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Environmental Management

Estimating Air
Emission Rates

Marc Karell, P.E. Stack testing, material balances, emission factors,


Climate Change &
Environmental Services, LLC and engineering equations are the most common
methods that can be used to estimate air emissions.

A
ir pollution is an important public health issue in the The cost of medical treatment, hospitalizations, and
U.S. and worldwide. The World Health Organiza- missed work time due to air-related health issues is stagger-
tion (WHO) estimated that in 2012, 7 million people ing, and borne mainly by the public through government
died (about one-eighth of all mortalities) from illnesses programs, not by those that cause the exposure. Therefore,
related to exposure to air pollutants (1). In addition to the laws over the past decades have been promulgated to reduce
human costs, there are also financial costs, including higher emissions from potential sources to reduce the risk of expo-
public health care costs associated with increased hospital- sure and adverse health risk. However, there are limits to the
izations, as well as lost productivity. The high frequency stringency of such rules, because overly stringent rules may
of respiratory ailments, as well as the necessity of wearing cause costs to rise and encourage facilities to move to loca-
an anti-pollution mask to reduce inhalation of pollutants in tions with less stringent requirements.
certain countries, is well documented in the news media. It is critical for a facility to make realistic estimates of
In the U.S., concern over air pollution is significant. A the emissions it produces, which will help in determining
2015 Gallup poll showed that 38% of Americans were con- compliance, predicting potential public exposure and health
cerned about air pollution “a great deal” (2). A 2013 study impacts, and designing effective air pollution control equip-
by researchers at the Massachusetts Institute of Technology ment or strategies.
(MIT) estimated that about 200,000 Americans die pre- Processes and their emissions are dynamic and emission
maturely each year because of air pollution, although this rates may continuously vary slightly; hence, we use the term
toll is brought on by all sources of air pollution — includ- “estimation” of emissions. The hope is that the estimated
ing nonindustrial ones — such as indoor combustion (e.g., rate either will be reasonably close to the actual emissions
cooking, home boilers) and mobile sources (e.g., auto­ or is conservative enough that it likely will not be exceeded
mobiles, trucks, etc.) (3). in practice.

Copyright © 2017 American Institute of Chemical Engineers (AIChE) CEP  July 2017  www.aiche.org/cep  59
Environmental Management

Many different techniques to estimate emissions are The basic direct testing methodology
available. Each has advantages and disadvantages, or is best The basis of direct measurement is the group of proce-
suited for a specific process. The user must determine the dures published by the EPA in 40 CFR Part 60, Appendix A
best method to estimate the emission rate of the air contami- (4). Appendix A contains several dozen methods. Virtually
nant in question. all U.S. regulatory agencies recognize these methods. These
Factors to consider when choosing an estimation tech- methods contain precise standards for performing the
nique include: procedure, with QA/QC steps, and specify which data
• appropriateness for the contaminant of interest to record. Not following the procedure to the letter seri-
• accuracy required ously risks the integrity of the results and jeopardizes their
• variability of the process approval.
• cost. The general procedure for collecting a sample from
You may need to select a technique that sacrifices some an exhaust stack for analysis is found in Methods 1–5, as
accuracy for the sake of practicality and cost-effectiveness. are guidelines on setting up a testing train. Figure 1 is a
Different techniques may be needed for different operations. schematic of a typical train (this particular setup is used to
What is most important is to develop a program to regularly measure particulate matter emissions) (5).
estimate emissions with needed accuracy from different Every stack testing method involves inserting a testing
processes that change over time. probe into a hole in the exhaust or stack. The end of the
The four major techniques for estimating emission probe must have an opening to allow the collection of some
rates are: exhaust flow. This flow moves through the inside of the
• direct measurement probe, typically through an area that pretreats the exhaust
• material balance sample before it is tested for the contaminant of concern.
• emission factors The sample must be maintained at 248 ± 25°F (measured by
• engineering equations. a thermocouple) to prevent condensation.
Trains contain an S-type pitot tube to measure stack gas
Direct measurement of air emission rates velocity by detecting a pressure difference proportional to
The U.S. Environmental Protection Agency (EPA) and velocity. Given the velocity and the stack diameter, flowrate
other regulatory authorities and industry groups have pub- is estimated and combined with contaminant concentration
lished standards for the direct measurement of regulated air to determine a mass emission rate.
pollutants from many processes. Commonly known as stack In most trains, the sample then flows through a heated
testing, this is the direct measurement of the contaminant in filter box to remove particulate matter. This is necessary for
question in the exhaust while the operation is taking place. measuring particulate emissions or removing particulates
Regulators often require a facility to perform such a test to that may interfere with analysis of the desired compound.
demonstrate compliance with an emission limit in an operat- The sample typically then flows through impinger tubes
ing permit or regulatory standard. containing chemicals that remove and measure specific
Performing a stack test that meets a published standard is compounds. In most cases, the tubes are chilled by ice to
technically complex. If your company is required to perform condense out water. The gas sample leaving the impingers
one, I strongly urge you to hire a testing firm experienced can then be directed to the appropriate analyzer to measure
in the specific methods required. This article gives general the concentration of the subject compound. A pump trans-
background information about direct measurement of air ports the sample at a uniform rate throughout the system. A
pollutants; this information by itself should not be used to centralized control box allows monitoring and adjustment of
perform tests, but should help you work effectively with a flow, temperature, etc.
testing contractor. Method 1 contains guidance for the selection of sam-
Direct measurement involves collecting a represen- pling ports and traverse points for acceptable sampling of a
tative sample of gas from the exhaust or stack during representative aliquot of exhaust. A key concern is col-
process operation, pretreating the gas sample to remove lecting a uniform sample over time. The placement of the
any components that may interfere with the testing, and probe within the exhaust is less important when measuring a
performing a chemical analysis to measure the concentra- gaseous compound than particulate matter, because the gas
tion of the compound of interest. Simultaneously measuring concentration is generally uniform across the pipe’s diame-
the exhaust flowrate enables conversion of concentration ter. However, the samples should not be taken from a section
into an emission rate (typically in pounds per hour). Quality of exhaust exhibiting cyclonic or swirling flow. (Method 1
assurance (QA) and/or quality control (QC) procedures contains procedures for determining whether cyclonic or
accompany each step. swirling flow exists.)

