Archive for the ‘U.S. Environmental Protection Agency’ Category

EPA OIG — Improvements to EPA Policies and Guidance Could Enhance Protection of Human Study Subjects

April 3, 2014 Comments off

Improvements to EPA Policies and Guidance Could Enhance Protection of Human Study Subjects (PDF)
Source: U.S. Environmental Protection Agency, Office of Inspector General

The EPA obtained approval to conduct the five human research studies, including approval from a biomedical Institutional Review Board (IRB) and the EPA Human Studies Research Review Official (H SRRO). However, t he EPA’s policies and guidance do not address when HSRRO approv al is needed for significant study modifications. Developing guidance for when HSRRO must approve significant modifications would ensure their independent review.

The EPA obtained informed consent from the 81 human study subjects before exposing them to pollutants. While the consent forms met the requirements of 40 CFR Part 26, we found that exposure risks were not always consistently represented. Further, the EPA did not in clude information on long-term cancer risks in its diesel exhaust studies’ co nsent forms. An EPA manager considered these long-term risks minimal for short-term study exposures. We believe presenting consistent information about risks further ensures that study subjects can make the most informed choice about participating in a study.

The EPA addressed six adverse events during its studies, reported them to the IRB, and provided clinical follow-up after t he events. While the clinical follow-up appeared to be reasonable, the EPA’s polic ies, guidance and cons ent forms do not establish the EPA’s clinical follow-up re sponsibilities. Acco rding to EPA managers, the agency uses the latest University of North Carolina at Chapel Hill (UNC) IRB’s adverse event definitions and reporting ti meframes to respond to adverse events. However, the agency’s guidance provides different definitions and reporting timeframes and does not state that t he EPA has adopted the UNC-IRB definitions and timeframes. Using EPA’s guidance, the EPA reported two of the six adverse events later than required and did not report two other events to IRB.

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CRS — EPA’s Vessel General Permit: Background and Issues

March 11, 2014 Comments off

EPA’s Vessel General Permit: Background and Issues (PDF)
Source: Congressional Research Service (via University of North Texas)

In November 2011 the Environmental Protection Agency (EPA) proposed two Clean Water Act (CWA) permits to regulate certain types of vessel discharges into U.S. waters. The proposed permits would replace a single Vessel General Permit (VGP) issued in 2008 that was due to expire in December 2013. As proposed, the permits would apply to approximately 71,000 large domestic and foreign vessels and perhaps as many as 138,000 small vessels. This universe of regulated entities is diverse as well as large, consisting of tankers, freighters, barges, cruise ships and other passenger vessels, and commercial fishing vessels. Their discharges are similarly diverse, including among other pollutants aquatic nuisance species (ANS), nutrients, pathogens, oil and grease, metals, and toxic chemical compounds that can have a broad array of effects on aquatic species and human health, many of which can be harmful.

EPA proposed two permits, one (draft VGP) for large vessels to replace the 2008 VGP, and one for smaller vessels covered by a congressionally enacted temporary moratorium (draft sVGP). Both were proposed well in advance of the VGP’s expiration to provide ample time for the regulated community to prepare for new requirements. On March 28, 2013, EPA issued a final version of the VGP for large vessels. It took effect December 19, 2013. The permit for smaller vessels is still under review.

Water Security Toolkit User Manual: Version 1.1

February 26, 2014 Comments off

Water Security Toolkit User Manual: Version 1.1
Source: U.S. Environmental Protection Agency

The Water Security Toolkit (WST) assists in the evaluation of multiple response actions in order to select the most beneficial consequence management strategy. It includes hydraulic and water quality modeling software and optimization methodologies to identify: (1) sensor locations to detect contamination, (2) locations in the network in which the contamination was introduced, (3) hydrants to remove contaminated water from the distribution system, (4) locations in the network to inject decontamination agents to inactivate, remove, or destroy contaminants, (5) locations in the network to take grab samples to confirm contamination or cleanup, and (6) valves to close in order to isolate contaminated areas of the network. This user manual describes the different components of WST and how to use the software.

