VOCpubs.awma.org/flip/EM-Nov-2014/emnov14.pdf · Chris Tennant, Shirish Shimpi, Tao Huai, Jorn Herner, Ed Nam, Thomas Long, Henry Hogo, and Matthew Thornton Page 26 Air Pollution

NOVEMBER 2014

Conference Highlights:Coordinating Research Council

24th Real-World Emissions Workshop in San Diego, CA

2014 Air Pollution Workshop in Guadalajara, Mexico

Also in this issue:

VOCEmissions& Control

_C1_EM1114-Cover.indd 1 10/20/14 1:09 PM

Copyright 2014 Air & Waste Management Association

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EM, a publication of the Air & Waste Management Association (ISSN 1088-9981), is published monthly with editorial and executive offi ces at One Gateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA 15222-1435, USA. ©2014 Air & Waste Management Association. All rights reserved. Materials may not be reproduced, redistributed, or translated in any form without prior written permission of the Editor. Periodicals postage paid at Pittsburgh and at an additional mailing offi ce. Postmaster: Send address changes to EM, Air & Waste Management Association, One Gateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA 15222-1435, USA. GST registration number: 135238921. Subscription rates are $310/year for nonprofi t libraries and nonprofi t institutions and $465/year for all other institutions. Additional postage charges may apply. Please contact A&WMA Member Services for current rates (1-800-270-3444). Send change of address with recent address label (6 weeks advance notice) and claims for missing issues to the Membership Department. Claims for missing issues can be honored only up to three months for domestic addresses, six months for foreign addresses. Duplicate copies will not be sent to replace ones undelivered through failure of the member/subscriber to notify A&WMA of change of address. A&WMA assumes no responsibility for statements and opinions advanced by contributors to this publication. Views expressed in editorials are those of the author and do not necessarily represent an offi cial position of the Association.

EPA Priority: Leak Detection and Repair (LDAR)by Inaas Darrat, Trinity Consultants Inc. Page 6

Progress on VOC Control and Management for the Petrochemical Industry in Chinaby Peng Liang, Xueshuang Zhou, and Yiming Yang, Appraisal Center for Environment and Engineering (ACEE), Ministry of Environmental Protection, Beijing, China; and Weiping Dai, Trinity Consultants Inc. Page 12

VOC Emission Characteristics and LDAR Strategies for a Chemical Industrial Park in Jiangxi, Chinaby Jian Li, Liushui Yan, and Qun Cao, Nanchang Hangkong University, Nanchang, Jiangxi, China; Mingming Lu, University of Cincinnati; Chunjuan Xie, Jiaotong University, Nanchang, Jiangxi, China Page 16

PtD and P2: Eliminating VOC Emissionsby Pamela Heckel, independent consultant Page 22

Highlights from the Coordinating Research Council 24th Real-World Emissions Workshop in San Diego, CAby Garry Gunter, Dominic DiCicco, Kevin Black,

Chris Tennant, Shirish Shimpi, Tao Huai, Jorn Herner, Ed Nam, Thomas Long, Henry Hogo, and Matthew Thornton Page 26

Air Pollution at the Local, Regional, and Global Scale: A Summary of the 2014 Air Pollution Workshop in Guadalajara, Mexico

by Judi Krzyzanowski and Sirkku Manninen Page 32

COLUMNS

EPA Research Highlights: Smog Simulator Offers Unique Capabilities to Study Health Impacts of Urban Air Pollutant Mixtures . . . . . . . . . . . . 36

PM File: Contingency Planning Leads to Realistic Project Budgets . . . . . . 38by David Elam

ASSOCIATION NEWSMessage from the President: That Time of the Year . . . . . . . . . . . 2by Michael Miller

DEPARTMENTSNews Focus . . . . . . . . . . . . 40Advertiser’s Index . . . . . . . 42Washington Report . . . . . . 45Canadian Report . . . . . . . . 47Calendar of Events. . . . . . . 48JA&WMATable of Contents. . . . . . . . 48

november 2014 em 1awma.org

Next Month...

Meeting the U.S. 1-hr SO2/NO2

Ambient Standards

FEATURES

12

22

Volatile Organic Compound (VOC) Emissions and Controlby Mingming Lu, University of CincinnatiControlling a myriad of volatile organic compounds (VOCs) emissions can be complicated and challenging. Further complicating matters, ground-level ozone is formed when certain VOCs combine with oxides of nitrogen in the presence of sunlight and heat. This month, EM looks at how some entities are addressing VOC emissions and control. Page 4

CONFERENCE HIGHLIGHTS

16

01_EM1114-TOC.indd 1 10/20/14 12:22 PM


A&WMA HEADQUARTERSJim Powell, QEPExecutive Director

Air & Waste Management AssociationOne Gateway Center, 3rd Floor420 Fort Duquesne Blvd.Pittsburgh, PA 15222-14351-412-232-3444; 412-232-3450 (fax)[email protected]

ADVERTISINGKeith [email protected]

EDITORIAL Lisa BucherManaging [email protected]

EDITORIAL ADVISORY COMMITTEEMingming Lu, ChairUniversity of CincinnatiTerm Ends: 2016

John D. Kinsman, Vice ChairEdison Electric InstituteTerm Ends: 2016

John D. BachmannVision Air ConsultingTerm Ends: 2016

Gary Bramble, P.E.Dayton Power and LightTerm Ends: 2015

Prakash Doraiswamy, Ph.D.RTI InternationalTerm Ends: 2017

Ali FarnoudTrinity ConsultantsTerm Ends: 2017

Steven P. Frysinger, Ph.D.James Madison UniversityTerm Ends: 2016

C. Arthur Gray, IIICP Kelco-HuberTerm Ends: 2016

Christian HogrefeU.S. Environmental Protection AgencyTerm Ends: 2016

Ann McIver, QEPCitizens Energy GroupTerm Ends: 2017

C.V. Mathai, Ph.D., QEPRetiredTerm Ends: 2015

Dan L. Mueller, P.E.Environmental Defense FundTerm Ends: 2017

Brian NoelGE LightingTerm Ends: 2017

Blair NorrisAshland Inc.Term Ends: 2017

Paul Steven PorterUniversity of IdahoTerm Ends: 2015

Teresa RaineERMTerm Ends: 2017

Jacqueline SibbliesIndependent ConsultantTerm Ends: 2017

Jesse L. ThéLakes Environmental SoftwareTerm Ends: 2016

Susan S.G. WiermanMid-Atlantic Regional AirManagement AssociationTerm Ends: 2015

James J. Winebrake, Ph.D.Rochester Institute of TechnologyTerm Ends: 2015

emawma.org

by Michael Miller [email protected]

em • message from the president

That Time of the Year

As I write this message, I am embarking on several visits to local A&WMA Section and Chapter meet-ings. Sections and Chapters are the very founda-tion of our Association. This is where most of us got our start in A&WMA by networking at local meet-and-greets, participating in workshops and conferences, and even assuming leadership roles within our local units.

For each of these meetings, I have been asked to provide a status report on the Association. Since many of these meetings are being held concur-rently, I have enlisted the assistance of A&WMA President-Elect Dallas Baker to help me fulfi ll these requests, as it is critically important that we listen to what the members are saying, in terms of their issues and needs.

My message to the Sections and Chapters is three-fold. First, the Association has seen less-than-expected revenue this year, primarily due to lower-than-expected attendance at events. Membership has also seen a slight decrease this year, primarily in the individual member cate-gory, while organizational memberships have increased. Executive Director Jim Powell and staff are doing a tremendous job streamlining opera-tions at headquarters to reduce costs and provide value to members, thus bringing fi nancial stability to the organization.

Second, I note that environmental issues are becoming increasingly complex on a local and global scale. While the Association focuses primar-ily on air and waste issues, we need to extend that to other media and issues. We need to add water, sustainability, and natural resources to the topics we address in partnership with other organizations. Associations like ours provide a forum to debate, discuss, learn, and form relationships that assist us in our professional lives. I have heard from several

people about how A&WMA meetings provide the opportunity for the regulatory community and the industrial community to discuss issues outside of a formal regulatory process. The participants get to know one another personally, which helps when it’s time to negotiate permit conditions.

Third, I emphasize the timeliness and importance of our strategic planning process. As mentioned in prior messages, this year we solidifi ed our vision, mission, and core purpose for the Association and instituted goals, objectives, and action plans to lead us into the next 100 years. My mantra has been “to be stronger, not necessarily bigger.” We need to make sure that this Association is providing the right products and services to members and external stakeholders, thus also fulfi lling the socie-tal benefi t requirement of our not-for-profi t charter.

It’s worth repeating that Sections and Chapters are the very foundation of our Association. They address local issues and identify local needs. They offer programs of relevance, provide network-ing opportunities, extend scholarships to stu-dents entering the environmental fi eld, and most importantly, provide leadership opportunities for enhancing members’ professional development.

Time constraints and my day-job have prevented me from attending all of the meetings to which I have been invited over the past year. However, please keep those invitations coming and we will endeavor to participate in as many meetings as possible. Finally, I’d like to take this opportunity to thank our Sections and Chapters leadership for all of your efforts, in terms of the work you all do in enhancing the value and reputation of A&WMA. em

awma.org2 em november 2014

02_EM1114-PresMessage.indd 2 10/20/14 12:22 PM


2014 President-Elect and Board of Directors

NOMINATIONSBackground

• Nominations are solicited to fill three Board of Directors positions and the President-Elect position. The deadline for receiving nominations is Friday, March 1, 2013.

• You may nominate yourself or any other Air & Waste Management (A&WMA) Association member. All nominees musthave been members of the Association for at least three consecutive years, and nominees for President-Elect must befrom the Regulatory Category and also have previously served on the Board of Directors for at least one year. TheNominating Committee will screen the nominees and submit a slate of candidates for consideration by the Board of Directors in May 2013. The election will be held during spring 2013.

• President-Elect – The nomination package must not exceed six pages: the Nomination Form (see below), a one-page resume, and a brief description of the nominee’s interests/qualifications under the following six criteria: vision for theAssociation, team building commitment and skills, leadership skills, knowledge of A&WMA/ its products and services,financial management skills, and written and verbal communication skills.

• Directors – The nomination package must not exceed six pages: the Nomination Form (see below), a one-page resume,and a brief description of the nominee’s interests/qualifications under the following seven criteria: vision for the Associa-tion, team building commitment and skills, leadership skills, knowledge of A&WMA/its products and services, financialmanagement skills, written and verbal communication skills, and potential contribution to continued growth andstrength of the Association.

• This year’s Nominating Committee members are: Jeffry Muffat (Chair, Immediate Past President), Donna Jean Kilpatrick,Steve Rybolt, Ken Weiss, Cynthia Smiley, Bill Palermo, Ciara De Jong, and Ning Ai.

Nomination Form for 2016 A&WMA President-Elect and Board of Directors:

Nominee’s name: ________________________________ Affiliation: __________________________________

Street address: _____________________________________________________________________________

City: __________________________________________ State/Province: ______________________________

Postal code:_____________________________________ Country: ___________________________________

Phone: ________________________________________ E-mail:_____________________________________

Section/Chapter affiliation: ________________________ Date joined A&WMA: ________________________

Submitted by (please print): __________________________________________________________________

Signature: _____________________________________ Date: _____________________________________

Membership Category: Regulated Regulatory Other

Position Sought: President-Elect Board of Directors

NOMINATIONS2016 President-Elect and Board of Directors

Background

• Nominations are solicited to fill up to three Board of Directors positions and the President-Elect position. The deadline forreceiving nominations is Friday, January 16, 2015.

• You may nominate yourself or any other Air & Waste Management (A&WMA) Association member. All nominees must have been members of the Association for at least three consecutive years, and nominees for President-Elect are being sought from the Regulated Category and also have previously served on the Board of Directors for at least one year. The Nominating Committee will screen the nominees and submit a slate of candidates for consideration by the Board of Directors in March 2015. The election will be held during spring 2015.

• President-Elect – The nomination package must not exceed six pages: the Nomination Form (see below), a one-page resume, and a brief description of the nominee’s interests/qualifications under the following six criteria: vision for the Association, team building commitment and skills, leadership skills, knowledge of A&WMA/ its products and services, financial management skills, and written and verbal communication skills.

• Directors – The nomination package must not exceed six pages: the Nomination Form (see below), a one-page resume, and a brief description of the nominee’s interests/qualifications under the following seven criteria: vision for the Association, team building commitment and skills, leadership skills, knowledge of A&WMA/its products and services, financial management skills, written and verbal communication skills, and potential contribution to continued growth and strength of the Association.

• This year’s Nominating Committee members are: Sara Head (Chair, Immediate Past President), Art Spratlin, Barbara Toole-O’Neil, Camille Taylor, Dan Mueller, David Greene, Jen Moore, Mark Rood, and Jim Ryckman.

Submit completed applications to:Stephanie Glyptis/Nominating CommitteeA&WMAOne Gateway Center, Third Floor420 Fort Duquesne Blvd.Pittsburgh, PA 15222-1435 USAE-mail to: [email protected] or Fax: +1-412-232-3450

EM1114BOD.indd 1 10/16/14 1:14 PM



em • cover story

by Mingming Lu

Mingming Lu, Ph.D., is an associate professor at the University of Cincinnati. E-mail: [email protected]

Dr. Lu is Chair of EM ’s Editorial Advisory Committee.

Emissions and ControlA look at how some entities are meeting the challenge of controlling VOC emissions.

Volatile Organic Compounds (VOCs)

04_EM1114-CS-Lu.indd 4 10/20/14 12:23 PM



It is well known that some VOCs contribute to ground-level ozone formation, which results in ozone exceedance in many metropolitan areas around the world, while others are classified as hazardous air pollutants (HAPs) and linked to adverse health effects both indoors and outdoors. This issue of EM focuses on VOC emissions and control, with four articles that discuss various emissions and control policies, as well as the cur-rent status of leak detection and repair (LDAR) compliance in the United States and China. A significant portion of VOC control lies in LDAR programs. Understanding LDAR applicability and the associated compliance requirements involves a combination of process experts, environmental experts, and sound legal advice.

The first article by Inaas Darrat provides an over-view of the LDAR program in the United States.Its requirements expended from petroleum refin-eries to the chemical industry, the pharmaceutical industry, and potentially natural gas processing plants. The author identifies potential issues in the LDAR program in order to facilitate proper future implementation.

In contrast to the relatively mature LDAR program in the United States, the LDAR program in China is new and upcoming. The regional haze and other air quality problems experienced in many major metropolitan areas in China have been frequently in the news since 2013. As a result, the Chinese people are very much aware of and deeply con-cerned with the worsening air quality and the Chi-nese government has started to invest heavily on air pollution control solutions.

In the second article by Peng Liang et al., the authors describe the newly formed VOC Pollution

Control Workgroup in China. The workgroup comprises participants from the Chinese Ministry of Environmental Protection, various petroleum companies, and experts from overseas. The goal is to formulate VOC control and management strat-egies. It is expected that the petroleum industry in China will implement LDAR programs during China’s Twelfth Five-Year Plan (2011–2015).

In the third article, Jian Li et al. present an over-view of a pilot LDAR program initiated at a pet-rochemical industrial park in Jiangxi Province (an inland province in southern China). Fugitive VOC emissions are controlled using U.S. Environmental Protection Agency Method 21.

In the final article, Pamela Heckel describes another approach for VOC control: elimination at the source through pollution prevention and prevention through design. The author provides examples from various businesses that have switched products or practices to help lower their VOC emissions.

The authors’ contributions to the body of knowl-edge on VOC management and control are greatly acknowledged. em

It is well known

that some VOCs

contribute to

ground-level ozone

formation, while

others are classified

as hazardous air

pollutants (HAPs).