60  www.aiche.org/cep  July 2017  CEP Copyright © 2017 American Institute of Chemical Engineers (AIChE)
Tube location is critical for measuring particulate mat- able PM (the latter is found condensed in impingers down-
ter because particulates are not equally mixed within the stream of the filter). Typically, the PM measured in both
exhaust. Particle flow is slowest along and near stack walls locations must be combined. Other Method 5 procedures
and fastest (and held up less) in the center of the stack. exist for specific circumstances from specific source types
Therefore, to collect a true representative sample of par- (i.e., wood heaters, asphalt industry, etc.). Methods 201 and
ticles, the probe must be moved in stages during the test 202 are tests that should be considered for ultrafine PM.
— from just inside the wall to the center of the exhaust — The integrity of any test depends on ensuring the
based on an equation presented in Method 1. sampling train is a closed system with minimal outside
Disturbances in flow, such as pipe bends, contractions, (clean) air leakage, which would dilute the concentration of
or expansions, will also affect particulate concentration. the contaminant in the exhaust sample. It is critical that all
Ideally, a probe should be placed at least eight pipe diam- connections in the sampling train are fully fitted and sealed,
eters downstream and two diameters upstream of any such normally with silicone grease. Method 5 requires — and
disturbance. The probe must be adjusted during the sample other methods recommend — that a leak check be per-
collection period to collect exhaust throughout the interior formed before and after the sampling event to determine the
of the duct. The locations where the probe should be placed degree of leakage. If leakage exceeds the allowable amount
are called traverse points. The EPA methodology contains specified in the method, the test run is invalid.
separate tables for particulate collection and non-particulate Most of the remaining Appendix A methods pertain to
collection, from circular and rectangular stacks. the measurement of gaseous contaminants (Table 1). There
Method 2 contains the procedure for measuring exhaust are also methods for measuring other contaminants, such
velocity and volumetric flowrate. as specific volatile organic compounds (VOCs) and metals.
Method 5 contains guidance for measuring particulate For these methods, the sample is typically collected through
matter (PM) from two sources: filterable PM and condens- a heated probe and is pretreated to remove compounds that

Temperature Sensor
Optional Impinger Train, May Be Replaced
by an Equivalent Condenser
Probe

Type S Pitot Temperature


Tube Sensor Temperature
Sensor
Temperature
Sensor Heat-Traced Impingers
Gooseneck Glass-Lined
Nozzle Probe
Check
Valve

Glass Filter
Holder Ice
Water
Type S Pitot Bath
Tube Heated Area Vacuum
Stack Line
Wall Manometer Water
Temperature Empty Silica
Sensors Gel
Vacuum
Gage
Orifice

Bypass Main Valve


Valve
Dry Gas Meter

Airtight
Pump

p Figure 1. A typical process train to measure particulate matter emissions has a heated filter box and impinger tubes to measure the presence of specific
compounds. Source: Adapted from (5).

