The EPA’s Protocol Gas Verification Program (PGVP) has been evolving over the past few years, and is due to be finalized this year.
Specialty gas companies produce EPA Protocol gases to calibrate continuous emissions monitoring systems (CEMS). However, the EPA noted in 2008 when it initially launched the program that the accuracy of protocol gases it audited was actually declining - a situation that could have affected results from continuous emissions monitoring (CEM) and led to inaccurate figures for pollution. A major specialty gas company that said that the PGVP had not been properly promulgated also challenged the EPA. As a result the program was withdrawn for further revisions, the results of which are now on the table. The minimum competency requirements for air emission testing bodies (AETB) have also been re-evaluated.
The changes now underway involve upgrades to the rules and requirements for creating and using EPA protocol gases - the ultimate goal is to optimize EPA Protocol gases’ accuracy. This will give the best possible data, which in turn can be used to operate emissions trading programs. The EPA’s proposals to amend its PGVP and minimum competency requirements for air emission testing have now been on the table for several months - a final ruling is due soon.
When the PGVP comes into force, amendments to 40 CFR Parts 72 and 75 will be the first major change to the EPA Protocol program since 1998. Both EPA Protocol gas manufacturers and those in the business of emissions testing will be affected.
How will the specialty gas industry be affected? Specialty gas companies wishing to participate in the PGVP will need to have each production site registered by the EPA with a unique vendor ID number, which will be included on analysis certificates. Registration will be valid for one year, and the EPA will conduct annual audits by blind tests on cylinders procured from registered sites. The National Institute of Standards and Technology (NIST) will carry out the analyses, at the manufacturer’s expense. The results of these tests will be posted on the EPA’s website. If a manufacturer fails an audit, or to provide required information, the EPA will be able to delist them. There are steps a company can take to get back on the list should this occur. AETB will have to use Protocols manufactured only by PGVP participants who have passed the audit and are on the list.
“Generally, these changes will not have a significant impact on the many competent manufacturers of EPA Protocols in the specialty gas industry,” Larry Ingle, product manager of Specialty Gases at Air Liquide America told Specialty Gas Report. “Those companies who had problems with previous audits will be challenged to tighten up their production and analytical procedures to pass future audits,” he added. Although the ever-increasing demand for accuracy for such standards is an ongoing test of the skills of specialty gas manufacturers, the trend towards tighter emissions controls and trading looks set to continue. Those who meet the challenge will contribute to improved air quality and fair participation in trading schemes that hopefully we will all benefit from both now and for future generations. Look out for more coverage on the PGVP in Specialty Gas Report once a final ruling is made.
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