Thinkstock Photo

04_EM1114-CS-Lu.indd 5 10/20/14 12:23 PM


6 em november 2014 awma.org

by Inaas Darrat

Inaas Darrat, P.E., is a principal consultant and director of Chemical Sector Services with Trinity Consultants Inc., Houston, TX. E-mail: [email protected].

em • feature

EPA Priority:

Leak Detection and Repair (LDAR)A brief overview of the established U.S. Leak Detection and Repair (LDAR) program.

VOCs

06_EM1114-FT1-Darrat.indd 6 10/20/14 12:24 PM



A LDAR program is a facility’s system of procedures to minimize fugitive volatile organic compound (VOC) and hazardous air pollutant (HAP) emissions from leaking components (e.g., valves, pumps, con-nectors, compressors, and agitators).2 It is a struc-tured program to detect and repair equipment that is identifi ed as leaking. A portable device is used to identify equipment that is emitting suffi cient amounts of material above a specifi ed threshold (e.g., 10,000 parts per million by volume [ppmv]) to warrant reduction of the emissions through repair techniques. Additionally, sight, sound, and/or smell inspections are performed for certain types of equipment. LDAR is applied to equipment types that can be repaired while in operation, resulting in immediate emissions reduction.

The U.S. Environmental Protection Agency (EPA) has identifi ed the reduction of fugitive VOC and HAP emissions as a key enforcement priority and has been conducting audits and pursuing enforce-ment actions of LDAR programs in the petroleum refi ning and chemical manufacturing since the late 1990s. Both large and small facilities have been reviewed under this coordinated EPA program. EPA is also conducting LDAR inspections at natural gas processing plants.

EPA’s Inspection ProgramInitially, EPA focused on petroleum refi neries for its LDAR-related enforcement activities. Since 2005, however, the agency has also concentrated enforce-ment efforts within the chemical industry (e.g., facili-ties subject to Hazardous Organic NESHAP [HON], Pharmaceutical MACT, Miscellaneous Organic NESHAP [MON], and NSPS VV/VVa). Further-more, EPA has conducted inspections for natural gas processing plants, including those potentially

EXAMPLE FINDINGS in Recent Notices of Violations 1. Having open-ended lines. Inspectors can easily identify

this issue by visual inspection during audit walkthroughs. Inspectors commonly fi nd open-ended lines at sampling connection systems.3

2. Not conducting monitoring of each regulated component every monitoring period, or not having suffi cient documentation that monitoring was conducted.

3. Not repairing leaks within the timeframes required (e.g., completing repair, including Method 21 monitoring within 15 days of discovery).

4. Not conducting follow-up monitoring after leak repair (i.e., monitoring conducted within three months of repair or monitoring for two consecutive months with no leaks discovered, depending on the rule).4

5. Not maintaining leaker tags. 6. Improperly applying “delay of repair”. 7. Classifying insulated valves as exempt from monitoring.5 8. Not maintaining required lists (e.g., diffi cult-to-monitor

[DTM], unsafe-to-monitor [UTM], instrumentation systems, and pressure relief valves equipped with rupture disks).

9. Not reporting delay of repair technical infeasibility information in periodic reports.

10. Not maintaining complete leak repair records.

Fabio Cardano/iStock/Thinkstock

Leak Detection and Repair (LDAR)

initiatives are required as part

of several standards estab-

lished under the U.S. Code of Federal

Regulations (CFR): New Source Per-

formance Standards (NSPS; 40 CFR

60); National Emissions Standards for

Hazardous Air Pollutants (NESHAP; 40

CFR 61); Maximum Achievable Control

Technology (MACT; 40 CFR 63); and

Hazardous Waste Handling (40 CFR

264/265).1 While the LDAR regula-

tions all have similar requirements,

unrecognized nuances and the overall

complexity within each regulation can

result in potential violations.



subject to NSPS rules. As shown in recent notices and/or findings of violations, the compliance issues discovered by EPA at chemical manufacturing facil-ities encompass all facets of the LDAR standards.

In a typical LDAR program, portable analyzers are utilized to periodically monitor each regulated component at a frequency varying from monthly to every eight years, depending on the applicable regulation and component being monitored. If the component is found to be leaking, it is tagged and must be repaired within a specified time.

Please note that these are leak detection programs; therefore, leaks are expected to be discovered. Finding a leak is not always a violation; however, failure to conduct appropriate monitoring, record-keeping, reporting, and repairs would be viola-tions. Therefore, a review of recordkeeping (e.g., repair timing records and leak rate calculations), reporting (delay of repair), and monitoring fre-quencies are key components to any EPA inspec-tion (see sidebar “Example Findings in Recent Notices of Violations” on previous page).

Example Finding: Not Conducting Method 21 ProperlyFor both petroleum refineries and chemical man-ufacturing facilities, EPA has cited inappropriate application of 40 CFR 60, Appendix A, Method 21 (Method 21). Method 21 requires a portable monitoring device for identifying components emitting VOC/HAP above the applicable leak definitions (e.g., 10,000 ppmv or 500 ppmv). One of the primary methods by which EPA assesses adherence to the Method 21 is “comparative monitoring.” Often when conducting comparative monitoring, EPA inspectors will observe the facility LDAR technician while conducting parallel moni-toring per Method 21, which includes observing the following:

• zero and leak definition calibration checks;• calibration precision testing;• instrument response time checks;• time spent monitoring per component; and• leak interface monitoring techniques for each

component.

According to

EPA, being one

centimeter away

from the interface

can cause the

technician to miss

a defined leak.


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Upon completion of the monitoring, EPA will compare its leak rates (e.g., percentage of leak-ing components to number of components mon-itored) with the facility technician’s leak rates. In a study covering 17 petroleum refineries, the leak rate based on EPA monitoring was approximately 5%, while the leak rate based on industry mon-itoring was approximately 1%.6 Discrepancies between the leak rates can be due to any one of the above-listed factors and increases the level of scrutiny for facility leak rates previously reported. For example, according to EPA, being one centi-meter away from the interface can cause the tech-nician to miss a defined leak.6

Consent Decree-Enhanced LDARAs a result of recent LDAR audits and associated enforcement actions, EPA has initiated enhanced LDAR programs as part of the most recent con-sent decrees.7,8 The enhanced LDAR programs for chemical facilities are more stringent than the enhanced LDAR required for the refining industry. Starting in 2000, petroleum refineries were required by consent decree to implement

enhanced LDAR programs. The petroleum refin-ery enhanced LDAR includes four main elements:

1. Leak definitions were lowered from NSPS VV levels (e.g., 10,000 ppmv) to HON levels (e.g., 500 ppmv);

2. Limited delay of repair usage until “drill and tap” is utilized;

3. Initial attempts at repair were required at con-centrations as low as 200 ppmv (not a “leak” but a lowered action level); and

4. Periodic internal/third-party audits were required, including comparative monitoring of valves.9

Recent chemical industry consent decrees have included enhanced LDAR programs incorporating many of the petroleum refinery enhanced LDAR requirements, while adding several new aspects:10

1. Lowering the leak definitions: pumps—lowered from HON (e.g., 1,000 ppmv) and Pharma MACT (e.g., 2,000 ppmv) levels to 500 ppmv; agitators—lowered from HON/Pharma MACT


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levels (e.g., 10,000 ppmv) to 2,000 ppmv or 500 ppmv; and all other components—lowered from 500 ppmv to 250 ppmv or sometimes even lower (i.e., lower than the petroleum refin-ery enhanced LDAR leak definitions).

2. Requiring certified “low-leak” technology and packing materials for repair of leaking or instal-lation of new valves and connectors.

3. Periodic monitoring of closure devices associ-ated with open-ended lines via Method 21 at a defined leak definition (e.g., 200 ppmv).

4. Requiring more stringent delay of repair pro-visions.

5. Comparative monitoring within third-party LDAR audits for valves, closure devices on open-ended lines, pumps, connectors, and agi-tators.

6. More frequent periodic monitoring of certain valves, connectors, pumps, and agitators and removing monitor frequency reduction allow-ances for good performance.

LDAR Penalty PolicyIn addition to enhanced LDAR, consent decrees have a penalty fee and stipulated penalties associ-ated with them. EPA has an LDAR penalty policy that is organized by the following categories:11

• Recordkeeping violations ($250—$37,500).• Reporting violations ($250—$37,500 for miss-

ing information and $250 per day for late reports with a cap as high as $37,500).

• Failure to identify equipment, including mis-identifying equipment ($250—$5,000 per component depending on the component type, with a cap of $2.5MM).

• Inspection and Method 21 monitoring viola-tions ($100—$2,000 per component for missed inspections, $250 per calibration non-compli-ance, and $2,500—$18,500 per monitoring requirement per process unit for failure to mon-itor correctly).

• Failure to tag leaking equipment for repair ($100—$2,000 per component).

• Failure to repair leaks on time or at all ($100—$3,000 per component per day with caps of $1,000—$375,000 per component).

• Equipment standard violations (e.g., OELs, com-pressor seals; $750—$2,000 per component, or higher for long-term violations).

• Pressure testing violations ($100—$2,000 per component).

A multiplier is applied to the fee listed in the policy if emissions are associated with HAPs, HAPs with risk to communities, and/or VOC non-attainment areas.

In addition to the above penalties for past non-com-pliance, stipulated penalties are outlined to address any future specific non-compliance, such as not developing a timely, written LDAR plan; not con-ducting Method 21 accordingly; and not conduct-ing third-party LDAR audits, as required.

SummaryEPA will continue to conduct LDAR audits and seek enhanced LDAR requirements for facilities undergoing enforcement action. Facilities subject to LDAR requirements that have not been affected thus far should consider the lessons learned from the refining and chemical sectors that have already been affected. em

Finding a leak is not

always a violation;

however, failure to

conduct appropriate

monitoring,

recordkeeping,

reporting, and

repairs would be

violations.


Notes and References1. It should be noted that 40 CFR 98 also requires leak detection for greenhouse gases (GHGs). 2. Other pollutants are regulated, such as GHGs under 40 CFR 98, but this article focusses primarily on LDAR for HAP and VOC emissions.3. Per 40 CFR 63.161, as well as other definition sections of LDAR regulations, Open-ended valve or line means any valve, except pressure relief

valves, having one side of the valve seat in contact with process fluid and one side open to atmosphere, either directly or through open piping.4. Connectors, depending on the regulation, may also be subject to follow-up monitoring. Please refer to your applicable LDAR regulations

for other examples.5. While there is an exemption from monitoring for insulated connectors for regulations where periodic monitoring is required, no such ex-

emption exists for insulated valves.6. See Leak Detection And Repair—A Best Practices Guide; EPA-305-D-07-001; Office of Enforcement and Compliance Assurance, U.S. Envi-

ronmental protection Agency, October 2007; http://www.epa.gov/compliance/resources/publications/assistance/ldarguide.pdf.7. Please note not all chemical facilities that received LDAR-related consent decrees have been required to initiate an enhanced LDAR programs.8. While current filed consent decree for natural gas processing plants are not on the same order as refining and chemical industries consent

decrees, it does not mean that future consent decrees for oil and gas industry would not be similar to chemical and refining industries consent decrees.

9. The frequency of third-party audits was dependent on each individual consent decree. It could be annual, biennial, every five years, etc.10. Please note that this is not a rigorous list and not all consent decrees will include all these elements.11. Appendix VI—Leak Detection and Repair Penalty Policy; Office of Enforcement and Compliance Assurance, U.S. Environmental protection

Agency, September 2012.

em • feature




In recent years, many large metropolitan areas in China, including Beijing, Tianjin, and the Yangtze River Delta (Shanghai), have been experiencing persistent hazy atmospheric conditions that occur for long durations and across large areas. Fine particulate matter (PM2.5) is considered a major contributor to these events and may seriously affect public health. Volatile organic compounds (VOCs) are considered one of the major pre-cursors for secondary formation of this PM2.5. Studies conducted in China report that VOC emissions from industrial sources have been increasing steadily every year. However, studies on VOCs were not begun in China until recently.

Numerous issues have severely restricted the effective implementation of VOC pollution con-trols in China: the VOC defi nition is vague; the baseline emissions of VOCs are not clear; emis-sions quantifi cation methods are not established; the VOC standards are not comprehensive; and

em • feature

Progress on VOC Control and Management for thePetrochemical Industry in ChinaA joint collaboration between government agencies and the

petrochemical industry in China led to the establishment

of a workgroup to carry out research and address issues

related to volatile organic compound (VOC) pollution control

and management.

VOCsApplication of a portable device for leak detection and monitoring.

12_EM1114-FT2-Dai.indd 12 10/20/14 12:26 PM


Figure 1. Demonstration of No Leakage Management System.


by Peng Liang, Xueshuang Zhou, Yiming Yang, and Weiping Dai

Peng Liang is the Deputy Director General of the Appraisal Center for Environment and Engineering (ACEE), Ministry of Environmental Protection, Beijing, China. Xueshuang Zhou is the Director of the Review Division of Petrochemical and Light Industry Projects, ACEE. Yiming Yang is a project manager with the Review Division of Petrochemical and Light Industry Projects, ACEE. Dr. Weiping Dai is the General Manager of China Operations and BREEZE Software, Data, and Services for Trinity Consultants Inc., Dallas, TX. E-mail: [email protected].

VOC control technologies are lagging. In response to these issues, the Chinese Central Government recently promulgated regulations to require fur-ther control of VOC emissions. In 2013, the State Council of the People’s Republic of China issued the “Action Plan on Prevention and Control of Air Pollution” (Action Plan), which establishes clear limits and controls of the total amount of VOC emissions and subjects industries with VOC emis-sions to certain emission fees. VOC control has never been paid such great attention before the promulgation of the Action Plan.

The VOC Pollution Control WorkgroupTo assist in the full implementation of the Action Plan, the Appraisal Center for Environment and Engineering (ACEE), a major technical support institution of the Chinese Ministry of Environ-mental Protection (MEP), led a joint effort along with several major Chinese industrial companies, including the China Petroleum & Chemical Cor-poration (Sinopec), the China National Petroleum Corporation (CNPC), the China National Off-shore Oil Corporation (CNOOC), and the China Shenhua Group Corporation. Through this joint effort, a VOC Pollution Control Workgroup was established to carry out research related to VOC pollution control and management.

Upon the completion of an extensive literature review of VOC regulations and practices around the world, site assessment of VOC emissions, and active communication with key stakeholders, the Workgroup compiled the findings into two docu-ments: “Research Report on VOCs Definition and Characterization” and “Comprehensive Improve-ment Plan on VOCs Control and Management for Petrochemical Industry”. These reports established a definition of VOCs based on photochemical reactivity (similar to the U.S. definition). In addition, a phased-in approach and a refined management system were recommended to characterize VOCs for the purposes of testing and emissions quanti-fication. These documents were recognized and commended by MEP.

VOC Control and Management through LDARIn the course of the site assessment of VOC emis-sions, the workgroup decided to focus on VOC

control and management for the petrochemical industry due to the following two considerations: petrochemical operations may potentially emit large quantities of VOCs in relatively high con-centrations; and it is relatively easy to implement and enforce the requirements in the petrochem-ical industry.

China’s “Twelfth Five-Year Plan for Air Pollution Prevention and Control in Key Areas” clearly states that the petrochemical industry should fully implement leak detection and repair (LDAR) pro-grams. These programs are best suited for valves and pumps, and also can be used for connecting components. Using fixed or portable monitoring equipment, petrochemical facilities can monitor the VOC emissions from locations that are prone to leaks, fix any leak exceeding certain concentra-tions, and effectively control release of VOC pollu-tion to the environment.

Currently, LDAR programs are being actively promoted in China. Zhejiang Province, Shang-hai, Jiangsu Province, and the Beijing-Tianjin-He-bei region are encouraging the petrochemical industry to carry out LDAR programs as a pilot program. The Government of Ningbo City, Zhe-jiang Province even provides financial subsidies to encourage petrochemical enterprises to carry out an LDAR program regularly to reduce fugitive leaks of VOCs.