Copyright © 2017 American Institute of Chemical Engineers (AIChE) CEP  July 2017  www.aiche.org/cep  61
Environmental Management

may interfere with the analysis. Then the sample enters a Continuous emission monitoring
monitor, which measures the content of the contaminant An alternative to performing one-time direct measure-
in question. ment is to perform continuous measurement of the con-
taminant using a continuous emissions monitor (CEM,
Tips on performing a stack test sometimes referred to as continuous emissions monitor-
Performing a stack test is very complicated. Many ing system). A CEM has many of the same attributes as a
things could go wrong or introduce error into the results. stack test. A probe is inserted in the stack and the sample is
For that reason, virtually all agencies require that emissions conditioned appropriately before it enters an analyzer for
be reported as an average of at least three successful runs, determination of concentration. A data acquisition system
each of which consists of sufficient sample collection and (DAS) calculates, stores, and organizes data. Typically, the
a successful leak test. Each run generally spans one hour. CEM takes samples at regular intervals and results can be
However, for contaminants found at dilute concentrations averaged as needed.
(for example, trace metals), a longer sampling time is neces- The EPA specifies QA/QC procedures for ensuring a
sary to collect a sufficient sample to measure. CEM’s accuracy for compliance purposes. Calibration and
Because of the complexity of the test methods, most reg- evaluation of drift from zero must be performed daily. Regu-
ulatory agencies require a formal written protocol that must lar audit testing must be performed at intervals designated
be approved before the test begins. Normally prepared by by regulatory requirements, such as running a sample with a
the testing firm, these protocols should list the test methods, known concentration of the compound being measured and
describe the method and sampling equipment thoroughly, running a “relative accuracy” test of the subject CEM versus
and provide necessary calculations, such as the number and another, recently calibrated CEM (relative accuracy) at the
locations of traverse points. same time.
Once the protocol is approved, the facility and testing Purchasing (or leasing) and maintaining a CEM is
firm should set a mutually agreeable date with the regulatory expensive. It can, however, provide a reliable, consistent
agency. It is critical to coordinate testing with plant opera- means to evaluate emissions over a short period or a long
tions to ensure that the equipment in question is operating period of time and provide information about emissions
as intended during the stack test, and any deviations from through various points in your production cycle.
standard operating conditions are recorded. Direct measurement of air contaminant emission rates
After the field work is complete, a stack test report that has the major advantage of measuring real-time emissions
summarizes the methodology, presents the results, and during process operation. Disadvantages include its com-
includes raw data must be submitted to the regulatory agency. plexity and cost, as well as significant potential cumulative
Results are often provided as a concentration or mass error associated with the many steps involved in sampling
emission rate based on the measured volumetric flow and analysis.
through the exhaust. A lower limit is often defined below Particularly given their costs, stack testing and CEM
which the contaminant cannot be measured. operation cannot practically be used to measure emissions
from all pieces of equipment in a facility in all process
Table 1. The basis of direct measurement of air emissions is situations.
the group of procedures published by the EPA in
40 CFR Part 60, Appendix A. These methods contain the Material balance
standards for measuring specific contaminants.
Whatever quantity of a chemical enters a process or piece
Method Contaminant of equipment must either leave that process or piece of equip-
6 Sulfur Dioxide ment, stay within it, or be converted by a chemical reaction
7 Nitrogen Oxides (Figure 2). When you perform a material balance to deter-
8 Sulfuric Acid and Sulfur Dioxide mine the quantity of emitted chemical, you can eliminate the
middle option. Therefore, the total quantity of raw material
10 Carbon Monoxide
entering the process must equal the sum of the quantities that
11, 15, 16 Hydrogen Sulfide and Reduced Sulfides leave it. The material entering the process may be converted
12 Lead in a chemical reaction, or it can exit the process as:
13 Fluoride • product
18, 24, 25 Volatile Organic Compounds (VOCs) • liquid or solid waste
• air emissions.
201, 202 PM-10*
As an alternative to direct measurement of emissions,
*Particulate matter that is 10 µm or less in diameter
you can estimate air emissions by estimating the other