EPA Revises Permitting Guidance for Using Diesel Fuel in Oil and Gas Hydraulic Fracturing

February 14, 2014 Comments off

EPA Revises Permitting Guidance for Using Diesel Fuel in Oil and Gas Hydraulic Fracturing
Source: U.S. Environmental Protection Agency

Today, the U.S. Environmental Protection Agency (EPA) released revised underground injection control (UIC) program permitting guidance for wells that use diesel fuels during hydraulic fracturing activities. EPA developed the guidance to clarify how companies can comply with a law passed by Congress in 2005, which exempted hydraulic fracturing operations from the requirement to obtain a UIC permit, except in cases where diesel fuel is used as a fracturing fluid.

EPA is issuing the guidance alongside an interpretive memorandum, which clarifies that class II UIC requirements apply to hydraulic fracturing activities using diesel fuels, and defines the statutory term diesel fuel by reference to five chemical abstract services registry numbers. The guidance outlines for EPA permit writers, where EPA is the permitting authority, existing class II requirements for diesel fuels used for hydraulic fracturing wells, and technical recommendations for permitting those wells consistently with these requirements. Decisions about permitting hydraulic fracturing operations that use diesel fuels will be made on a case-by-case basis, considering the facts and circumstances of the specific injection activity and applicable statutes, regulations and case law, and will not cite this guidance as a basis for decision.

CRS — Federal Pollution Control Laws: How Are They Enforced?

January 28, 2014 Comments off

Federal Pollution Control Laws: How Are They Enforced? (PDF)
Source: Congressional Research Service (via National Agricultural Law Library)

As a result of enforcement actions and settlements for noncompliance with federal pollution control requirements, the U.S. Environmental Protection Agency (EPA) reported that, during FY2012, regulated entities committed to invest an estimated $9.0 billion for judicially mandated pollution controls and cleanup, and for implementing mutually agreed upon (supplemental) environmentally beneficial projects. EPA estimated that these efforts achieved commitments to reduce, treat, or eliminate 2.2 billion pounds of pollutants in the environment, primarily from air and water. EPA also assessed more than $208.0 million in civil penalties (administrative and judicial) and $44.0 million in criminal fines and restitution during FY2012. Noncompliance with federal pollution control laws remains a continuing concern. The overall effectiveness of the enforcement organizational framework, the balance between state autonomy and federal oversight, and the adequacy of funding are long-standing congressional concerns.

This report provides an overview of the statutory framework, key players, infrastructure, resources, tools, and operations associated with enforcement and compliance of the major pollution control laws and regulations administered by EPA. It also outlines the roles of federal (including regional offices) and state regulators, as well as the regulated community. Understanding the many facets of how all federal pollution control laws are enforced, and the responsible parties involved, can be challenging. Enforcement of the considerable body of these laws involves a complex framework and organizational setting.

CRS — Environmental Laws: Summaries of Major Statutes Administered by the Environmental Protection Agency

January 28, 2014 Comments off

Environmental Laws: Summaries of Major Statutes Administered by the Environmental Protection Agency (PDF)
Source: Congressional Research Service (via National Agricultural Law Library)

With congressional approval, the Nixon Administration established the Environmental Protection Agency (EPA) in 1970 under an executive branch reorganization plan, which consolidated numerous federal pollution control responsibilities that had been divided among several federal agencies. EPA’s responsibilities grew over time as Congress enacted an increasing number of environmental statutes and major amendments to these statutes. EPA’s primary responsibilities have evolved to include the regulation of air quality, water quality, and chemicals in commerce; the development of regulatory criteria for the management and disposal of solid and hazardous wastes; and the cleanup of environmental contamination. The implementation and enforcement of many of these federal authorities is delegated to the states. EPA also provides financial assistance to states and local governments to aid them in administering pollution control programs and in complying with certain federal environmental requirements. Several federal statutes provide the legal authority for EPA’s programs and activities. The major provisions of each of the following statutes are summarized in this report, as laid out in existing law as of this writing.

CRS — EPA Regulations: Too Much, Too Little, or On Track?

January 28, 2014 Comments off

EPA Regulations: Too Much, Too Little, or On Track? (PDF)
Source: Congressional Research Service (via National Agricultural Law Center)

Since Barack Obama was sworn in as President in 2009, the Environmental Protection Agency (EPA) has proposed and promulgated numerous regulations implementing the pollution control statutes enacted by Congress. Critics have reacted strongly. Many, both within Congress and outside of it, have accused the agency of reaching beyond the authority given it by Congress and ignoring or underestimating the costs and economic impacts of proposed and promulgated rules. The House has conducted vigorous oversight of the agency in the 112th and 113th Congresses, and has approved several bills that would overturn specific regulations or limit the agency’s authority. Particular attention has been paid to the Clean Air Act; congressional scrutiny has focused as well on other environmental statutes and regulations implemented by EPA.