Sinopec and CNPC are also working on devel-oping their own LDAR technology platforms. For example, a subsidiary of Sinopec is currently implementing a “Full Participation in Leak Check-ing and Plugging” work mode. They collect

12_EM1114-FT2-Dai.indd 13 10/20/14 12:26 PM


The 39th Annual A&WMA/EPA Information ExchangeDecember 2-3, 2014 • Research Triangle Park, NC • www.awma.org/infoexchange

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All attendees of the Information Exchange are invited to attend the Research Triangle Park Chapter Dinner Meeting. The dinner will be held at the Marriott at Research Triangle Park, 4700 Guardian Drive, Durham, NC 27703.

6:00 - 7:00 p.m. Social7:00 - 7:45 p.m. Dinner7:45 - 8:00 p.m. A&WMA Executive Director and President 8:00 - 8:45 p.m. “Air Quality Science and Policy”

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Return registration form to: A&WMA, One Gateway Center, Third Floor, Pittsburgh, PA, 15222, or fax to: +1-412-232-3450. For more information, call +1-412-232-3444 or 1-800-270-3444. Refund Policy: If written notice of cancellation is received on or before November 18, 2014 payment will be refunded. Substitutions may be made at any time; payment for any difference is due at the time of substitution. This refund policy applies to all occurrences, including weather-related events and other natural disasters. In the unlikely occurrence of event cancellation, the Association is not liable for any expenses incurred by the registrant other than the full refund of registration fee(s) paid.





































EM1114EPAInfoExchange-BF-R1.indd 1 10/16/14 10:51 AM


graphical data from instruments, seal point data, and establish a computer management program named “No Leakage Management System” by monitoring the network (see Figure 1). In addi-tion, they also encourage staff to carry out on-site inspection work and ultimately implement the leak and repair process management program for the whole company.

The workgroup conducted on-site surveys at sev-eral major petrochemical facilities, including Jinling Petrochemical, Yamba, Bairun Chemical, Shang-hai Petrochemical, SECCO Petrochemical, Zhenhai Refining & Chemical, LG Yongxing Chemical, and Formosa Petrochemical. The on-site surveys cov-ered LDAR program applications and VOC pollu-tion control measures, such as oil and gas recovery and catalytic combustion. A large collection of first-hand data were incorporated into the workgroup research report.

The implementation of a LDAR program can help to reduce the fugitive VOC emissions in petro-chemical operations. However, problems remain, including a lack of consistent VOC testing stan-dards and consistent recognition of the potentially achieved control efficiency. Therefore, the Chinese Central Government should enact a series of stan-dard LDAR testing procedures, such as monitoring methods, leak standards, and repair requirements as soon as possible.

In addition, the benefits of LDAR are not simply limited to leak detection and repair. Through a

LDAR technology platform, data about leaks and repairs can be statistically analyzed, which is help-ful to determine the cause of leaks and to further enhance petroleum industry design specifications and material standards.

Direction of VOC Control and Management in ChinaOn July 21, 2014, ACEE hosted a VOC Pollution Control Workgroup Forum with participants from China Petroleum & Chemical Corporation, China National Petroleum Corporation, China National Offshore Oil Corporation, and China Shenhua Group Corporation Ltd., as well as invited experts (see Figure 2).

At the end of the event, the ACEE responsible officer recommended that the VOC workgroup should further develop its organization and coor-dination functions, build alliances, and integrate research efforts. It was suggested that the work-group learn more about the experiences of VOC control and management of its member enter-prises, establish clear research focuses and priori-ties, and coordinate resources and division of labor to both promote the comprehensive management of VOCs in the petrochemical industry and con-tribute to the smooth implementation of the air pollution control Action Plan in China.

In its next phase, the workgroup will focus on four key aspects of VOC control and management in China: monitoring methods, statistical analysis, con-trol measures, and management assessment. em

Currently, LDAR

programs are

being actively

promoted in China.

Figure 2. VOC Pollution Control Workgroup Forum.


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12_EM1114-FT2-Dai.indd 15 10/20/14 12:26 PM



VOCs

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Thinkstock Photo

A study of the fugitive emissions measured at a chemical industrial park located in the Jiangxi Province.

VOC EmissionCharacteristics & LDAR Strategiesfor a Chemical Industrial Park in Jiangxi, China

In recent decades, China has made a roaring suc-cess of its economy and has quickly emerged as the world’s second-largest economy (based on GDP). However, due to the sharp increase in

land and labor costs associated with a fast-growing economy, thousands of factories have moved from the traditional industrial areas of the coastal cities to inland provinces in Central and West China, such as Jiangxi Province, Anhui Province, Hubei Province, and Sichuan Province; some have even moved out of China altogether to parts of Southeast Asia.

16_EM1114-FT3-Li-New.indd 16 10/20/14 12:28 PM



Along with significant economic benefits to the local region, the new and relocated fac-tories have brought a series of environment problems, including air quality deterioration. In 2013, the number of national average haze days was 4.7, 2.3 more than the long-term average (2.4 days), and the highest level since 1961.1 In north-ern Jiangsu and central Henan, there were up to 15 more haze days than the long-term average.1 Furthermore, in 2014, a wide range of long-time haze appeared for the fi rst time in Central China. Composite regional air pollution has now become the prominent environmental problem in China.

Fugitive EmissionsVolatile organic compounds (VOCs) are defi ned as organic compounds that with high volatility and can easily participate in photochemical reactions.2

VOCs also play a prominent role in the formation of ozone and secondary organic aerosol (SOA), which are considered to have strong correlation with the composite-regional air pollution.3,4 Recent studies have shown that chemical industries are a major source of VOCs in urban areas, such as Guangzhou,5 Houston,6 and Hong Kong.7 Zheng et al. found that solvent use-related industrial sources accounted for more than 80% of the total VOC emission in the Pearl River Delta region in 2011.5 Chen et al.8 suggested that a chemical industrial park was an odorous source that affected the population near the industrial district.

Fugitive emissions can generally be described as unintentional and uncontrolled emissions from equipment leaks and may arise due to the normal wear and tear, improper or incomplete assembly

Figure 1. Sampling at the chemical industrial park.(a) Sampling inside man-ufacturing workshop and warehouse of raw materi-als (fugitive emission).(b) Sampling at stack emission and ambient air.

(a)

(b)

Thinkstock Photo

by Jian Li, Mingming Lu, Chunjuan Xie, Liushui Yan, and Qun Cao

Jian Li is with the Laboratory of Jiangxi Province for Ecological Diagnosis-Remediation and Pollution Control, School of Environmental and Chemical Engineering, Nanchang Hangkong University, Nanchang, Jiangxi, PR China, and the Department. of Biomedical, Chemical, and Environmental Engineering, University of Cincinnati, OH; Mingming Lu is with the Department. of Biomedical, Chemical, and Environmental Engineering, University of Cincinnati, OH; Chunjuan Xie is with the School of Basic Science Departments, East China Jiaotong University, Nanchang, Jiangxi, PR China; and Liushui Yan and Qun Cao are both with the Laboratory of Jiangxi Province for Ecological Diagnosis-Remediation and Pollution Control, School of Environmental and Chemical Engineering, Nanchang Hangkong University, Nanchang, Jiangxi, PR China. E-mail: [email protected]



of components, corrosion, manufacturing defects, damage, fouling, and environmental effects.9,10 Recent studies have shown that a significant pro-portion of VOC emissions are fugitive emissions. In 2010, the United Nations Framework Convention on Climate Change (UNFCCC) reported that fugi-tive emissions contributed an estimated 4%–18% of total greenhouse gases (GHGs) and VOCs in the European Union, United States, and Canada.11 While according to the U.S. Environmental Pro-tection Agency’s (EPA) Method 21, approximately 20% of potential leaks are not regularly checked due to a lack of resources, difficulty of access, and/or safety concerns.12

It is our belief that investigating VOC emission characteristics in a chemical industrial park in the Jiangxi Province is critical for understanding the formation of composite-regional air pollution and

devising effective control policies. In our study, the fugitive emissions ratios are even as higher at approximately 34%–48% of total VOC concentra-tions. Leaking valves are considered to account for approximately 50%–60% of fugitive emissions.13 Many countries are now focusing on how to con-trol fugitive emissions, through the development of standards for the installation, operation, mainte-nance, and inspection of the valves.14

The chemical industrial park is located east of a major city in the middle-east of Jiangxi Province with a total planning area of 10 km2. The park was built in 2001 and was regarded as one of the largest in central southern China. The leading industries include fine chemistry and pharmaceu-tical chemistry. The location has a humid subtrop-ical climate with four distinct seasons. Winters are short and fairly mild (i.e., the average low in Jan-uary is 2°/35.6°F), but occasional frosts and snow is not unheard of. Summers are long and humid, with among the highest temperatures in China (i.e., the average temperature in July is 34°/93°F).

VOC SamplingAs shown in Figure 1, stack emission and fugi-tive emission samples were collected from three selected plants in the chemical industrial park in winter (January 1–8, 2014) and summer (July 16–20, 2014). Ambient air sampling measure-ments were carried out at the core of the each selected plant. Manufacturing workshops, ware-houses of raw materials and goods, and stack emission were also selected for the sampling sites. VOC sampling was collected by using a leak-free, two-liter, stainless steel canister (UCI, USA) equipped with a restricted sampler operating at 38 mL/min (Entech Instrument Inc., California, USA). Other parameters (e.g., ozone concentration and emissions of sulfur dioxide [SO2], total suspended particles [TSP], nitrogen dioxide [NO2], ammonia [NH3], hydrogen chloride [HCl], and chlorine [Cl2]) were also monitored at the same time of each sampling using portable equipment.

VOC Emission CharacteristicsVOC concentrations were measured by analyz-ing the average results of samples from different industrial sectors or processes, such as manufac-turing workshops, stack emissions, and ambient


Figure 2. The total mean concentration ratios of stack emission fugitive emission and ambient levels of the chemical industrial park.

Fig.2. The total mean concentration ratios of stack emissionchemical industrial park

Winter

Summer

Ambient levels: 23%

Fugitive emissions: 34%

Stack emissions: 43%

Ambient levels: 18%



(b)


Winter

Ambient levels23%

Ambient levels18%

Fugitive emissions34%

Stack emissions43%

Stack emissions35%

Summer



Winter

Summer

Ambient levels: 23%



Ambient levels: 18%



(a)


Winter

Ambient levels23%

Ambient levels18%


Stack emissions43%

Stack emissions35%

Summer




levels. These sectors were divided into “fugitive emission (leakages),” “stack emissions,” and “ambi-ent levels.” A total of 33 VOC species in winter samplers and 41 VOC species in summer sam-plers were detected in this study.

Figure 2 shows that the total VOC concentrations varied widely between different industrial sectors and processes. Among the three types of sectors, stack emissions showed the highest total VOC concentrations (43%) in winter. The total mean concentrations were in descending order from stack emissions to fugitive emissions to ambient levels, and the ratio of the three was 43%: 34%: 23% (Figure 2a). While in summer, fugitive emis-sions increased sharply and contributed more than 48% of the total VOC mean concentration, com-pared to 35% of stack emissions (Figure2b).

The results suggest that fugitive emissions are one of the most important sources of VOC emissions in the chemical industrial park during summer, owing to the high temperatures that can accelerate

the speed of VOCs leaking from valves, tank lids, and pumps. Furthermore, indoor air quality inside the manufacturing workshops and warehouses were important microenvironments for exposure to VOCs, especially in summer.

In China, the study of leak detection and repair (LDAR) is still in its infancy. To support improve-ments in this area, our investigation reviewed and compared LDAR programs from around the world. Currently, the most widely recognized standard for LDAR is EPA’s Method 21.12 Other standards related to LDAR are: ISA-93.00.01 Stan-dard Method,15 International Standard ISO 15848 Industrial Valves,16 and Shell MESC SPE 77/312 Industrial Valves.17 Table 1 summarizes selected examples of applying the LDAR for monitoring the fugitive emissions of VOCs.

As shown in Table 1, LDAR programs based on EPA Method 21 are effective and have been extensively employed for the control of VOC fugitive emissions. The control effectiveness in


A&WMA’s 2015 Annual Conference & ExhibitionJune 22-25, 2015 | Raleigh Convention Center | Raleigh, NC

Professional Development CoursesThe Air & Waste Management Association is recruiting instructors to be a part of the Professional Development Course program at the 2015 Annual Conference in Raleigh, North Carolina on June 21-25, 2015.

A&WMA is seeking courses in the following areas/topics:

• Air Pollution and Control • Modelling and Monitoring • Environmental Management • Air and Waste Management • Air and Waste Regulatory Compliance and Permitting • QEP Prep • Any other area of interest in line with the mission and goals of A&WMA

If you are interested in teaching a course, please visit http://ace2015.awma.org/courses and fill out a Course Proposal form.

The deadline for submission is Monday, December 15, 2014.

Learn more at http://ace2015.awma.org.

It is our belief

that investigating

VOC emission

characteristics in a

chemical industrial

park in the Jiangxi

Province is critical

for understanding

the formation of

composite-regional

air pollution and

devising effective

control policies.



these LDAR programs ranges from 72.2% to 95%. Unfortunately, among the 110 plants in the chemical industrial park, only one plant has implemented an LDAR program (only 20% of the valves were involved in the Hongbo’ LDAR pro-gram). In process plants, fugitive emissions are the main sources of VOC exposure to workers.18 Our study found that the total concentration of VOC fugitive emissions might be even higher than for stack emissions for some VOC species like acetone and ethane. Long-time exposure may threaten the health of plant workers. As a result, VOC fugitive emission control strategies are in urgent need.

LDAR Strategies for VOC Emission ControlIt is estimated that the LDAR costs for a typi-cal refinery (with more than 20,000 connec-tors, valves, and pumps) in the United States may exceed one million dollars.19-22 Labor costs accounted for the vast majority of the total cost. The following list includes some LDAR strategies for improving the quality of program and reducing labor costs that emerged during our investigation:

• Using online technology for VOC data collec-tion, storage, transmission, and management;

LocationEquipment Type and service

Initial Leak Rate (kg/hr)

Final Leak Rate (kg/hr)

Control Effectiveness

(%)

Standards (LDAR

program) Refences

RasGas Company, Qatar Valves-gas 4.46 0.741 83.4

EPA Method 21 (RasGas’ LDAR

program)9

RasGas Company, Qatar

Valves-Light Liquid 1.36 0.318 76.6

EPA Method 21 (RasGas’ LDAR

program)9

Benzene plant, Malaysia Valves 2.99 a - - - 18

Benzene plant, Malaysia

Valves and Plumps 3.75 a 0.50 a 86.7

Piping and instrumentation

diagram (PID) program

18

PETROL plant, USA

Valves, pumps and fl nges 89.6 4.45 95.0

EPA Method 21 (Smart LDAR

program)19

Cracker plant, Taiwan

Manufacturing process 129.3 b 25.6 b 80.2 EPA Method 21 20

SINOPEC, China Valves 62.8 8.98 85.7EPA Method 21

(SINOPEC’ LDAR program)

21

SINOPEC, China Plumps and Tanks 15.7 - -

EPA Method 21 (SINOPEC’

LDAR program)21

Hongbo Chemical industrial plant,

ChinaValves 6.81 1.89 72.2

EPA Method 21 (Hongbo’ LDAR

program)

In this study

Other plants in the chemical

industrial parkN N N N N In this

study

Table 1. Control Effec-tiveness of Implementing the LDAR Program for Monitoring VOC Fugitive Emissions. Notes: a mg/s was used in the original reference, and was converted to kg/hr in this study.b ton/yr was used in the original reference, and was converted to kg/hr in this study (365 days/ year).

N = Not LDAR program currently.




