2010 Issue

42 REGULATORY CHANGE — continued from page 37 Member Societies www.aaee.net www.acecutah.org www.aiaa.org www.asce.org www.utahashrae.org www.asme.org www.ewh.ieee.org/r6/utah www.aspe.org www.ite.org www.same.org www.seau.org www.swe.org www.ucls.org www.uspeonline.com chosen vendor’s solution. Scale-up and Applicability to Other Sources? Another critical decision was to determine the scope and applicability of the standard. This is best understood by examining the relationship between Method 9 and human- observer smoke school certification. As it stands today, a hu- man observer can be certified in a smoke school and generally they are certified for all sizes of stationary emission sources. Because Method 9 has been in place for several decades, it was granted great latitude in many areas where supporting data was not collected. Unfortunately, in today’s regulatory environment, a newmethod cannot be granted the same broad latitude in its application without supporting data. Therefore the ASTM process requires fairly significant data supporting applicability, and offers a very strong forum for industry to voice concerns regarding overstepping, or generalizing applicability based on the data provided. As such, various participants have limited the ASTM standard applicability to stationary sources of less than seven feet in diameter. ASTM, however, does provide a modification procedure. When data supporting the addition of seven feet and greater stacks is provided, the scope of the standard will be modified. Table 1 summarizes differences between Method 9 and the method based on the ASTM standard. Conclusion With ASTMStandard D7520-09 approved and in publication, the Hill AFB industry partnership teamcontinues the effort of comply- ing with EMC GD 022R3. A summation package is to be sent to the director of the EPA’s Emission Measurement Center which is required for adoption of the ASTM D7520-09 as an alternative test method for measurement of visible emissions. To insure the ASTMalternativemethod is approved, the Hill AFB and industry teamwill continue to work with recognized research and development centers such as the Electric Power Research Institute (EPRI) and the American Petroleum Institute (API) to perform situational testing of the DOCS II to validate ASTM’s alternative method. Steve Rasumssen the principle investiga- tor from Hill AFB says, “the process of securing alternative test methods to reduce compliance cost and increase efficiency is long and tedious, but for good reason.” The Hill AFB environmental group is confident that with the backing of the EPA, ASTM and their industry partnership that an alternative to Method 9 will soon be endorsed and supported by the regulatory agencies. Mr.RasmussenanalumnusofWeberStateUniversity,istheAirQualityProgramManager attheHillAirForceBase. He iswiththeBasesince1995. Hehasbeen involvedasa DepartmentofDefenserepresentativeonairprogramsinitiativeswiththeEPAandthe CleanAirAct.TheseincludetheAerospaceNESHAP,ChromeNESHAPandtheDefense Land Misc Equipment NESHAP.