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Testo 350 Field Guide - Actoolsupply.com

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• Non-Attainment Area = 25 tons per year (t/y)<br />

• Severe Non-Attainment Area = 10 tons per year (t/y)<br />

As such, a facility must look at ALL of their air pollution sources, <strong>com</strong>bine the total<br />

and if it exceeds the limits stated above, they are NOW considered a large<br />

source. With this large source designation <strong>com</strong>es extensive data gathering and<br />

reporting and it also triggers other federal and state regulations.<br />

Once designated as a Title V facility, each source must propose what methods it<br />

will do to control and monitor emissions. The acceptance of each proposal<br />

depends upon the local and/or state requirements. The sources have a variety of<br />

ways to monitor their emissions. They may use f-factors and fuel calculation; to<br />

temperature or other parametric monitoring; to measuring flue gas with either<br />

portable analyzers, stack testing trailers, or CEMS. The authorities wish is to<br />

have real flue gas measurements and portable analyzers provide a very good<br />

means to collect true, accurate and less costly data.<br />

Title V regulations, including the Compliance Assurance Monitoring (CAM) and<br />

Periodic Monitoring (PM) are the driving force in targeting these smaller sources.<br />

CAM and PM were developed to address all the sources not previously identified<br />

through the other programs.<br />

Fundamental Change in Compliance<br />

A fundamental regulatory change has recently taken place. Historically, sources<br />

only needed to be in <strong>com</strong>pliance during their stack test (generally tested once<br />

every 1 or 5 years). Now, sources are required to be in <strong>com</strong>pliance 100% of the<br />

time. The proof of <strong>com</strong>pliance is now the responsibility of the source and not the<br />

one-time emission (stack) test.<br />

A <strong>com</strong>pany officer is now legally responsible for his facility’s air quality<br />

<strong>com</strong>pliance. The regulatory enforcement agencies have the authority to issue<br />

civil fines and/or take criminal action if <strong>com</strong>pliance is not met. These two new<br />

concepts of continuous <strong>com</strong>pliance and enforcement authority provide the<br />

incentive to <strong>com</strong>ply with the regulations. This opens a whole new market for<br />

portable analyzers.<br />

Trends for Portable analyzers<br />

The step to testing smaller sources provided a good reason to utilize another analyzer<br />

technology, namely electrochemical sensors. They provide accurate data, are<br />

more cost effective, and are widely available. Portable electrochemical analyzers<br />

are now accepted at the federal, state, and local levels for monitoring emissions.<br />

43.2<br />

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