-967-0500
ABSTRACT
Beginning March 27, 2012, each Part 75 stack test or relative accuracy test audit (RATA) must be performed by an “Air Emission Testing Body” (AETB), as defined in 40 CFR 72.2 (i.e., the “Minimum Competency Rule”, and at least one “Qualified Individual” (QI), as defined in §72.2, must be on-site during the testing (see Part 75, Appendix A, Section 6.1.2). By definition, an AETB is a source testing firm that conforms to ASTM D7036, Standard Practice for Competence of Air Emission Testing Bodies.
Although the Minimum Competency Rule allows an AETB to limit the scope of ASTM D7036 conformance to Part 75 test programs, the ASTM standard is intended to apply to all work that an AETB performs, including Part 60 and performance engineering test programs. Further, the Source Evaluation Society (SES) awards the Qualified Source Testing Individual (QSTI) credential, which can satisfy the QI requirement of ASTM D7036; however, there are timing differences in QI and QSTI requirements, which can be challenging to differentiate. The result is that a seemingly straightforward regulatory requirement can be confusing and challenging.
This presentation examines three key areas.
1. The requirements of ASTM D7036 and the Minimum Competency Rule and the relationship between the two.
2. The experience of the Stack Testing Accreditation Council (STAC), an Accreditation Body focused on ASTM D7036, with assessments of AETB’s.
3. The results of queries of EPA’s Emission Collection and Monitoring Plan System (ECMPS) database, the system that Part 75 sources use to report Part 75 test programs.
The presentation will shed light on the challenges associated with the proper implementation of ASTM D7036, providing valuable insights to regulators, the regulated community, AETBs, and other Accreditation Bodies. These insights will enable all parties to develop strategies to quickly identify problems with ASTM D7036 conformance. Such information will allow the selection of properly qualified AETBs and when necessary, be helpful in the establishment and evaluation of effective correction action plans.