From: David Gossman <dgossman@gcisolutions.com>
Newsgroups: sci.environment
Subject: Re: PM 2.5 Formation
Date: Mon, 27 Oct 1997 22:31:18 -0600

Wigger, John wrote:

> I am interested in finding information on the atmospheric formation of
> PM 2.5. I have read many references that indicate that SOx and NOx are
> contributers, but I have not found any of the chemistry behind these
> claims.
>
> If anyone has any reference material or good web site to research,
> please let me know.
>
> Thanks in advace,
>
> John Wigger
>
> http://www.webzone.net/jwigger

Ammonium chloride and ammonium sulfate are good examples of condensibles
that may be considered PM 2.5. Biggest problem is the test method! EPA
in traditional fashion is establishing a standard without a test method.
Consider that the agency is establishing standards based on data
gathered in a variety of fashions with little QC to accurately determine
the quantitation limit of the methods involved. We are right now
discovering that EPA has been setting MACT standards using data from
unvalidated methods, much of the data being below the quantitation
limits for those methods/sources. Talk about a catch 22. How would you
like to have to comply with an emission limit set so low that the method
REQUIRED to be used to demonstrate compliance cannot accurately measure
values that low. I am very much afraid that that is where we are headed
on PM2.5.
--
--------------------------------------------
|David Gossman  | Gossman Consulting, Inc. |
|President      | http://gcisolutions.com  |
|    The Business of Problem Solving       |
--------------------------------------------
"If it can't be expressed in figures, it is not science;
 it is opinion." - Lazarus Long aka Robert Heinlein

From: David Gossman <dgossman@gcisolutions.com>
Newsgroups: sci.environment
Subject: Re: PM 2.5 Formation
Date: Tue, 28 Oct 1997 22:54:34 -0600

Tom Adams wrote:
>
> David Gossman wrote:
> >
> > . We are right now
> > discovering that EPA has been setting MACT standards using data from
> > unvalidated methods, much of the data being below the quantitation
> > limits for those methods/sources. Talk about a catch 22. How would you
> > like to have to comply with an emission limit set so low that the method
> > REQUIRED to be used to demonstrate compliance cannot accurately measure
> > values that low.
>
> As MACT standards are based on the best demonstrated industrial
> technology, your previous statement on MACTs are rather foolish.  And
> certainly, under credible evidence, your statement is even more
> nonsense.

MACT standards are based on test data. Much of that test data has been
gathered with test methods that have not been validated. Much of that
data is below the quantitation limits for the methods used. Those are
simple, verifiable facts. If you disagree please be specific. For
example your statement that MACT standards are based on technology is
only partially correct. Where do you think the data came from to show
that the technology produces certain emission levels if not some form of
emission testing. Take a look at how the Clean Air Act requires the use
of the best 12% of emission test results to identify the best technology
and set the limits. Unvalidated test methods and data from below the
quantitation limit for those methods is being used to set emission
standards that industry is garunteed to fail based on statistics alone,
no matter what technology they have in place. A nearly perfect setup for
an agency that is step by step abandoning the science upon which it was
founded in favor of the politcs that provides its current power base. A
real recipe for future disaster in my opinion.
>
> The U.S. EPA is under a mandate to protect Human Health and the
> environment.  The medical data is there, the new Pm2.5 standard will not
> be implimented until after monitoring data shows that there is a
> exceedance.

And I will ask you how was that medical data gathered if the test
methods for PM2.5 have never been validated or standardized?! I will not
argue the medical impact although I have always been concerned about the
potential that many of the studies are based on urban environments which
produce a very different chemistry of PM2.5 than rural environments and
some types of industrial sources. I am already seeing attempts by permit
writers to incorporate PM2.5 limits into new air permits for industrial
sources. Currently the stongest arguement preventing this is the lack of
an approved standard test method but that won't last long.

--
--------------------------------------------
|David Gossman  | Gossman Consulting, Inc. |
|President      | http://gcisolutions.com  |
|    The Business of Problem Solving       |
--------------------------------------------
"If it can't be expressed in figures, it is not science;
 it is opinion." - Lazarus Long aka Robert Heinlein

From: David Gossman <dgossman@gcisolutions.com>
Newsgroups: sci.environment
Subject: Re: PM 2.5 Formation
Date: Thu, 30 Oct 1997 16:00:46 -0600

Tom Adams wrote:
>
> David Gossman wrote:
> >
> > MACT standards are based on test data. Much of that test data has been
> > gathered with test methods that have not been validated. Much of that
> > data is below the quantitation limits for the methods used. Those are
> > simple, verifiable facts. If you disagree please be specific. For
> > example your statement that MACT standards are based on technology is
> > only partially correct. Where do you think the data came from to show
> > that the technology produces certain emission levels if not some form of
> > emission testing. Take a look at how the Clean Air Act requires the use
> > of the best 12% of emission test results to identify the best technology
>
> What I don't know is what point you are trying to make.  U.S. EPA,
> States and industrial representitives develop MACT standards.  The best
> testing data is used, sometimes OSHA methods are used for HAP
> identification, sometimes surrogates are used, and sometimes guesses are
> made.  Bloody Hell, we are engineers, we do the best we can, we used the
> best data and our judgement.  What else do you want.  If you want
> perfection, we'd still be arguing forever like we did on the old NESHAP
> standards.