62  www.aiche.org/cep  July 2017  CEP Copyright © 2017 American Institute of Chemical Engineers (AIChE)
parameters — including the quantity of compound incorpo- A high emission factor can cause calculated
rated into product, chemically converted, contained in solid total facility emissions to be higher than
waste, and contained in liquid waste.
Typically, the quantity of a compound entering the expected, which can subject the facility to
process or equipment can be estimated, as can the quantity more stringent regulations.
leaving as product and in the solid and liquid waste, leaving
the air emissions as the difference. The advantages of this applied to a substrate will evaporate into the air, leaving
technique are that it is simple and it avoids the need for behind the solid. So VOC emissions would equal the entire
probes and other complex determinations. solvent portion of the paint used. Solids stay on the sub-
The major disadvantage of estimating air emissions via strate, so PM emissions can be estimated by determining the
material balance is its potentially poor accuracy. Often, air overspray, i.e., the quantity of paint that misses the substrate
emissions represent the smallest component of the material and is potentially captured in the exhaust of the paint spray
balance. Measuring the other components has small, but booth (taking into consideration any filter control).
discernable, errors in technique, and those errors are com-
pounded in the estimation of the air portion. For example, Published emission factors
if 100 lb of Compound A enters a reactor during a batch Emission factors are available in the literature for many
process and 80 lb of that is chemically converted, 12 lb are process situations and types of equipment. These are often
found in the solid waste, and 7 lb are found in the waste­ calculated and published by equipment vendors, trade
water, a material balance would conclude that the emission associations, the EPA, and other agencies. Many of these
rate is 1 lb of A per 100 lb used. But what if there is a slight emission factors are published in normalized terms, such as
error in those estimates? If 79 lb are incorporated into the lb of contaminant per 1,000 gal of a certain fuel combusted,
final product instead of 80 (an error of only 1.25%), 11.5 lb lb per kW of electricity produced, etc. Manufacturers often
of A was solid waste (an error of 4.1%), and there was a 3% provide an emission factor as a guarantee, which enables the
error in measuring the content of A in the wastewater, then user to estimate emissions from the equipment and obtain a
the balance — the total estimated to be emitted into the air permit for the unit.
— would not be 1 lb, but 2.7 lb (an error of 270%). The EPA has published a compilation of emission factors
It is possible to end up with an unreasonably high or for different types of equipment and operations referred to as
low air emissions estimate because of estimation errors. AP-42 (the Government Printing Office’s publication num-
The potential error margin is often greater than the quantity ber for the document) (6). Emission factors are also used in
of air emissions. calculating greenhouse gas (GHG) emissions. The World
Therefore, a material balance should only be used for Resources Institute (WRI) has published the GHG Protocol
simple systems in which there are few pathways for the (7), which provides GHG emission factors for different types
chemical, the product and waste streams are easy to mea- of direct and indirect sources. Published emission factors
sure, and the air emissions component is considerable. For are revised periodically based on new testing or control
example, a material balance is acceptable for painting (coat- technologies.
ing) processes. All of the solvent VOCs contained in a paint Like material balances, the main advantage of emission
factors is their simplicity. To estimate emissions, simply
multiply the emission factor by the rate of usage (e.g., gal-
Air lons of fuel combusted per year or kW of energy produced).
However, their disadvantage is that they may not be
applicable to specific equipment. For example, AP-42
emission factors are based on dozens of emissions measure-
Raw Material Product ments from related equipment. Some of that equipment in
use today is not state-of-the-art and may have been designed
when environmental regulations were less stringent. Equip-
ment vendors often provide emission factors as performance
guarantees; they may wish to set these emission factors high
Waste to better ensure their equipment will meet their guarantee.
Emission factors tend to be conservative (i.e., they
overestimate emissions). Conservative emissions may be a
p Figure 2. The basis for a material balance states that any material
that enters the process must leave the process as product, waste, or air detriment if a high degree of accuracy is necessary, such as
emissions. when a regulatory agency calculates potential exposure and