• Using the portable analytical instrument, if possible, using the infrared (IR) camera tech-nology to detects gas leaks and measures the temperature (although the IR camera might be expensive, the detected effi ciency would greatly improve the LDAR program, and thus, can save cost in the long run);

• Auditing LDAR program standards and staff to ensure the standardization of the LDAR pro-gram and prevent misoperation;

• Establishing an LDAR tracking plan to ensure complete LDAR program implementation;

• If the LDAR program performs well, try lower-ing the leak defi nition concentration to improve the quality of LDAR program and enhance the VOC control effectiveness; and

• Pay more attention to the high-leak valves and equipment (e.g., for valve seals, better contain-ment would be achieved by using new sealing technologies and materials and by replacing the packing regularly).

SummaryA successful chemical industry is necessary for developing the economy. However, it is now widely recognized that the industry must decrease its environmental impacts to allow for sustainable development. A major contributing factor will be through controlling emissions. A combination of public pressure, environmental legislation, and the enterprises’ social responsibility will drive the expansion of the application of LDAR programs at more facilities. LDAR (or Smart LDAR) will play a vital role in the environmental performance of industrial plants. However, in China, industrial complexes still have a long way to go to imple-ment their own LDAR programs. Apart from the increasing of awareness of environment and health issues, the facilities must be conscious of lowering VOC emissions and adopting LDAR programs and realize that effective LDAR programs can minimize the loss of valuable feed stocks and enhance over-all productivity. em


References1. Government report; China Meteorological Administration, 2013. See http://www.cma.gov.cn.2. Kota, S.H.; Park, C.H.; Hale, M.C.; Werner, N.D.; Schade, G.W.; Ying, Q. Estimation of VOC emission factors from fl ux measurements using

a receptor model and footprint analysis; Atmos. Environ. 2014, 82, 24-35.3. Chen, W.H.; Persily, A.K.; Hodgson, A.T.; Offermann, F.J.; Poppendieck, D.; Kumagai, K. Area-specifi c air fl ow rates for evaluating the impacts

of VOC emissions in U.S. single-family homes; Bldg. Environ. 2014, 71, 204-211.4. Wei, W.J.; Xiong, J.Y.; Zhao, W.P.; Zhang, Y.P. A framework and experimental study of an improved VOC/formaldehyde emission reference

for environmental chamber tests; Atmos. Environ. 2014, 82, 327-334.5. Zheng, J.Y.; Yu, Y.F.; Mo, Z.W.; Zhang, Z.; Wang, X.M.; Yin, S.S.; Peng, K; Yang, Y.; Feng, X.Q.; Cai, H.H. Industrial sector-based volatile

organic compound source profi les measured in manufacturing facilities in the Pearl River Delta, China; Sci. Total Environ. 2013, 456, 127-136.6. Zhao, W.; Hopke, P.K.; Karl, T. Source identifi cation of volatile organic compounds in Houston, Texas; Environ. Sci. Technol. 2004, 38, 1338-

1347.7. Zheng, J.Y.; Zhong, L.J.; Wang, T.; Louie P.K.K. Ground-level ozone in the Pearl River Delta region: Analysis of data from a recently established

regional air quality monitoring network; Atmos. Environ. 2010, 44, 814-823.8. Chen, L.Y; Jeng, F.T.; Chang, M.W.; Yen, S.H. Rationalization of an odor monitoring system: A case study of Liu-Yuan petrochemical park;

Environ. Sci. Technol. 2000, 34, 1166-1173.9. Chris, H.; Roger, M.; Julius, B. The experience in using LDAR for monitoring fugitive emissions of volatile organic compounds with special

reference to RasGas’ experience. In Proceedings of the 2nd Annual Gas Processing Symposium, 2010; pp. 51-58.10. Carol, A.B.; Matthew, R.J. Identifying sources of fugitive emissions in industrial facilities using trajectory statistical methods; Atmos. Environ.

2012, 51, 46-55.11. United Nations Framework Convention on Climate Change data on greenhouse gas emissions, 2010. See http://unfccc.int/ghg_data/

ghg_data_unfccc/items/4146.php.12. EPA Method 21. Determination of volatile organic compound leak. Code of Federal Regulations. Title 40, Part 60, Appendix A. Washington,

DC, USA. Revised June 1990.13. Chambers, A.K. Refi nery Demonstration of Optical Technologies for Measurement of Fugitive Emissions and for Leak Detection (ARC

Contract Report No. CEM 9643); Carbon and Energy Management, Alberta Research Council Inc., Edmonton, Alberta, Canada. See http://www.ptac.org.env/dl/envp0403.pdf.

14. Adem, O. A review of fugitive emissions; Sealing Technology 2006, 10, 7-9.15. ISA-93.00.01 Standard method for the evaluation of external leakage of manual and automated on-off valves.16. (DIS)ISO 15848 Industrial valves-fugitive emissions-measurement test and qualifi cation procedures.17. Shel l MESC SPE 77/312 Indu strial valves: Fugitive emission measurement, classifi cation system, qualifi cation procedure, and prototype and

production tests of valves.18. Mini, H.H.; Markku, H.; Paul, R.A.; Faisal, I.K. Fugitive emissions in chemical processes: The assessment and prevention based on inherent

and add-on approaches; J. Loss Prevention in the Process Industries 2012, 25, 820-829.19. Epperson, D.; Lev-On, M.; Taback, H.; Siegell, J.; Ritter, K. Equivalent Leak Defi nition for smart LDAR (Leak Detection and Repair) When

Using Optical Imaging Technology; J. A ir & Waste Manage. Assoc. 2007, 57 ,1050-1060.20. Yen, C.H.; Horng, J.J. Volatile organic compounds(VOCs) emission characteristics and control strategies for a petrochemical industrial area

in middle Taiwan; J. Environ. Sci. Health, Part A:Toxic/Haz. Subs. Environ. Eng.2009, 44, 1423-1429.21. Li, L.B.; Liu, Z.S.; Fang, X.C.; Ma, R.H. Stra tegies of Refi nery VOC emission control: Equipment leaks; Petroleum & Petrochemical Today (in

Chinese) 2013, 9, 1-9.22. Leak Detection and Repair Compliance Assistance Guidance—A Best Practices Guide; U.S. Environmental Protection Agency; Washington,

DC, 2007.

ACKNOWLEDGMENT: This work was fi nan-cially supported by the National Natural Science Foundation of China (Grants 41003057, 21467018 and 41203076), Natural Science Foundation of Jiangxi Province of China (20122BAB213017 and 20142BBG70005) and Foundation of Jiangxi Educa-tional Committee (GJJ14511).




by Pamela Heckel

Pamela Heckel, Ph.D., P.E., is a member of A&WMA’s Board of Directors and Chair of the 2015 P2: Increase Profits Reduce Pollution Conference to be held in Cincinnati, OH, January 13–14, 2015. E-mail: [email protected]. For more information about the P2 confer-ence, visit www.awma.org/conferences/conferences-detail-view/p2--increase-profi s- reduce-pollution.

em • feature

Prevention through Design (PtD) is an initiative administered by the National Institute for Occupa-tional Safety and Health (NIOSH), a division of the U.S. Centers for Disease Control and Prevention, to reduce worker illness and injury by designing out hazards.1 The principles of PtD apply to all processes, tools, and methods of doing work and can be broadly applied.2 Ergonomic solutions are considered PtD, but PtD goes beyond ergonomics to the root cause of injuries and illness.3

According to the American Industrial Hygiene Association’s Hierarchy of Controls, the most effec-tive way to manage risk is to eliminate exposure.4 This can be most easily accomplished during the design phase of the capital project planning pro-cess. We all learn from experience. Over time, a company accumulates an incident record, and a record of solutions. This record forms the basis to manage changes in equipment, processes, tools, and layout. By front-loading lessons learned

PtD & P2A brief overview of the Prevention through Design (PtD) and Pollution Prevention (P2) initia-

tives and how they can help facilitate in lowering emissions of volatile organic compounds

(VOC) and thus reduce the risks for workers and their families.

Eliminating VOC Emissions

VOCs

22_EM1114-FT4-Heckel.indd 22 10/20/14 12:30 PM



into the earliest discussions of changes in facility design, a company can improve its safety record and avoid costly retrofits.

Pollution Prevention (P2) is an initiative admin-istered by the U.S. Environmental Protection Agency (EPA). EPA defines pollution prevention as “reducing or eliminating waste at the source by modifying production, the use of less toxic substances, better conservation techniques, and re-use of materials.”5 This can be accomplished through new technology, changes in processes, using a different feedstock, reformulation, better industrial hygiene, and recycling. The ideal dispo-sition of waste products is to sell them as feedstock for another process.

Reduction of volatile organic compound (VOC) emissions can be accomplished through the use of more precise equipment, such as low-flow paint nozzles that reduce overspray, or through the use of alternatives (e.g., thermoset enamels, vegetable oil-based paints, ultraviolet- and electron beam-cured [UV/EB] inks, and plastics) to solvent-based paints for some applications. Graphics printed under climate-controlled conditions onto vinyl film can be applied to smooth surfaces; when humidity is controlled, water-based glues may be substituted for solvent-based ones. Each of these solutions

reduces the amount of VOCs emitted (P2) and improves working conditions (PtD). Changes in the way companies do business may also prove more profi able by improving customer satisfaction, reducing energy demand, and eliminating waste.

P2 Workshop Success StoriesIn 2003, I attended a pollution prevention work-shop conducted by Bob Pojascek and Cam Met-calf. Each told a story that I still remember today. Pojascek talked about a producer in the sugar beet industry who wanted to avoid the expense of an ammonia permit. An additional process line was added to capture ammonia emissions. This not only saved money in terms of permits and raw materials, but also provided an addi-tional source of revenue through the sale of the ammonia byproduct.

Metcalf talked about a large corporation in the print-ing industry that wanted to eliminate solvent-based metallic inks. He described the transition from sol-vent-based inks to soy-based inks. One global cus-tomer used cadmium red in its logo. A vote by its Board of Directors to accept the non-metallic red facilitated the transition. This reduced exposure to solvents and to metallic inks throughout the entire supply chain and customer base. Both printer and ink technologies continue to evolve.

Thinkstock Photo



Greener Inks = Fewer VOCsA leader in green ink technology is Mutoh Indus-tries Inc. Christopher Brown, engineering man-ager for Mutoh’s Advanced Engineering Group, says, “Tightening environmental and worker safety regulations here in the [United States], as well as in Europe and Japan, combined with growing demand from our end-users have accelerated our development of ‘greener’ inks.”

Brown explains, “Mutoh currently has two inks aimed at lowering VOC emissions for improved worker comfort and environmental safety. Our Eco Ultra® inks are a virtually odorless low-VOC solvent ink designed for printing on plastic films and other flexible plastic substrates. They offer the same high abrasion resistance and outdoor dura-bility of legacy solvent inks, while eliminating the odors and harsh fumes that were once considered part-and-parcel of solvent-based inkjet printing.”

Brown continues, “Mutoh also offers a UV-LED ink, which is a relatively new technology. It is entirely solvent-free, so there are no potentially harmful VOCs or hazardous air pollutants. It uses the energy from UV LEDs operating in the safer deep violet range of the spectrum to cure, convert-ing from liquid to solid almost instantly. And, these inks can print on virtually any substrate, includ-ing rigid and non-white materials, and provide

an optimal worker environment. Going forward, Mutoh will continue to develop ever more envi-ronmentally conscious inks.”

Low-Flow Paint Sprays = Fewer VOCsSome auto body shops have found ways to reduce VOC emissions, while having a positive impact on their business. Chris Sterwerf, of Fair-field Auto & Truck Service Inc., says his company uses an ionized, heated, nitrogen fluid carrier to spray Axalta Coating Systems™ (formerly Dupont Performance Coatings) Imron® polyurethane coat-ings. This allows them to use lower air pressures and smaller atomizing spray gun tips to refinish auto bodies with the lower VOC paint offerings. The nitrogen system increases transfer efficiency, minimizes overspray, reduces paint consump-tion, and increases quality. The increase in qual-ity means fewer reworks, which in turn, leads to fewer VOC emissions.

Why Do We Care?VOCs are organic gases emitted from plants (e.g., evergreen species and the products derived from them, such as solvents, glues, and adhesives), sol-ids (e.g., vinyl, coal, and rubber), and liquids (e.g., cleaning supplies, dry cleaning solutions, pesti-cides, and petroleum-based fuels). The official defi-nition: A VOC is any organic compound having an initial boiling point less than or equal 250°C under




standard atmospheric pressure of 101.3 kPa.6

Exposure to VOCs has been linked to adverse health effects when used indoors without ade-quate ventilation. Excessive exposure to VOCs has been correlated with an increased risk of asphyxia-tion, asthma, and cancer. Affected organs include the central nervous system, eyes and skin, bone marrow, and respiratory system. Common early warning signs are headache, nausea, dizziness, and/or irritation of the eyes, skin or nose.7

Outdoors, VOCs react in sunlight with oxides of nitrogen to create ozone at ground level. The National Ambient Air Quality Standards limit the

ambient concentration of six criteria pollutants, of which ozone is one.

Benefits may accrue when a substance contain-ing VOCs is replaced by a less toxic substance.8 Chemical substitutions for solvents generally are water-based and require higher temperatures and pressures to achieve the desired results. This may result in a different set of hazards.

The PtD and P2 initiatives facilitate a convergence between occupational safety and health and cor-porate sustainability practices, especially in the area of lower VOC emissions. Lower exposures help reduce the risks for workers and their families. em


Each year, the Air & Waste Management Association (A&WMA) recognizes outstanding students who are pursuing courses of study and research leading to careers in air quality, waste management, environmental management/policy/law, and sustainability. Award opportunities include:

Scholarships A&WMA has scholarships available for air quality research, solid and hazardous waste research, waste management research and study, and air pollution control and waste minimization research; last year the Association headquarters awarded $33,000 in scholarships.

Thesis and Dissertation AwardsA&WMA acknowledges up to two exceptional Masters Thesis and up to two exceptional Doctoral Dissertations each year. Nominations shall be made by the student's faculty advisors, who are members of A&WMA, only.

Visit www.awma.org/resources/students for more information.

A&WMA Student OpportunitiesAll Applications Due Monday, January 12, 2015

Best Student Platform Paper AwardThe Platform Paper Award will acknowledge up to two exceptional technical papers at the M.S. and Ph.D. academic levels for papers submitted for presentation at the 2015 A&WMA Annual Conference & Exhibition on June 22-25, 2015 in Raleigh, NC.

Best Student Poster AwardThe Student Poster Awards recognizes student posters to be the best amongst those considered in the undergraduate, masters, and doctoral categories. Student must present the poster during the 2015 A&WMA Annual Conference & Exhibition on June 22-25, 2015 in Raleigh, NC to be eligible for this competition.

References1. Prevention through Design (PtD); National Institute for Occupational Safety and Health (NIOSH). See www.cdc.gov/niosh/topics/ptd.2. Schulte, P.; Rinehart, R.; Okun, A.; Geraci, C.; Heidel, D. National Prevention through Design (PtD) Initiative; J. Safety Res. 2008, 39, 115-121.3. The state of the national initiative on prevention through design; U.S. Department of Health and Human Services, Centers for Disease Control

and Prevention, National Institute for Occupational Safety and Health, Cincinnati, OH, 2014; Publication No. 2014-123.4. Peterson, J.E. Principles for controlling the occupational environment. The industrial environment—its evaluation and control; U.S. Department

of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, DHHS (NIOSH), Cincinnati, OH, 1973, p. 117.

