(171b) Delivering a Successful Ethylene Section 114 Information Collection Request Test Program

Although every emission testing project is important, some are more important than others. Routine test programs help sources demonstrate compliance with permit limits. Engineering test programs help sources make fiscally responsible decisions regarding operations or the installation of air pollution control equipment. But Information Collection Request (ICR) test programs are different – the data from these programs will be used to evaluate emission levels and may result in the establishment of emission limits or work practices that may affect the economic viability of an individual facility or an entire industry. Accordingly, ICR test programs demand the highest level of test program planning and execution to deliver defensible data that fully conforms to the requirements of the ICR.

In April 2016, EPA issued an ICR for ethylene production facilities under the statutory authority of Section 114 of the Clean Air Act (CAA). This ICR was one of the most complex that EPA has issued and presented significant technical and logistical challenges. The decoking process itself presents numerous technical challenges.

This presentation is based on the mantra of “prepare hard, test easy.” The significant technical hurdles in sampling will be addressed, as well as the logistical and personnel side of the project. When the logistical aspects of the sampling program from glassware washing procedures to the need to have 4,000 pounds of ice delivered are handled before test team deployment, the full intellectual capabilities of the test team can be focused on the range of challenges associated with field operations. The presentation will examine the planning and communication side of the project, the execution of the test matrix, explanation of the technical hurdles jumped and ultimately the data that these complex programs generate.

The presentation is based on the following:

I Close Coordination with the Source Owner

1. Site visit
2. Working with Environmental staff and with “process owner”
3. Understand the process life cycle
4. Grasp and master site safety requirements and build the safety plan

II Identification of the Test Matrix

1. Decoding the ICR test requirements
2. Exploring multiple methodologies to determine sampling compatibility
3. Formalize test matrix

III Identification of the required analyses based on the matrix

1. Determine required analytes
2. Evaluate minimum detection limits versus test run length
3. Build a results timeline

IV Understanding the technical challenges in executing the matrix

1. Evaluate physical environment
   1. Heat
   2. Noise
   3. Elevation
   4. Power
   5. Laboratory location
2. Evaluate sample stream
   1. Decoking versus furnace only operation
   2. Dealing with saturated streams

V Designing and implementing a Quality Assurance/Quality Control plan

1. Use the published test methods as a starting point, not an end point
2. Integrating the organizational QMP into the sampling event

VI Building a strong field team

1. The sports team analogy: put the player in the best place to succeed
2. The military analogy: we’re only as good as the non-coms
3. Assign roles, emphasize accountability, reward performance

VII Identification of Technical Partners

1. Using organizational experience to winnow
2. Understand that ultimate success or failure of the program is in the hands of your outside laboratory

VIII Execution of the matrix

1. Too much communication is almost enough
2. Where are the failures hiding?
3. Planning to succeed
4. Logistics, logistics, logistics

IX Using the QA/QC plan to streamline data entry and data reduction

1. Field Data Reduction
2. Quality manager and peer review
3. Critical Step Checklists

X Delivering a final document and EDR package to the Source Owner

1. Once the data set is reviewed, enter it
2. The boilerplate can be written before mobilization
3. Give the Source Owner plenty of time