Copyright © 2017 American Institute of Chemical Engineers (AIChE) CEP  July 2017  www.aiche.org/cep  63
Environmental Management

adverse health impacts. A higher emission factor can also ration for the equipment’s reuse. A gas sweep is also used
cause calculated total facility emissions to be higher than as a safety measure to prevent buildup of solvent in the
expected, which can subject the facility to more stringent headspace (in cases where the solvent concentration may
regulations. approach its lower explosive limit). The sweep gas carries
solvent vapor out of the headspace, and those emissions
Engineering equations are based on the gas sweep rate and vapor pressure of the
Equations to estimate emissions are typically based on components.
the process operation, the components’ likely chemical and Evaporation. Evaporation, or the transfer of a volatile
physical properties, and the degree of volatilization of con- substance from the liquid phase to the gaseous phase within
taminants during the process step. the headspace of the tank or reactor, is a common chemical-
Engineering equations are most useful in the chemical emitting step.
and pharmaceutical industries, because they can determine Evacuation. Some process steps must be performed
the emissions from the myriad steps comprising a process. under vacuum. Therefore, the headspace must be evacuated,
The engineering equations for many chemical and phar- removing some or all components.
maceutical manufacturing operations can be found in the Heating. Heating components in a reactor causes a
Pharmaceutical Maximum Achievable Control Technology thermal expansion of the liquid, displacing vapor from the
(Pharma MACT) rule, found in 40 CFR Part 63, Subpart headspace. At a higher temperature, this displaced vapor
GGG (8). contains more solvent than at room temperature.
Certain process steps in a chemical or pharmaceutical Drying. Wet chemical or pharmaceutical product is
plant that generate emissions are better suited for estimating placed in large ovens (sometimes under vacuum) for final
emissions by engineering equations (Figure 3). drying — often for many hours. Most of the solvent is emit-
Filling (or charging). Filling, or charging, is a common ted in the initial hours. The emission rate profile is usually an
chemical-emitting step. As a reactor or a tank is filled with exponential decay curve.
solvent, the volume of solvent being added displaces an Gas evolution. In some cases, chemical reactions
equal volume of vapor from the headspace to the atmo- form new compounds that escape into the exhaust and
sphere. The displaced vapor is laden with the solvent (sol- atmosphere.
vent already in the tank and solvent being added). Therefore, Most of the equations used to estimate emissions are
the emission rate is based on the material filling rate. Charg- derived from the ideal gas law and Raoult’s law. The volume
ing solid material into a vessel also displaces headspace, of gas displaced from the vessel and partial pressure of the
and will likewise generate emissions. Note that storage compound must be determined by other equations based on
tanks have “breathing” losses, as well. Breathing losses are the chemical’s unique properties and data pertaining to the
the emission of vapor from a tank through expansion and process step.
contraction due to changes in temperature and barometric Chemical or pharmaceutical production may involve
pressure, which must be accounted for. hundreds of steps with the potential to emit, as well as
Gas sweep. Equipment may be purged with an inert multiple chemicals. Commercial software will allow you
gas, such as nitrogen, to remove residual solvent in prepa- to conveniently input chemical and physical data, perform
the large number of calculations for these many steps and
compounds, and calculate total emission rates. Software can
reduce errors in managing the sheer volume of input data
Filling
(Charging) Heating and recordkeeping. Features to look for in emission estima-
tion software include:
• a comprehensive chemical database, including
Antoine’s constants for calculating vapor pressure at a vari-
ety of temperatures
Gas Sweep Evaporation • an equipment database that allows the user to enter
names and capacities of all process equipment and the effec-
tiveness of air pollution control equipment
• a database of process steps for the operation in ques-
Vessel tion that can be edited (this is particularly important, because
process characteristics may change over time)
p Figure 3. Common industrial process operations such as charging, • an emission model database where the calculations are
heating, and sweeping often lead to volatilization. recorded for each run.