5. Pollution Prevention (P2) Program; U.S. Environmental Protection Agency (EPA). See http://www.epa.gov/p2/pubs/basic.htm.6. An Organizational Guide to Pollution Prevention; U.S. Environmental Protection Agency, Cincinnati OH, 2003.7. Pocket Guide to Chemical Hazards; National Institute for Occupational Safety and Health (NIOSH). See www.cdc.gov/niosh/npg/search.html.8. Schulte, P.; McKernan, L.; Heidel, D.; Okun, A.; Dotson, G.S.; Lentz, T.J.; Geraci, C.; Heckel, P.; Branche, C. Occupational Safety and Health,

Green Chemistry, and Sustainability: A review of areas of convergence; Environ. Health 2013, 12 (4), 31.




by Garry Gunter, Dominic DiCicco, Kevin Black, Chris Tennant, Shirish Shimpi, Tao Huai, Jorn Herner, Ed Nam, Thomas Long, Henry Hogo, and Matthew Thornton

Garry Gunter is with Phillips 66 Company; Dominic DiCicco is with Ford Motor Company; Kevin Black is with the U.S. Federal Highway Administration; Chris Tennant is with the Coordinating Research Council; Shirish Shimpi is with Cummins Inc.; Tao Huai and Jorn Herner are both with the California Air Resources Board; Ed Nam and Thomas Long are both with the U.S. Environmental Protection Agency; Henry Hogo is with the South Coast Air Quality Management District; and Matthew Thornton is with the National Renewable Energy Laboratory. E-mail: [email protected].

em • conference highlights

Highlights from the Coordinating Research Council 24th

Real-World EmissionsWorkshop in San Diego, CAFor decades, the Coordinating Research Council (CRC) has held an annual vehicle

emissions workshop, gathering international practitioners in the field of vehicle/engine

emissions to discuss the latest activities in emissions measurement and monitoring,

inspection and maintenance, modeling, and vehicle and fuel effects. The most recent,

the 24th Real-World Emissions Workshop, was held March 30–April 2, 2014, in

San Diego, CA. The workshop consisted of presentations, posters, and equipment

demonstrations. Margo Oge, former Director of the Office of Transportation and Air

Quality at the U.S. Environmental Protection Agency (EPA), presented the keynote

address, describing her role in crafting vehicle emissions policy. Highlights of the

2014 workshop sessions are summarized on the following pages.

Rafal Olkis/iStock/Thinkstock

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Vehicle Emissions Measurement by Remote SensingRemote sensing measurements of passenger car emissions in Southern California indicated that due to the decline in new car sales, emissions remained 10–28% higher than expected with fleet average age increase by 1.7 to two years. Remote sens-ing measurement studies conducted on European cars indicated that diesel cars have higher nitro-gen oxides (NOx) emissions compared to gasoline cars. Comparisons of European diesel cars with U.S. cars found that European diesel cars gener-ally had higher NOx emissions compared to U.S. gasoline-powered cars (see Figure 1).

An on-road, heavy-duty vehicle monitoring sys-tem, where trucks were taken aside and run under a long tent-like fly was used to measure emissions from a large number of trucks at a single location. Emission results from 1,000 trucks collected in two areas in California indicated that model year 2010 and newer truck emissions of particulate matter (PM) and black carbon were three times lower than emissions standards. The top 1% of 2006 to 2009 model year trucks showed elevated PM emissions indicating some form of malfunction.

Vehicle Emissions Measurement in the LaboratoryIn-use drive cycles on a chassis dynamome-ter were used to assess emissions from heavy-duty port trucks in goods movement vocations. Testing found that for port vehicles (near dock, local, and regional), diesel powered trucks with selective catalytic reduction/diesel particulate fil-ter (SCR/DPF) systems showed the lowest NOx emissions under high-load conditions and rel-atively high NOx levels at low-load conditions. Low-temperature NOx emissions varied between and within manufacturers.

EPA and the Colorado Department of Public Health and Environment (CDPHE) collaborated on a long-term study to develop a large database of emissions measurements from Tier 2 vehicles. Data analyzed over the first two years showed an expected trend in vehicle emissions over time, but it was inconclusive for validating catalyst deteriora-tion as modeled by the Motor Vehicle Emissions Simulator (MOVES) model.

A follow-on study of evaporative emissions leaks provided information on running loss emissions from leaking vehicles over a range of leak sizes. Vehicles were tested using gasoline containing 10% ethanol (E10) with Reid vapor pressure (RVP) of 7 and 10 psi. The data include fuel system pressure and contains information for a variety of purge strategies, as well as trends by RVP, leak diameter, and location.

Finally, VTT Technical Research Centre of Fin-land used a chassis dynamometer to evaluate emissions and efficiency impacts of cold weather (Nordic) driving conditions. The tests were per-formed at +23°C (73°F) and -7°C (19°F), using the New European Drive Cycle (NEDC) and two of VTT’s own drive cycles. Gasoline vehicles pro-duced lower NOx, but higher hydrocarbon emis-sions and fuel consumption under cold driving conditions. Similar trends were observed for gas-oline hybrids, but the fuel consumption penalty was smaller. Conversely, diesel vehicles showed higher NOx and lower fuel consumption under cold driving conditions.

NOx Emissions from Passenger Cars in Europe

g/k

g F

uel

Model Year

Figure 1. NOx emissions measurements from European gasoline (blue) and diesel (red) cars.



Vehicle Emissions Measurement by PEMSReal-world emissions were measured using por-table emissions monitoring systems (PEMS) for both light- and heavy-duty vehicles. Comparisons were made to emission standards and laboratory methods. Refuse trucks with unique duty cycles needed better representation in laboratory testing. SCR in refuse truck applications achieved sufficient operating temperatures, but there may be other still unknown challenges in achieving low NOx. A hydraulic hybrid system was able to double refuse truck fuel economy.

In Europe, PEMS measurements showed that light-duty diesel emits considerably higher NOx on road than expected, while underestimating PM emissions in Hong Kong. Real-world fuel economy in 100 tested light-duty vehicles agreed, on average, with vehicle fuel economy estimated by EPA methods. The effect on carbon dioxide (CO2) emissions of providing real-time informa-tion to the driver about speed versus speed limit was evaluated and found to be quite small. Initial

testing suggests that diffusion charger-based PEMS devices may hold promise for the 2017 European particle number (PN) requirement.

Emissions Measurement Methods DevelopmentThis session included presentations on instru-ments used in vehicle emission testing, such as a spectrometer, a cascade laser, and cooled Fourier transform infrared (FTIR) for nitrous oxide (N2O) measurements. Five N2O analyzers were evalu-ated using exhaust samples generated by light-duty vehicles on a chassis dynamometer.

At this time, FTIR-based instruments are not an approved method to quantify regulated pol-lutants. FTIR was evaluated as an alternative to PEMS instruments. Comparative studies demon-strated FTIR capabilities against constant volume sampler (CVS) measurements while engine cer-tification test compared the total hydrocarbon flame ionization detector (THC FID) difference method and the FTIR direct measurement method (see Figure 2).

Finally, the session discussed using raw (undiluted) measurements to certify engines below 560kW for PM emissions, providing a potential option in lieu of CVS systems, although significant chal-lenges remain. The ExhaustTrak venturi system was described as a method for simplifying and improving emissions measurement by eliminating complicated post-test chemical balance analysis (see Figure 3).

Off-Road Vehicle EmissionsReal-world emissions from a bulldozer and exca-vator equipped with hybrid powertrains were compared to similar machines using conventional diesel engines to promote deployment of com-mercialized hybrid construction equipment (see Figure 4). First-generation hybrids showed possible fuel consumption savings, but with increased NOx and PM emissions.

Advanced engine and exhaust aftertreatment technologies and alternative fuels (i.e., fatty acid methyl ester biodiesel fuels) helped the mining industry reduce exposure of underground workers to gases and aerosols emitted by diesel-powered equipment and comply with regulations. Biodiesel


Figure 3. The ExhaustTrak venturi system for emissions measurement.

Figure 2. Test matrix for studies comparing FTIR and PEMS instruments.

Test Matrix



also showed a significant emission reduction ben-efit over ultra-low sulfur diesel fuel in locomotive and marine applications.

Particulate Matter Emissions MeasurementLight-duty Tier III emissions regulations at 3 mg/mi (2017) and future 1 mg/mi (2025+) levels drove research on gravimetric PM techniques to increase PM mass on the filter. Dilution factor, filter face velocity, combining filters over the federal test procedure (FTP), and filter handling were investi-gated. A denuder made of alumina/zeolite catalyst on a cordierite honeycomb substrate was used to remove PM artifact from the PM filter material and has shown nearly 100% soot penetration and greater than 94% removal of gas phase sulfuric acid and hydrocarbons. Studies showed that not all combustion soot is black carbon and care should be taken when interpreting real-time PM based on optical absorption measurements.

The European PN emissions measurement method requires hot dilution and high temperature vapor-ization of non-solid components of PM. A Con-densation Particle Counter (CPC) operated under ambient conditions provided PN count, while a high temperature CPC allowed PN measurement under “raw” conditions without dilution and the use of a vaporizer. Appropriate high temperature CPC

fluid was essential to enable high temperature CPC. Another study showed PN repeatability and repro-ducibility of 0.6% and 99.4% of total variation. Varia-tion in reproducibility was identified as being related to the test process rather than the instrument.

Emissions ModelingA significant update to the EPA MOVES inventory model (MOVES2014) included new data, control programs, and processes. Of note were improve-ments in evaporative emissions, light- and heavy-duty emissions, as well as activity, and fuel and temperature effects. MOVES outputs were shown to be sensitive to the region-supplied data, partic-ularly fleet age/mix, vehicle miles traveled (VMT) fractions, and speed distributions. The model has many users, including internationally; Monterrey, Mexico, for example, is developing regional inputs to evaluate emission control scenarios.

The California Air Resources Board (CARB) Emis-sions Factor (EMFAC) inventory model is undergo-ing a significant update in 2014. The heavy-duty diesel fuel volumes have been validated to sales data. In another study, a new real-time heavy-duty diesel engine model was created starting with EMFAC that more accurately captures after-treatment behavior. EMFAC was also compared to the Integrated Bus Information System (IBIS), which contains a mathematical empirically-based

Figure 4. A track excava-tor outfitted for emissions measurement.




emission model for transit buses. IBIS will help transit agencies with vehicle procurement.

The Community Multiscale Air Quality (CMAQ) model was used to evaluate the impact of recent mobile source regulations on ozone concentra-tions in the eastern and western United States in 2018 and 2030. Results showed significant reduc-tions in the East, but fewer in the West.

Fuel Effects on Emissions from Heavy-Duty VehiclesEmissions were compared for current diesel and natural gas-fueled heavy-duty vehicles, finding that NOx emissions and global warming potential were lower for natural gas. A comparison of the latest conventional and hybrid bus technologies at low operating temperature demonstrated that the hybrid bus showed fuel economy and emis-sions benefits, but discovered that both vehicles showed higher in-use NOx than expected. A study of a variety of heavy-duty trucks fueled with bio-diesel blends found NOx increases of 1–4% for diesel blends containing 5% and 10% soy-based

biodiesel (B5 and B10), no difference in NOx for animal-based biodiesel blends, and general reduc-tions of PM, carbon monoxide (CO), and total hydrocarbons (THC) from the addition of biodiesel.

Fuel Effects on Emissions from Light-Duty VehiclesSpark Ignition Direct Injection (SIDI) vehicle tech-nology market share increased to 24% in 2012, so it is important to understand the resulting changes in regulated, PM, mobile source air toxics (MSAT), volatile organic compounds (VOC), carbonyls, and polyaromatic hydrocarbons (PAH) emissions. Both wall-guided (WG-SIDI) and spray-guided (SG-SIDI) SIDI emissions were tested using three ethanol and three isobutanol blends. The SG-SIDI vehicle had significantly lower PM mass, soot, and PN compared to the WG-SIDI vehicle. Addition of ethanol produced a decrease in PM for the WG-SIDI vehicle, but the SG-SIDI vehicle showed no significant change in PM with either oxygenate.

Direct injection (DI) of liquid petroleum gas (LPG) and gasoline were compared in a specially-adapted


Distributed monthly to A&WMA’s general membership, EM explores a range

of issues affecting environmental managers with timely, provocative articles

and regular columns written by leaders in the field. More than 75% of

members are involved in purchasing decisions, and represent 45 countries

and all 50 states. EM is a key resource that keeps readers abreast of

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vehicle. LPG-DI counteracted the reduction in vol-umetric efficiency inherent to port fuel injection of LPG. LPG-DI reduced emissions of CO2, THC, NOx, PM, PN, VOC, and PAH compared to gas-oline. However, acetaldehyde and acrolein emis-sions increased and fuel economy decreased.

A Taiwanese study of fuel effects in two 125 cc motorcycles found that CO, THC, benzene, tol-uene, ethylbenzene, xylene (BTEX), and alkane, alkene, and aromatic group emissions decreased; acetaldehyde emissions greatly increased; and NOx was not significantly affected by an increase in ethanol content of gasoline.

Emissions of 15 light-duty vehicles were measured using three test fuels of varying properties includ-ing ethanol content from 0% to 15%. The data were intended to validate predictive models devel-oped during the EPAct/V2/E-89 study and used the same test fleet. Results were directionally con-sistent with model predictions for some pollutants, but inconclusive for others due to lack of statistical significance. Substituting particulate matter index (PMI) for aromatics and T90 fuel properties in the EPAct/V2/E-89 data set improved the fit of the PM models. An interaction between PMI and ethanol suggests that the PMI formula could be improved to accommodate ethanol blends.

Emissions Control Measures, Inspection and Maintenance, and On-Board Diagnostic SystemsOn-board diagnostic system (OBD II) data col-lected in inspection and maintenance (I/M) programs showed that “not-ready” rates for evap-orative control systems are about five times higher than for other systems. I/M programs that enforce OBD checks have lower failure rates than pro-grams in which OBD is advisory only. This effect was corroborated with Oregon data that showed vehicles in I/M areas had a lower rate of malfunc-tion indicator light (MIL) events and sought repair more quickly than vehicles in non-I/M areas. A novel method for an on-board check of the evap-orative canister involved monitoring substrate tem-peratures during known adsorption (refueling) and desorption (purging) events.

A PEMS-based on-road emissions test for light-duty vehicles in Europe to verify in-use compliance

with Euro 6 NOx limits was described. Heavy-duty diesel emissions were measured by driving vehi-cles through a portable “tunnel” with sample ports at the top (see Figure 5). This showed good cor-relation with PEMS results and may be used for I/M testing, clean-screening, and identification of high-emitters. A “smoky” diesel truck enforcement program in the M5 East Tunnel in Sydney, Austra-lia, identified high-emitting vehicles using opacity sensors and video cameras (see Figure 6).

Efforts by CARB to control new-vehicle and in-use emissions from heavy-duty trucks were described. Although current emission control systems (e.g., particulate filters and SCR systems) were highly effective when properly functioning, in-use dura-bility was shown to be a concern. Modeling of heavy-duty diesel engines showed that improving waste-heat recovery to help meet CO2 standards may reduce exhaust temperature and SCR activity.

Next WorkshopOngoing interest in emissions reduction technolo-gies and measurement methods produces a con-tinuing need for collaboration among researchers to improve data, measurement methods, and mod-eling capabilities. The 25th Coordinating Research Council Real-World Emissions Workshop is sched-uled for March 22–25, 2015, in Long Beach, CA. Proceedings of the 24th Workshop are available online at www.crcao.org. em

Figure 5. (top) Method for real-time testing of heavy-duty diesel trucks.

Figure 6. (bottom) Opacity sensors and video cameras identify high-emitting vehicles in a tunnel in Australia.





em • conference highlights

Mike_Kiev/iStock/Thinkstock

AIR POLLUTION at the Local, Regional,and Global ScaleA summary of the 2014 Air Pollution Workshop in Guadalajara, Mexico.

by Judi Krzyzanowski and Sirkku Manninen

Judi Krzyzanowski is the owner of and principal scientist for Krzyzanowski Consulting in Ontario, Canada. Sirkku Manninen is a senior lecturer in the Department of Environmental Sciences at the University of Helsinki, Finland. E-mail: [email protected].

