Kent Nilsson R.,TRC Environmental Corporation
PEERS Conference 2014 | Year: 2014
The recent, highly-publicized releases of residuals or chemicals from industrial containment structures into public waters has focused new attention on treatment basins and impoundments located on rivers and waterways. By nature of its facility locations, the forest products industry is expected to be under increased regulatory and public scrutiny. These existing impoundments are most typically constructed of earthen berms. The containment can be either lined or unlined. Owner concerns can range from the potential for leaking to catastrophic structural failure. Failure can be the result of deferred maintenance, changes in storm water management, material deterioration, inattentive operation, etc. Understanding and managing the risks associated with the entire containment system will be critical to maintaining impoundment integrity and preventing any release.
Serne J.,TRC Environmental Corporation
Proceedings of the Air and Waste Management Association's Annual Conference and Exhibition, AWMA | Year: 2012
In December 2010, the EPA replaced Method 201A for PM10 sampling and Method 202 for determining condensable PM with new sampling and analytical procedures. PM2.5 and/or PM10 can be determined by the new Method 201A. However, at many emission sources, especially those equipped with efficient control devices, Method 201A test runs would need to be several hours long in order to collect sufficient PM in the cyclone(s) to gravimetrically determine the PM10 and/or PM2.5 size cuts. An alternative sampling and analytical procedure is described that entails collecting the particles on smooth surfaced filters which can be analyzed by SEM. It focuses on the differences between EPA Method 201A and the SEM based test method. Differences in sampling equipment, analytical procedures, as well as potential differences in test results and cost are discussed. This is an abstract of a paper presented at the 106th AWMA Annual Conference and Exhibition (Chicago, IL 6/25-28/2013).
Krall M.,TRC Environmental Corporation
Environmental Conference 2013 | Year: 2013
The refinery ICR initiated a sampling and analysis undertaking that challenged the refineries, air testing groups and analytical laboratories. Many sources presented unique challenges in applying traditional EPA test methodologies. The request to gather standard pollutant and hazardous air pollutant (HAP) data from delayed coking unit (DCU) vent exhausts using traditional EPA combustion source test methods presented perhaps one of the most significant challenges. Most, if not all, DCU vent sources are comprised of moisture vapor on the order of >90% (and often up to 98-99%). In addition, these vents are typically hot and have high velocities during their short venting cycles. Despite pretesting discussions over the methods applicability, the refinery ICR went forward with the challenge of using traditional air testing methods to collect data from, essentially, a liquid stream. The challenge was met head on and through planning, pretesting, and imaginative modifications to the required test methods, DCU vent exhaust data was generated. Unfortunately, the generated data was shown to be limited in its application to the development of future MACT standards for DCU vent sources due to a number of factors, specifically, elevated limits of detection for a number of compound groups. This presentation is designed to show that through thoughtful consideration and imagination, solutions can be developed and applied to a seemingly "un-testable" source, but the use of air methods on super-saturated vent exhausts has brought into question the applicability of those methods based on the data results.
Krall M.J.,TRC Environmental Corporation
Air and Waste Management Association - International Conference on Thermal Treatment Technologies and Hazardous Waste Combustors 2013 | Year: 2013
The term Comprehensive Performance Test (CPT), as it relates to hazardous waste combustion (HWC), implies trialing a combustor under extreme operating conditions to demonstrate air emissions compliance and provide flexibility for future operations. Typically, a CPT is conducted for the purpose of complying with RCRA-based HWC MACT standards (i.e. organic compounds destruction, particulate matter, metals and chlorine control, etc.). Recently, the owner of a thermal desorption system (TDS) has been advised that the equipment must comply with the HWC MACT standards as well as state air permit regulations regardless from the fact the TDS does not "combust" hazardous waste. In addition, the TDS owner wishes to obtain further operating flexibility through the treatment of PCB-waste, governed by the (soon to be defunct) TSCA regulations. This presentation will be focused on an integrated approach to provide data to permit and comply the TDS with HWC MACT, TSCA and state air regulations all within the structure of a single test program. The permitting and regulatory aspects of each authority are presented, the details of the test matrix, how each test parameter feeds the requirements of each regulation, and finally, the detailed testing logistics to collect all the required data simultaneously from a single, 4" exhaust location with emphasis on safety, quality, and efficiency.
Hoffnagle G.F.,TRC Environmental Corporation
Air and Waste Management Association - Guideline on Air Quality Models 2013: The Path Forward | Year: 2013
Before EPA requires extremely expensive modeling of new sources to address the secondary impact questions, it must consider the additional burden on new sources to accomplish this modeling and recognize that the expected secondary formation impacts are trivial to less than significant. Sources, such as in the examples presented here, may not contribute significant secondary impacts.