Environmental groups and other supporters of the agency disagree that EPA has overreached. Many of them believe that the agency is, in fact, moving in the right direction, including taking action on significant issues that had been long delayed or ignored in the past. In several cases, environmental advocates would like the regulatory actions to be stronger

EPA states that critics’ focus on the cost of controls obscures the benefits of new regulations, which, it estimates, far exceed the costs. It maintains that pollution control is an important source of economic activity, exports, and American jobs, as well. Further, the agency and its supporters say that EPA is carrying out the mandates detailed by Congress in the federal environmental statutes.

This report provides background information on EPA regulatory activity during the Obama Administration to help address these issues. It examines major or controversial regulatory actions taken by or under development at EPA since January 2009, providing details on the regulatory action itself, presenting an estimated timeline for completion of the rule (including identification of related court or statutory deadlines), and, in general, providing EPA’s estimates of costs and benefits, where available. The report includes tables that show which rules remain under development, and an appendix that describes major or controversial rules that are now final.

EPA Does Not Adequately Follow National Security Information Classification Standards

November 20, 2013 Comments off

EPA Does Not Adequately Follow National Security Information Classification Standards (PDF)
Source: U.S. Environmental Protection Agency, Office of Inspector General

Our review of both originally and derivatively classified documents generated by three offices found that the EPA does not sufficiently follow national security information classification standards.

Of the two originally classified documents we reviewed, portions of one needed different classification levels and the other contained numerical data that was incorrectly transferred from another document. The National Homeland Security Research Center in the Office of Research and Development agreed to correct the documents. We also noted that the approved classification guide and the three guides under review had narrow scopes, which limits their usefulness. The three proposed guides have been in the approval process for 12 months when it must take no more than 30 days. Additionally, the declassification process needs clarity since the one pending declassification request has also been in the approval process for almost a year when it should take no more than 60 days.

None of the 19 derivatively classified documents we reviewed completely met the requirements of Executive Order 13526 and the implementing regulations. The derivative classifiers did not include some required information and did not correctly transfer information from the source documents. As a result, those who later access the information may not know how to protect it or be able to properly identify or use it as a source for their own derivative decision. A lack of training for derivative classifiers and incorrect information in the annual refresher training given to all clearance holders contributed to the classification problems noted. The EPA had not promptly updated guidance. Not all cleared employees who needed an element relating to designation and management of classified information as part of their performance evaluation had such an element.

Hat tip: Secrecy News

EPA Proposes 2014 Renewable Fuel Standards / Proposal Seeks Input to Address “E10 Blend Wall,” Reaffirms Commitment to Biofuels

November 19, 2013 Comments off

EPA Proposes 2014 Renewable Fuel Standards / Proposal Seeks Input to Address “E10 Blend Wall,” Reaffirms Commitment to Biofuels
Source: U.S. Environmental Protection Agency

The U.S. Environmental Protection Agency (EPA) today proposed for public comment the levels of renewable fuels to be blended into gasoline and diesel as required by Congress under the Energy Independence and Security Act of 2007. Developed with input from the U.S. Department of Energy and U.S. Department of Agriculture, the proposal seeks public input on annual volume requirements for renewable fuels in all motor vehicle gasoline and diesel produced or imported by the United States in 2014. The proposal seeks to put the Renewable Fuel Standard (RFS) program on a steady path forward – ensuring the continued long-term growth of the renewable fuel industry – while seeking input on different approaches to address the “E10 blend wall.”

Report on the Workshop on Radionuclides in Wastewater Infrastructure Resulting from Emergency Situations

August 21, 2013 Comments off

Report on the Workshop on Radionuclides in Wastewater Infrastructure Resulting from Emergency Situations
Source: U.S. Environmental Protection Agency

The Water Environment Research Foundation (WERF), in partnership with the U.S. Environmental Protection Agency (U.S. EPA) National Homeland Security Research Center (NHSRC), hosted an expert workshop December 3-4, 2012, in Alexandria, Virginia, to engage with subject matter experts and wastewater utility stakeholders on radionuclides in wastewater collection and treatment systems. The key objective of this workshop was to provide EPA NHRSC recommendations and technical information in the area of radionuclides in wastewater infrastructure resulting from emergency situations, as well as related needs and concerns of, and potential solutions for, the wastewater industry.