Substantial progress has been made in reducing air pollution in North America

and Europe since the 1st Air Pollution Workshop, held at The Pennsylvania State

University in 1969. However, elevated levels of atmospheric pollutants

remain a major problem across the globe. Combined with climate

change, we require multidisciplinary research and decision-

making to verify and manage the complex interactions and

effects of atmospheric pollutants on ecosystems and

society. Following is a summary of the topics discussed

during the 46th Air Pollution Workshop held earlier this

year at the University of Guadalajara in Mexico.

32_EM1114-APW-Summary.indd 32 10/20/14 12:35 PM


Figure 1. Spatial patterns of total inorganic nitrogen deposition (mg N/m2/yr1) in (a) 1860, (b) the early 1990s, and (c) 2050.3


The 46th Air Pollution Workshop, held April 8–10, 2014, in Guadalajara, Mexico, coin-cided with the 50th anniversary of the Schools of Agriculture and the Veterinary

Sciences at the University of Guadalajara. The workshop drew scientists and graduate students from Mexico, India, the United States, Canada, and Europe to discuss current and emerging air quality issues.1 Workshop sessions covered the following themes: Spatial and temporal aspects of air qual-ity, greenhouse gases (GHGs), and global change; direct and indirect effects of atmospheric nitrogen (N); air quality and climate change interactions with ecosystems, biodiversity, and food security; technol-ogy transfer between developed and developing countries; and public policies and perceptions on air quality and climate change.

Despite substantial efforts to reduce air pollutants at the local, regional, and global scale, ecosystems and people remain exposed to harmful levels of atmospheric pollution. Although between 1990 and 2006 sulfur dioxide (SO2) emissions were reduced by 36% in the United States and Can-ada, and by 70% within the European Union—thanks to policies such as the U.S. Clean Air Act, the Canada–U.S. Air Quality Agreement, and the United Nations Economic Commission for Europe’s (UNECE) Convention on Long-Range Transboundary Air Pollution (CLRTAP) and its Gothenburg Protocol—emissions of reactive N compounds have remained high throughout much of the world.2,3

The consequences of increased emissions and deposition of reactive N are striking as reactive N compounds contribute to biodiversity and ecosys-tem structure, and function via both acidification and eutrophication.4 Although not well publi-cized, human activities now perturb the global N cycle to a greater extent than those of carbon (C) and sulfur (S). While tropospheric carbon dioxide (CO2) has increased ~30% from pre-industrial levels,5 atmospheric deposition of N has more than tripled.6

Trends in Air QualityDespite decreases in SO2 emissions, in 2012 much of the Eastern United States received precipita-tion with a pH < 5.1 (i.e., acidic precipitation).7

This is partly due to persistently elevated sulfate (SO4

2-) deposition originating from local and regional SO2 sources.8 Although S emissions were the main driver of acid deposition and the acidification of soils and freshwater in the 1970s

(a)

(b)

(c)



and 1980s, reactive N compounds, particularly ammonia (NH3), are playing an ever-increasing role.7,9 High exposures to NH3 are more likely to produce visible foliar injury than exposures to nitrogen oxides (NOx). NH3 also causes imbal-anced plant nutrition, decreased growth, reduced frost hardiness, changes in root mycorrhizae, and increased insect susceptibility.10 Finally, excess N can be leached (primarily as nitrate [NO3

-]) into ground- and surface-water contributing to eutro-phication and acidification.4,9,10

Global emissions of reactive N compounds and subsequent deposition are expected to increase further in coming years. However, the major sources, form and magnitude of N emissions vary across space and time (see Figure 1). For example, the largest anthropogenic sources of NOx are related to fossil fuel combustion,3 while animal and crop agriculture contribute ~60% of global atmospheric NH3 emissions and up to 90% in the United States.9-11 Moreover, cata-lytic converters in today’s automobiles contribute substantially to atmospheric NH3.12,13 Agriculture is also an important source of GHGs, contribut-ing ~60% of nitrous oxide (N2O) and ~50% of methane (CH4) emissions globally,14 and ~72% of N2O and ~29% of CH4 emissions in the United States in 2006.15

As NOx emissions act as precursors for surface ozone (O3), the negative effects of elevated N deposition are accompanied by those of O3. While peak O3 concentrations have declined in both North America and Europe, O3 distributions are becoming narrower due to an upward trend in background concentrations from increases in global precursors, particularly from South and East Asia. Based on future emission scenarios, the European threshold for plant damage (40 parts per billion, ppb) will be exceeded over most conti-nents by 2100.16 Moreover, O3 formation may be further enhanced under a sunnier and warming climate. Numerical modeling of the impacts of a changing climate on future O3 concentrations revealed that the O3 season will be extended, and peak O3 levels will increase by as much as 8 ppb in the Northeast United States.17 Ground-level O3 also acts as a GHG adding complexity to O3 assessment and management.18

Tools for Managing Air PollutionThe O3 sensitivity of plants varies markedly depending on genotype. Visible O3 injuries, first noted in California in 1944,19 are relatively easy to diagnose and most chronic (species-specific) injury types observed in the field have been validated by controlled fumigation experiments.20 These read-ily observable symptoms provide opportunities for utilizing sensitive plants as bioindicators of mul-tiple pollutants, providing an economical means of identifying high pollution areas. Plants may be introduced to a system, exist naturally, indicate disturbance, accumulate pollutants, or indicate ecosystem changes.21

Atmospheric monitoring is the most effective tool for identifying air quality problems or non-compli-ance with regulatory standards. However, air mon-itoring, especially for multiple pollutants over large geographical areas, is costly. Passive samplers pro-vide a relatively inexpensive means of measuring contaminant exposure over a defined period and offer an alternative or supplement to active moni-toring networks.22

Air quality models are often used to supplement measurements, or to provide estimates of pol-lutant concentrations at a high spatial resolution over a large area. Models are useful tools for air quality management and policy-making, and can help resolve issues presented by interactions between air pollutants and climate change.

Science must play an active and decisive role in the development of air pollution and emissions policies. A combination of techniques, such as bio-indicator plants, passive samplers, and dispersion modeling, can be especially effective in informing policy decisions, particularly in developing econo-mies such as Mexico.

Challenges for Future Air Quality Research and PolicyDespite current knowledge on the negative effects of air pollutants and climate change, and measures taken to reduce emissions, air pollution remains a global problem.

Due to the transboundary nature of air pollut-ants, local and national policies are sometimes




unsuccessful in improving local air quality, and pol-icy of a more global scale is required to manage issues, such as the long-range transport of Asian particulate matter (PM),23 mercury,24 SO4

2-, NO3-,

and ammonium (NH4+)25 to western North Amer-

ica; or the transport of O3 from North America to Europe.26 Although global policies (e.g., UNECE’s CLRTAP) have been effective in reducing multi-ple pollutants across some international borders, national air pollution regulations have addressed air quality issues one pollutant at a time. How-ever, air pollutants do not exist in isolation, and in combination can act additively, antagonistically or synergistically, having a range of effects. This

complexity combined with additional disturbances and climate change, presents the greatest chal-lenge facing the makers of air quality policy today.

According to a 1992 defi nition provided by the Air & Waste Management Association, ‘clean air’ is “represented by air that is essentially odorless, tasteless, looks clear and has no measurable short- or long-term effects on people, animals, or the environment”. Although air pollution con-tinues to be a major issue in the developed and developing countries, we have come a long way from the fi rst Air Pollution Workshop that was held 45 years ago. em


References1. Homepage for the Air Pollution Workshop, 2014. See http://www.apworkshop.org (accessed June 6, 2014).2. UNECE’s Convention on Long-Range Transboundary Air Pollution celebrates 30th anniversary. See http://www.unece.org/env/lrtap/30

anniversary.html (accessed June 8, 2014).3. Galloway, J.N.; Dentener, F.J.; Capone, D.G.; Boyer, E.W.; Howarth, R.W.; Seitzinger, S.P.; Asner, G.P.; Cleveland, C.C.; Green, P.A.; Holalnd,

E.A.; Karl, D.M.; Michaels, A.F.; Porter, J.H.; Townsend, A.R.; Vörösmarty, C.J. Nitrogen Cycles: Past, Present and Future; Biogeochemistry 2004 70, 153-226.

4. Vitousek, P.M.; Aber, J.D.; Howarth, R.W.; Likens, G.E.; Matson, P.A.; Schindler, D.W.; Schlesinger, W.H.; Tilman, D.G. Human Alteration of the Global Nitrogen Cycle: Sources and Consequences; Ecol. Appl. 1997 7, 737-750.

5. IPCC Fourth Assessment Report: Climate Change 2007. See http://www.ipcc.ch/publications_and_data/ar4/wg1/en/tssts-2-1-1.html (accessed June 8, 2014).

6. Galloway, J. The Global Nitrogen Cycles: Past, Present, and Future; Sci. China C Life Sci. 2005 48, Suppl. 2, 669-678.7. Lehmann, C.M.B.; Gay, D.A. Monitoring Long-Term Trends of Acid Wet Deposition in U.S. Precipitation: Results from the National Atmo-

spheric Deposition Program; PowerPlant Chem. 2011 13 (7), 386-393.8. Lamarque, J.-F.; Dentener, F.; McConnell, J.; Ro, C.-U.; Shaw, M.; Vet, R.; Bergmann, D.; Cameron-Smith, P.; Dalsoren, S.; Doherty, R.; Faluvegi,

G.; Ghan, S.J.; Josse, B.; Lee, Y.H.; MacKenzie, I.A.; Plummer, D.; Shindell, D.T.; Skeie, R.B.; Stevenson, D.S.; Strode; S.; Zeng, G.; Curran, M.; Dahl-Jensen; D.; Das, S.; Fritzsche, D.; Nolan, M. Multi-Model Mean Nitrogen and Sulfur Deposition from the Atmospheric Chemistry and Climate Model Intercomparison Project (ACCMIP): Evaluation of Historic and Projected Changes; Atmos. Chem. Phys. 2013 13, 7997-8018.

9. Aneja, V.P.; Schlesinger, W.H.; Erisman, J.M. Effects of Agriculture upon Air Quality and Climate: Research, Policy, and Regulations; Environ. Sci. Technol. 2009 43, 4234-4240.

10. Krupa, S.V. Effects of atmospheric ammonia (NH3) on terrestrial vegetation: a review; Environ. Pollut. 2003 124 (2), 179-221; and Schlesinger, W.H.; Hartley, A.E. A global budget for atmospheric NH3; Biogeochemistry 1992 15, 191-211.

11. Aneja, V.P.; Schlesinger, W.H.; Erisman, J.M. Farming Pollution; Science 2008 1, 409-411.12. Cape, J.N.; Tang, Y.S.; van Dijk, N.; Love, L.; Sutton, M.A.; Palmer, S.C.F. Concentrations of Ammonia and Nitrogen Dioxide at Roadside

Verges, and their Contribution to Nitrogen Deposition; Environ. Pollut. 2004 132, 469-478.13. Whatmough, S.A.; McDonough, A.M.; Raney, S.M. Characterizing the infl uence of highways on springtime NO2 and NH3 concentrations

in regional forest monitoring plots; Environ. Pollut. 2014 190, 150-158.14. Eckard, R.J.; Graunger, C.; de Klein, C.A.M. Options for the abatement of methane and nitrous oxide from ruminant production: A review;

Livest. Sci. 2010 130 (1-3), 47-56.15. Johnson, R. Climate Change: The Role of the U.S. Agriculture Sector. Report for Congress, March 6, 2007. See http://fpc.state.gov/documents/

organization/81931.pdf (accessed June 6, 2014).16. Sitch, S.; Cox, P.M.; Collins, W.J.; Huntingford, C. Indirect Radiative Forcing of Climate Change through Ozone Effects on the Land-Carbon

Sink; Nature 2007 448, 791-795.17. Nolte, C.G.; Gilliland, A.B.; Hogrefe, C.; Mickley, L.J. Linking Global to Regional Models to Assess Future Climate Impacts on Surface Ozone

Levels in the United States; J. Geophys. Res. 2008 113, D14307; doi:10.1029/2007JD008497; and Porter, P.S., Rao, S.T., Zurbenko, I.G, Wolff, G.T., Dunker, A.M. Ozone Air Quality over North America: Part II—An Analysis of Trend Detection and Attribution Techniques; J. Air & Waste. Manage. Assoc., 2001 51 (2), 283-306.

18. Prather, M.; Ehhalt, D.; Dentener, F.; Derwent, R. G.; Dlugokencky, E.; Holland, E.; Isaksen, I.S.A.; Katima, J.; Kirchhoff, V.; Matson, P.; Midgley, P.M.; Wang, M. Chapter 4: Atmospheric Chemistry and Greenhouse Gases. In Climate Change 2001: The Scientifi c Basis. Contribution of Working Group I to the Third Assessment Report of the Intergovernmental Panel on Climate Change; J.T. Houghton et al., Eds.; Cambridge University Press: New York, 2001; pp 239-287.

19. Middleton, J.T.; Kendrick, J.B. Jr.; Schwalm, H.W. Injury to herbaceous plants by smog or air pollution; Plant Dis. Rep. 1950 34, 245-252.20. Ozone Injury Database, International O3 Webpage of WSL. See http://hermes.wsl.ch/didado/ozoniwww.page0?sprache=E (accessed June

1, 2014).21. Krupa, S.V.; Legge, A.H. Chapter 12: Concluding Remarks. In Air Quality and Ecological Impacts. Relating Sources to Effects; Legge, A.H., Ed.;

Developments in Environmental Science 9, Krupa, S.V., Ed.; Elsevier: Amsterdam, The Netherlands, 2009; Vol. 9; pp 295-304. 22. Krupa, S.V.; Legge, A.H. Passive Sampling of Ambient, Gaseous Air Pollutants: An Assessment from an Ecological Perspective; Environ.

Pollut. 2000 107, 31-45.23. McKendry, I.G.; Hacker, J.P.; Stull, R.; Sakiyama, S.; Mignacca, D.; Reid, K. Long-range transport of Asian dust to the Lower Fraser Valley.

British Columbia, Canada; J. Geophys. Res. 2001 106 (D16), 18,361-18,370.24. Prestbo, E.M.; Gay, D.A. Wet deposition of mercury in the U.S. and Canada, 1996–2005: Results and analysis of the NADP mercury depo-

sition network (MDN); Atmos. Environ. 2009 43, 4223-4233.25. Park, R.J.; Jacob, D.J.; Field, B.D.; Yantosca, R.M.; Chin, M. Natural and transboundary infl uences on sulfate-nitrate-ammonium aerosols in

the United States: Implications for policy; J. Geophys. Res. 2004 109 (D15204).26. Akimoto, H. 2003 Global Air Quality Pollution; Science 2003 302 (5651), 1716-1719.

ACKNOWLEDGMENT: This article is dedi-cated to Dr. Sagar V. Krupa, who passed away on May 12, 2014, for many years of tireless dedication to the Air Pollution Workshop and for his substantial con-tributions toward improving our un-derstanding of the effects of air pollution and climate change on food production and natural resource conservation.



em • epa research highlights

For decades, EPA officials have set health standards for major air pollutants, including particulate matter (PM), ozone, and other common pollutants. The risk of health

effects arising from elevated levels of ozone and PM in the air are indicated in the color-coded Air Quality Index that ranges from good air quality (0–50) “Code Green” and moves through several colors up to “Code Maroon ” for hazardous air quality (above 300).

But what happens when these pollutants co-ex-ist in the atmosphere? Does the presence of two pollutants edging close to the upper limit of the “good” category double the health risk? What if one pollutant affects the lungs, while the other impacts the heart or vascular system? And how do the effects of other co-pollutants or so-called “natural” sources of pollution—such as certain bio-genic compounds from trees or ash from wild-fires—enter into the equation?

