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MdI Nov 08, 2018 02:50 PM
The PROBLEM of Acrolein and Formaldehyde Analysis from Stationary Source in Italy.
In Italy use EPA TO-11A 1999 for Industry Emission Stationary Source, not only for Formaldehyde (Instead of e.g. EPA M 0011 ) but also for Acroleine (Instead of e.g. NCASI 99.02). It is an absurd scientific and technicaly that could hide acroelin emission from some industry, like ceramic industry, due to the combustion of thousands of tons / year polyacrylates (used as slurry fluids), glycerol, vegetable oils and other polymers used as screen printing vehicles, as well as to underestimate formaldehyde due to the same use of glycols, polyglycols, etc. ..

All in ovens that have known problems of incomplete combustion due to the countercurrent supply of the tiles, which bring a large part of the organic substances to decompose between 250-450 °C before arriving in the part of the furnace where they would arrive between 800-1200 ° C for complete combustion.

In detail:
The PROBLEM of Acrolein and Formaldehyde Analysis from Stationary Source in Italy. The Emilia Romagna Region,(but it is not the only one in Italy...) with DGR 2236/2009 attachment 3 B indicates as methods suitable for the analysis of aldehydes and formaldehyde at emissions the following two methods:
EPA TO-11A of 1999 and the NIOSH 2016. Both methods for ambient air with DNPH derivative in silica cartridge. They are obviously ambient air methods and therefore off-field application among other things with derivatization method that is notoriously inadequate to the acrolein analysis and sampling flows below 2 l / min. A ceramic industry kiln emission , in example that is the mayor local kind of industry, have a flow rate between 20 and 30 thousand m3 / h corresponding to flows of about 400/500000 liters per minute.
EPA TO-11A has suffered an addendum in 2000 that specifies that this method not to be applicable acrolein and in the list of necessary updates of the EPA March 2018 is specified not to be adequate to the acrolein analysis:[…]/toxcompd.pdf
The NIOSH 2016 always indicated by the Region for generic analysis aldehydes is actually a room air derivatization for formaldehyde very similar to EPA to-11A. The analogous NIOSH 2018, which would be the apllicable in ambient air for generic aldehydes, also reports on page 5 the NON applicability to unsaturated aldehydes (with a 30% lower recovery). In addition, we always talk about ambient air methods and if we consider the indications in points 10.3 of the same EPA TO-11 A it is clear that the conditions of applicability of the same not only for acrolein, but for aldehydes in general a Stationary Stack are incompatible with the typical ones authorized for a ceramic kiln indicated here (and provided for by Legislative Decree 1159/2014 Emilia Romagna):[…]?id=2421&idlivello=1487
Among other things, we mention that this method the EPA Methods for Emissions Flows conveyed for formaldehyde / aldehydes are others and indicated here:[…]/final-rule-methods-innovation-rule-mir

NO METHOD is indicatedwith DNPH-Silica or other similar support

It's clear is not an alternative national or international or industrial counterpart to measure chimney in formaldehyde or acrolein and therefore does not comply with the provisions of UNI CEN TS 15675 of 2008 and EN ISO / IEC 17025, see the first with regard to Annexes A and C and see the second for the concept of "scope".
This does not conform to the principles of Integrated Pollution Prevention and Control (IPPC) or to the European Commission's MMR Guideline No. 5 of 2012 and is not even in line (and specifically for formaldehyde and in analogy for acrolein) with the JRC Reference Report on Monitoring of Emissions to Air and Water from 2018 IED Installations:[…]/ROM_2018_08_20.pdf
of which we report appropriate table (ANNEX 7) from which to choose suitable methods for formaldehyde. EPA M 0011 (in the JRC table for formaldehyde together with other NCASI and CARB methods) must not be confused with EPA TO-11A used in Emilia Romagna as one is an impinger DNPH method (specifically applicable for formaldehyde and other selected carbonyls) and the other is an exclusive ambient air method (with the exception of automobile emission) that uses Silice-DNPH cartridge (the florisil support is not expected even if some suppliers sell DNPH-florisil for EPA to-11A against what is provided by the method) as indicated in Section 1 of:[…]/to-11a_list_of_known_needed_updates.pdf
where EPA also officially declares the demonstrated inapplicability to the acrolein analysis.

The unique acrolein National / Industry Standard recognized for Stationary Stack Emission fron Industry is the NCASI IM / CAM / WP 99.02 which, in analogy to what is indicated in the table presented, can be considered a Method compliant with the requirements of the BREF JRC Reference Report in the absence of specific National and International Technical Standards.

In addition, we note that there are laboratories in Italy accredited for acrolein ambient air with EPA to-11A and NIOSH 2018 against what is recognized on their inapplicability for the analysis of the same and laboratories accredited to chimney for some aldehydes with EPA TO-11A 1999 we ask if it is CONSIDERED OR LESS OUT OF APPLICATION FIELD, IT IS ALSO VALID FOR THE PURPOSE, EVEN IF THE ABOVE IS INDICATED IT MAKES IT DIFFICULTY APPLICABLE.

I write on behalf of Reality, recalling the principles of the Aahrus Convention because AIR SHALL NOT LIVE BY PAPER ALONE.

Replies (5)
EEA Nov 09, 2018 05:33 PM
Dear Mdl,

It appears your letter was posted to the forum twice. Please see the thread of your first post for our reply:

Best regards,
EEA Enquiry Service
MdI Nov 09, 2018 07:28 PM

Yes my post appears twice because I could not put the title in place. Your comment, however, has arrived at the post only after it has been withdrawn. You could answer this. Sincerely
MdI Nov 09, 2018 07:28 PM

Yes my post appears twice because I could not put the title in place. Your comment, however, has arrived at the post only after it has been withdrawn. You could answer this. Sincerely
MdI Nov 12, 2018 11:49 AM
Is there no European office that could be interested in the fact that in a given country are made unsuitable analyzes to determine a carcinogen substance (formaldehyde) and a lethal one (acrolein) from Emission from Industrial Stationary Source?