New Pesticide Labels Will Better Protect Bees and Other Pollinators

August 20, 2013 Comments off

New Pesticide Labels Will Better Protect Bees and Other Pollinators
Source: U.S. Environmental Protection Agency

In an ongoing effort to protect bees and other pollinators, the U.S. Environmental Protection Agency (EPA) has developed new pesticide labels that prohibit use of some neonicotinoid pesticide products where bees are present.

The new labels will have a bee advisory box and icon with information on routes of exposure and spray drift precautions. Today’s announcement affects products containing the neonicotinoids imidacloprid, dinotefuran, clothianidin and thiamethoxam. The EPA will work with pesticide manufacturers to change labels so that they will meet the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) safety standard.

In May, the U.S. Department of Agriculture (USDA) and EPA released a comprehensive scientific report on honey bee health, showing scientific consensus that there are a complex set of stressors associated with honey bee declines, including loss of habitat, parasites and disease, genetics, poor nutrition and pesticide exposure.

The agency continues to work with beekeepers, growers, pesticide applicators, pesticide and seed companies, and federal and state agencies to reduce pesticide drift dust and advance best management practices. The EPA recently released new enforcement guidance to federal, state and tribal enforcement officials to enhance investigations of beekill incidents.

New From the GAO

June 10, 2013 Comments off

New GAO Report

Source: Government Accountability Office

Chemical Assessments: An Agencywide Strategy May Help EPA Address Unmet Needs for Integrated Risk Information System Assessments. GAO-13-369, May 10.
Highlights –

EPA OIG — Early Warning Report: Main EPA Headquarters Warehouse in Landover, Maryland, Requires Immediate EPA Attention

June 6, 2013 Comments off

Early Warning Report: Main EPA Headquarters Warehouse in Landover, Maryland, Requires Immediate EPA Attention (PDF)
Source: U.S. Environmental Protection Agency, Office of Inspector General

Our initial research at the EPA’s Landover warehouse raised significant concerns with the lack of agency oversight of personal property and warehouse space at the facility. In particular:

  • The warehouse recordkeeping system was incomplete and inaccurate.
  • The warehouse was filled with considerable valuable amounts of unusable, inoperable and obsolete furniture and other items.
  • The warehouse contained multiple unauthorized and hidden personal spaces that included such items as televisions and exercise equipment.
  • Numerous potential security and safety hazards existed at the warehouse, including unsecured personally identifiable information (such as passports).
  • Deplorable conditions existed at the warehouse; corrosion, vermin feces, mold and other problems were pervasive.

As a result of the conditions noted, EPA property at the warehouse was vulnerable to theft and abuse (including personally identifiable information), EPA property was not properly maintained, the EPA may not have received sufficient value for the funds it pai d for the warehouse’s operation, and warehouse workers were subjected to unsafe conditions for which the EPA could be held liable.

Full Report (PDF),
Report Briefing/Photos (PDF),
Statement from IG (PDF)

Report on the National Stakeholders Conference on Honey Bee Health

May 3, 2013 Comments off

Report on the National Stakeholders Conference on Honey Bee Health (PDF)
Source: U.S. Department of Agriculture and U.S. Environmental Protection Agency
From press release:

The U.S. Department of Agriculture (USDA) and the U.S. Environmental Protection Agency (EPA) today released a comprehensive scientific report on honey bee health. The report states that there are multiple factors playing a role in honey bee colony declines, including parasites and disease, genetics, poor nutrition and pesticide exposure.

“There is an important link between the health of American agriculture and the health of our honeybees for our country’s long term agricultural productivity,” said Agriculture Deputy Secretary Kathleen Merrigan. “The forces impacting honeybee health are complex and USDA, our research partners, and key stakeholders will be engaged in addressing this challenge.”

“The decline in honey bee health is a complex problem caused by a combination of stressors, and at EPA we are committed to continuing our work with USDA, researchers, beekeepers, growers and the public to address this challenge,” said Acting EPA Administrator Bob Perciasepe. “The report we’ve released today is the product of unprecedented collaboration, and our work in concert must continue. As the report makes clear, we’ve made significant progress, but there is still much work to be done to protect the honey bee population.”