It’s precisely these kinds of questions that a team of EPA researchers may soon answer with the help of a new mobile “smog simulator” located at research facilities in Research Triangle Park, NC, that can replicate mixtures of pollutants found in places as diverse as Denver, Los Angeles, or Houston. After two years of construction and test-ing, the smog simulator and testing facility began

operating in May, 2014 and is running its first set of experiments.

ObjectivesResearch findings will help support EPA’s evalua-tion of air mixtures as part of the agency’s periodic reviews of the National Ambient Air Quality Stan-dards. In addition, the ability to study health effects from different sources of pollutants will be invalu-able in developing approaches for controlling air pollution in ways that maximize public health ben-efits. Importantly, the smog simulator has a unique feature to enable climate-based adjustments, including temperature and the composition of the air, to study impacts of a changing climate on air photochemistry and physics and subsequent impacts on human and ecological health.

“The smog simulator’s capabilities are generating excitement that we can actually provide quanti-tative data to inform the Air Quality Index set-tings,” says Ian Gilmour, an EPA toxicologist and chief of the Cardiopulmonary and Immunotoxicol-ogy branch of the agency’s Environmental Public Health Division.

“If you have high ozone and high PM, should the Air Quality Index be more than just the highest level of one pollutant?” asks Gilmour. “What we want to do is to test whether exposure to a combination of


Smog Simulator Offers Unique Capabilitiesto Study Health Impacts of Urban Air Pollutant MixturesAfter two years of construction and testing, a team of EPA researchers may soon be able to

more accurately study the health effects of urban air pollutants with the help of a new mobile

smog simulator that can replicate mixtures of pollutants found in places as diverse as Denver,

Los Angeles, or Houston.

36_EM1114-EPA-Highlights.indd 36 10/20/14 12:36 PM


pollutants results in an overall increase in adverse health outcomes than what would be expected from any individual component.”

While there have been some attempts to study mixtures in the past, doing these experiments with real-world reactive atmospheres and more sophisticated and sensitive biomarkers will posi-tion researchers to answer questions about health effects of multipollutant mixtures. The smog sim-ulator can be used to study realistic formation of many types of multipollutant atmospheres, as well as their potential health impacts through the test-ing of animal models and human cell lines.

The EPA team can create customized smog “reci-pes” for different parts of the country. The pollutant mixtures can then be used to study the pathophysi-ology and toxicity pathways that signal the progres-sion to diseases, such as asthma and cancer, and to develop biomarkers for oxidative stress, an early sign of health impacts. They can also use animal models of cardiovascular and pulmonary diseases to evaluate how these diseases affect sensitivity to these atmospheres and under what circumstances. Moreover, these recipes can also be used with other in vitro (cell) and plant-based test systems to explore a variety of biological outcomes.

The four experiments being conducted this year are mimicking a pollution profile seen in many cit-ies in the Southeast that features ozone and par-ticles termed secondary organic aerosols, which form through the photochemical reaction of gas-oline vapor, nitric oxide from car exhaust, and alpha-pinene (a biogenic that comes from pine trees). Future research will enable investigations of other real-word atmospheric scenarios that could include a variety of air toxic mixtures.

Smog Simulator FeaturesThe smog simulator is a mobile unit and could be used in diverse locations. It consists of a 14-cubic meter Teflon-lined box that allows in light from 120 ultraviolet bulbs to simulate sunshine, a nec-essary ingredient for the creation of secondary pollutants such as ozone.

While pollutant simulators for the study of air chemistry date back some 30 years, this is the first

one that is has been developed specifically to link the air physico-chemistry and climate parameters for health effects research. The simulator’s unique capability to modulate temperature of the photo-chemical reaction of mixtures precisely controlled from 45 to 110 degrees Fahrenheit makes it highly flexible for the study of smog formation under dif-ferent climatic conditions. Finally, the system is fully automated with custom software that controls the injection of various atmospheric chemicals, as well as the light cycles, flow rates, and other dynamic operations, and can operate consistently for weeks to months at a time.

“We over-engineered the system so it could sit in the North Carolina sunshine at 95 degrees and hold a temperature of 70 degrees inside with 120 four-foot lights turned on,” Gilmour adds. The smog simulator will advance our understanding of urban air mixtures and the interrelationship between climate change and air quality. em

For more information on the research discussed in this column, contact Ann Brown, U.S. Environmental Protection Agency, Office of Research and Development, Research Triangle Park, NC: phone: 1-919-541-7818; e-mail: [email protected].


EPA’s new mobile smog simulator can replicate pollutant mixtures found in urban environments in order to examine their effects on health.

36_EM1114-EPA-Highlights.indd 37 10/20/14 12:36 PM



Contingency Planning Leads to Realistic Project Budgets

The development of an accurate and real-istic project budget is a critical respon-sibility of the environment, health, and safety (EH&S) project manager. Although

we may think that insufficient attention to project budget development will lead to project budgets that do not cover project costs, insufficient atten-tion to project budgeting can also lead to inflated project budgets, resulting in projects that are not

funded. An important aspect of project budget-ing that is often overlooked for EH&S projects is the assessment of risks needed to develop con-tingency reserves. A proper assessment of proj-ect risks leads to realistic project budgets and can lead to improved project execution practices that improve project quality or reduce project costs.

The Project Management Body of Knowledge, Fifth Edition (PMBOK, Project Management Insti-tute, 2013) allocates three distinct elements to the project budget:

1. Cost Estimate: An estimate of project costbased on an analysis of effort, resources, andschedule required to deliver the project scope.

2. Contingency Reserve: Financial allowancesto address unplanned, but potentially requiredscope or cost changes resulting from identifiedrisks.

3. Management Reserve: Financial reserves toaddress unplanned changes to project scopeor costs.

The sum of the cost estimate and contingency reserve are referred to as the cost baseline and resources allocated to these items are typically under the full control of the project manager. Add-ing the management reserve to the cost baseline yields the project budget; however, the project manager must obtain management approval to access the management reserve.

em • pm file

by David Elam

David L. Elam, Jr.,CIH, CMQ/OE, PMP,is a consultant with TRCEnvironmental Corp. E-mail:[email protected].

An oft-overlooked aspect of EH&S project budgeting is the assessment of risks needed to develop contingency reserves.

kieferpix/iStock/Thinkstock

38_EM1114-PMfile.indd 38 10/20/14 12:37 PM


Cost EstimateExperienced EH&S project managers are typi-cally adept at developing accurate cost estimates because they understand the technical aspect of work processes, the resources required to execute those work processes, and how those processes should be sequenced and scheduled; however, the development of a reliable contingency reserve value is typically given modest attention. As a result, the cost baseline is developed by simply adding a fixed percentage of the cost estimate to the cost estimate to yield the cost baseline. In many cases, no distinction is made between con-tingency and management reserves.

The use of a fixed percentage approach to devel-oping contingency or management reserves may be appropriate for highly defined projects for which the project manager has a long history of performance information; however, we are poten-tially missing an opportunity for improving proj-ect delivery processes and reducing project costs when we ignore the evaluation of project risks, even if that evaluation is a periodic assessment of the factors influencing the fixed percentage that has been allocated for contingency or manage-ment reserve estimation. For these reasons, the development of risk-qualified project budgets should be a priority for any EH&S project man-ager. The challenge is the systematic identification, qualification, and quantification of risks.

Risk RegisterAn effective way to evaluate risks is to document them in a risk register. A risk register is a tool for recording identified project risks, their likelihood of occurrence, the planned response should a risk materialize, and the cost of implementing the response. At the base level, this exercise yields a weighted financial value that can be assigned to the contingency budget. But the real value in the process is an analysis of the information.

The identification of project risks and the sub-sequent development of a risk register forces us to think about the execution of our project with an eye toward reducing risks. This is perhaps the most significant value of the risk qualification and quantification exercise: we gain insights that allow us to tailor project delivery to reduce risks, and in

so doing, may find opportunities to improve proj-ect execution leading to improved project quality or reduced project cost.

If we are not able to adjust our project delivery processes to mitigate risks, then the risk evalu-ation exercise provides us the clear information we need to develop a contingency budget. While the factors that management determines import-ant for allocation of management reserves may be outside of the control of the project manager, a solid cost estimate, coupled with a documented and defensible contingency budget, will allow management to develop better management reserve estimates.

Although the technical skills that EH&S project managers typically bring to their projects may drive a relaxed approach to risk evaluation, the applica-tion of those same technical skills to the identifica-tion of risks and the evaluation of response actions will provide insights that support realistic contin-gency budgets and can lead to improved project execution and reduced project costs. For these rea-sons, contingency evaluation and planning, even if performed periodically for repeat projects, pro-vides information that supports the development of accurate and realistic project budgets. em


In the Next Issue...

Meeting the U.S. 1-hr SO2/NO2 Ambient Standards

A look at some of the challenges faced in meeting the 1-hour sulfur dioxide (SO2) and nitrogen dioxide (NO2) ambient standards, including the rationale for the standards, the role of modeling and monitoring in establishing compliance, and real-world experiences that illustrate compliance strategies and costs.

Also look for…• IT Insight • IPEP Quarterly • 2014 Author and Subject Indexes

Sujaimages2/iStock/Thinkstock

38_EM1114-PMfile.indd 39 10/20/14 12:37 PM


em • news focus

The U.S. Environmental Protection Agency (EPA) will extend until December 1 the com-ment period on a proposed rule that would

establish greenhouse gas emissions standards for existing power plants. The extension comes after states, senators, and industry groups asked EPA for additional time to prepare their comments on the proposed rule. The comment period, originally 120 days, was set to close on October 16.

“We hope this additional time will give those enti-ties wishing to submit comments the time they need to engage with us, ask questions, and ulti-mately provide input that will help ensure that, in the end, this plan is practical, flexible and achievable,” Janet McCabe, EPA Acting Assistant Administrator for Air and Radiation, told reporters September 16.

Despite the extension, EPA said it still intends to issue the final rule in June 2015, as required by

President Barack Obama’s Climate Action Plan. McCabe said EPA met extensively with affected industries and states prior to proposing the rule and doesn’t anticipate the agency would require any additional time to review public comments.

“We’ll have plenty of time to consider all the com-ments we get and do all the work we need to do,” she said. “We’ve been working directly with stakeholders all along.”

Bill Becker, Executive Director of the National Association of Clean Air Agencies, said states appreciate the additional time to prepare their comments on the existing-plant standards.

“This was a very helpful decision and one that the state and local agencies greatly appreciate,” he told Bloomberg BNA in an e-mail. “They can use the extra time to fully analyze the proposal. We are pleased that it will not delay the final rule.”

EPA’s Clean Power Plan, proposed in June (RIN 2060-AR33), would set carbon dioxide emissions rates for existing power plants in each state, with state agencies administering those emissions standards under Section 111(d) of the U.S. Clean Air Act. EPA anticipates that the proposal could reduce carbon dioxide emissions from existing power plants by 30% by 2030, compared with 2005 levels.

Extension PraisedIndustry groups also praised EPA’s decision to allow more time for public comments.

“An extension of the comment period for EPA’s proposed greenhouse gas emissions regulations is a step in the right direction, but the cost and impacts of the proposal itself are still a major con-cern for our over 160 members,” Lisa Camooso Miller, a spokeswoman for the Partnership for a Better Energy Future, said in a statement. “EPA

EPA Extends Comment Periodfor Power Plant CO2 Rule


40_EM1114-News-Focus-FNL.indd 40 10/20/14 12:38 PM


should use these 45 days to listen seriously to the concerns of stakeholders. Without significant changes, EPA’s proposal will threaten the availabil-ity of affordable and reliable electricity to Ameri-can families and businesses.”

EPA had received several requests to extend the comment period from individual states and industry groups. In a September 11 letter, 53 senators asked EPA for an additional 60 days to submit public comments. —By Andrew Childers, Bloomberg BNA

The U.S. Environmental Protection Agency (EPA) is hoping to launch a new evaluation program in the fall of 2015 for air moni-

toring devices that utilize nanosensors and other cutting-edge technologies, an agency official said September 11.

The program is necessary because the 30-year-old standard is designed for large, expensive, station-ary air monitoring units currently in use, and may not be feasible for all of the small, less expensive, portable models that are now being produced, said Ronald Williams, a project leader with EPA’s Office of Research and Development’s National Exposure Research Laboratory. But the evaluation program needs to be funded before it can start, Williams said.

Next-Generation TechnologyWilliams spoke at a workshop on nanotechnology for sensors organized by the National Nanotech-nology Initiative, which coordinates the federal government’s research and development efforts on nanotechnology. While EPA is often portrayed as a strict enforcer of environmental regulations, Williams showed another side of the agency by mainly focusing on how agency resources can help sensor makers develop marketable products.EPA has been a major proponent of new air sensor technology. The agency has hosted stakeholder workshops, run a design competition, funded research and created guidance materials, such as its June 2014 air sensor guidebook and its online “Air Sensor Toolbox for Citizen Scientists.”

Next-generation technology, such as wearable sensors and handheld monitors, are used by reg-ulators, safety personnel, workers, researchers,

and individuals to assess air quality. They generally aren’t used to monitor compliance with occupa-tional exposure limits to airborne contaminants, a process that involves air sampling at the worksite and testing at an off-site laboratory.

EPA ‘Seal of Approval’EPA gives its “seal of approval” to sensor technol-ogy that conforms to its requirements under the federal regulations for ambient air monitoring, Wil-liams said. To win that approval, the agency tests monitoring technology to assure it is accurate, reproducible, durable, easy to operate, and free from significant interference from ambient gases.

“It doesn’t really matter what the sensing technol-ogy is,” Williams said. “It could be a nanotechnol-ogy, it could be electrochemical, it could be optical.”

The seal of approval relates to testing for the air pollutants under the National Ambient Air Qual-ity Standards (NAAQS): carbon monoxide, lead, sulfur dioxide, ozone, nitrogen dioxide, and par-ticulate matter. EPA also has separate monitoring standards for air toxics like benzene, formalde-hyde, 1,3-butadiene, and hexavalent chromium.

But Williams said monitoring technology that falls short of the requirements for pollutants or toxics could still be appropriate for other purposes, such as education or community awareness. —By Rob-ert Iafolla, Bloomberg BNA

[Editor’s Note: For more on air quality sensor tech-nology, see the January 2014 and August 2014 issues of EM. See also the EPA Research Highlights column on “The Citizen Science Toolbox” published in the September 2014 issue of EM.]


EPA to Launch Program for Evaluating Cutting-Edge Air Monitors, If Funded

The agency

tests monitoring

technology to assure

it is accurate,

reproducible,

durable, easy to

operate, and free

from significant

interference from

ambient gases.

scanrail/iStock/Thinkstock



News Focus is compiled from the current edition of Environment Reporter, published by the Bureau of National Affairs Inc. (Bloomberg BNA). For more information, visit www.bna.com. Note: All amounts in U.S. dollars.

Bloomberg BNA Inc. (bna.com) ............................................................................10

California Air Resources Board (arb.ca.gov) .....................................................9

To advertise in EM, call Keith Price at 1-410-584-1993.

Cambridge Environmental Research Consultants (cerc.co.uk) ............................................................. Inside Front Cover

Lakes Environmental Software Inc. (weblakes.com) ............... Back Cover

Advertisers’ IndexEM Advertiser (www) Page EM Advertiser (www) Page

Criminal Environmental Prosecutions Down From Five Years Ago, Report Says

The Obama administration is prosecuting 26.5% fewer criminal environmental cases than five years ago and significantly fewer

than in former President George W. Bush’s last year in office, a nonpartisan data gathering and distribution service has found.

The current administration has reported initiating 271 new environmental prosecutions so far in fiscal year 2014, which, at that rate, would mean a nearly 20% decrease in environmental prosecutions from fiscal year 2013 at 361 environment prosecutions for the full year, a Transactional Records Access Clearinghouse (TRAC) report found.