I just want good science that includes stack test methods that can be
used to reliably demonstrate compliance. Without that the "limits"
become meaningless hype used for political puposes and potentially used
to take scientifically invalid enforcement actions. While I do not have
personel knowledge of the circumstances I understand a similar problem
has existed with permit limits set in waste water discharge permits and
it was fought all the way to the supreme court. I don't want that to
happen in the air emissions area since it discredits both industry and
the EPA.
>
> You know what input industry has had in the setting of MACT standards,
> you know what pressure the EPA is under from an increasingly hostile
> congress.  Each and every MACT standard is fought in the comittee room,
> in corporate offices and in wars of public relations.  It is good
> responsible government.

Not if it is bad science!
>
> > and set the limits. Unvalidated test methods and data from below the
> > quantitation limit for those methods is being used to set emission
> > standards that industry is garunteed to fail based on statistics alone,
> > no matter what technology they have in place. A nearly perfect setup for
> > an agency that is step by step abandoning the science upon which it was
> > founded in favor of the politcs that provides its current power base. A
> > real recipe for future disaster in my opinion.
> >
> >
> > And I will ask you how was that medical data gathered if the test
> > methods for PM2.5 have never been validated or standardized?! I will not
> > argue the medical impact although I have always been concerned about the
> > potential that many of the studies are based on urban environments which
> > produce a very different chemistry of PM2.5 than rural environments and
> > some types of industrial sources. I am already seeing attempts by permit
> > writers to incorporate PM2.5 limits into new air permits for industrial
> > sources. Currently the stongest arguement preventing this is the lack of
> > an approved standard test method but that won't last long.
>
> As a licensed Biomedical Engineer, I will be happy to testify the
> methodology for doing respitory particle size is there.  Just because
> there is not a large scale published EPA method , does not mean that
> there are not research medical method.
> You don't expect me to fall for such an easy misdirection to you.

But can you also testify that the nonexistant EPA approved stack test
method will identify the same particulate catch the the research medical
method has? And what is the quantitaiton limit of that same stack test
method? EPA has established Methods 5, 23, 26, and 29; requires testing
with all of these and has yet to determine the quantitation limits for
any major source category for these methods.  Doesn't that strike you as
odd?
>
> And you also know that the regulated air pollutant is no longer PM10 and
> is now PM2.5.  And as with the common sense of credible evidence has
> stated, just cause there isn't a publish EPA method, doesn't mean you
> can't protect the environment.

So please tell us how a source is suppose to reliably demonstrate
compliance?!
>
> Sir, I am familar with your organization, you are well aware of these
> facts.  What I don't understand is why you are spending your time doing
> these logical misdirections to confuse the less experienced?

Because, while I have been aware of the deficiencies of a number of
these stack testing methods, I have only become aware recently of the
seriousness of the situation based on some quantitative dual train
source testing that indicates the qunatitation limits are much higher
than even I had suspected. I would rather see industry and EPA deal with
the problem now than wait till after still more MACT limits that can't
be complied with in a demonstrable fashion are on the books. The real
question is why has the agency, in the process of validating these
methos for use, not established quantitation limits so that industry,
the public, permit writers, and regualtion writers have something real
to hang their hat on.  Why would you or anyone else want to see MACT
limits based on invalid data?

If you are really interested there is a major study group being set up
by ASME to look into the issue. It is called the Reference Method
Accuracy and Precision Consortium. The contact at ASME is Greg Barthold
at 202-785-3756 if you have an interest in participating.

If you know my organization then you also know that on occasion I have
taken stands based on science against regualtory requirements that I
actually make money off of. I raise this issue because it is a serious
technical problem and not to confuse anyone.
--
--------------------------------------------
|David Gossman  | Gossman Consulting, Inc. |
|President      | http://gcisolutions.com  |
|    The Business of Problem Solving       |
--------------------------------------------
"If it can't be expressed in figures, it is not science;
 it is opinion." - Lazarus Long aka Robert Heinlein

From: David Gossman <dgossman@gcisolutions.com>
Newsgroups: sci.environment
Subject: Re: PM 2.5 Formation
Date: Sun, 02 Nov 1997 20:32:33 -0600

Tom Adams wrote:
>
> David Gossman wrote:
> >
>
> > I just want good science that includes stack test methods that can be
> > used to reliably demonstrate compliance. Without that the "limits"
> > become meaningless hype used for political puposes and potentially used
> > to take scientifically invalid enforcement actions. While I do not have
> > personel knowledge of the circumstances I understand a similar problem
> > has existed with permit limits set in waste water discharge permits and
> > it was fought all the way to the supreme court. I don't want that to
> > happen in the air emissions area since it discredits both industry and
> > the EPA.
>
> Don't mention lawyers and science in the same paragraph.  If the bloody
> emissions are a threat to the public health and the environment, then
> don't pull this weak arguement that the method does not exist.