New From the GAO

April 29, 2013 Comments off

New GAO Reports

Source: Government Accountability Office

1. Toxic Substances: EPA Has Increased Efforts to Assess and Control Chemicals but Could Strengthen Its Approach. GAO-13-249, March 22.
Highlights –

2. State and Local Governments’ Fiscal Outlook: April 2013 Update. GAO-13-546SP, April 29.

EPA Survey Finds More Than Half of the Nation’s River and Stream Miles in Poor Condition

March 27, 2013 Comments off

EPA Survey Finds More Than Half of the Nation’s River and Stream Miles in Poor Condition

Source: U.S. Environmental Protection Agency

Today, the U.S. Environmental Protection Agency released the results of the first comprehensive survey looking at the health of thousands of stream and river miles across the country, finding that more than half – 55 percent – are in poor condition for aquatic life.

The 2008-2009 National Rivers and Stream Assessment reflects the most recent data available, and is part of EPA’s expanded effort to monitor waterways in the U.S. and gather scientific data on the condition of the Nation’s water resources.

EPA partners, including states and tribes, collected data from approximately 2,000 sites across the country. EPA, state and university scientists analyzed the data to determine the extent to which rivers and streams support aquatic life, how major stressors may be affecting them and how conditions are changing over time.

Findings of the assessment include:

- Nitrogen and phosphorus are at excessive levels. Twenty-seven percent of the nation’s rivers and streams have excessive levels of nitrogen, and 40 percent have high levels of phosphorus. Too much nitrogen and phosphorus in the water—known as nutrient pollution—causes significant increases in algae, which harms water quality, food resources and habitats, and decreases the oxygen that fish and other aquatic life need to survive. Nutrient pollution has impacted many streams, rivers, lakes, bays and coastal waters for the past several decades, resulting in serious environmental and human health issues, and impacting the economy.

- Streams and rivers are at an increased risk due to decreased vegetation cover and increased human disturbance. These conditions can cause streams and rivers to be more vulnerable to flooding, erosion, and pollution. Vegetation along rivers and streams slows the flow of rainwater so it does not erode stream banks, removes pollutants carried by rainwater and helps maintain water temperatures that support healthy streams for aquatic life. Approximately 24 percent of the rivers and streams monitored were rated poor due to the loss of healthy vegetative cover.

- Increased bacteria levels. High bacteria levels were found in nine percent of stream and river miles making those waters potentially unsafe for swimming and other recreation.

- Increased mercury levels. More than 13,000 miles of rivers have fish with mercury levels that may be unsafe for human consumption. For most people, the health risk from mercury by eating fish and shellfish is not a health concern, but some fish and shellfish contain higher levels of mercury that may harm an unborn baby or young child’s developing nervous system.

EPA plans to use this new data to inform decision making about addressing critical needs around the country for rivers, streams, and other waterbodies. This comprehensive survey will also help develop improvements to monitoring these rivers and streams across jurisdictional boundaries and enhance the ability of states and tribes to assess and manage water quality to help protect our water, aquatic life, and human health. Results are available for a dozen geographic and ecological regions of the country.

Environmental Decisions in the Face of Uncertainty

March 9, 2013 Comments off

Environmental Decisions in the Face of Uncertainty

Source: Institute of Medicine

The U.S. Environmental Protection Agency (EPA) is one of several federal agencies responsible for protecting Americans against significant risks to human health and the environment. EPA estimates the nature, magnitude, and likelihood of risks to human health and the environment; identifies the potential regulatory actions that will mitigate those risks and protect public health and the environment; and uses that information to decide on appropriate regulatory action. Uncertainties in the data and analyses on which these decisions are based enter into the process at each step. As a result, the informed identification and understanding of the uncertainties inherent in the process is an essential feature of environmental decision making.

The EPA asked the IOM to provide guidance to its decision makers and their partners in states and localities on approaches to managing risk in different contexts when uncertainty is present. It also sought guidance on how information on uncertainty should be presented to help risk managers make sound decisions and to increase transparency in its communications with the public about those decisions.