64  www.aiche.org/cep  July 2017  CEP Copyright © 2017 American Institute of Chemical Engineers (AIChE)
A major advantage of engineering equations is that, may be too expensive to stack test them all, or there is insuf-
using the proper software, they can quickly and consistently ficient data for engineering equation estimates). You may
determine emission rate data for a large number of steps and need to select only the most commonly manufactured prod-
compounds. They are also good for performing “what-if” ucts or the ones that likely result in the greatest emissions to
analyses (e.g., how would emissions change if a certain step estimate total plant emissions. Understanding your products
or compound had to be changed?). The disadvantage is that, and the steps involved in their production will enable you to
even with software, hundreds of potential emissions steps select true representative products to evaluate.
necessitate gathering an enormous amount of process data, Validate supporting data. Virtually all of the emission
which can be difficult and time-consuming. estimation techniques presented in this article depend on
quality data about the process and/or equipment. For direct
Tips to improve your emission estimation effort measurement, it is important to know all compounds that
Identify all steps and phases. It is beneficial to perform a might be present in the exhaust and how they might affect
total review of your processes, including a detailed walk- the use of a testing methodology; it is also important to know
through of your plant and review of “recipes” to ensure that about any disturbances in your exhaust piping. When con-
you have accounted for all of the equipment and ancillary ducting a material balance, accurate measurement of the vari-
activities related to your processes. I have performed several ous inputs to and outputs from the process or equipment is
emission inventories where operations were done differently critical. To use emission factors, it is important to ensure that
than documented in the operating procedures and equip- the factor is correct as applied to your process or equipment
ment was operating that was not present on drawings. Know and that there are no extenuating circumstances to invali-
where all major exhausts are traveling and understand the date it. For engineering equations, input data (e.g., chemical
steps that contribute to the development of air emissions. composition, temperature, pressure, etc.) at every stage in the
In terms of estimating total plant emissions, it may process are integral to estimating the emission rate.
be that your plant manufactures so many products or in Your facility may depend on emission results for critical
unpredictable quantities (e.g., production based on short- reporting to a regulatory agency or for meeting emission
term customer demand) that it is too challenging to use the reduction goals. Therefore, it is important to do a little extra
techniques described in this article for every product (e.g., it homework to ensure that all data used to estimate emissions
is current, transparent, and accurate. It is often helpful to
work with the operators at the plant who have experience
Literature Cited with the process. It might also be helpful to seek outside,
1. World Health Organization, “7 Million Premature Deaths independent review and verification of input data.
Annually Linked to Air Pollution,” WHO Media Centre,
www.who.int/mediacentre/news/releases/2014/air-pollution/en Check your emission estimates
(Mar. 25, 2014). After the emission estimates are complete, spend some
2. Jones, J. M., “In U.S., Concern About Environmental Threats
Eases,” Gallup, www.gallup.com/poll/182105/concern-environ-
time checking them. Perform an initial check to determine
mental-threats-eases.aspx (Mar. 25, 2015). whether or not they make sense. As mentioned earlier, a
3. Chu, J., “Air Pollution Causes 200,000 Early Deaths Each Year material balance that provides an emission rate of zero or
in the U.S.,” MIT Laboratory for Aviation and the Environment, negative should be of immediate concern. With any tech-
http://lae.mit.edu/air-pollution-causes-200000-early-deaths-each- nique, human involvement will result in errors, which can
year-in-the-u-s/ (Aug. 29, 2013).
affect results. Review input data where feasible to ensure
4. U.S. Environmental Protection Agency, “Standards of
Performance for New Stationary Sources,” 40 CFR Part 60, that no mis-estimations were made. Revisit estimates
Appendix A. periodically. CEP

5. U.S. Environmental Protection Agency, “Method 5 —


Determination of Particulate Matter Emissions from Stationary
Sources,” U.S. Government Publishing Office. MARC KARELL, P.E., CEM, is the founder and principal of the environmental
6. U.S. Environmental Protection Agency, “AP-42: Compilation consulting firm Climate Change & Environmental Services, LLC, located
of Air Emission Factors,” AP-42 EPA, Air Emissions Factors and in Mamaroneck, NY (Email: karell@CCESworld.com; Phone: (914) 584-
6720). He is a licensed Professional Engineer and a Certified Energy
Quantification (Jan. 1995). Manager. He has over 25 years of experience in the environmental,
7. World Resources Institute, and World Business Council energy, and sustainability fields, working for the U.S. EPA and as an
for Sustainable Development, “Greenhouse Gas Protocol,” environmental consultant for industry. His main areas of expertise are
www.ghgprotocol.org. air quality, climate change, carbon footprinting, energy, and sustain-
ability. He earned a BS in biochemistry from New York Univ., an MS
8. U.S. Environmental Protection Agency, “National Emission in biochemistry from the Univ. of Wisconsin, and an MS in chemical
Standards for Pharmaceuticals Production,” 40 CFR Part 63, engineering from Columbia Univ. He is a member of AIChE and serves
Subpart GGG. on CEP’s Editorial Advisory Board.

Copyright © 2017 American Institute of Chemical Engineers (AIChE) CEP  July 2017  www.aiche.org/cep  65

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