FPA ENVIRONMENTAL SUMMIT A L C A N I N C.

Transcription

1 FPA ENVIRONMENTAL SUMMIT A L C A N I N C.

2 Agenda Method SW 846 Method 24 Method 25 and 25A Method 204 Alcan Packaging Slide 2

3 SW 846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, Official compendium of analytical and sampling methods that have been evaluated and approved for use in complying with the RCRA regulations. SW-846 functions primarily as a guidance document for responding to RCRA-related sampling and analysis requirements. To determine if a material is a hazardous waste To determine if certain constituents are present in the waste, soil or groundwater EPA Web page link epa.gov/epaoswer/hazwaste/test/sw846.htm#how Alcan Packaging Slide 3

4 SW846 Key Areas One reference all sampling and testing methodologies approved by the Office of Solid Waste. The manual provides methodologies for collecting and testing representative samples of waste and other materials to be monitored. Aspects of sampling and testing in SW-846 include quality control, sampling plan development and implementation, analysis of inorganic and organic constituents, the estimation of intrinsic physical properties, and the appraisal of waste characteristics. Short falls Using to determine all hazardous waste codes Understanding of quality control requirements Understanding of the materials you are trying to identify Alcan Packaging Slide 4

5 Method 24 & 24A Method 24 - for paint, varnish, lacquer and coatings to determine: volatile matter content water content Density volume solids, and weight solids. Method 24A for solvent-borne publication rotogravure inks and related publication rotogravure coatings. VOC weight fraction Material density Solvent Density VOC volume fraction Alcan Packaging Slide 5

6 Method 24 Shortfalls Cannot be used to determine VOC in water based materials accurately. ASTM working on Method to be finalized by 2007 Alcan Packaging Slide 6

7 Method 25 This method is applicable for the determination of volatile organic compounds (VOC) (measured as total gaseous nonmethane organics (TGNMO) and reported as carbon) in stationary source emissions. This method is not applicable for the determination of organic particulate matter. The Agency says when the outlet concentration exceeds 50 ppmv this method must be used (April 1995 memo) Agency recognizes that the cost, logistics and other practicalities of source testing may make other methods more preferred for source testing. Alcan Packaging Slide 7

8 Method 25 Inconsistent results Why not repeatable Key Elements for Success Alcan Packaging Slide 8

9 Method 25A This method is applicable for the determination of total gaseous organic concentration using a flame ionization analyzer. Good for concentrations of vapors consisting primarily of alkanes, alkenes, and/or aromatic hydrocarbons. The concentration is expressed in terms of propane (or other appropriate organic calibration gas) or in terms of carbon. Alcan Packaging Slide 9

10 Method 25A Key Elements for Success Alcan Packaging Slide 10

11 Method 25 vs 25A EPA interpretation letter of April 1995 when 25A allowed When the regulation limits the exhaust concentration to < 50 ppmv When the VOC concentration at the inlet of the control device and the required level of control are such to result in exhaust < 50 ppmv, or If because high efficiency of control device the expected exhaust is < 50 ppmv MACT standards Coating (JJJJ) Use same method on inlet and outlet Use Method 25A if any of the following apply The control device is not an oxidizer. The control device is an oxidizer but an exhaust gas VOM concentration of 50 ppmv or less is required to comply with the emission standards, or The control device is an oxidizer but the VOM concentration at the inlet to the control system and the required level of control are such that they result in exhaust gas VOM concentrations of 50 ppmv or less; or The control device is an oxidizer but because of the high efficiency of the control device the anticipated VOM concentration at the control device exhaust is 50 ppmv or less, regardless of inlet concentration Alcan Packaging Slide 11

12 Method 25 vs 25A What has FPA done Letter to Agency requesting information What should we do? Alcan Packaging Slide 12

13 July 11, 2005 Gary McAlister Dave Salman US EPA Mailroom US EPA Mailroom Mail Code D Mail Code C Research Triangle Park, NC Research Triangle Park, NC Re: Applicability of Method 25A to Outlet Concentration Over 50 ppmv Dear Gary and Dave: We appreciated the opportunity to talk with you today regarding our contention that Method 25A is superior to Method 25, even if the anticipated outlet concentration level exceeds 50 ppmv. The purpose of this letter is to request the support documentation that Gary spoke of during our conversation, which established the Agency s preference for the use of Method 25 over Method 25A for oxidizers with VOC outlet concentration exceeding 50 ppmv. According to Gary s recollection, these references apparently discuss the formation of incomplete combustion products in oxidizers and their impact on destruction accuracy. As you know, FPA members are concerned about the inherent lack of replicability and data validity from the use of Method 25, and therefore would like to be able to assess the basis for the Agency s concerns about the application of Method 25A in lieu of Method 25. Thank you for agreeing to share this Method 25A background information and forward it to us. Sincerely, Ram Singhal Director, Regulatory and Government Relations Cc: Barrett Parker Mike Trutna Peter Tsirigotis Alcan Packaging Slide 13

14 Method 204 Testing must consist of at least three three hour test Method Criteria for and Verification of a Permanent or Temporary Total Enclosure Method 204A - Volatile Organic Compounds Content in Liquid Captured Stream Method 204B - Volatile Organic Compounds Emissions in Captured Stream Method 204C - Volatile Organic Compounds Emissions in Captured Stream (Dilution Technique) Method 204D - Volatile Organic Compounds Emissions in Fugitive Stream from Temporary Total Enclosure Method 204E - Volatile Organic Compounds Emissions in Fugitive Stream from Building Enclosure Method 204F - Volatile Organic Compounds Content in Liquid Input (Distillation Method) Alcan Packaging Slide 14

15 Method 204 Recommended Test Methods Protocols Enclosure Verification Liquid Input (L) Capture Emissions (G) Fugitive Emissions F or FB CE Formula PTE M204 NA NA NA 100% TTE gas/gas M204 NA M204B or M204C M204D G/(G+F) TTE liquid/gas M204 M204A or M204F NA M204D (L-F)/L BE gas/gas M204 NA M204B or M204C M204E G/(G+FB) BE liquid/gas M204 M204A or M204F NA M204E (L-FB)/L Alcan Packaging Slide 15

16 Alternative Capture Efficiency Methods Two Methods Data Quality Objective (DQO) Lower Confidence Limit (LCL) Alcan Packaging Slide 16