The drop would be even more significant—a 61% decrease—in comparison to environmental cases under President Bush, whose administration pros-ecuted 927 criminal environmental cases in fiscal year 2007 alone, the report said.

Much of the drop over a five-year period from slightly under 500 cases in fiscal year 2009 to an estimated 361 prosecutions in fi cal year 2014 occurred in the number of wildlife crimes prose-cuted, which dropped 36.7% over that time frame, according to the report.

Environmental criminal cases prosecuted, such as water or air pollution violations, dropped only 8.6% over five years, the report said.

David Burnham, co-director of TRAC, told Bloomberg BNA that the drop is significant, but he didn’t offer insight into why these drops occurred.

The U.S. Justice Department, the U.S. Environ-mental Protection Agency, and the Interior Depart-ment didn’t offer explanations for the decreases in cases, although a former Justice Department official questioned the report’s methodology.

U.S. Attorneys’ Office Data UsedTRAC compiled its results using the Executive Office for United States Attorneys’ data regarding environmental prosecutions, sorting the results by “program categories,” Burnham said. The U.S. Attorneys’ office’s records don’t include any environmental prosecutions brought without U.S. attorneys, which Burnham said wouldn’t affect the key take-aways from the report.

The report also found that the most common environmental prosecutions a year ago involved illegal taking of fish and wildlife; illegal taking, kill-ing or possessing of migratory birds; and water pollution violations.

One area of contention regarding the report is whether including cases prosecuted solely by the Justice Department’s Environment and Natural Resources Division without the U.S. Attorneys’ Office would change the results of the study.

Burnham said while these separate prosecutions sometimes occurred, their inclusion wouldn’t change the overall findings of the report. He pointed to Title 28, Section 547 of the U.S. Code, which names U.S. attorneys as the nation’s primary litigators for criminal cases brought by the federal government. —By Rachel Leven, Bloomberg BNA


The current

administration

has reported

initiating 271 new

environmental

prosecutions so

far in fiscal year

2014, which, at

that rate, would

mean a nearly

20% decrease

in environmental

prosecutions from

fiscal year 2013.



The Journal of the Air & Waste Management Association (JA&WMA) Announces a

New Page Charge Scholarship

JA&WMA is pleased to announce a new page charge scholarship program with funds generously provided bythe China Section of A&WMA.

Corresponding authors, who are members in good standing with A&WMA, are invited to apply for a scholarshipto cover page charges of new journal papers not yet submitted via the online manuscript submission systemif they meet either of the following criteria:

1. Young Professionals, who meet A&WMA’s criteria for this membership category (i.e., the correspondingauthor should be 35 years of age or younger at the time of submission of the manuscript and can providea valid membership ID), and/or

2. Members from “developing countries”. We will use the International Monetary Fund’s (IMF) World EconomicOutlook classification to qualify for this criterion and any corresponding author who is NOT from theIMF’s list of “Advanced Economies” will be eligible to apply for this scholarship (this list is available athttp://www.imf.org/external/pubs/ft/weo/2012/02/weodata/groups.htm#ae).

The chair of A&WMA’s Editorial Review Board will consider all applications for the PageCharges Scholarship and make the final decision on accepting/rejecting theapplications based on the above criteria.

Please note approval of page charge scholarship funding does not guaranteethat the manuscript will be accepted for publication. All manuscripts must beformatted as directed in the guidelines, will be assessed via the standard reviewprocess, and will only be accepted if the reviewers deem it worthy of publication.

ISSN 1096-2247

For more information and to download a copy of the application form, please go to http://pubs.awma.org/docs/application_for_China_Section_funds.pdf.

MissingPages.indd 2MissingPages.indd 2 4/24/14 1:59 PM4/24/14 1:59 PM


Here’s just a sampling of the benefi ts you receive as an A&WMA Member:

Quality Information: from the Journal of the Air & Waste Management Association to EM magazine to technical books and publications, you get the technical, practical, and professional information you need.

Professional Development and Education: improve your professional skills and expertise at more than 30 continuing education programs, specialty conferences, and a wide variety of workshops held each year, in addition to the Annual Conference & Exhibition.

Networking and Contacts: take advantage of numerous opportunities to meet with your peers and expand your circle of valuable business contacts.

Job Search and Employment: fi nd a position in the environmental fi eld or fi ll a vacancy in your organization through our online job board.

Membership and Resource Directories: your quick reference for fi nding colleagues and a range of products and services.

Discounts: members receive substantial discounts on publications, conferences, educational seminars, insurance coverage, logo merchandise, and more.

Recognition: get recognized for your accomplishments through the A&WMA awards programs, publishing an article in EM or the Journal, or serving on an A&WMA committee.

A&WMAMembership Benefi ts

For more information on these great member benefi ts, contact A&WMA Member Services at 1-800-270-3444 or visit us online at www.awma.org.



em • washington report

Coal Prices Too Low, Fueling Climate Change, Advocates SayThe Bureau of Land Management (BLM) is ignoring coal exports, underpricing coal, and thereby, fueling climate change, according to a report commissioned by four environmental groups. The failure to assess the true economics of coal exports has led the BLM to “systematically underprice coal owned by

the American public, potentially leading to millions of dollars in foregone revenue each year,” said the report, Unfair Market Value, released by Sightline Institute, in collaboration with the North-ern Plains Resource Council, the Powder River Basin Resource Council, WildEarth Guardians, and the Western Organization of Resource Councils.

Coal exports carry significant costs for the climate, air and water quality, and human health, “costs that are borne by the public, but are not incorporated into the price that private coal compa-nies pay for federally owned coal,” the report said.

Environmentalists often refer to the climate change impacts of coal as part of the “social cost of carbon.” In response, Luke Popovich, spokesman for the National Mining Association in

Washington, said that accounting for the social cost of coal isn’t required by the National Environmental Policy Act.

“We are exporting a fuel desperately needed by hundreds of millions of people around the world who don’t have the advantages enjoyed by the lawyers for WildEarth Guardians,” Popovich said. Export sales of coal “require a different cost framework than simply selling coal mined from a lease in Col-orado to a power plant in Illinois or Wisconsin,” he said. em

Private Sector Partners Enlisted to Use Big Data for Climate ResilienceThe White House has tapped Microsoft Corp., the Coca-Cola Co., and more than two dozen other private-sector partners to leverage big data toward making the agricultural sector more resilient to the impacts of climate change. The White House said the new partnerships will help connect farmers, food distribu-tors, and agricultural businesses with the data, tools, and infor-mation they need to better understand how climate change impacts are affecting their operations today and in the future.

To help the agricultural sector deal with climate impacts, the Obama administration is making government data about the risks of climate change to food production, supply, nutrition, and security more accessible through an online climate data hub, climate.data.gov. em

Compiled by Mark Williams, BNA Bloomberg, www.bna.com. Note: All amounts in U.S. dollars.

EPA to Continue Requirements for GHGs under Air Permits

M ajor stationary sources that are subject to a prevention of significant deteriora-tion (PSD) construction permit or Title V

operating permit requirements for conventional pollutants still will be required to implement best available control technology (BACT) requirements for greenhouse gas (GHG) emissions, according to the U.S. Environmental Protection Agency (EPA).

EPA, in a memorandum, said those sources remain subject to existing permitting regulations, despite a June ruling by the U.S. Supreme Court that removed GHG permitting requirements for cer-tain sources of pollution. The court ruled that while EPA may require GHG controls for major station-ary sources that trigger permitting requirements for conventional pollutants, a facility’s GHG emissions

alone don’t trigger PSD or Title V permitting requirements. The agency said, in accordance with the court’s ruling, new and modified sources that trigger PSD permitting requirements on the basis of conventional air pollutants, known as Step One or “anyway sources,” remain subject to BACT require-ments for GHGs and other pollutants. The agency will continue to apply BACT requirements to a new “anyway” source’s GHG emissions if the source has the potential to emit 75,000 tons per year of GHGs.

EPA said that in light of the court’s ruling, it will no longer apply or enforce federal regulatory provi-sions requiring PSD or Title V permits for sources if GHGs are the only pollutant that would trig-ger the permitting requirements, which are also known as “Step Two” sources. em


In light of the

court’s ruling, EPA

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Report: How Would an Oil Spill be Tracked under Artic Ice?A report prepared for the Nunavut Planning Commission has concluded that science has a very limited understanding of how an oil spill would behave beneath the Arctic ice. The report,

Oil Spill Detection and Modeling in the Hudson and Davis Straits, was prepared by LOOKNorth.

The Nunavut Planning Commis-sion is developing a draft land use plan and commissioned the report in response to concerns from residents about the impact to shorelines of potential offshore oil and gas exploration. Under the

Nunavut Land Claims Agreement, the commission’s jurisdiction extends to marine areas, according to Adrian Boyd, director of Policy with the Nunavut Planning Commission.

The report concludes that there is very little research on the effectiveness of remote-sensing technologies in Arctic envi-ronments. Remote-sensing technologies are commonly used to monitor oil spills on water. “The question is, if [the oil] is under the sea ice, how would it be tracked?” asks Boyd. The not-very-reassuring answer appears to be “we’re not sure.” That could pose a serious problem in the event of a spill off Nunavut’s coastline, which has ice cover for as much as 10 months of the year. The report is available online at http://bit.ly/Wl95GD. —By Mark Sabourin, Ecolog em

Survey: BC Residents Committed to Carbon ReductionA survey commissioned by the Pembina Institute, Clean Energy Canada and the Pacific Institute for Climate Solutions, confirms British Columbia (BC) residents’ reputation as committed to carbon reduction—at least so long as it doesn’t cause them to dig too deeply into their pocketbook.

The survey, released July 2014, was conducted April 1 and 2, 2014, and used the recently-signed Pacific Coast Action Plan on Climate and Energy as its starting point. The action plan is a new agreement entered into by BC and the states of Washing-ton, Oregon, and California. In the action plan, the signatories make a number of general commitments, and the survey listed five of them, asking respondents to rate them on a range from “top priority” to “not a priority”.

The commitments were: Meet existing provincial targets to cut carbon pollution; ensure that, within two years, 10% of new vehicles purchased by governments and companies are electric vehicles; enable a transition to homes and build-ings that require very little energy to heat and cool; continue using a carbon tax to reduce the pollution that causes climate change; and maintain an existing requirement for lower car-bon transportation fuels.

Among respondents, 43% rated the continuation of the carbon tax as a top or high priority for the government. For more information on the survey, visit http://www.pembina.org/2014-PCAP-polling-summary. —By Mark Sabourin, Ecolog em

Ecojustice: Canadian Drinking Water Standards Fall Short

Canadians who have felt proud of the quality of their drinking water may want to take a closer look at what flows out of the tap.

The environmental group, Ecojustice, compared the Guidelines for Canadian Drinking Water Qual-ity with the drinking water standards of the United States, European Union, and Australia, as well as guidelines recommended by the World Health Organization. It reports that Canadian drinking water standards actually fall considerably short on several important parameters. For instance, Ecojustice reports that 105 substances that are

regulated elsewhere and that are known to be present in Canada are not regulated under the Canadian guidelines. For another 27 substances, Canada has the weakest standard, or is tied for last place. As Ecojustice points out, these are not all esoteric substances. Canada has the weakest standard for 2-4-D, a commonly used herbicide and suspected human carcinogen. Canada has no standard for styrene or microbiological treatment.

For more information, see www.ecojustice.ca/ publications/waterproof-standards/attachment. —By Mark Sabourin, Ecolog em

Canadian Report is compiled with excerpts from EcoLog News and the EcoCompliance.ca newsletter, both published by EcoLog Information Resources Group, a division of BIG Information Product LP. For more Canadian environmental information, visit www.ecolog.com. Note: All amounts in Canadian dollars.

em • canadian report


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47_EM1114-CanadianReport.indd 47 10/20/14 12:40 PM


Events sponsored and cosponsored by the Air & Waste Management Association (A&WMA) are highlighted in bold. For more information, call A&WMA Member Services at 1-800-270-3444 or visit the A&WMA Events Web site: www.awma.org/events.

To add your events to this calendar, send to: Calendar Listings, Air & Waste Management Association, One Gateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA 15222-1435. Calendar listings are published on a space-available basis and should be received by A&WMA’s editorial offi ces at least three months in advance of publication.

This piece was printed on Opus 30 Web manufactured by Sappi Fine Paper North America with 30% PCW. 100% of the electricity used to manufacture Opus 30 web is GREEN-E(R) CERTIFIED RENEW-ABLE ENERGY


Critical Review Discussion� Public health and components of particulate matter: The changing assessment of black carbon

Review Paper� Sources of atmospheric nitrous acid: State of the science, current research needs, and future prospects

Technical Papers� Characterization of indoor air quality and resident health in an Arizona senior housing apartment building

� Direct N2O decomposition over La2NiO4-based perovskite-type oxides

� Assessment of N2O emission from cement plants: Real data measured with both FTIR and NDIR

� Major ionic compositions of fi ne particulate matter in an animal feeding operation facility and its vicinity

� Immobilization of antimony waste slag by apply-ing geopolymerization and stabilization/solidifi cation technologies

� Recycling research on spent fl uorescent lamps on the basis of extended producer responsibility in China

� Indoor pollution and burning practices in wood stoves management

� Characterization and seasonal variations of levo-glucosan in fi ne particulate matter in Xi’an, China

� Computational fl uid dynamics modeling of laboratory fl ames and an industrial fl are

2014NOVEMBER19 A&WMA Upper Midwest Section

Conference on the Environmentwww.awma-ums.org/calendar/conference-environment

DECEMBER2–3 39th Annual A&WMA/EPA

Information ExchangeResearch Triangle Park, NC; www.awma.org

2015JANUARY13-14 P2: Increase Profi ts Reduce Pollution

Cincinnati, OH; www.awma.org

JUNE22–25 A&WMA’s 108th Annual

Conference & ExhibitionRaleigh, NC; ace2015.awma.org

em • calendar of events

Listed here are the papers appearing in the November 2014 issue of EM ’s sister publica-tion, the Journal of the Air & Waste Manage-ment Association. For more information, go to www.tandfonline.com/UAWM.

NOVEMBER 2014 • VOLUME 64

JOURNAL

WANTED: Professional Development Course Instructors

A&WMA is recruiting instructors to be a part of the professional devel-opment course program at the 2015 Annual Conference & Exhibition in Raleigh, NC, June 21-25, 2015.

Courses are being sought in the following areas:• Air Pollution and Control• Modelling and Monitoring• Environmental Management• Air and Waste Management• Air and Waste Regulatory Compliance

and Permitting• QEP Prep• Any other area of interest in line with

the mission and goals of A&WMA

� If you are interested in teaching a course, visit http://ace2015.awma.org/courses and fi ll out a course proposal form.

The deadline for submissions is Monday, December 15, 2014.

WANTED:

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Plan to join the Air & Waste Management Association inRaleigh for the “must-attend” event for environmentalprofessionals worldwide.The technical program will focus on Connecting the Dots: Environmental Qualityto Climate, while also offering the most current information on the latest air andwaste issues. Come connect with top environmental professionals from industry,government, consulting, legal, and academic backgrounds.

This year’s conference will feature:

• Over 400 Speakers

• 120 Exhibitors Displaying the Newest Products and Services

• Professional Development Courses Taught by Expert Instructors

• Social Tours and Networking Events

Mark your calendar for June 22-25,

2015!

A&WMA’s 108th Annual Conference & ExhibitionConnecting the Dots:Environmental Quality to Climate

SAVETHEDATEJune 22-25th,2015Raleigh Convention Center Raleigh, North Carolina

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EM1114Lakes.indd 1 10/9/14 3:02 PM


Documents

VOCpubs.awma.org/flip/EM-Nov-2014/emnov14.pdf · Chris Tennant, Shirish Shimpi, Tao Huai, Jorn Herner, Ed Nam, Thomas Long, Henry Hogo, and Matthew Thornton Page 26 Air Pollution