CRS — Cars, Trucks, and Climate: EPA Regulation of Greenhouse Gases from Mobile Sources

February 25, 2013 Comments off

Cars, Trucks, and Climate: EPA Regulation of Greenhouse Gases from Mobile Sources (PDF)
Source: Congressional Research Service (via Federation of American Scientists)

On October 15, 2012, the Obama Administration took a major step toward reducing greenhouse gas (GHG) emissions from motor vehicles when it promulgated GHG emission standards for model year 2017-2025 light duty vehicles. Under the standards, GHG emissions from new cars and light trucks will be reduced about 50% by 2025 compared to 2010, and average fuel economy standards will rise to nearly 50 miles per gallon. EPA had previously set GHG emission standards for MY2012-2016 vehicles as well as for 2014-2018 model year medium- and heavy-duty trucks.

These steps have been taken as the Congress (particularly the House) and the Administration have reached an impasse over climate issues. The Administration has made clear that its preference would be for Congress to address the climate issue through new legislation. Nevertheless, in the wake of a 2007 Supreme Court decision, it has moved forward on several fronts to define how the Clean Air Act will be used and to promulgate regulations.

The key to using the CAA’s authority to control greenhouse gases was for the EPA Administrator to find that GHG emissions are air pollutants that endanger public health or welfare. EPA Administrator Jackson promulgated such an endangerment finding in December 2009. With the endangerment finding finalized, the agency has proceeded to regulate emissions from motor vehicles.

In all, EPA has received 12 petitions asking that it make endangerment findings and proceed to regulate emissions of greenhouse gases. Ten of the 12 petitions addressed mobile sources: besides motor vehicles, the petitions cover aircraft, ships, nonroad vehicles and engines, locomotives, and fuels, all of which are covered by Title II of the CAA. This report discusses the full range of EPA’s authority under Title II and provides information regarding other mobile sources that might be regulated under this authority, in addition to describing the car and truck regulations.

Regulation of GHGs from mobile sources has led the agency to establish controls for stationary sources, such as electric power plants, as well. Stationary source options, the authority for which comes from different parts of the CAA, are addressed in CRS Report R41212, EPA Regulation of Greenhouse Gases: Congressional Responses and Options.

EPA Updates Greenhouse Gas Emissions Data from Large Facilities

February 7, 2013 Comments off

EPA Updates Greenhouse Gas Emissions Data from Large Facilities
Source: U.S. Environmental Protection Agency

Today, the Environmental Protection Agency (EPA) posted the second year of greenhouse gas (GHGs) emissions data on its website, which provides public access to emissions data by sector, by greenhouse gas, and by geographic region such as county or state.

Greenhouse gases are the primary driver of climate change, which can lead to hotter, longer heat waves that threaten the health of the sick, poor or elderly; increases in ground-level ozone pollution linked to asthma and other respiratory illnesses; as well as other threats to the health and welfare of Americans.

The 2011 data, collected through the congressionally mandated Greenhouse Gas (GHG) Reporting Program, includes information from facilities in 41 source categories that emit large quantities of greenhouse gasses. The 2011 data also contains new data collected from 12 additional source categories, including petroleum and natural gas systems and coal mines.

For facilities that are direct emitters of GHGs the data show that in 2011:

- Power plants remain the largest stationary source of GHG emissions, with 2,221 million metric tons carbon dioxide equivalent (mmtCO2e), roughly one-third of total U.S. emissions. 2011 emissions from this source were approximately 4.6 percent below 2010 emissions, reflecting an ongoing increase in power generation from natural gas and renewable sources.

- Petroleum and natural gas systems were the second largest sector, with emissions of 225 mmtCO2e in 2011, the first year of reporting for this group.

- Refineries were the third-largest emitting source, with 182 mmtCO2e, a half of a percent increase over 2010.

Evaluation of Hydrogen Peroxide Fumigation for HVAC Decontamination

October 2, 2012 Comments off

Evaluation of Hydrogen Peroxide Fumigation for HVAC Decontamination

Source: U.S. Environmental Protection Agency (Homeland Security Research)

The primary objective of this project was to determine the efficacy of the Vaporous Hydrogen Peroxide (VHP) fumigation method on deactivating spores inside a Heating, Ventilation and Air Conditioning (HVAC) duct. Secondary objectives were to determine the effect that flow rate, distance from injection point, flow and pressure points at turns such as elbows, inlet concentration of fumigant, and fumigant residual effects may have on the decontamination efficacy. Two types of duct were tested: galvanized metal and galvanized metal lined internally with fiberglass duct insulation.


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