Your comment about lawyers and science is appropriate although somewhat
out of place. I am still trying to understand how you can first
determine the presence of a threat and then set and measure a protective
standard without an accurate method. What is weak about my arguement? I
don't see how your suggestion can be considered at all realistic.
>
> > Not if it is bad science!
>
> Why is is bad science, do you truly believe the check and balances that
> are being used to develop the MACT science is bad science?  Companies
> used a hundred ASTM, instrument and other methods to monitor their
> process   concentrations.  They don't wait for a government agency to
> develop an 'approved method' for them.  Why should they be any less
> competent in estimating and monitoring stacks.

The "checks and balances" are political - as bad as lawyers and science
is the suggestion that politics can produce good science.:) If industry
had the responsibility/authority to develop standards then ASTM would be
a good route. Ever check on how many ASTM methods for stack testing
exist? EPA has clearly determined that that role is theirs. Now that the
data on method accuracy is out maybe that will change with the efforts
of the ASME group. What I wait to see is wether or not EPA will try to
interfere with politics or cooperate to produce some real science.
> > >
> > > As a licensed Biomedical Engineer, I will be happy to testify the
> > > methodology for doing respitory particle size is there.  Just because
> > > there is not a large scale published EPA method , does not mean that
> > > there are not research medical method.
> > > You don't expect me to fall for such an easy misdirection to you.
> >
> > But can you also testify that the nonexistant EPA approved stack test
> > method will identify the same particulate catch the the research medical
> > method has? And what is the quantitaiton limit of that same stack test

> So nothing can be done until a method is established? One of My
> undergrad mentors at U of Ky told me a very wise bit of advise, and that
> was don't let the instrumentation drive your experiment.  Develop the
> need, the instrumentation will follow.

Please legislate the laws of gravity out of existance and see what
happens! You propose to require a limit without a method. EPA mandates a
limit and a test method that doesn't work. I don't see how either of
those approaches accomplish the goal of reducing emissions.
>
> > method? EPA has established Methods 5, 23, 26, and 29; requires testing
> > with all of these and has yet to determine the quantitation limits for
> > any major source category for these methods.  Doesn't that strike you as
> > odd?
>
> I don't understand your point.  As the commonwealth of Kentucky has Air
> Toxic regulations, as do many other states, Kentucky use method 26 and
> 26A quite regularly, combustion of Chlorocarbons produced quite alot of
> HCl, both a Ky Air Toxic and an HAP. As sources are required to
> quantifiy their HAP, and prehaps the damn MACT Hammer, why should we not
> have a test method.  What I would love is to have one for HF, and not
> Fluorides as HF.

Believe it or not 26 produces chlorides as HCL just like it can be used
for flourides as HF - no difference. In fact 26 has the known
interference of ammonium chloride. I don't mean that it is not useful
but EPA has used Method 26 data to pull cement plants in as a major
source under the MACT rule while their own scientists have said in
writing that Method 26 is not valid for use on a cement kiln - thanks
for the perfect example.

> > And you also know that the regulated air pollutant is no longer PM10 and
> > > is now PM2.5.  And as with the common sense of credible evidence has
> > > stated, just cause there isn't a publish EPA method, doesn't mean you
> > > can't protect the environment.
> >
> > So please tell us how a source is suppose to reliably demonstrate
> > compliance?!

> For most PSD compliance issues, the thresholds and such, the use of
> Pm2.5 is a relaxation of standard.  Testing is still done by the Pm or
> if you have the bucks the Pm10 method.  It would be different if we were
> talking about aerosol formation.

In some states and for some sources we are. Either way the current
Method 5 for total particulates may have a quantitation limit well above
some of the proposed MACT limits. Recent attempts by EPA and others to
validate particulate CEMs have run into problems not because of the CEMs
but because Method 5 which EPA requires to be used as the reference
method is not accurate enough. One european manufacturer actually pulled
their units from the trials, refusing to participate in a scientific
farce - so much for your idea of industry providing the methods!

> > If you are really interested there is a major study group being set up
> > by ASME to look into the issue. It is called the Reference Method
> > Accuracy and Precision Consortium. The contact at ASME is Greg Barthold
> > at 202-785-3756 if you have an interest in participating.
>
> Nah, spending too much time working on some MACT standard development.

Just make sure you can accurately measure the standard you are proposing
and that the data you use to set the standard is accurate. My own
experience as well as that of others suggests that databases being used
for MACT standard development contain at least 30% inaccurate data on
its face not counting the issue of quantitation limits. Do you honestly
consider that science?
--
--------------------------------------------
|David Gossman  | Gossman Consulting, Inc. |
|President      | http://gcisolutions.com  |
|    The Business of Problem Solving       |
--------------------------------------------
"If it can't be expressed in figures, it is not science;
 it is opinion." - Lazarus Long aka Robert Heinlein